ML20195F689

Safety Evaluation Accepting Proposed Reduction in Commitment in Quality Assurance Program to Remove Radiological Assessor Position

ML20195F689
Person / Time
Site:	Perry
Issue date:	11/05/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20195F679	List: ML20195F674 ML20195F689
References
NUDOCS 9811200059
Download: ML20195F689 (2)

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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ELIMINATION OF THE RADIOLOGICAL ASSESSOR POSITION ElBSTENERGY CORPORATION PERRY NUCLEAR POWER PLANT DOCKET NO. 50-440 i

1.0 INTRODUCTION

1 As a result of the Three Mile Island accident, the NRC performed an assessment of radiation protection programs throughout the industry. This effort resulted in NUREG-0855," Health Physica Appraisal Program." Due in part to the concerns raised by the NRC in NUREG-0855, the positien of Corporate Health Physicist was created in 1984.

1 By letter dated September 23,1998, pursuant to 10 CFR 50.54(a), FirstEnergy proposed a change to the FNPP Updated Safety Analysis Report (USAR), Section 17.2.1.3.2.1, which describes responsibilities of the Radiological Assessor (formerly Corporate Health Physicist).

The proposal requests to eliminate the Radiological Assessor position. The Radiological Tssessor provides oversight of the PNPP radiation protection program. The licensee considers mis oversight function to be redundant to the oversight functions already provided by on-site and off-site work groups (e.g., the Quality Assurance Section and the Company Nuclear Review Board).

2.0 EVALUATION I

PNPP proposes to revise USAR Section 17.2.1.3.2.1 by deleting the following sentences:

'The Radiological Assessor reports to the General Manager, PNPPD [ Perry Nuclear Power Plant Department]. The function of the Radiological Assessoris to provide health physics overview and evaluations of design and operationalprograms."

PNPP states that the responsibilities of the Radiological Assessor are redundant to other required programs. The Quality Assurance Section performs audits and surveillances (USAR Section 17.2.18) and has the ability to augment these audit / surveillance teams with experienced, technical experts. The off-site review board (the Company Nuclear Review Board

[CNRB)) is required to have a member qualified in the area of radiation protection (USAR Section 17.2.1.3.5). CNRB functions include the independent review and audit of various plant activities, which includes radiological safety activities (USAR Section 17.2.1.3.5 and 17.2.18.3.2).

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2 Additionally,10 CFR 20.1101 requires all licensees to periodically (at least annually) review the radiation protection program content and implementation. Finally, the ALARA Subcommittee (USAR Section 12.1.3) which is comprised of various disciplines including operations, engineering, and radiation protection, considers the concepts of ALARA when performing various site activities.

3.0 CONCLUSION

The proposed reduction in commitment is acceptable because it only changes a self-imposed PNPP commitment. This proposal does not take any new exceptions to PNPP's quality assurance program (USAR Chapter 17) which commits to NRC Regulatory Guides and ANSI '

Standards that provide the basis for satisfying 10 CFR 50 Appendix B. The proposed removal of the Radiological Assessor position described by the licensee as a " reduction in commitment" continues to satisfy the provisions in Section 17.2 of the Standard Review Plan (NUREG-0800).

Principal Reviewers: Michael T. Bugg Roger L. Pedersen Date: November 5, 1998 u

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