ML19329A381
| ML19329A381 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/13/1977 |
| From: | Parker W DUKE POWER CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19329A380 | List: |
| References | |
| NUDOCS 8001030955 | |
| Download: ML19329A381 (8) | |
Text
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8 DUKE POWER COMPMY Powen Brn omo 422 Sorin Curucn Starrr. CRAHLOTTE, S. C. 262 52 m ia-o aa:ca. o May 13, 1977
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s Mr. Benard C. Rusche, Director y
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Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Wa shington, D. C.
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4 Attention:
Mr. A. Schwencer, Chicf Operating Reactor Branch #1
Reference:
Oconee Nuclear Station Docket Nos. 50-269, -270, -287
Dear Sir:
Your letter of March 9, 1977 provided guidance concerning the criteria which should be met by " Individuals Qualified in Radiation Protection Procedures".
It is our opinion that the criteria listed in your letter are adequate to assure that the responsible individuals provide proper radiation protection at an operating shift crew level. Personnel assigned shift coverege pursuant to the technical specification require-ments delineated in Oconee Technical Specification Table 6.1-1, Note 5, meet these criteria.
Additionally, your letter requested that the Oconee Technical Specifica-tions be revised to require that the individual performing the function of Radiation Protection Manager (RPM) meet the minimum qualification requirements of Regulatory Guide 1.8, September, 1975. With regard to the qualifications of the Radiation Protection Manager (RPM), designated ;
as the Station Health Physicist in the Oconee organization, it is our position that the qualif* cations established in ANSI N18.1-1971 are f
appropriate minimum requirements for this position.
ANSI N18.1-1971 states that "the responsible person shall have a minimum of 5 years experience in radiation protection at a nuclear reactor facility.
A minimum of 2 years of this 5 years experience should be related technical training. A maximum of 4 years of this 5 years experience may be fulfilled by related technical or academic training". The minimum qualifications of the Station Health Physicist (RPM) at Oconee Nuclear Station are based on these requirements.
Regulatory Guide 1.8 requires the RPM to have 9 years of training and experience (a Bachelor's Degree plus an additional 5 years experience, 3 of which must be in radiation protection). The requirements for station Manager and Technical Services Superintendent, as established by ANSI N18.1-1971 and as deemed acceptable by Regulatory Guide 1.8, sgre 10 years and 8 years of experience, respectively, with a degree not being a require-g In tl.e Oconee organization, the Station Health Physicist (RPM) mente s
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Mr. 32 nard d. Ruccht sirector Pagt Two May 13,1977 reports directly to the fechnical Services Superintendent who in turn reports to the station Manager. Therefore, while the critical importance of the RPM position is recognized, it is not considered that experience commensurate with that of the station Manager, or the Technical Services Superintendent, the two levels of management directly above the RPM, is necessary for the fulfillment of the responsibilities of this position.
Additionally, the requirement for a Bachelor's Degree is not considered to be germane to the specific functions of the RPM.
The only position at the station which presently requires a Bachelor's Degree is that of The attributes of a good RPM are considered to be the Reactor Engineer.
gained almost exclusively by specialized on-the-job, practical and super-j visory experience rather than through the broad generalized, academic
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training received by a Bachelor's Degree.
Regulatory Guide 1.8 states that "The Radiation Protection Manager (RPM) i should be an experienced professional in applied radiation protection at nuclear facilities dealing with radiation prstection problems and programs similar to those at nuclear power stations. The RPM should be familiar with the design features and operations of nuclear pcwer stations tnat The RPM affect the potential for exposures of persons to radiation.
should have the technical competence to establish radiation protection programs and the supervisory capability to direct the work of professionals, technicians, and journeymen required to implement the radiation protection programs". This paragraph implies that the RPM is the sole stor,ehouse of technical knowledge who will establish, implement and audit the radiation protection program of the nuclear station.
In Duke's unique situation, however, the Station Health Physicist (RPM) and the Station Health Physics organization are supported by a General l
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Office Health Physics staf f called the System Health Physics unit.
staff presently consists of eleven people, nine of whom are professionals in the field of Health Physics. The staff has four people with Masters Degrees and three with Bachelors Degrees. The System Health Physics Unit represents over sixty man-years of direct power reactor health physics experience. The System Health Physicist is presently certified by the American Board of Health Physics and several other staff members are also in the process of becoming certified. The Duke Power Company System Health Physicist and his staff establish the Health Physics Program for each neclear power station; provide technical 31rection for conducting these programs; estab13:b the environmental radioactivity monitoring program and the emergency plan; audit the efficacy of these programs and modify them as required, and coordinate a centralized Radiological Laboratory which provides persontel dosimetry, instrument calibration and environ-mental monitoring servfces to each station.
I The Station Dealth Physicist (RPM) is responsible for conducting the established Health Physics Program.
It is his duty to measure and control the radiation exposure of personnel; to continually evaluate and review p
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Mr. Bannrd C. Rucche, Director Paga Thrso May 13,1977 the radiological status of the station; to make recommendations for control or elimination of radiation hazards; to train personnel in radiation safety; to assist all personnel in carrying out the radiation safety responsibilities, and to protect the health and safety of the public both on-site and in the surrounding areas.
The Station Health Physicist is further supported by two levels of responsi-ble management, the Technical Services Superintendent and the station Manager, as previously mentioned. The Technical Services Superintendent supervises the on-site professional - technical groups which deal with the areas of 3
health physics, chemistry, biology, performance and technical services, and
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he assures that radiation safety is maximized by the proper application of 3 g-the Health Physics Program and good interaction between the Station Health Physics organization and other station organizations. The station Managet
,' 'h e has the final responsibility for the protection of all persons against p
radiation and for compliance with NRC regulations, stat $sn technical speci-fications, etc.
. n-1 Thus, to accomplish the goals of Duke's Health Physics Program which are:
(1) to protect the public in the vicinity of a nuclear station, (2) to pro-tect nuclear station personnel, and (3) to protect the nuclear station, a coordinated effort between the Station Health Physicist (RPM) at each nuclear
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power station, the System Health Physicist and his staff in the General Office organization and the system-wide Radiological Laboratory operated by the System Health Physics organization is utilized.
Since the Station Health Physicist (RPM) is supported by two levels of management and c central Health Physics organization, and the requirements
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of ANSI N18.1-1971 are minimum requirement;, it is considered that the proposed qualifications of Regulatory Guide 1.8 are not appropriate for Duke Power Company.
In addition, it is considered that the program for qualification of the Oconee Station Health Physicist will assure that personnel assigned to this position are fully capable of performing the required duties.
It is therefore concluded that personnel appointed to the position of we**<***"
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Station Health Physicist are and will continue to be qualified as specified in ANSI N18.1-1971.
p.r.s.a.. re.sm-Very ruly yours,
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William O. Parker, Jr. U LJB:ge i
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g, SAMPLE LETTER #3 Docket No. 50-Licensee Gentlemen:
RE:
We note that your facility technical.pecifications do not require that the individual performing the function of Radiation Protection Manager (RPt)) meet the minimum qualification requirements of Regulatory Guide 1.8, September 1975. As stated in this guide, it is the NRr position that if the RPM is reassigned or the incumbent replaced, the new RPM should have qualifications equivalent to those stated in this guide.
To implement this provision, we request that you determine if the individual performing the function of Radiation Protection Manager meets the minimum qualifications of Regulatory Guide 1.8, September 1975.
In the event the RPM is so qualified, you should propose a technical specification to be included in the Administrative Controls Section which state', that "the RPfl (or equivalent position title) shall reeet or exceed the qualifications of Regulatory Guide 1.8, September 1975".
In the event you determine that the present incumbent does not meet the minimum requirements of the guide, you should advise us of this fact and provide a written commitment that the successor to the incumbent will be so qualified and that you will propose a technical specification to that effect at that time.
The above action should be completed within 60 days of receipt of this letter.
In the event you shSuld desire further discussion of this matter, please contact us.
Sincerely,
, Chief Operating Reactors Branch #
Division of Operating Reactors l
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phnt esperience rnay be ful611ed by academic or re. to the active position, the responsible person shall isted lethnical training on a one.for.one time basis.
have a minimum of fue years experience in radia.
At the time of initial core loading or appointment to tion protection at a nuclear reactor facility. A mini.
d,, sethe position, such a supervisor shall hold an mum of two yean of this fise years experience should be related technical training. A maximum of four appropriate AEC license.
yean of this five years experience may be ful611ed ors S. r Requiring AEC by related technical or academic training.
4.3.2 Superru.
o Licenses At the time of initial core loading or appointment to 4.5 Operator Technician. Repairrnan the acthe position, a supenisor in this category shall 4.5.I Operators ka e a high school diploma or equivalent and a At the time of the initial core loading or appointment ininirnum of four yean of experience in the craft or to the active position, operators to be licensed by I
di.ciolint he supervises.
the AEC shall have a high school diploma or equi.
fG Professional. Technical valent and two years of power plant experience of which a minimum of one year shall be nuclear power L ne professional technical groups shall include indniduah with the following qualifications in the plant experience. Further, before being acceptable for full responsibility in the job, they shall hold an indinted disciplines. A single individual may be AFC Reactor Operator's License.
quali6ed and perform in more than one discipline.
Suitable organizational depth should exist to provide All operators, whether or not they are to be licensed for en absence of the principal.
by the AEC should hase a high school diploma or 4.4.1 Reactor Engineering and Physics equivalent, and should possess a high degree of man.
At the time of initial core loading or appointment
".l dextedty and mature judgement. Selection inter.
a in the active position, the responsible person shall views and examinationsjhould be used for all oper.
at n t aid in determining indisidual ability to pro.
have a minimum of a Bachelor's Degree in Engi.
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- high levels of responsibility and to eventual seering or the Physical Sciences and two years ex.
AEC h.eensmg.
perience in such areas as reactor physics, core mea-surements, core heat transfer, and core physics test.
g g ang programs.
Technicians in responsible positions shall have a 4.4.2 Instrumentation and Control minimum of two years of working experience in At the time of initial core loading or appointment to their speciality. These personnel should have a mini.
the active position, the responsible person shall have mum of one year of related technical training in a minimum of five yean experience in instrument-addition to their experience.
ation and control, of which a minimum of six months shall be in nuclear instrumentation and control. A 4.5.3 Repairmen minimum of two years of this five years experience Repairmen in responsible positions shall have a abould be related technical training. A maximum of minimum of three years in one or more crafts. Hey four yean of this five years experience may be ful-nould possess a high degree of manual dexterity and b' led by related technical or academic training.
aoility and should be c.apable of learning and apply.
I ing basic skills in maintenance operations.
4.4.3 Radiochemistry At the time of initial core loading or appointment 4.6 Technical Support Personnel to the s'etive position, the responsible person shall 4.6.I Engineer in Charge have a minimum of five years experience in chemis.
try of which a minimum of one year shall be in The engineer in charge shall have a minimum of ndiochemistry. A minimum of two years of this five a Bachelor's Degree in Engineering or the Physical years experience.hould be related technical training.
Scienas and have a minimum of three years of A maximum of four years of this five years experi-Professional level experience in nuclear servias, nu-mee may be fulfilled by related technical or acadcmic clear plant oper, tion, or nuclear engineering, and training.
the necessary overall nuclear background to deter.
mine when to call consultants and contractors for 4.4.4 Rediation Proseerloa dealing with complex problems beyond the scope of At the time of initial core loading or appointment owner.organlaation expertise.
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g LETTER TO: Sconce
SUBJECT:
Radiation Protection Manager
Dear Sir:
to Bernard C. Rusche addresses the NRC Your letter of May 13, 1977 position with respect to the qualifications of the plant Radiation Protection Manager (RPM) as specified in Regulatory Guide 1.8, Septem-We have carefully reviewed your comments and would like to t
ber 1975.
i clarify so=e of the issues of concern.
Regulatory Guide 1.8 states that the RPM should have a bachelors in-in a science or engineering subject, degree, or the equivalent, We have cluding some formal training in radiation protection.
established some guidelines that should clarify the intent of "or the
" Equivalent,"
equivalent" when referenced to the " bachelors degree."
(a) 4 years of as used above, may be met with any one of the folowing:
schooling in science of engineering, (b) 4 years of applied radiation protection experience at a nuclear facility, (c) 4 years of operational or technical experience / training in nuclear power, (d) any combination of the above totaling 4 years.
From the above, it is clear that we do not require a bachelors degree for tion the RPM. Our prime concern is that the onsite level of radiation protec i
expertise at all Duke Power plants continue to be of high qual ty.
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.2-It is therefore requested that you adopt the provisions of Regulatory Guide 1.8 for any replacement of the current Radiation Protection Manager in accordance with our previous letter to you dated March 9, 1977.
Please respond within 30 days stating your intentions with respect to our request.
Sincerely, t
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