ML20094M972

Application for Amends to Licenses DPR-24 & DPR-27,revising Health Physics Manager Qualifications

ML20094M972
Person / Time
Site:	Point Beach
Issue date:	11/17/1995
From:	Link B WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20094M976	List: ML20094M972 ML20094M987
References
VPNPD-95-092, VPNPD-95-92, NUDOCS 9511270314
Download: ML20094M972 (4)

Text

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1 Ay . l Wisconsin \

fihSCfTPC: i

. POWER COMPANY :j

' 231 W Mchigan, POI Box 2046. Mdwoukee. WI S3201 2046 (414J 2212345 - -l

'VPNPD-95-092' 10CFR50.90 November 17, 1995

-Document Control' Desk, U.S. NUCLEAR REGULATORY COMMISSION Mail Station F1-137

Washington, DC 20555 Gentlement DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATIONS CHANGE REOUEST 182 HEALTH PHYSICS MANAGER OUALIFICATION POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 y . Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, i Units 1 and 2, hereby requests amendments to Facility Operating Licenses '!

DPR-24 and DPR-27, respectively. The proposed amendments will incorporate changes to the plant Technical Specifications. These changes will allow management flexibility in meeting the Technical Specification required;

qualifications for the Health Physics Manager. A copy of the Technical Specifications including the proposed changes, the safety evaluation, and j

.the. determination of no significant hazards consideration are attached.

Existina License Conditl2D Technical Specifications Section 15.6.'3, " Facility Staff Qualifications,"

Specification 15.6.3.2,-delineates the qualification requirements for the Health Physics Manager. . The Health Physics Manager, as used in this

, Specification, fulfills the requirements _for professional-technical expertise

required by Section 4.4.4 lof ANSI N18.1-19711 1n the Health Physics function.

. specification 15.6.3.2 modifies and supplements the qualification requirements of ANSI N18.1-1971. Technical Specification 15.6.3.1 commits Point' Beach Nuclear Plant to ANSI N18.1-1971.

Prooosed License Condition We proposed to modify Technical Specification Section 15.6.3, replacing Health Physics Manager with Health Physicist throughout the Specification.

Justification for Chanae Prior to Amendments 128 and 132 for Point Beach Nuclear Plant, Units 1 and 2

'respectively, the qualification requirements defined in Specification 15.6.3.2 applied to the position of Health Physicist. This position could be filled by a qualified individual separate from the management of the overall health physics organization and served to advise plant management on matters concerning radiological safety. The specification did not prohibit the individual responsible for health physics organization management from filling the '

position.

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Document Control Desk Nove'mber 17, 1995 ,

Page 2 Amendments 128 and 132 were approved for Units 1 and 2 respectively, on September 4, 1991, following a reorganization such that the qualification requirements applied to the Superintendent-Health Physics who concurrently fulfilled the Health Physicist position. The title of Superintendent-Health Physics was changed in subsequent amendments to Health Physica Manager.

Defined in this way, the specification restricts the ability to rotate management personnel into the position of Health Physics Manager who are otherwise qualified to fill the health physics management position, thereby l limiting overall management development.  !

Redesignating the Specification for the Health Physicist enables the plant manager to designate a qualified individual to fill this position without diluting the expertise available to advise plant management on radiological safety issues and allows appropriate utilization of management expertise.

We have reviewed the proposed changes and have determined that they are l administrative only. Accordingly, the amendments meet the eligibility '

criteria for categorical exclusion set forth in 10CFR51.22(c)(lO). Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the proposed amendments.

If you have any questions, or require additional information, please contact us.

Sincerely, Bob Link Vice President Nuclear Power TGM cc: NRC Resident Inspector NRC Regional Administrator PSCW Subscribed and sworn before me on this 1% day of Nm k 1995.

un LI ry ublic, State of Wisconsin My ecmmission expires IOlJ1/9l,.

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4 Attachment 1 SAFETY EVALUATION TECHNICAL SPECIFICATIONS CHANGE REQUEST 182 HEALTH PHYSICS NANAGER QUALIFICATIONS POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant (PBNP), requests changes to the Technical Specifications modifying the qualification requirement for the Health Physics Manager. The requirements, defined in Technical Specification 15.6.3.2 modify and supplement the requirements of ANSI N18.1-1971, Section 4.4.4 for profession-technical expertise available in the radiation protection organization. Point Beach Nuclear Plant is committed to ANSI N18.1-1971 as required by Technical Specification 15.6.3.1 for facility staff qualifi-cations.

The requirements of Specification 15.6.3.2' place unnecessary restrictions upon the overall management of the PBNP health physics organization. The intent of the qualification require-ments presently specified for the Health Physics Manager, is to ensure that appropriate expertise is available on the PBNP staff to assist and advise plant management in matters concerning radiological safety.

ANSI N18.1-1971, Section 4.4.4 does not require this expertise to be specifically assigned to the management of the radiological protection organization.

Prior to amendments 128 and 132 issued on September 4, 1991, for PBNP Units 1 and 2 respectively, Specification 15.6.3.2 applied to the position of Health Physicist. The existing specification was reworded at that time to reflect organizational changes at PBNP in which the Health Physics Superintendent (Manager) position was formed in the organization. This position also met the j qualification requirements for the Health Physicist. The proposed specification returns to this wording designating the qualification requirements for the  !

Health Physicist.

The Health Physicist position will be designated in writing by the plant l manager. The position of Health Physicist may be filled by supervisory or non-supervisory personnel who meet the qualification requirements. This will enhance the ability of plant management to ensure the appropriate expertise is used in the Health Physicist and Health Physics Manager positions, thereby enhancing the overall radiation protection function at PBNP.

The overall safety of the public and plant personnel will be assured and enhanced by this change.

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l Attachment 2 )

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! DETERNINATION.0F NO SIGNIFICANT EAEARDS )

! TECENICAL SPECIFICATION CEANGE REQUEST 182' i

ERALTE PEYSICs unmangR gUALIFICATIONS POINT BEACE NUCLEAR PLANT, UNITS 1 AND 2 i

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i i We have evaluated the proposed change to Technical Specification 15.6.3.2 and l 15.6.3.3 in accordance with the requirements.of 10CFR50.91 against the standard i in'10CFR50.92, and have determined that operation of the Point Beach Nuclear-

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. Plant in accordance with the proposed changes does not result in a significant hazards consideration. The proposed changes are. administrative in nature, l replacing the position title Health Physics Manager, with Health Physicist.

Our evaluation against each requirement of the standard in 10CFR50.92 follows.:

1. Operation of the Point Beach Nuclear Plant in accordance with the proposed

$ amendments does not result in a significant increase in the probability or i consequences of an accident previously evaluated.

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The proposed changes separate the qualifications requirements of the

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Technical Specifications from the Health Physics Manager, while requiring i that the same qualifications be fulfilled by a designated Health Physicist

] position within the crganization. This change maintains _the present

!- knowledge requirements of the PBNP staff. The personnel holding the health  !

1 physics qualifications are not considered in the probability of any accident. l l- By ensuring the appropriate expertise remains'on the staff to advise l'

management on issues related to radiological safety, appropriate action is assured during analyzed events to assess and mitigate the radiological I consequences. Therefore, this change does not affect the prebability or j consequences of any accident previously evaluated.

j 2.' operation of the Point Beach Nuclear Plant in accordance with the proposed

amendments will not result in'a new or different kind of accident from any j accident previously evaluated.

} The proposed change separates the Health Physics Manager qualifications from l the position while maintaining the requirements for that expertise to be i maintained within the organization. This is an administrative change only

and does not affect any plant structures, systems and components.

j Therefore, a.new or different kind of accident from any accident previously

evaluated cannot result.

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3. Operation of the Point Beach Nuclear Plant in accordance with the proposed amendments will not result in a significant reduction in a margin of safety.

The proposed changes are administrative only. The required levels of expertise and experience will be maintained within the Health Physics organization. Therefore, there is no reduction in a margin of safety.