ML18353A889

Letter Request for Change to Technical Specifications on Minimum Qualification Requirements for Radiation Protection Manager (Health Physicist)

ML18353A889
Person / Time
Site:	Palisades
Issue date:	05/17/1977
From:	Hoffman D Consumers Power Co
To:	Schwencer A Office of Nuclear Reactor Regulation
References
Download: ML18353A889 (5)

Text

• • consumers .

Power comp*nY General Offices: 212 *west Michigan Avenue, .Jackson, Mich;gan 49201

• Area Code 517 788-o'550 .

May i7, 1977 Director of Nuclear Reactor Regulation Att: }Ir Albert Schwencer, Chief.

• Operating Reactor Branch No 1

• US Nuc)..ear Regulatory Commission Washington ;*De 20555 DOCKET 50-255 -*LICENSE DPR-20

.PALISADES PLANT - T/S CHANGE:

.HEALTH PHYSICIST M~N QUAL Transmitte.d hereWith are 'three ( 3 )_ original and* thirty'-seven ( 37) conformed

• copies of a request for* a Te.chnical .SpE:cifications c~ange to Docket 50'-255, License DPR-20.

The purpose of this submittal is to incorporate the minimum qualification

• requirements of the Radiation Protection Manage.r (Health Physicist) into the Technical Specifications *as requested_ by your letter.of March 9, 1977.

David .p :troffnian Assistant-Nuclear Licensing Adininistrator CC : JG Keppler, -. USNRC

.e CONSUMERS POWER COMPANY.

Docket 50-255 Request for Change to the Technical.Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in Provisional Operating License DPR-20, Docket 50-255, issuedto Consumers Power Company on October 16, 1972, be changed as described in Section I, below:

I. Changes A. Add Section 6.3.2 as follows:

"6.3.2 The Health Physicist. shall meet or exceed the qualifications of Regulatory Guide 1. 8, September 1975 _(l ).,

(l )F~~-the purpose of this se.ction "Equivalent," as utilized in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years

• of any one or combination of the following: .(a) Formal schooling in science*

or engineering; or (b) operational or technical experience/training .in nu~

clear power.

• Note: See attachment for proposed page change.

II. Discussion This proposed Technical Specifications addition is submitted in accordance with your r.ecommendation dated March 9, 1977.

In discussions with your staff concerning the* implementation of Regulatory Guide 1.8, the requirement that' the Radiation Protection Manager (Health Physicist) "~ . ~ sho~d -h.a-ie -a bachelor's* degree ~-~ ~qui vaient in .a science or an engineering subject ... " was addressed. It is Consumers Power Company position that the equivalency to a bachelor's degree is a minimum of four years operational or technical experience/training in nuclear power, and specifically for the Health Physicist, in radiological protection and con-trols. This interpretation will allow highly competent technicians without bachelor's degrees to assume the position of Health Physicist as long as the other requirements of Regulatory Guide 1.8 are met .

• The submission of this Technical Specifications change request is based upon the understanding that this interpretation is acceptable, 1

• III. Conclusions Based on the foregoing, the Palisades Plant Review Committee has concluded that this change does not involve an unreviewed safety question.

CONSU-MERS .POWER COMPANY

& Transmis Sworn and subscribed to before me this 17th day of May 1977.

• ~f~dJ

. . .~Tha;er;:NO"t Public.

Jackson County, Michigan My commission expires July 9, 1979 .

• 2

• -"4,1*

6.0

.~* . :........

ADMINISTRATIVE CONTROLS

• 1: *1::; t :~* ~ ~ ,..*~~*J~ ..... ~n 6.1 RESPONSIBILITY ti ' ~~ r *:*' , "i 6.1.1 The Plant Superintendent shall be responsible for overall plant operation and shall delegate in'\*ftifi,'g t'l].g ~u~!cl;!~~'ion for this reponsibility during his absence.

• 6.2 ORGANIZATION 6.2.1 OFFSITE The offsite organization for plant management and technical support shall be as shown on Figure 6.2-1.

6. 2_. 2 PLANT STAFF '

The plant organization shall be as sho'W!l on Figure 6.2-2 and:

a. Each on-duty shift shall be composed of at least the minimum shift crew composition sho'W!l in Table 6.2-1.

b. At least one licensed Operator shall be in the control room when fuel is in the reactor.

c. At least two licensed Operators shall be present in the control room during reactor start-up (through 15% power), scheduled reactor shutdown and during recoverjr from reactor trips.

d. *An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor.

e. All core alterations after the initial fuel loading shall either be performed by a licensed Reactor Operator under the general supervision of a Senior Reactor Operator or directly supervised by a licensed Senior Reactor Operator (or Senior Operator limited to Fuel Handling) who has no other concurrent responsibilities during this operation.

6.3 PLANT STAFF .QUALIFICATIONS 6.3.1 Each member of the plant staff shall meet or exceed the minimum qualifica-tions of ANSI NlB.1-1971 for comparable positions.

6.3.2 The Health Physicist shall m~et or exceed the qualifications of Regulatory Guide 1.8, September 1975. (lJ * *

( 1) For the purpose of this section "Equivalent," as utilized in Regulatory Guide 1. 8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following; *(a) Formal schooling in science or engineering, or (b) operational or technical experience/training in nuclear power.

6.4 TRAINING

• 6.4.1 A retraining and replacement training program for the plant staff shall be maintained under the direction of the Nuclear Training Administrator and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI Nl8.l-1971 and Appendix "A" of 10 CFR, Part 55.

RECEIVED DOCUHEMT PROCESSING UNIT 19Tf MAY 20 AM .8 41