ML19345E148
| ML19345E148 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/19/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8012230330 | |
| Download: ML19345E148 (6) | |
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DUKE POWER COMPm Powes Bt:st.ntxo 4cc Socrat Curucu Starrr. Cruat.orre. N. C. asa sa m ua o.Paa ca.sa.
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4 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. B. J. Youngblood, Chief Licensing Projects Branch No. 1
Subject:
McGuire Nuclear Station Dockets 50-369 and 50-370 i
y
Dear Mr. Denton:
One of the items discussed at length during your visit of November 17, 1980 to McGuire was Duke's Health Physics Program as it is implemented at McGuire Nuclear Station. Of particular interest was the reporting relationship and functional interaction between the Station Health Physicist and the Station Manager. This issue was originally raised in NRC letters of June 4, 1980 and September 17, 1980. Duke responded to these letters on August 6, 1980 j
(revised September 8, 1980) and October 10, 1980. As of the November 17, 1980 meeting this issue was still unresolved.
During the course of the November 17, 1980 meeting, all parties involved agreed that the single most important factor in a successful Health Physics i
program is a strong management commitment to that program. Duke is committed to an effective Health Physics program at all of its nuclear stations. This commitment is present at both the corporate and station management levels as well as in corporate organizations responsible for supporting the station Health Physics programs.
The best expression of Duke's commitment to effective Health Physics programs is the success of the Oconee Nuclear Station Health Physics Program. Seven years of operating Oconee Nuclear Station has provided Duke with the experience i
l necessary to develop a Health Physics organization which has proven very effective. Duke has been utilizing an identical Health Physics organization at McGuire Nuclear Station. The NRC Health Physics appraisal of Oconee Nuclear Station conducted in October 1980 confirms the effectiveness of the Health Physics programs Duke has established at both Oconee Nuclear Station and McGuire Nuclear Station. These programs are briefly described below.
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6 Mr. Harold R. Denton, Director December 19, 1980 Page Two Duke Power's radiation protection policies are established in a System Health Physics Manual that is approved by the Vice-President, Steam Production and is issued by the Manager of Nuclear Production. As stated in this manual, "The Duke Power Company System Health Physicist and his staff are responsible for establishing the Health Physics Program; for providing technical assistance for conducting the program; for assuring management that personnel exposures are maintained "as low as reasonably achievable"; for auditing the efficacy of the program in complying with NRC and other govern = ental regulations and Regulatory Guides; and for modifying the program as required by experience and by regulatory and technical changes." The System Health Physicist and his staf f maintain frequent communications with both the Station Health Physicist and the Vice-President of S*.eam Prcouction. This link provides a mechanism for long-term improvement of the dealth Physics program as well as providing for continuing support of the program by corporate management.
The Station Health Physicist is responsible for conducting the Health Physics program that has been established for the station. The Station Health Physicist has the duty and the authority to measure and control the radiation expcaure of personnel to a level that is as low as reasonably achievable and within regulatory exposure limits; to continuously evaluate and review the radiological status of the station; to make reco=mendations for control or elimination of radiation hazards; to train personnel in radiation safety; to assist all personnel in carrying out their radiation safety responsibilities; and to protect t!.e health and safety to the public both on site and in the surrounding area. Technical support from the System Health Physics organiza-tion is available if needed. However, the Station Health Physicist retains the responsibility for directing the Station Health Physics program.
In the event of absence of the Station Health Physicist a qualified Health Physics subordinate is delegated the authority and responsibility of the Station Health Physicist.
Relief from unnecessary administrative duties is essential for the Stacion Health Physicist to successfully perform his duties. This is accomriished at Duke's nuclear stations by having the Station Health Physicist report directly to the Superintendent of Technical Servicee. The Superintendent of Technical Services provides both administrative and technical support to the Station Health Physicist so that he can effectively implement the Station Health Physics program.
I The Station Manager is responsible for the protection of all persons against radiation and for compliance with NRC regulations and license conditions. This responsibility is in turn shared by all Superintendents. Furthermore, the Station Health Physicist is responsible for reporting matters of immediate radiological concern directly to the Station Manager. This provision is con-tained in the Station Health Physicist's Position Guide as well as the FSAR.
In addition, routine radiological reports prepared by the Station Healtn Physicist are reviewed by the Station Manager. These reports include the radiological section of the annual operating report and the daily printout of personnel exposure values. The Station Manager has the sole authority to approve exceeding Duke administrative personnel ?xposure limits which are lower than NRC requirements.
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Mr. Harold R. Dentoa, Director December 19, 1980 Page Three As discussed earlier Duke places a great emphasis upon the Health Physics i
program. The Health Physics organizational structure at both McGuire Nuclear Station and Oconee Nuclear Station does not reduce this emphasis at all. Neither does this organizational structure interfere with the direct interaction of the Station Health Physicist and Station Manager, or increase the amount of operating pressures placed upon the Station Health l
Physicist. An example of this independence from operating pressure is the Radiation Work Permit program which does not permit any station modifica-tions or maintenance activities involving radiological exposure without j
prior approval by the Station Health Physicist.
l In conclusien, it is Duke's position that the Health Physics Program which has been established at both McGuire Nuclear Station and Oconee Nuclear Station is effective in reducing radiation exposure to levels "as low as reasonably achievable" and in protecting the health and safety of the public a
and station personnel. This position was made clear to the NRC in Duke's responses of August 6, 1980 (revised September 8, 1980), October 10, 1980, and in the November 17, 1980 meeting with the NRC. Furthermore, the operational history of Oconee Nuclear Station demonstrates the efficacy of Duke's Health Physics program.
Very truly yours, I
/t William O. Parker, Jr.
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THH:ses l
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D MCGUIRE NUCLEAR STATION POSITION GUIDE TITLE:
STATION HEALTH PHYSICIST BASIC FUNCTION:
This position is responsible for the direction of the Station Health Physics program consistent with the System Program and NRC Regulations.
POSITION QUALIFICATIONS:
Must meet the Company's general requirements and in addition:
1.
Should have a minimun of seven (7) years experience in Radiation Protection.
A minimum of two (2) years of this experience should be related technical training. A maximum of four (4) years of experience may be fulfilled by academic or related technical training.
2.
Should ue a Registered or Certified Health Physicist.
3.
Should have demonstrated the ability to lead and organize the efforts of a technically oriented work group.
4.
Should be able to work effectively with station / company personnel at all organizational levels.
5.
Should be capable of training, developing, coaching and appraising subordinates.
6.
Should have well developed communicative skills, both written and oral.
GENERAL DUTIES AND RESPONSIBILITIES:
This position achieves the objectives and goals of this function through the following general duties and responsibilities:
1.
Contribute to the establishment of next higher level objectives, goals, etc.
2.
Develop and implement effective plans for accomplishing required position work in support of related group goals and objectives.
3.
Assist in the selection of qualified personnel in this area and conduct a planned program of coaching individual employees on work improvement I
needs and overall career direction.
4.
Implement work planning and reviews with individual employees to measure l
and report progress tous providing work direction and assistance to
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employees.
5.
Evaluate the contribution of employees and recommend appropriate recog-nition and compensation practices.
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6.
Integrate related section goals and work with those cf other sections establish and maintain effective working relationships internal and external to the group.
7.
Participate with the next level of management in identifying a program of performance improvement; remain current with advances or new approaches to radiological controls.
S.
Identify and implement solutions to work related problems; develop and recom=end standards and participate in measuring the work of the position.
9.
Establish and maintain effective com=unications with sources of necessary information and with those who receive necessary information keeping management infor=ed where their responsibilities are affected.
10.
Represent the Station, Department and Company in appropriate industry and community related activities.
11.
When so designated, assume the responsibilities of the Technical Services Superintendent.
SPECIFIC DUTIES AND RESPON3IBILITIES:
In addition to the general duties and responsibilities, this position is responsible for the following specific duties:
1.
Implement uniform policies and procedures approved for Station Health Physics and Environ = ental Programs.
2.
Ensure that all Health Physics personnel are sufficiently trained to carry out their assigned function.
3.
Provide radiological control, support, and guidance for development of station programs and procedures.
4.
Responsible for the timely submittal of routine technical reports and records in the Health Physics Area.
5.
Establishment and conduct of an effective program to ensure exposures to ionizing radiation is maintained ALARA.
l 6.
Ensure that all radioactive materials shipped. received or discharged meet the applicable regulations and specifications.
7.
Coordinate Health Physics support and evaluate sound radiological work practices for the effective operation and =aintenance of the station.
8.
Preparation of incident reports for unusual radiological occurrences and violations of exposure criteria or Radiological Technical Specifications.
I 9.
Prepares Health Physics input to station manpower, expense and capital budgets to ensure cost effective operation.
10.
Perform other tasks as assigned by the Superintendent of Technical Services.
4 o 11.
Maintain an equitable balance of personnel from various ethnic backgrounds.
RELATIONSHIPS:
1.
Reports directly to the Superintendent of Technical Services.
2.
Accesses the Station Manager, directly, in matters of radiological protection.
3.
Directs the activities of Health Physics Supervisors, Staff Health Physicists and other Health Physics personnel through these individuals.
4.
Maintains a close liaison with the System Health Physicist and his staff.
5.
Interfacew with all station groups and sections and related groups from other stations.
6.
Interfaces with various vendor and professional organizations and societies.
7.
Serves as Chairman of the Station ALARA Committee.
ACCOUNTABILITIES:
This position is held accountable for:
1.
Contributing to improved organizational and individual employee performance by defination, development and coordination of section responsibilities.
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2.
Ensuring that training and development of the Health Physics personnel is sufficient to conduct a sound program by providing cross training and thru periodic evaluation of personnel and qualifications.
3.
Ensuring that occupational and general public exposure resulting from operation of the station is maintained as low as reasonably achievable by providing sufficient Health Physics support, fostering sound radio-logical work practices and ensuring that all discharges are within the applicable limits.
4.
Ensuring that all records and radiological data are traceable, accurate and meet the intent of the specifications and regulations thru develop-cent of a sound Health Physics Program.
5.
Awareness of the radiological status of the plant and major jobs under-l way thru good communications with subordinates.
6.
The attitudes and awareness of all Health Physics personnel fosters a l
good working relationship with interfacing personnel by development, coaching and motivation of subordinate personnel.
7.
Maintaining an equitably balanced staff in accordance with EEOC guide-lines by seeking qualified personnel of various ethnic backgrounds.
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