View source for AECM-85-0346, Application for Amend to License NPF-29,revising Tech Spec 6.3.1 for one-time Exception of Reg Guide 1.8 Re Qualifications of Chemistry/Radiation Control Superintendent

{{Adams
| number = ML20138J711
| issue date = 10/23/1985
| title = Application for Amend to License NPF-29,revising Tech Spec 6.3.1 for one-time Exception of Reg Guide 1.8 Re Qualifications of Chemistry/Radiation Control Superintendent
| author name = Kingsley O
| author affiliation = MISSISSIPPI POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = 
| docket = 05000416
| license number = 
| contact person = 
| case reference number = RTR-REGGD-01.008, RTR-REGGD-1.008
| document report number = AECM-85-0346, AECM-85-346, TAC-59680, TAC-59692, NUDOCS 8510290449
| package number = ML20138J704
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 7
| project = TAC:59680, TAC:59692
| stage = Request
}}

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET No. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and MIDDLE SOUTH ENERGY, INC.
and-SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, O. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of Mississippi Power & Light Company; that on behalf of-Mississippi Power & Light Company, Middle South Energy, Inc., and South Mississippi Electric Power Association I am authorized by Mississippi Power & Light Company to sign and file with the Nuclear Regulatory Cornission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of Mississippi Power & Light Company; and that the statements made and the matters set forth therein are true and correct to            best of my knowledge, information and belief.
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T.\JN Kings       Jr STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN TO beforg me, a Nop ry Public, in and for the County and . State above named, this ,Q4AJ' day of /(2nf4v                     ,  1985.
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My commission expires:
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Attechmsnt 1 Proposed Change to the Operating License (PCOL-85/15)
(Revision 1)
I.     

==SUBJECT:==
NLS-85/11 Technical Specification 6.3.1, p. 6-6 and Figure 6.2.2-1 II. DISCUSSION:
A revision to Technical Specification 6.3.1 is proposed to indicate that either the Chemistry / Radiation Control (C/RC) Superintendent or his
* Technical Assistant will meet or exceed the qualification requirements of Regulatory Guide 1.8 (September 1975). The proposed revision adds the reference to the C/RC Superintendent's Technical Assistant.
A revision to Technical Specification Figure 6.2.2-1 is also proposed to reflect the addition of Technical Assistant to the C/RC Superintendent, consistent with the content of this PCOL.
This version of the PCOL revises and supersedes that submitted to the NRC on September 13, 1985 via MP&L letter AECM-85/0263. The specific changes described above are provided in Attachment 2.
This proposed change represents a one-time exception to Specification 6.3.1 and would be effective until such time that the current C/RC Superintendent successfully completes the proposed training program described below or until an NRC approved individual is placed in that position.
III. BACKGROUND MP&L proposed a one-time exception to the Grand Gulf Nuclear Station (GGNS) technical specifications in its letter to the NRC, dated September 13, 1985 (AECM-85/0263). The exception pertained to Technical Specification 6.3.1, as it relates to Regulatory Guide 1.8 and the qualification requirements for the C/RC Superintendent. Additional background detail on this issue can be found in AECM-85/0263.
In discussions held with the NRC Staff on September 23 and 24 MP&L representatives were advised that without commitment to further compensatory measures the proposed exception wcul1 not be acceptable. In subsequent discussions with the NRC on October 17, MP&L proposed the following elements to resolve the issue:
(1)    Mr. John Vincelli, the current Radiation Control Supervisor, meets the   l qualifications for the site's Radiation Protection Manager (RPM) per     l Regulatory Guide 1.8 (September 1975). Given the concerns of the NRC regarding the qualifications of the C/RC Faperintendent, MP&L proposed that Mr. Vincelli function as the RPM on an interim basis.
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(2)  Mr. Vincelli would be assigned as a full-time Technical Assistant to the C/RC Superintendent. As such, Mr. Vincelli would be relieved of all responsibilities associated with the Radiation Control Supervisor position. A new Radiation Control Supervisor would be selected and appointed.
(3)  Mr. Vincelli would remain in this capacity at a minimum until the C/RC Superintendent has completed the proposed training program designed to qualify the C/RC Superintendent to Regulatory Guide 1.8. This training program is described below.
(4)  In the absence of the C/RC Superintendent from the GGNS site in
* fulfillment of the training program, Mr. Vincelli would assume all duties of the C/RC Superintendent.
(5) Based on this discussion with the NRC, MP&L proposed to revise and resubmit PCOL-85/15 (AECM-85/0263) for NRC review and approval.
IV. STAFF ASSISTANCE FROM QUALIFIED RADIATION PROTECTION MANAGER Based on the referenced conversations, MP&L understands that the NRC would consider the current C/RC Superintendent as a qualified RPM per Regulatory Guide 1.8 only after the suctessful completion of the proposed training program. The proposed program is discussed in Section V below. Pending completion of the training program, MP&L proposes to augment the current C/RC Superintendent with the assistance of a qualified RPM position staff member.
The proposed Technical Assistant position is to be filled by Mr. John Vincelli, currently the Radiation Control Supervisor on the GGNS plant staff.
A. Qualifications of The Proposed Radiation Protection Manager Mr. Vincelli has approximately five years experience at GGNS in the health physics / radiation protection areas. This experience includes both supervisory responsibilities (approximately three and one-half years) and a two month training period at a commercial BWR facility during a major refueling outage.
Prior to joining MP&L, Mr. Vincelli spent approximately six years in the U. S. Navy's nuclear power program. Following the standard training program, his service included three years as an Engineering Laboratory Technician. This service period included radiological control functions during major nuclear submarine repair periods, as well as, the shipping and disposal of radioactive waste material.
Mr. Vincelli's education includes over two years college credit in math, science, and engineering courses. In addition to this and the U. S. Navy nuclear power training, as detailed in Attachment 3, Mr. Vincelli has completed numerous courses in BWR systems design, health physics, supervisory skills, etc.
J16ATTC85101001 - 2

l  .                 .
I i
.                                                      Based on this education and training record, in combination
;                                                with his experience in technical and supervisory roles in radiation i'                                               protection / control applications, MP&L considers Mr. Vincelli to meet l                                                the requirements of GGNS FSAR 12.5.1.1 and Regulatory 1.8 (September i                                                 1975) and therefore qualified as a Radiation Protection Manager.
l                                B.              Principal Responsibilities of Technical Assistant to C/RC
 ;                                               Superintendent
!                                                      As Technical Assistant to the C/RC Superintendent, Mr. Vincelli's principal responsibilities are summarized below.
o    Radiation Protection Manager for GGNS.
i o    Technical evaluation and recommendation of corrective I
actions for BWR specific operational and maintenance
;                                                           evolutions which may cause radiological protection
;                                                           problems.
e o    Review of plant design changes for ALARA concerns.
o    Review of operational and maintenance activities to ensure proper BWR radiological protection precautionary measures are incorporated.
o    Recommend ALARA techniques to be incorporated into the
 !                                                          pre-planning of major jobs which involve significant exposure.
o    Evaluate and make recommendations on the material and equipment being used for exposure and contamination
 ;                                                          control. Evaluate and make recommendations for the preparations necessary to ensure the effectiveness of radiological controls for unscheduled and scheduled plant f                                                           outage maintenance periods.
As noted in Section III above, Mr. Vince111 would be relieved of those responsibilities associated with the Radiation a                                                 Control Supervisor position and would function as a full-time                      r i
Technical Assistant to the C/RC Superintendent. In the absence of 4                                                 the C/RC Superintendent, Mr. Vince111 would assume the duties and
;                                                 responsibilities of that position.
j                 V.              PROPOSED TRAINING PROGRAM la                                As discussed above, MP&L proposes a training program for the current C/RC Superintendent to address NRC concerns regarding RPM experience requirements.
l                MP&L proposes that C/RC Superintendent attend formal training in the following
 !                subjects (or participate in the described activities):
l i
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(a) General Electric Radiological Engineering Course (8 weeks)
This training is BWR specific applied radiological control techniques with emphasis on outage and refueling operations.
or Oak Ridge Applied Health Physics Course (5 weeks)
Intensive training course consinting of lectures, laboratories and nuclear facility tours. Covers topics from radiation physics to environmental monitoring.
(b) Planning for Nuclear Emergencies Course (1 week)
This course provides detailed coverage of all aspects of emergency planning, including accident source terms, plume projections and dose estinates, protective actions, and standards for emergency      "
actions.
(c) Grand Gulf BWR Systems Course (4 weeks)
This training provides the required working knowledge of plant systems and their. interface.
(d) BWR Refueling (4 week minimum)
Visit and participate, to the maximum extent allowable, in a BWR refueling as an assistant Health Physics supervisor.
(e) GGNS Outage and Refueling Plan, schedule and direct all Health Physics activities for the upcoming GGNS fall outage and first refueling outage. In this capacity he will be assisted by an RPM qualified staff member discussed in Section II above.
The course durations depicted above are approximate. Overall, the described training program has been estimated to be completed by June 1987.
The program is considered to be an effective combination of classroom and practical training, including BWR system design and radiation protection / health physics areas, as well as, refueling / outage experience.
VI. CONCLUSION The experience of the current C/RC Superintendent was discussed in detail in MP&L's letter of September 13, 1985 (AECM-85/0263). Of particular note, the current superintendent has considerable management expertise having demonstrated competence not only at MP&L but also in numerous, highly responsible roles in his naval service.      (See Attachment 1, Section IV.B of the referenced MP&L letter.)
As compensatory measures, in addition to corporate support discussed in the {{letter dated|date=September 13, 1985|text=September 13, 1985 letter}}, HP&L proposes that the C/RC Superintendent be assisted by an RPM qualified staff member. The qualifications and role of this Technical Assistant are described in Section IV above. To address NRC concerns regarding the superintendent qualifications as an RPM, a rigorous, thorough training program has been proposed for NRC Staff review.
Based on this proposed approach, MP&L requests approval of the proposed one-time exception to Technical Specification 6.3.1.
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c VII. SIGNIFICANT HAZARDS CONSIDERATION Mississippi Power & Light Company (MP&L) has proposed a one-time exception to Technical Specification 6.3.1.       The NRC Staff does not consider the current Chemistry / Radiation Protection (C/RC) Superintendent to meet the Regulatory Guide 1.8 requirements for the plant's Radiation Protection Manger (RPM). Therefore, MP&L proposes that the current C/RC Superintendent be assigned a Technical Assistant who is a qualified RPM.
The Technical Assistant's role includes specifically identified j    responsibilities to ensure proper integration and utilization of the RPM expertise. A training program has also been proposed to qualify the current
;    superintendent as an RPM.
* i (a) The proposed one-time exception does not involve a significant increase in the probability or consequences of an accident previously evaluated because the current superintendent will be assisted by an RPM meeting the technical specification requirements.
i                 Both individuals have significant experience in radiation protection, including supervisory roles. With one of the individuals meeting          ,
the specification's minimum requirements, there is essentially no decrease in the level of safety.
4 (b) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because both the current superintendent and the proposed Technical Assistant have significant experience in the radiation protection field. The assistant meets the specification's minimum requirements.
Specifically, the assistant has both radiation protection training and experience at GCNS and refueling outage experience at another operating BWR.
,            (c) The purpose change does not involve a significant reduction in margin of safety because the current superintendent will be assisted in a specified manner by an RPM qualified individual; therefore, the minimum specification requirements are met. The proposed exception
!                 represents essentially the same level of safety as would 1: ave been maintained without the exception.
i Based on the above discussion, the proposed one-time exception is not considered to represent a significant hazard.
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