ML20138H894
| ML20138H894 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/11/1985 |
| From: | MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20138H879 | List: |
| References | |
| TAC-59680, NUDOCS 8512170365 | |
| Download: ML20138H894 (10) | |
Text
r Att; chm:nt 1 PCOL-85/15 Rev. 2 Proposed Change to the Operating License (PCOL-85/15)
(Revision'2)*
I.
SUBJECT:
NLS-85/11 Technical Specification 6.3.1, p. 6-6 II. DISCUSSION:
It is proposed to add a "##" footnote on page 6-6 to the Regulatory Guide 1.8 (September 1975) references in Technical Specification 6.3.1.
The footnote provides an exception to the guidance of Regulatory Guide 1.8 with regard to the qualification requirements for the Chemistry / Radiation
~ Control (C/RC) Superintendent. The subject footnote is proposed to read as follows:
- Except that the individual identified in MP&L's letter to the NRC, dated December 11, 1985, is considered qualified to hold the position of Chemistry / Radiation Control Superintendent based on experience, education, and other information provided or referenced in that letter.
This version of the PCOL amends that previously submitted to the NRC on October 24, 1985 (AECM-85/0346). The specific change describ'ed above is 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 the above referenced letters to the NRC. 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 those letters.
Based on discussions with the NRC Staff on November 5, MP&L propose 3 the following elements to resolve the issue: l (1) Mr. John Vincelli, the current Radiation Control Supervisor, meets the qualifications for the site's Radiation Protection Manager (RPM) per Regulatory Guide 1.8 (September 1975). Given the concerns of the NRC regarding the qualifications of the C/RC Superintendent, MP&L proposed that Mr. Vincelli augment the RPM on an interim basis.
- Change bars in the right hand margin indicate changes from PCOL-85/15, Revision 1.
8512170365 851211 PDR ADOCK 05000416 J16ATTC85101001 - 1
(2) Mr. Vincelli would be assigned as a full-time Technical
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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 pro osed 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 successful 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 Regulatory Guide 1.8 l qualified 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 Technical Assistant Mr. .ncelli 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.
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Based on this education and training record, in combination
! with his experience in technical and supervisory roles in radiation protection / control applications, MP&L considers Mr. Vincelli to meet the requirements of GGNS FSAR 12.5.1.1 and Regulatory 1.8 (September 1975) and therefore qualified as a Radiation Protection Manager.
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 Act as the Radiation Protection Manager for GGNS during the absence of the C/RC Superintendent.
o Technical evaluation and recommendation of corrective actions for BWR specific operational and maintenance evolutions which may cause radiological protection problems, 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 nece'ssary to ensure the effectiveness of radiological controls for unscheduled and scheduled plant outage maintenance periods.
As noted in Section III above, Mr. Vince111 would be relieved of those responsibilities associated with the Radiation Control Supervisor position and would function as a full-time Technical Assistant to the C/RC Superintendent. In the absence of the C/RC Superintendent Mr. Vincelli would assume the duties and responsibilities of that position.
V. PROPOSED TRAINING PROGRAM As discussed above, MP&L proposes a training program for the current C/RC Superintendent to address NRC concerns regarding RPM experience requirements. MP&L proposes that C/RC Superintendent attend formal training in the following subjects (or participate in the described activities):
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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 consisting 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 estimates, 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 Re'ueling f (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 CGNS fall outage and first refueling outage. In'this capacity he will be assisted by an RPM qualified staff member discussed in Section II above.
4 The course durations depicted above are approximate. Overall, the
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-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 September 13, 1985 letter, MP&L proposes that the C/RC Super-intendent be assisted by a Regulatory Guide 1.8 qualified staff member. l 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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s 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 qualified to Regulatory Guide 1.8.
The Technical Assistant's role includes specifically identified responsibilities to ensure proper integration and utilization of the Regulatory Guide 1.8 expertise. A training program has also been proposed l to qualify the current superintendent as an RPM.
(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.
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.
(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 GGNS and refueling outage experience at another operating BWR.
(c) The proposed change does not involve a significant reduction in l margin of safety because the current superintendent will be assisted in a specified manner by Regulatory Guide 1.8 qualified individual; l therefore, the minimum specification requirements are met. The proposed exception represents ess'entially the same level of safety as would have been maintained without the exception.
Based on the above discussion, the proposed one-time exception is not considered to represent a significant hazard, i
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Attachment 2 PCOL-85/15
' Rev. 2 i
~ ADMINISTRATIVE CONTROLS INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) (Continued) p 4 RESPONSIBILITIES
. 6.2.3.3 The ISEG'shall be responsible for maintaining surveillance of unit activities.to provide independent verification" that,these activities are performed correctly and that human errors are reduced as much as practical.
! AUTHORITY 6.2.3.4 The ISEG shall make detail'ed recommendations for revised procedures, !
j equipment modifications, maintenance activities, operations activities or other means of improving unit safety to the Senior Vice President, Nuclear.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor sha'll provide technical support to the i Shift Superintendent in the areas of thermal hydraulir:3, reactor engineering and plant analysis with regard to safe operation of the unit. ,
6.3 UNIT STAFF QUALIFICATIONS 3 4 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications-of ANSI N18.1-1971 for comparable positions and the supplemental r requirenants specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC lette rto'all licensees, except for the Chemistry / Radiation Control Super-8 4- intendent who shal meet or exceed the qualifications of Regulatory Guide 1.8, September 197g5,theShiftTechnicalAdvisorwhoshallmeetorexceedthe l4grV f-qualifications referred to in Section 2.2.1.b of Enclosure I of the October 30, N 1979 NRC letter to all operating nuclear power plants; and those members of the g Independent Safety Engineering Group used for meeting the minimum complement specified in Section 6.2.3.2, each of whom shall have a Bachelor of Science
& degree or be registered as a Professional Engineer and shall'have at least two years experience in their field, at least one year of which experience shall be in the nuclear field. :
6.4 TRAINING 6.4.1 .A retraining and replacement training program for the unit staff shall i
be maintained under the direction of the Training Superintendent, shall meet l
or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 F and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC lette ft5 all j
> licensees, and shall include familiarization with' relevant industry operational ,
experience. )
OutspnsWo#4
- 6.5 REVIEW AND AUDIT dwem6s armd
. n@L W 6.5.1 PLANT SAFETY REVIEW COMITTEE (PSRC)
- F WS#8 Atas.-W/M.
FUNCTION AanEmmawWu
-- ^
i 6.5.1.1 The PSRC shall function to advise the GGNS General Manager on a matters related to nuclear safety.
- =
! Not respo'nsible for sign-off function.
/ MEET FCtDt#SS FWW1 AfJrT A6aL /6 I
GRAND GULF- ~1 6-6
PCOL-85/15 Rev. 2 FOOTNOTE INSERTS FOR PAGE 6-6 Except that the experience and other training information provided in a .PCOL-85/14 letter to the NRC dated July 29, 1985 are acceptable for the individuals AECM-85/0270 listed in that letter. 8/30/85 Except that the individual' identified in MP&L's letter to the NRC dated PCOL-85/15 December 11, 1985-is considered qualified to hold the position of Rev. 2 Chemistry / Radiological Control Superintendent based on the experience, education, and other information provided or referenced in that letter.
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-* Attcchment 3 Pega 1 NAME: John C. Vincelli BIRTHDATE: 1952 FORMAL EDUCATION AND TRAINING:
o Navy Nuclear Power Program (Jan. 1974 - Oct. 1975)
This program included:
1.. A three month training course in electrical theory, distribu-tion systems and repair of electrical equipment.
- 2. A six month basic nuclear power training program in math, nuclear physics, thermodynamics, radiation protection, chemistry controls, reactor theory, and plant systems.
- 3. An eight month training period at an operating Navy nuclear unit. This program included applied on-the-job training in the areas of plant operations, maintenance, radiation and chemistry controls. Several specialized training courses were conducted in such areas as equipment maintenance and repair techniques, applied ALARA methods, primary and secondary chemistry controls, and plant system operational interrelationships.
- 4. A three month Engineering Laboratory Technician (ELT) School.
This school consisted of formal classroom training in radio-logical protection and chemistry fundamentals and practical application techniques in the areas of exposure and contamina-tion contrels, dosimetry, respiratory protection, shielding, ALARA reviews, radiological surveys, and chemistry controls.
o 110 Credit Hours College Approximately 65 credit hours in math, sciences, and engineering.
One graduate-level course completed in Radiation Biology.
o General Electric BWR Radiological Engineering School This two month training course included BWR specific topics such as:
- 1. BWR radioactivity sources
- 2. Shielding
- 3. Applied external dosimetry techniques
- 4. Internal dosimetry
- 5. Radiation detection instrumentation e
r Attechment 3
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Pcge 2
- 6. Counting statistics
- 7. Regulations
- 8. Radwaste shipping
- 9. Radiological survey techniques and RWPs
- 10. Air sampling techniques
- 11. BWR exposure and contamination control methods
- 12. Respiratory protection and engineering controls
- 13. Outage Health Physics planning
- 14. Radiological emergencies o Health Physics Training Program This three month training progran consisted of basic Health Physics
- fundamentals and applied techniques for commercial power plant Health Physics technicians. It was conducted at Grand Gulf Nuclear Station.
o Other Short Courses Completed
- 1. OSHA Respiratory Protection - I week
- 2. Respiratory Protection for Nuclear Power Plants - I week
- 3. BWR Systems - 4 weeks
- 4. Radwaste Shipping and Disposal - 2 weeks
- 5. Mitigation of Core Damage - 2 weeks
- 6. Supervisory Training - I week
- 7. Kepner Tregoe Problem Solving and Decision Making - I week EXPERIENCE 1973 - 1979 U. S. Navy
_Liad ELT (Aug.1977 - Aug.1979) - Supervised the ship's radiological
_ protection and chemistry programs. These programs included exposure and contamination control, radiological controls for plant maintenance and operational evolutions, dosimetry, respiratory protection, equipment decontamination Radwaste, radiological survey instrumentation, training of ship's personnel, primary and secondary system chemistry controls, and radioactive material accountability. During this period I supervised the radiological protection program for an extended overhaul period.
ELT (Aug. 1976 - Sept. 1977) - Responsible for the ship's dosimetry program, radioactive material accountability, instrumentation, and training of ship's personnel.
Attechnent 3 Pogs 3 Radiation Controls Supervisor (Dec. 1976 - Feb. 1977. July - Sept. 1977)
While serving as Lead ELT and ELT, temporarily assigned to two steam generator inspec. tion teams, Responsibilities included supervising the radiological controls for the performance of eddy current testing and
, plugging of steam generator tubes. Also, directly supervised the post-job plant and equipment decontamination effort.
Radiation Controls Monitor (Nov. 1975 - Aug. 1976) - Responsibilities included providing radiological coverage for major nuclear repairs of submarines during extended repair periods and the shipping and disposal of Radwaste.
1980 - present Mississippi Power & Light Company Radiation Control Supervisor (Mar.1982 - present) - Responsible for the development and implementation of an effective radiological protection program at the Grand Gulf Nuclear Station. This program includes exposure and contamination control, dosimetry, respiratory protection. ALARA, emergency planning, Radwaste shipping and disposal, and radiological engineering. Directly responsible for the selection, training and qualification of a staff of up to 65 Health Physicists.
Site Emergency Planning Coordinator (May 1981 - March 1982) -
Developed GGNS's Emergency Plan Procedures and coordinated the successful completion of the station's first NRC Emergency Preparedness Appraisal and Exercise. Additional responsibilities included procurement of emergency supplies, establishment of onsite emergency facilities, and coordination of training programs.
Health Physicist (Oct. 1980 - May 1981) - Responsible for the development of the respiratory protection program including procedural preparation and the purchase of equipment and supplies.
During this period I was temporarily assigned to Hatch Nuclear Station for a two month training period during a major refueling outage.
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