ML20236G176
| ML20236G176 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/30/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-REGGD-01.008, RTR-REGGD-1.008 WM-87-0205, WM-87-205, NUDOCS 8708040149 | |
| Download: ML20236G176 (3) | |
Text
y W6M.F CREEK NUCLEAR OPERATING CORPORATION P
cs.:s.euuv.ome.r -
July 30, 1987 l
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Letter: WM 87-0205 Re:
Docket No. 50-482 Ref:
Letter dated 6/30/87 from JEGagliardo, NRC, to' BDWithers, WCN0C Subj :
~ Response to Violation 482/8712-01 Gentlemen:
Attached is a detailed -response to violation (482/8712-01) which was documented.in the Reference.
The violation concerns the qualifications of.
the Site Health Physicist as they relate to hi s abilitly to assume the function of the Radiation Protection Manager.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Iery truly yours, ll Bart D. Withers i
President and Chief Executive Officer j
BDW:11 k Attachment cc:
P0'Connor (2)
RMartin JCummins 8708040149 870730 DR ADOCK 050 2
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P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364 8831
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An Equal Opporturuty Ernployer M'FHC/ VET
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_.-___________J
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Att=chmsnt to WM 87-0205.
Page 1 of 2 July 30, 1987 Violation (482/8712-01):
Radiation Protection Manager Qualifications Finding:
Technical Specification 6.3.1 states "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS3.1-1978, except for the Site Health Physicist who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 for a Radiation Protection Manager".
Regulatory Guide 1.8 states the Radiation Protection Manager should have a Bachelor's Degree or the equivalent, including some formal training in Radiation Protection and at least 5 years of professional experience in applied radiation protection.
Contrary to the above, the NRC inspectors determined on May 21,
- 1987, the Site Health Physicist did not meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
The Site Health Physicist satisfied the bachelor's degree equivalent requirements, but only had 3 years of professional experience in applied radiation protection.
Reason for Viol,ation:
Wolf Creek Nuclear Operating Corporation (WCNOC) believes that the individual who held the Site Health Physicist position on May 1, 1987 does meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
The professional responsibilities assigned to the individual from May, 1983 to the time of appointment as Site Health Physicist (April, 1987) was reviewed by station management and determined to be directly applicable to the experience requirements of Regulatory Guide 1.8.
The activities
- included, but were not limited to, such activities as Off-site Dose Calculation Manual (ODCM) development, process monitor calibration procedure development, and Regulatory Guide 1.21 semi-annual report preparation.
Even though the above activities were performed by the individual wnile assigned to the station chemistry group, the professional experience requirement has been met as the experience base and knowledge gained in applied radiation protection was not lessened.
Corrective Steps Which Have Been Taken and Results Achieved:
Even though WCNOC believes the individual met the required qualifications and full compliance to Regulatory Guide 1.8 was met, several corrective steps have been taken to alleviate the NRC's concern with this issue.
The Site Health Physics group has been transferred to the Plant Support Group under the Superintendent of Plant Support who meets the Regulatory Guide 1.8, September 1975 criteria for Radiation Protection Manager.
The Superintendent of Plant Support has been assigned as the Radiation Protection Manager until the Site Health Physicist gains the additional two ytars of professional experience in applied radiation protection.
Additionally, a change to Technical Specification.s,'Section 6.3.1, has been submitted which changes the requirement that the Site Health Physicist meet the Radiation Protection Manager qualifications.
This change will require that the Radiation Protection Manager meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
E
t Attachment to WM 87-0205 Page 2 of 2 July 30,1987 Corrective Steps Which Will Be Taken To Avoid Further Violations:
The Superintendent of Plant Support will continue to hold the position of j
Radiation Protection Manager until the Site Health Physicist gains additional professional experience in applied radiation protection.
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved when the NRC formally approves the Technical Specification change to Section 6.3.1.
s 4
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