ML20113H027
| ML20113H027 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/30/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20113H026 | List: |
| References | |
| GL-88-06, GL-88-6, NUDOCS 9205150237 | |
| Download: ML20113H027 (3) | |
Text
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ftELATED TO AMENDMENT NO. 63 TO FACILITY OPERATING LICENSE N0. NPF-62 ILLIN0IS POWER COMPANY. ET AL.
CLIN 10," POWER STATION. UNIT N0. 1 DOCKET NO. 50-461
1.0 INTRODUCTION
On February 21, 1992, the Illinois Power Compat (IP), the licensee, submitted an application to amend Facility Operatm9 License No. NPF-62, Appendix A -
Technical Specifications (TS), for the Clinton Power Station (CPS).
The amendment would delete a specific reference to the " Director - Plant Radiation Protection" in TS 6.3.1.
2.0 DISCUSSION Qualification requirements for plant staff members are prescribed under TS 6.3,
" Unit Staff Qualifications." TS 6.3.1 currently states, "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 except the Director - Plant Radiation Protection who shall meet or exceed the qualifica-tions of Regulatory Guide 1.8, September 1975." The intent of this exception for the Director - Plant Radiation Protection is to impose stricter qualification requirements for this position relative to the 1971 version of this ANSI standard; however, IP is committed to the 1978 varsion. As this (TS) requires compliance with the 1978 version, the exception is redundant.
ThereforL, IP submitted a proposal to delete this phrase from the IS.
3.0 EVALUATION The Feptember 1975 version of Regulatory Guide 1.8, " Personnel Selectir nJ Training,"_ was written to address /^ i N18.1-1971, " Selection and Training of i
Nuclear Power Plant Perscnnel."
- t. hough this ANSI standard did prescribe qualification requirements for supervisory-level radiation protection personnel (Ref. Section 4.4.4),* the NRC determined, cs documented in the Regulatary Guide, that the recommended qualification regtIre,ents were insufficient.
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- ANSI N18.1-1971 recommended that the responsible person (in the area of l
radiation protection) "have a minimum of five years experience in radiation protection at a nuclear reactor facility. A minimum of two years of this five years experience should be related technical training. A maximum of four years of this five years experience may be fulfilled by related or academic training."
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2-The NRC indicated in the Regulatory Position section of Regulatory Guide 1.8 (1975), "The criteria for the selection and training of nuclear power plant personnel contained in ANSI Ni8.1-1971... are generally acceptable and provide an adequate basis for the telection and training of nuclear power plant personnel except for the position Supervisor Radiation Protection (hereafter referred to as Radiation Protection Manager (RPM]) " Specifically, the following enhanced qualification requirements were prescribed for the RPM:
The Radiation Protection Manager (RPM) should be an experienced professional in applied radiation protection at nuclear facilities dealing witi radiation protection problems and programs similar to those at nuclear power stations.
The RPM should be familiar with the design features and operations of nuclear power stations that affect the potential for exposures of persons to radiation. The RPM should have the technical competence to estab'ish radiation protection programs and the supervisory capability to direct the work of professionals, technicians, and journeymen required to implement the radiation protection programs.
The RPM should have a bachelor's degree or the equivalent in a science or engineering subject. including some formal training in radiation protection.
The RPM should have at least five years of professional experience in applied radiation protection.
(A master's degree may bc :onsidered equivalent to two years of professional experience where course work related to radiation protection is involved.) At least three years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations, preferably in an actual nuclear power station.
After issuance of the September 1975 version of Regulatory Guide 1.8, ANSI N18.1-1971 was revised to ANSI /ANS 3.1-1978. As a part of this revision, section 4.4.4 was revised, incorporating the qualificatica requiremer.ts specified for the RPM in Regulatory Guioe 1.8 (1975). With respect to the qualification requirements for the RPM, the combination of ANSI N16.1-1971 and the qualification enhance-ments/ exception provided in Regulatory Guide 1.8 thus became equivalent to ANSI /ANS 3.1-1978.
At one time, as it appeared in the draft CPS Technical Specifications, TS 6.3.1 referred to ANSI N18.1-1971 (along with the exception referring to Regulatory
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Guide 1.8).
Later, during further development of the draft TSs for CPS, the licensee modified this reference to ANSI /ANS 3.1-1978 :ons h it with the version of the standard referenced in the CPS USAR bui. Tailed to delete the exception specified for the Director-Plant Radiation Protection.
Deletion of this wording from TS 6.3.1 eliminates an unnecessary reference to a specific job /potition title in the CPS plant staff organization. Consistent with the intent of the Generic Letter 88-06 (
Subject:
Removal of Organizational l
l
e Charts from TS Administrative Control Requirements), this change could prevent unnecessary changes to the TS (and thus, eliminate unnecessary license amend-ments) in the future due to title / organizational changes involving the " Director-Plant Radiation Protection."
It shculd be emphasized that the proposed change does ' t involve a change to the qualification requirements for unit staff personnel i1cluding the position that is equivalent to the " responsible person (Professional - Technical, Radiation Protection)" identified in the.\\NSI standard or the " Radiation Protection Manger" identified ir, Regulatory Guide 1.8.
The reference to ANSI /ANS 3.1-1978 in TS 6.3.1 remains unchanged consistent with IP's commitment to this standard as identified in the CPS USAR.
Therefore, the staff approves the proposed modification to TS 6.3.1
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the appropriate Illinois State official was notified of the proposed issuance of the amendment.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment' relates to changes in recordkeeping, reporting, or administrative procedures or requirements.
Accordingly, the amendment meets the eligi'oility criteria for categorical exclusion set ferth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed matner, (2) such activities will be conducted in compliance with the Commis ion's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
?rincipal Contributor: A. Gody, Jr.
Date: April 27, 1992