JSP-095-92, Application for Amend to License NPF-62,revising TS 6.3, Unit Staff Qualifications, to Delete Inappropriate Exception to ANSI Std in TS 6.3.1 Re Qualification Requirements for Director - Plant Radiation Protection

Application for Amend to License NPF-62,revising TS 6.3, Unit Staff Qualifications, to Delete Inappropriate Exception to ANSI Std in TS 6.3.1 Re Qualification Requirements for Director - Plant Radiation Protection

ML20092M567
Person / Time
Site:	Clinton
Issue date:	02/21/1992
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092M569	List: JSP-095-92, Application for Amend to License NPF-62,revising TS 6.3, Unit Staff Qualifications, to Delete Inappropriate Exception to ANSI Std in TS 6.3.1 Re Qualification Requirements for Director - Plant Radiation Protection ML20092M577
References
JSP-095-92, JSP-95-92, U-601938, NUDOCS 9202270384
Download: ML20092M567 (7)

Text

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-._ libno!s Power Cornpany _

y 8? Chnton Power Stahon

, P O Box 678 Chnton, IL 61727 i

, Tel 217 935-6226 J 51ephen Perry ,

Vice Present ILLIN91S---

PG M R- JSP-095-92 L47 2-21)-LP February 21, 1992 BE.100a 1

-Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D,0.- 20555

Subject:

Clinton Pwer Station -i Proposed Amendment of Facility ope ratinct License No. NPF-62

Dear Sir:

' Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A -

Technical Specifications, for Clinton Power Station (CPS).

• is request consists-of a proposed change to Technical Specification 6.3, " Unit Staff Qualifications," in order to delete an Linappropriate exception to the applicable ANSI standard as specified in Technical Specification 6.3.1 regarding qualification requirements for the Director - Plant Radiation Protection. A description of the proposed Technical-Specification: change, the associated justification (including a Stasis For No Significant Hazards Consideration), and a marked-up copy of the page from the current Technical Specifications are

~'provided in.~ Attachment 2. In addition, an affidavit supporting the-facts set forth in this letter and its attachments is provided in-Attachment 1.

IP-was reviewed the proposed change against the criteria of 10cFR51.22 for- categoriccal excit4sion from environmental' impact

considerations. The proposed change does not involve a significant hazards consideration, or significantly increase the

. amounts or-change the types of effluents that may be released

~offsite,.nor-does it significantly increase individual or cumulative occupational-radiation exposures. Based on the foregoing, IP concludes that the proposed change. meets the criteria given 'in' 10CFR51.22 (c) (9) for a categorical exclusion from-the requirements for an Environmental Impact Statement.

Sincerely yours, S. Perry Vice-Presid 't TBE/alh Attachments I

, g f o m n n -t-

, . If ( v * -9202270384-920221 l l PDR ADOCK 05000461 l- , , . . . -

P PDR-

U-601938 L4 7-9 2 (02-21) -LP

. 8E.100a cc: 11RC Clinton Licensing Project Manager 11RC Resident Of fice Regional Administrator, Region III, USliRC Illinois Department of 11uclear Safety

- - m .__ _ _ .. _ _ _ _ _ _ _ _ _ . _ _ _ . _

. Attachment 1

'to U-601938 j STATE OF ILLINOIS COUNTY OF DEWITT J. Stephen Perry, being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company;-that the application for amendment of Facility Operating Licenso NPP-62 has been prepared under his supervision and direction; that he knows the contents thereof;.and that to the best-of his knowledge and belief said application and the facts contained therein are true and correct.

DATE: This 11 day of February 1992

' Signed: b "r -

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,! , % :$? y' Subscribed' and sworn to befo[c{gh [pcy / day of February 1992. f gA g,3/.y e4e n .;

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Notary Public t

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Attachment 2

. to U-601938-

- LS-92-005

. Page-1 of 5 Background /Deracription of Proposed Chance

-Qualification requirements for plant staff members are prescribed under Technical Specification 6.3, " Unit Staff Qualifications." Technical Specification 6.3.1 currently states, "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 except for the Director - Plant Radiation Protection who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975."

The intent of this exception for the Director - Plant Radiation Protection is to impose stricter qualification requirements for this position relative to an earlier version of this ANSI standard. IP has determined that this exception is appropriate and necessary relative only to the 1971 version of this ANS1 standard and not to the 1978 version. As this Technical Specification requires compliance with the 1978 version, the exception is redundant and inappropriate.

Therefore, IP proposes to delete this phrase from Technical Specification 6.3.1 as indicated on the enclosed marked-up-page from the CPS Technical Specifications and as further explained below.

Basis / Justification for Proposed Chance Due to a_recent review of the baais for the exception specified in Technical Specification 6.3.1, it was noted that the September 1975 version of Regulatory Guide 1.8, " Personnel Selection and Training," was written to address endorsement of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." (ANSI N18.1-1971 was the latest version of the applicable ANSI standard at that time.) Although this ANSI standard did prescribe qualification requirements for superv{sory-level radiation protection personnel (Ref. Section 4.4.4)., the NRC determined, as documented in the Regulatory -

Guide, that the recommended qualification requirements were insufficient.

( The NRC indicated in the Regulatory Position section of Regulatory Guide 1.8 (1975), "The criteria for the selection and training of nuclear power plant personnel contained in ANSI N18.1-1971...are generally acceptable and provide an adequate basis for the selection and training of nuclear power plant personnel except for the position Supervisor - Radiation Protection (hereafter referred to as the Radiation Protection ANSI N18.1-1971 recommended that the responsible person (in the area of radiation protection) "have a minimum of five years experience in radiation protection-at a nuclear reactor facility. A minimum of two years of this five years experience should be related technical training. A maximum of four years of this five years experience may be fulfilled by related or academic training."

Attachment 2

. to U-601938-LS-92-005 Page 2 of 5 Manager _(RPM])." Specifically, the following enhanced qualification requirements'were prescribed for the RPM: l The Radiation Protection Manager (RPM) should be an experienced professional in applied radiation protection at nuclear facilities dealing with radiation protection problems and programs sinilar to those at nuclear power stations. The RPM should be familiar with the design features and operations of nuclear power stations that affect the potential for exposures of persons to radiation. The RPM should have the technical competence to establish radiation protection programs and the supervisory capability to direct the work of l professionals, technicians, and journeymen required to-i implement the radiation protection programs.

The RPM should have a bacheler's degree or the equivalent in a science or engineering subject,-including some formal training in radiation protection. The RPM should have a least five years of professional experience in applied radiation protection. (A master's degree may be considered equivalent to two years of professional experience where course work related to radiation protection is involved.) At least three years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in 1 clear power stations, preferably in an actual nuclear power atation.

After issuance of the September 1975 version of Regulatory Guide 1.8, ANSI N18.1-1971 was revised and renumbered to ANSI /ANS 3.1-1978. As a part of this revision, section 4.4.4 was revised,_ incorporating the qualification requirements specified for the RPM in Regulatory Guide 1.8 (1975). With respect to the qualification requirements for the RPM, the combination of ANS1 N18.1-1971 and the qualification i enhancements / exception provided in Regulatory Guide 1.8 thus became equivalent to ANSI /ANS 3.1-1978.

At one time, as it appeared irr the draft CPS Technical Specifications, Technical Specification 6.3.1 referred to ANSI .

N18.1-1971 (along with the exception referring to Regulatory Guide-1.8). Later, during further development of the draft Technical Specifications for CPS, this reference was changed to ANSI /ANG 3.1-1978 consistent with the version of the standard referenced in the CPS USAR. This effectively rendered the exception specified for the Director-Plant Radiation Protection redundant due to the incorporation of the Regulatory Guide 1.8 guidance in the 1978 version of the ,

associated ANSI standard. However, the exception was not-deleted from the draft Technical Specifications at that time.

In light of the above, IP has determined that it is appropriate to delete the exception specified in CPS Technical

Attachment a to U-601938 LS-92-005 Page 3 of 5 Specification 6.3.1 to eliminate the redundancy. Further,

-deletion of this wording from Technical Specification 6.3.1 eliminates, an unnecessary reference to a specific job / position title in the CPS plant staff organization. Consistent with the intent of Generic Letter 88-06 (

Subject:

Removal of Organizational Charts from Technical Specification Administrative Control Requirements), this change could prevent unnecessary changes to the Technical Specifications (and thus eliminate unnecessary license amendments) in the future due to title / organizational changes involving the

" Director-Plant Radiation Protection."

It should be emphasized that the proposed change does not involve a change to thn qualification requirements for unit staff personnel including the position that is equivalent to the " responsible person (Professional - Technical, Radiation Protection)" identified in the ANSI standard or the " Radiation Protection Manager" identified in Regulatory Guide 1.8.

The reference to ANSI /ANS 3.1-1978 in Technical 6.3.1 remains unchanged consistent with IP's commitment to this standard as identified in the CPS USAR.

Basis for No Sionificant Hazards Consideration In accordance with 10CFR50.92, a proposed change to the operating license-(Technical Specifications) involves no significant hazards considerations if operation of the facility in accordance with the proposed change would not (1) involve a-significant increase in the probability or l -consequences of any accident previously evaluated, (2) create l the possibility.of a new or different kind of accident from i

any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The pr aposed change is evaluated against each of these criteria as follows:

(1) The proposed change is administrative in nature as it only pertains _to qualification requirements for unit staff personnel (in the area of radiation protection) and does not affect any plant equipment, system l configurations, or operation. Furthermore, though the l proposed _ change pertains to qualification requirements l

i for unit staff personnel, the proposed change does not

. involve a technical change to these qualification requirements since the requirements of Regulatory Guide 1.8, September 1975 are contained in ANSI /ANS 3.1-1978.

As a result, the proposed change cannot increase the probability or the consequences of any accident previously evaluated.

(2) As noted above,-the proposed charge only concerns the qualification requirements for a particular plant staff member (s) and does not involve any changes to plant equipment, system configurations or analyses. As a result, this~ proposed change does not introduce any new failure modes and cannot create the possibility of a new

Attachment 2 to-U-601938 LS-92-005 Page 4 of 5  !

l- or different kind of accident from any accident t previously evaluated.

(3) The proposed change specifically and only addresses a textual change to the administrative control requirement concerning-the qualification requirements of the radiation protection supervisor / manager position within the plant staff organization. The proposed change only eliminates a redundant requirement and would not alter the qualification requirements for this position ulace the requirements of Regulatory Guide 1.8, September 1975 are contained in ANSI /ANS 3.1-1978 (which is referenced in the Technical Specifications). Therefore, the penpn9nd chango will net recult in a cignificant reduction in any margin of safety.

Based upon the foregoing, Illinois Power has concluded that this proposed change does not involve a significant hazards consideration.

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