ML20128B369

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Proposed TS 6.3.1.2, Unit Staff Qualifications, Covering Designation of Health Physics Mgt Personnel as Radiation Protection Manager
ML20128B369
Person / Time
Site: Callaway Ameren icon.png
Issue date: 01/27/1993
From:
UNION ELECTRIC CO.
To:
Shared Package
ML20128B366 List:
References
ULNRC-2756, NUDOCS 9302030025
Download: ML20128B369 (10)
v • d • e


Text

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4 ULNRC-2756 ,

6 ATTACHMENT 1 TECHNICAL SPECIFICATION CHANGES 9302030025 930127

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.. g ADMINISTRATIVE CDC ROLS 6.2.3 INDEPENDENT SAFETY ENS!NEERING GROUP (ISEG}.

FUNCTION 6.2.3.1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, REPORTABLE EVENTS and other sources of plant design and operating experience infomation, including plants of similar design, which may indicate areas for improving plant safety. The ISEG shall make detailed recomendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of improving plant safety to the Manager, Nuclear Safety and Emergency Preparedness and the Manager, Callaway Plant.

COMPOSITION 6.2.3.2 The ISEG shall be composed of at least five, dedicated, full-time engineers located on site. Each shall have a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field.

RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

  • that these activities are performed correctly and that human errors are reduced as much as practical. .

RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, maintained, and forwarded each calendar month to the Manager Nuclear Safety and Emergency

) Preparedness and the Manager, Callaway Plant.

6.2.4 SHIFT TECHNICAL ADVISOR The Shift Technical Advisor (STA)** shall provide technical support to the Shif t Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit.

6.3 UNIT STAFF OUALIFICATIONS

d 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica.

tions of ANSI /ANS 3.1-1978 with the following exceptions:

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w 6.3.1.1 Shift Supervisors, Operating Supervisors Reactor Operators, and Shift S Technical Advisors shall meet or exceed the qualifications of ANSI /ANS 3.1-1981

~K.T .o as endorsed by Reg. Guide 1.8, Revision 2, with the same exceptions as contained g ~$ in the current revision to the Operator Licensing Examiner Standarcs NUREG-1021, i

ES-202.

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'Not respons1 Die f or sign-of f function.

! "The STA position shall be manned in MDDES 1, 2, 3 and 4 unless the Shif t Supervisor or the individual with a Senior Operator license meets the qualifi-cations for the SIA as required by the NRC.

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CALLAWAY - UNIT 1 6-6 Amendment No. 60 i

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., ULNRC 2756  : I I

i Insert A i G.3.1.2 The Superintendent, Health Physics, the Suoerviso n  :

liealth Physics, Technical Support. or the Supervisor. Health  !

EhyEics. Operations (who) shall meet or exceed the qualificetions of USNRC Regulatory Guide 1.8, Septerrber 1975, for a' Radiation Protection Manager. The Radiation Protection Manaaer will b_e  ;

desionated by the Plant Manauer. .

i (Note: Additions are underlined;. deletions are bracketed.) -

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ADMINISTRATIVE CONTROLS 0.2.3 INDEPENpjNT SAFETY ENGINEERING GROUP (ISEG)

ERNCTION 6.2.3.1 The ISEG shall function to examino plant operating characteristics, NRC issuancos, industry advisorios, REPORTABLE EVENTS and other sourcos of plant design and operating experienco information, including plants of similar design, which may indicato areas for improving plant safety. The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenanco activities, operations activities or other means of improving plant safety to the Manager, ,

Nuclear Safety and Emergency Preparednoss and the Manager, Callaway Plant.

COMERS 11LQfi 0.2.3.2 The ISEG shall be composed of at least five, dedicated, full-timo ongincors located on sito, Each shall have a bachelor's degreo in engineering or related selonco and at least 2 years professional lovel experience in his field.

1 RESPONSIBILLI[ES G.2.3.3 The ISEG shall be responsible for maintaining survoillance of plant activities to  ;

provido indopondent verification' that those activities are performed correctly and that human orrors are reduce as much as practical, HECORDS 6.2.3.4 Records of activities porformed by the ISEG shall be prepared, rnaintainod, and forwarded each calendar month to the Managor, Nuclear Safety and Emergoncy '

Preparodnoss and the Manager, Callaway Plant.

D.2.4 SHIFT TECHNICAL ADVISOR The Shif t Technical Advisor (STA) shall provido technical support to the Shif t Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit.

L3 QNIT STAFF QUALIFICATIONS . _ _

6.3.1 Each member of the unit staff shall meet or exceed the minirnum qualifications of ANSI /ANS 3.1 1978 with the following exceptions:

0.3.1,1 Shif t Supervisors, Operating Supervisors, Reactor Operators, and Shif t Technical Advisors shall moet or exceed the qualifications of ANSI /ANS 3,1 1981 as ondorsed by Reg. Guido 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operator Licensing Examiner Standards, NUREG-1021, ES 202.

6.3.1.2 The Superintendent, Health Physics, the Supervisor, Health Physics, Technical Support, or the Suporvisor, Health Physics, Operations shall meet or excoed tho qualifications of USNRC Regulatory Guido 1.8, September 197S, for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the Plant Manager.

'Not responsibio for sign-off function.

  • 'The STA position shall be manned in MODES 1,2,3 and 4 unless the Shift Supervisor or the individual with a Senior Operator license moots the qualifications for tho STA as required by the NRC.

CALLAWAY - UNIT 1. 6-6 Amendment No. 60

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- ULNRC- 27$6 I

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ATTACIIMENT 2 I l

SAFETY EVALUATION i i

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. ULNRC 2756

. Attachment 2

  • Page 1 of 1 SAFETY RyhLUJ1TlDJ{

This amendment application requesto a revision to Technical specification 6.3.1.2 to allow any one of three nanagement personnel within the llealth Physics department, i.e., the Superintendent, llealth Physics, the Supervisor, Health Physics, Technical Support, or the Supervisor, Health Physics, Operations, to be designated as the Radiation Protection Manager as long as that person meets or exceeds the qualifications of USNRC Regulatory Guide 1.8, September 1975, for a Radiation Protection Manager ao clarified in NUREG/CR-5569, " Health Physics Positions Data Base," May 1992. The Radiation Protection Manager will be designated by the Plant Manager.

The proposed change to the Technical Specifications does not --

involve an unreviewed safety question because operation of the Callaway Plant with this change would not:

1. Increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.

The proposed change does not affect accident initietors or assumptions. The radiological consequences of any accident previously evaluated remain uncnanged.

2. Create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report.

The proposed change does not create any new accident initiators nor involve any modifications or changes in the plant.

3. Reduce the margin of safety as defined in the basis for any technical specification.

The proposed change does not affect any safety limits or boundary or tystem perf ormance.

This change does not reduce management control of the Callaway Plant radiation protection program nor affect the potential for exposures vf persons to radiation. The proposed change does not reduce the overall base of experience at the Callaway Plant nor the commitment to minimum qualifications. Callaway Plant personnel will continue to have the training, experience, and expertise necessary to recognize, analyze, assess, evaluate, and effectively respond to plant transients or other abnormal events.

Given the above discussions, as well as those presented in the Significant Hazards Consideration, the proposed cr.ange does not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

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. - ULNRC- 2756 ATTACHMENT 3 '

SIGNIFICANT HAZARDS EVALUATION W.

m_ __--_.__-__ _____________._._______ ___m _.m___________.______-_______..______________m. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

?  :-.-- ULNRC- 2756

... -Attachment 3- -

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-SIGNIFICANT'HAZARDSfEV.1LUATION This amendment application requestsLa-revision--to? Technical 1

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Specification'6.3,1~.2Lto allow any one of three_ management  ;

personnelLwithin the' Health' Physics department, i.e., _the Superintendent, Health: Physics, the= Supervisor,L Health-Physics,:

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-Technical' Support,-or the Supervisor,JHealth Physics, 0perations; to be designated as the' Radiation Protection Manager as long:as that person meets or exceeds the qualifications ofLUSNRCL '

Regulatory Guide 1.8,_ September:1975, for-a-Radiation ~ Protection Manager. _The Radiation Protection Manager will be designated by the Plant Manager.

The proposed change to Technical Specifications--does not-involve a significant hazards consideration because operationLof the Callaway Plant with this change would not:

1.- Involve a significant increase in the probability 'ori coneequences of an accident previously evaluated.

The change does not affect accident initiators or assumptions. The radiological' consequences of any-accident previously evaluated remain unchanged.

2. Create _the possibility-of a new or different kind.of accident from any previously evaluated.

The proposed change does not create any new accident initiators nor involve any modifications or changes-in-the 4 plant.

- 3. Involve a significant reduction in a margin of safety.

The proposed change will not affect any safety limits.or boundary or system performance.

This change does not reduce management: control of the1Callaway -

Plant radiation protection program nor affect'the_ potential _for exposures of persons to radiation. The-proposed change does not reduce the overall base of experience at the _Callaway Plant. nor: ,

the commitment to minimum qualifications. ~Callaway PlantL personnel will continue to have'the training,iexperience,fand expertise necessary to. recognize, analyze,- assess,_ evaluate, and effectively respond.to plant transients or other abnormal events.

, As discussed above, the proposed change does not involve a:

significant increase in.the probability or consequences of an accident-previously evaluated, create the possibility-of a new'or -

different kind of accident:from any previously evaluated, or:

result in a-significant reduction in a margin of safety.

Therefore, it has been determined that the proposed change does not involve a significant hazards consideration.

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  • ULNRC-2756 ATTACHMENT 4 EtNIRONMENTAL CONSIDERATION I

. ULNRC- 2756

. Attachment 4 Page 1 of 1 ENVIRONMENTAla CONSIDERATION This amendment application requests a revision to Technical Specification 6,3.1.2 to allow any one of three management personnel within the Health Physics department, i.e., the Superintendent, Health Physics, the Supervisor, Health Physics, Technical Support, or the Supervisor, Health Physics, Operations, to be designated as the Radiation Protection Manager as long as that person meets or exceeds the qualifications of USNRC Regulatory Guide 1.8, September 1975, for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the Plant Manager.

The proposed amendment involves a change to the administrative controls on plant personnel located within the restricted area as defined in 10CFR20. Union Electric has determined that the proposed amendment does not involve:

1) A significant hazard consideration, as discussed in Attachment 3 of this amendment application;
2) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite;
3) A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51.22 (b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

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