ML20037A337

Forwards Proposed Response to Util Re Qualification of Onsite Radiation Protection Manager

ML20037A337
Person / Time
Site:	Oconee
Issue date:	08/29/1977
From:	Grimes B Office of Nuclear Reactor Regulation
To:	Goller K Office of Nuclear Reactor Regulation
Shared Package
ML20037A332	List: ML20037A331 ML20037A337
References
NUDOCS 8001090777
Download: ML20037A337 (2)

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ADO T. S ti77 MEMORANDlH FOR: Karl R. Goller, Assistant Directcf fSr Operating Reactors Division of Operating Reactors Brian K. Grimes, Chief, Environmental Evaluation Branch, i

FROM:

Division of Operating Reactors I

RESPONSE TO DUKE POKER COM?ANY 1.ETTED. REGARDIHG RADIATIO StBJECT:

PROTECTION MANAGER' (7AC - 6888) 4-

-In a Duke Power Company letter to Rusche., dated May 1.3,1977 ( Attachment l'),'

the licensee takes exception to the NRC_ position with~ respect to the qualification of the onsite Radiation Protcction Mariager (RPM) (Attachment 2), as recommended by Regulatory Guida 1.8.

Duke pro:oses to use the i

guidance specified in ANSI 18.-1, 1971 (Attachment 3).

We have reviewed Duke's position and recommend the reicnnse to them as We feel that the ANSI 18'.1,1971 standard does shown in Attachment 4.

not provide the appropriate cualifications required for the onsite RPM whose responsibility is to manaae a radiation protection program with For example, personnel exposures an impressive annual man-rem budget.

from all three units at the Oconee $tation were 517 nn-rem in 1974, 457 man-rem 1975, and 990 man-rem in 1976.

Although -hese values are not unique in the nuclear power..-eactor industry, they are still impressive with respect to all other nuclear facilities.. Consea' ently, they should be managedby professicnal experts who are at the station to assure that exposures frca normal operations, mai'ntenance, -etc. are maintained at levels that-are as. low as is reasonably achieveable (MRA).

The licensee claims that the RPM presently assigned a: Oconee meets the 18.1,.1973 He therefere should provide qualification specifed in ANSI a couaitment that his successor will be cualified in accordance with N

• Regulatory Guide.1.8.

Ma do not feel.that Duke will Euffer an unnecessary to Attachment hardship under 4hese circumstances since industry reston 2 has othemise been positive.

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Brian X. Grimes, Chief Environmental Evaluation Branch Division of Operati:9 Reactors cc: Sae following page

Contact:

S. Block, EEB/ DOR X20066

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SA".PLE LETTER Gogge Docket No. 50-3 m r' 0

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Licensee cw D '3'T J

D Gentlemen:

RE:

11e note that your facility technical specifications do not requir the. individual performing the function'of Radiation Protection (RP!1) meet the minimum qualification reqairerents of flegulato that if the RPi1 is ~ reassigned or the incunb

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1 should have qualifications equivalent to those stated in this guide l-To implement this provision, we request that meets the mininum qualifications of Regulatory. Guide 1.8, September

. i? df 1915.

In the event the RPft is so qualified, y:e should propose a "2

technical specification to be included in the Ac:!nistrative Controls

*,3 Section which states that "the RP!1 (or equivalent position title) shall r..eet or exceed the qualifications of Regulatory Guide 1.8,

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September 1975".

CI the minimum requirements of the gu.ide, you s

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~2 fact and provide a written commitment that the su:cessor to the specification to that effect at that time. incumbent will be The above action should be completed within 60 days of r 1etter.

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In the event you should desire further discussion of this matter, please' contact us.

Sincerely.

, thief Operating Reac*. ors Branch i Division of Operatir,ig Reactors cc: See next para

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