ML20135G129

Application for Amend to License NPF-29,requesting one-time Tech Spec Exception for Qualifications of Replacement Individual for Chemistry/Radiation Control Superintendent Position

ML20135G129
Person / Time
Site:	Grand Gulf
Issue date:	09/13/1985
From:	Kingsley O MISSISSIPPI POWER & LIGHT CO.
To:
Shared Package
ML20135G123	List: AECM-85-0263, Forwards Application for Amend to License NPF-29,requesting one-time Tech Spec Exception for Qualifications of Replacement Individual for Chemistry/Radiation Control Superintendent Position.Fee Paid ML20135G129 ML20135G134
References
TAC-59680, NUDOCS 8509180187
Download: ML20135G129 (8)

Text

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r AECM-85/0263 Page 4 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.

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 8 Light Company, Middle South Energy Inc., and South Mississippi Electric Power Association I as authorized by Mississippi

' Power & Light Company to sign and file with the Nuclear Regulatory Commission, 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 t best of my knowledge, information and belief.

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,c ', 0. V Kings .

. STATE OF MISSISSIPPI .

COUNTY OF HINDS 4

/ SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the' County and State above named, this AfLlay of y/m Mu A/d , 1985.

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Attcchment 1 to AECM-85/0263 Page 1 of 6 Proposed Change to the Operating License (PCOL)-85/15 i I.

SUBJECT:

NLS-85/11 Technical Specification 6.3.1, p. 6-6 f

II. DISCUSSION: It ia' proposed to add a "if" footnote on page 6-6 to the '

Regulatory 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/RCl SuperintIndent. The subject footnote is proposed to read as follows: )

ifExcept that the individual identified in MP&L's letter to,the NRC, dated (letter date refers to this PCOL and will be inserted by NL&S on the submittal date) is considered qualified to hold the position of Chemistry / Radiation Control Superintendent, haced on experience, education, and other

, information provided in that letter.

The proposed' change to page 6-6 is presented in Attachment 2. This change is considered to be a one-time exceptLon pertaining only to the current C'RC

~

Superintendent.

III. BACKGROUND: As a result of the departt:re of the person holding the C/RC Superintendent position in May 1985, a replacement was sought to fill this operating staff vacancy. Mr. J. V.

Parrish, who joined MP&L in January 1985, was selected for the position following a review of his education and experience against the requirements of Technical Specification 6.3.1 and Regulatory Guide 1.8 (September 1975). MP&L considered Mr. Parrish to be well qualified for the superintendent position based on extensive nuclear experience in the U. S. Navy, including chemistry and radiation control, as well as. demonstrated competence in several demanding management roles. Based

.on this review of Mr. Parrish's background and experience, MP&L determined that he met the requirements of the Guide with regard to five years professional experience in radiation protection work.

During:a site inspection in July NRC Region II concerns were raised regarding strict compliance with the Guide's

-literal requirements in Section C. The inspection's findings on the matter are documented in Inspection ReportNo.p0,-416/85-24, dated August 30, 1985 J16ATTC85090901 - 1 l

• e Attcch2:nt 1 to AECM-85/0263 Page 2 of 6 )

(MAEC-85/0307). The matter was discussed in a meeting with NRC Region II management at the plant site on July 30, 1985. A more detailed appraisal and categorization of Mr. Parrish's experience had been completed by MP&L and was the subject of that meeting and several subsequent conference calls.

4 In the later, more detailed appraisal of Mr. Parrish's experience, MP&L confirmed its earlier conclusion that the experience requirements of this Guide were met.

However, MP&L recognizes that experience credit allotted in any given segment of time is subject to interpretation. Based on numerous discussions with the NRC, MP&L understands that the NRC Region II Staff has concluded that while Mr. Parrish does have appropriate management expertise, his experience in the field of applied radiation protection does not meet the Guide's literal requirements. As a result of discussions on this subject in an August 29, 1985 conference call with NRC NRR and Region II Staff, MP&L committed to provide documented justification supporting its conclusions that Mr. Parrish is qualified to fill the position of C/RC Superintendent and an associated proposed change to Technical Specification 6.3.1.

IV. JUSTIFICATION:

A. QUALIFICATIONS OF INCUMBENT C/RC SUPERINTENDENT MP&L considers Mr. Parrish to meet the qualification requirements of Section C of the Guide and is, therefore, qualified to hold the position of C/RC Superintendent. MP&L's conclusions are based on a review and evaluation of Mr.

Parrish's education and experience. The key elements of that review are discussed below.

Since 1966, Mr. Parrish has undergone continued health physics training and assumed positions of increasing responsibility in applied radiation protection. He has completed NAVSHIPS Article 108 training and qualification twice (once as a Navy enlisted man, again as an officer); has successfully completed both lectures and practical factors training; has audited the conduct of radiation protection activities at a variety of nuclear facilities; has been responsible for verifying the training and qualifications of other radiation protection personnel; and has effectively served as a radiation worker and radiation protection supervisor over the past 10 years.

Attachment 3 is a detailed listing of Mr. Parrish's applied i radiation protection experience. The listing indicates the t

amount of experience assigned by MP&L in the field of applied radiation protection and summarized below:

J16ATTC85090901 - 2 l

I Attachment 1 to AECM-85/0263 Page 3 of 6 Mr. Parrish holds a Master of Science degree as well as the B. S. degree in Chemical Engineering, surpassing the B. S. degree minimum requirement.

With over 60 collective months of applied radiation protection experience, Mr. Parrish exceeds the 5 year experience requirement, as tabulated below:

12 months (3/66-5/67 and 7/73-8/74) of Article 108 radiation control training which included practical '

abilities training and certification. Engineering Laboratory Technicians (ELTs) are normally granted full experience credit for this identical training.

- 3 months of health physics experience (5/67-5/68) where he provided the same radiation protection coverage for his own activities, as a self-monitor, as would have been provided by a Radiation Control Technician. Later duties also included radiation control coverage of maintenance activities performed by others.

20 months as a billeted Radiation Control Officer (8/74-5/77), with sole responsibility for all phases of applied radiation protection work.

10 months of supervising an entire crew, including radiation control, and delive-ing radiation control training (5/77-3/79). The same radiation protection policies and practices established prior to core load were continued afterwards.

19 months of supervisory radiation control responsibility (3/79-5/82) which included Reactor Compartment tours when accessible; radiation control Stop Work Order authority; appraisals of radiation protection systems, policies and procedures; evaluation of workers' radiation protection competence (including authority to disqualify

, workers if necessary); -- i.e., direct responsibility for all supervisory aspects of radiation control.

- 2 months as a Nuclear Weapons Security Officer (4/83-1/85) during which he exercised the same applied radiation protection skills as a professional health physicist in the commercial nuclear weapons industry. He monitored similar types of radioactivity which could be encountered in a nuclear power station and with the same techniques

! J16ATTC85090901 - 3

Attcchment 1 to AECM-85/0263 Page 4 of 6 generally used in the nuclear power industry.

During this period he was responsible for development, planning, and execution of nuclear weapons accident / incident drills and the training of personnel in the use of all radiation detection instrumentation.

He has 20 years of extensive experience in the U. S.

Navy, with virtually all assignments involving applied radiation protection responsibilities in some degree.

He has been the individual responsible for all, or a substantial portion, of the radiation control program at several different nuclear installations.

His formal training in radiation protection is among the finest available in that it was provided by the U. S.

Navy as part of its nuclear propulsion program.

The radiation protection problems he has handled have been similar (and in some cases identical), to those encountered by PWR and BWR commercial nuclear power stations.

As discussed with NRC Region II staff, in addition to experience in the radiation protection field, management expertise is considered to be an essential element in the qualifications for this position. In this area, as presented in the above experience summary and in Attachment 3, Mr.

i Parrish has numerous assignments in managerial roles, and

. based on MP&L's appraisal, has demonstrated competence in executing his responsibilities. In the time with MP&L, he 4

has demonstrated innovative and effective management skills i and already has made positive contributions to the GCNS plant 1 staff organization.

t B. OTHER CONSIDERATIONS: CORPORATE SUPPORT The role and association of the corporate radiation protection organization should be considered in evaluating the overall experience and management resources in the applied radiation protection area.

Assisting Mr. Parrish in the discharge of his duties as C/RC Superintendent is the Manager, Radiological & Environmental Services (R&ES) (a certified Health Physicist). The two

asnagers work together to identify and resolve operational

- health physics problems at GGNS. This is accomplished through joint technical meetings, radiation protection information exchange and onsite technical assistance visits.

J16ATTC85090901 - 4

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Attcchment 1 to AECM-85/0263 Page 5 of 6 The R&ES staff averages at least 2 of these visits to GGNS each week. If required to resolve a specific technical )

problem, continuous onsite R&ES staff support is available.

Mr. Parrish's operational experience, coupled with over 25 collective years of radiation protection experience in this corporate support group, enables him to effectively resolve radiation protection problems encountered at GGNS.

C.

SUMMARY

MP&L's review and evaluation of Mr. Parrish's experience indicates substantial experience in the field of applied radiation protection. He has held numerous highly responsible management positions and by MP&L's appraisal has executed those responsibilities in a competent, effective manner. His graduate degree in engineering exceeds the minimum education requirements. As the C/RC Superintendent he is complemented and assisted by the corporate radiation protection management group, contributing significant experience in the radiation protection field.

MP&L recognizes that the NRC Region II staff, in its review, allowed less radiation protection experience credit than MP&L, such that the literal Section C requirements were not met.

However, regardless of the exact amount of credit granted in this area Mr. Parrish clearly has substantial experience in the radiation protection field such that MP&L believes the intent of the Guide to be met. This experience combined with demonstrated managemert competence and effective corporate support, renders Mr. Parrish fully qualified for this position and, therefore, the proposed one-time exception to Technical Specification 6.3.1 is justified.

V. SIGNIFICANT HAZARDS CONSIDERATIONS:

Concerns were raised by the NRC Region II regarding the qualifications of the current Chemistry / Radiological Control (C/RC) Superintendent and the degree to which that individual met the requirements for this position as described in Regulatory Guide 1.8 (September 1975), as referenced in Technical Specification 6.3.1. MP&L, based on reviews of the individual's experience and education before and after selection as C/RC Superintendent, has concluded that the individual is qualified to hold the position and further, that the intent of Guide's requirements are met. The individual has demonstrated, both at MP&L and in prior .

assignments, the capability to effectively manage technical and operational disciplines, including radiation protection.

J16ATTC85090901 - 5 l

^* Attcchment 1 to AECM-85/0263 Page 6 of 6 The proposed exception does not involve an increase in the probability or consequences of an accident previously evaluated. The individual holding the C/RC Superintendent position holds an M.S. Degree in engineering and has significant practical and management experience in the areas of chemistry and radiation protection. For the same reasons, the proposed exception is not considered to create the possibility of a new or different kind of accident from any of those previously evaluated or to involve a reduction in a margin of safety.

Because the intent of the requirements are met and because the current C/RC Superintendent is believed to have already demonstrated proficient, competent management in the areas of chemistry and radiation protection, the requested one-time exception to Technical Specification 6.3.1 is not considered to represent a significant hazard.

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