WO 11-0015, License Amendment Request to Incorporate Proposed Changes Into WCGS Technical Specification

License Amendment Request to Incorporate Proposed Changes Into WCGS Technical Specification

ML11123A226
Person / Time
Site:	Wolf Creek
Issue date:	04/22/2011
From:	Hedges S Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 11-0015
Download: ML11123A226 (17)

Text

WLF CREEK NUCLEAR OPERATING CORPORATION Stephen E. Hedges Site Vice President April 22, 2011 WO 11-0015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Revision to Technical Specification (TS) 5.3, "Unit Staff Qualifications" Gentlemen:

Pursuant to 10 CFR 50.90, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License NPF-42 for the Wolf Creek Generating Station (WCGS) to incorporate proposed changes into the WCGS Technical Specifications.

The proposed changes will revise Technical Specification (TS) 5.3, "Unit Staff Qualifications,"

by making two administrative changes to TS 5.3.1.1.

The two administrative changes to TS 5.3.1.1 are as follows:

1.

Removal of the operator license applicants' education and experience requirements.

2.

Correction of inadvertent omissions in previous amendments relative to the Licensed Operators and Senior Operators qualification requirements.

Attachment I provides a description and technical evaluation of the proposed changes, including WCNOC's determination that the proposed changes involve no significant hazards consideration.

Attachment II provides existing TS pages marked-up to show the proposed changes. Attachment III provides the revised TS pages typed with the proposed changes incorporated. There are no TS Bases changes associated with these proposed changes.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNVET

WO 11-0015 Page 2 of 3 The WCNOC Plant Safety Review Committee reviewed the amendment application.

It has been determined that this application does not involve a significant hazard consideration pursuant to 10 CFR 50.92.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated Kansas State official.

WCNOC requests approval of this proposed amendment by April 1, 2012. Once approved, the amendment will be implemented within 90 days of approval.

There are no regulatory commitments associated with this application.

If you have any questions concerning this matter, please contact me at (620) 364-4190, or Mr. Gautam Sen at (620) 364-4175.

Sincerely, Step n E.

s SEH/rlt Attachments:

I Evaluation II -

Markup of Technical Specification Pages III -

Retyped Technical Specification Pages cc:

E. E. Collins (NRC), w/a T. A. Conley (KDHE), w/a J. R. Hall (NRC), w/a G. B. Miller (NRC), w/a Senior Resident Inspector (NRC), w/a

WO 11-0015 Page 3 of 3 STATE OF KANSAS

)) s COUNTY OF COFFEY )

Stephen E. Hedges, of lawful age, being first duly sworn upon oath says that he is Site Vice President of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By_.

7 Stephe

. H dges Site Vice P sident SUBSCRIBED and sworn to before me this 010L day of appi /

,2011.

RHONDA L. TIEMEVR SEFICAL~

MY COMMISSION EXPIRES Notary Public 4? 3ml Expiration Date d'ozi/

(I#

Attachment I to WO 11-0015 Page 1 of 10 EVALUATION 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusion

6.0 REFERENCES

Attachment I to WO 11-0015 Page 2 of 10 1.0

SUMMARY

DESCRIPTION The proposed changes in this amendment application will revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS) 5.3, "Unit Staff Qualifications;" by making the following two administrative changes to TS 5.3.1.1:

1.

Removal of the operator license applicants' education and experience requirements.

2.

Correction of inadvertent omissions in previous amendments relative to the Licensed Operators and Senior Operators qualification requirements.

2.0 DETAILED DESCRIPTION TS 5.3.1.1 states:

The education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in letter dated October 7, 2004 (WO 04-0031).

The positions of Shift Manager and Control Room Supervisor shall meet or exceed the qualifications of ANSI/ANS 3.1-1981.

The first proposed administrative change to TS 5.3.1.1 removes the first sentence. The first sentence establishes license applicants' education and experience requirements. The license applicants' education and experience requirements are controlled through the Updated Safety Analysis Report (USAR),

accredited licensed operator training program and training procedures. The additional TS requirement is not required to meet regulatory requirements.

The second proposed administrative change to TS 5.3.1.1 modifies the second sentence to correct omissions from previous amendments by stating the following:

Licensed Operators and Senior Operators shall meet or exceed the qualifications of ANSI/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2, and 10 CFR 55.

This modification now includes licensed operators that were not included in the positions of Shift Managers (licensed senior operator) and Control Room Supervisors (licensed senior operator); applies endorsement of Regulatory Guide 1.8, Revision 2, "Qualification and Training of Personnel for Nuclear Power Plants," to the American National Standards Institute (ANSI)/American Nuclear Society (ANS) standard; and, applies requirements of 10 CFR 55, "Operators' Licenses," to the qualification specification.

These proposed changes to TS 5.3.1.1 will align the wording to language approved by the NRC for Wolf Creek Nuclear Operating Corporation (WCNOC) in Amendment No. 123.

License Amendment No. 123, approved in March 1999, converted the Technical Specifications for WCGS to the Improved Technical Specifications (ITS) (Reference 1).

Attachment I to WO 11-0015 Page 3 of 10

3.0 TECHNICAL EVALUATION

The information below provides a history which describes each license amendment impacting the current TS 5.3.1, beginning with the first amendment subsequent to the 1987 issuance of 10 CFR 55, "Operators' Licenses," and associated implementation guidance of Regulatory Guide 1.8, Revision 2, "Qualification and Training of Personnel for Nuclear Power Plants."

License Amendment No. 54 In December, 1991, Amendment No. 54 (Reference 2) changed administrative controls in TS Section 6.3, "Unit Staff Qualifications," and Section 6.4, 'Training" to be consistent with 10 CFR 55, as amended in 1987, and the associated implementation guidance of Regulatory Guide 1.8, Revision 2. Amendment No. 54 implemented the following administrative controls relative to this proposed License Amendment:

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

a.

Licensed Operators and Senior Operators shall meet or exceed the qualifications of ANSI/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Manager Training and shall meet or exceed the requirements and recommendations of Section 5 of ANSI/ANS 3.1-1978 with the following exceptions:

a.

The training program for Licensed Operators and Senior Operators shall meet or exceed the requirements and recommendations of Section 5 of ANSI/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2, and 10 CFR 55.

The titles and wording of the two TS sections were made consistent with the section headings contained in the referenced American National Standards Institute (ANSI)/American Nuclear Society (ANS) standards. Section 4 in both ANSI/ANS 3.1-1978 and ANSI/ANS 3.1-1981 is titled "Qualifications" and Section 5 in both standards is titled 'Training."

License Amendment No. 123 In March 1999, Amendment No. 123 converted the Technical Specifications for WCGS to the Improved Technical Specifications (ITS) (Reference 1).

The guidance for TS 5.3.1 from NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 1, April 1995 is as follows:

Attachment I to WO 11-0015 Page 4 of 10 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of

[Regulatory Guide 1.8, Revision 2, 1987, or more recent revisions, or ANSI Standard acceptable to the NRC staff]. [The staff not covered by Regulatory Guide 1.8 shall meet or exceed the minimum qualifications of Regulations, Regulatory Guides, or ANSI Standards acceptable to NRC staff].

As approved in Amendment No. 123, WCNOC's implementation of NUREG-1431, Revision 1 guidance relative to this proposed License Amendment resulted in the following:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

5.3.1.1 Licensed Operators and Senior -Operators shall meet or exceed the qualifications of ANSI/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2, and 10 CFR Part 55.

The minimum qualification requirement delineated in TS 5.3.1.1 is consistent with the guidance in Section 4, "Qualifications," of the associated ANSI/ANS standards. Training requirements consistent with Section 5, 'Training," of the associated ANSI/ANS standard were moved to the USAR (Reference 1).

License Amendment No. 150 On January 18, 2001, NRC Regulatory Issue Summary (RIS) 2001-01, "Eligibility of Operator License Applicants," was issued to familiarize addressees with the NRC's current guidelines for the qualification and training of reactor operator (RO) and senior operator (SO) license applicants. In part, RIS 2001 -01 states:

'The staff encourages all facility licensees to review their requirements and commitments related to RO and SO education and experience and to update their documentation (e.g., FSAR, TS, and training program descriptions) to enhance consistency and minimize confusion."

Note that the RIS also states that there has been no change in NRC requirements or position with regard to license eligibility for reactor operators and senior reactor operators since 1987, when 10 CFR 55 and Regulatory Guide 1.8, Revision 2, was issued.

On September 27, 2001, WCNOC submitted a license amendment application to revise TS 5.3 (Reference 3). It states in part:

This amendment application would revise Technical Specification 5.3, "Unit Staff Qualifications," to revise requirements that have been superseded based on licensed operator training program being accredited by the Institute for Nuclear Power Operations and promulgation of the revised 10 CFR 55, "Operators' Licenses," which became effective on May 26,1987.

Attachment I to WO 11-0015 Page 5 of 10 WCNOC requests that the NRC review and approve the proposed TS change by March 29, 2002 to support the continued processing of licensed operator candidates.

The proposed Technical Specification change provides the needed flexibility for candidates to complete the licensed operator training program who meet the experience eligibility requirements of an accredited training program consistent with 10 CFR 55.31, "How to apply," but may not meet the American National Standards Institute (ANSI) or ANS/American Nuclear Society (ANS) or Regulatory Guide 1.8. Revision 2,

"Qualification and Training of Personnel for Nuclear Power Plants," experience requirements referenced in current Technical Specification 5.3.1.1.

This license amendment application appears to be based on a possible misconception by WCNOC that TS 5.3.1.1 applied to the training requirements of Section 5, 'Training," of ANSI/ANS 3.1-1981, in addition to the qualification requirements of Section 4, "Qualifications,"

of ANSl/ANS 3.1-1981 standard.

In November 2002, Amendment No. 150 (Reference 4) was issued in response to the September 2001 license amendment request (Reference 3) as well as supplemental information. The amendment changed administrative controls in TS Section 5.3.1 relative to this license-amendment application to the following:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

5.3.1.1 The education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in letter dated September 19, 2002 (WO 02-0051).

The impact of this change was to delete the requirement for licensed operators and senior operators to meet the qualifications of ANSl/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2, and 10 CFR 55.

Had WCNOC been aware of the specific application of TS 5.3.1.1 approved in Amendment No. 123, there would have been no need to apply for an amendment. The reference to 10 CFR 55 in the then current TS 5.3.1.1, as well as the 10 CFR 55 implementation guidance, which had already been moved to the USAR, allowed deviations from education and experience eligibility requirements for licensed operator applicants in ANSI/ANS 3.1-1981.

Based on the content of the license amendment application, the wording of TS 5.3.1.1 implemented through ITS conversion, Amendment No. 123, was adequate.

License Amendment No. 159 On October 7, 2004, WCNOC submitted a license amendment application to revise TS 5.3 (Reference 5).

This revision was partially prompted by the issuance of revised National Academy for Nuclear Training (NANT) guidance referenced in the current TS 5.3.1.1 and the discovery that the qualification requirements for the Shift Manager and Control Room

Attachment I to WO 11-0015 Page 6 of 10 Supervisor were inadvertently eliminated in Amendment No. 150. The amendment request states in part:

This amendment application would revise Technical Specification (TS) 5.3, "Unit Staff Qualifications." to reinstate the qualification requirements for the Shift Manager and Control Room Supervisor positions that were inadvertently eliminated through the issuance of Amendment No. 150. Additionally, this section is revised to reference this application for the use of the National Academy for Nuclear Training guideline, ACAD 00-003, Revision 1, "Guidelines for Initial Training and Qualification of Licensed Operators."

In January 2005, Amendment No. 159 (Reference 6) was issued in response to the October 2004 license amendment request (Reference 5).

The amendment changed administrative controls in TS Section 5.3.1 relative to this license amendment application to the following:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

5.3.1.1 The education and experience eligibility requirements for operator license applicants, and changes thereto, shall be those previously reviewed and approved by the NRC, specifically those referenced in letter dated October 7, 2004 (WO 04-0031).

The positions of Shift Manager and Control Room Supervisor shall meet or exceed the qualifications of ANSI/ANS 3.1-1981.

Even though it had been discovered that qualification requirements for the Shift Manager and Control Room Supervisor were inadvertently eliminated in Amendment No. 150, the implementation of Amendment No. 159 included two specific omissions, compared to the wording of TS 5.3.1.1 prior to Amendment No. 150:

The positions covered by ANSI/ANS 3.1-1981 were changed from "Licensed Operators and Senior Operators" to "positions of Shift Manager and Control Room Supervisor." As a result, qualification requirements for Licensed Operators are not addressed.

The reference to the qualifications of ANSI/ANS 3.1-1981 did not include "as endorsed by Regulatory Guide 1.8, Revision 2." The omission of this phrase is inconsistent with the implementation guidance for 10 CFR 55, as described above.

In conclusion, had WCNOC been aware of the specific application of TS 5.3.1.1 approved in Amendment No. 123, there would have been no need to apply for Amendment No. 150 or Amendment No. 159. Therefore, the wording of TS 5.3.1.1 originally implemented through ITS conversion, Amendment No. 123, was adequate. With the changes proposed by this letter in place, TS 5.3.1.1 is restored to the wording approved by the NRC in Amendment No. 123 (Reference 1).

Attachment I to WO 11-0015 Page 7 of 10

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations 50.36, '"echnical specifications":

(c) Technical specifications will include items in the following categories:

5) Administrative controls. Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in 10 CFR 50.4.

This license amendment request proposes to revise TS 5.3.1.1 to delete non-applicable requirements, apply endorsement by Regulatory Guide 1.8, Revision 2, "Qualification and Training of Personnel for Nuclear Power Plants," to the cited standard, and to include licensed control room operators in the unit staff qualification group. These changes are administrative changes.

With-these changes, the Technical Specifications will continue to provide administrative controls relating to organization and management of the WCGS to assure operation of the facility in a safe manner.

With the changes proposed in this license amendment request, the requirements of Title 10 CFR 50.36 continue to be met and are consistent with NUREG-1431.

10 CFR 55.31(a)(4) specifies in part that the Commission may accept certification that the applicant has successfully completed a Commission-approved training program provided the program is based on a systems approach to training, as defined in 10 CFR 55, and uses a simulation facility acceptable to the Commission under 10 CFR 55.45(b). NRC Generic Letter 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing - 10 CFR 55 and Confirming Amendments," and NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code Of Federal Regulations, Part 55 on Operators' Licenses," indicated that the NRC would accept a licensee's licensed operator training program if it is accredited and based on a systems approach to training.

The WCNOC licensed operator-training program is accredited by the National Academy for Nuclear Training (NANT) and is based on a systems approach to training. The license operator qualifications and training program will continue to comply with the requirements of 10 CFR 55.

4.2 Significant Hazards Consideration This amendment application would revise Technical Specification (TS) 5.3, "Unit Staff Qualifications," to reinstate the qualification requirements for Licensed Operators and Senior Licensed Operators that were inadvertently eliminated through the issuance of Amendment No. 150 and Amendment No. 159. TS 5.3.1 is also revised to remove the reference to a NANT guideline, as it has no relationship to the qualifications of Licensed Operators and Senior Licensed Operators.

Attachment I to WO 11-0015 Page 8 of 10 WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

(1)

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change is an administrative change to reinstate the qualification requirements for Licensed Operators and Senior Licensed Operators that were inadvertently eliminated through the issuance of Amendment No. 150 and Amendment No. 159, and to remove an unnecessary reference to a NANT guideline.

The proposed change does not directly impact accidents previously evaluated. WCNOC's licensed operator training program is accredited by the NANT and is based on a systems approach to training consistent with the requirements of 10 CFR 55.

Although licensed operator qualifications and training may have an indirect impact on accidents previously evaluated, the NRC considered this impact during the rulemaking process, and by promulgation of the revised 10 CFR 55 rule, concluded that this impact remains acceptable as long as the licensed operator training program is certified to be accredited and is based on a systems approach to training.

Therefore, the proposed change will not increase the probability or consequences of an accident previously evaluated.

(2)

Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?

Response: No The proposed change is an administrative change to reinstate the qualification requirements for Licensed Operators and Senior Licensed Operators that were inadvertently eliminated through the issuance of Amendment No. 150 and Amendment No. 159, and to remove an unnecessary reference to a NANT guideline. WCNOC's licensed operator training program is accredited by the National Academy for Nuclear Training and is based on a systems approach to training consistent with the requirements of 10 CFR 55. Although licensed operator qualifications and training may have an indirect impact on accidents previously evaluated, the NRC considered this impact during the rulemaking process, and by promulgation of the revised 10 CFR 55 rule, concluded that this impact remains acceptable as long as the licensed operator training program is certified to be accredited and is based on a systems approach to training.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

(3)

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change is an administrative change to reinstate the qualification requirements for Licensed Operators and Senior Licensed Operators that were -inadvertently eliminated through

Attachment I to WO 11-0015 Page 9 of 10 the issuance of Amendment No. 150 and Amendment No. 159, and to remove an unnecessary reference to a NANT guideline.

As noted previously, WCNOC's licensed operator training program is accredited and is based on a systems approach to training consistent with the requirements of 10 CFR 55. Licensed operator qualifications and training can have an indirect impact on the margin of safety. However, the NRC considered this impact during the rulemaking process, and by promulgation of the revised 10 CFR 55 rule, determined that this impact remains acceptable when licensees maintain a licensed operator training program that is accredited and based on a systems approach to training.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.3 Conclusion In conclusion, based on considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

WCNOC has evaluated the proposed amendment for environmental considerations.

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1.

Letter from J. N. Donohew, USNRC, to 0. L. Maynard, WCNOC, "Conversion to Improved Technical Specifications for Wolf Creek Generating Station - Amendment No.

123 to Facility Operating License No. NPF-42 (TAC NO. M98738)," March 31, 1999.

2.

Letter from W. D. Reckley, USNRC, to B. D. Withers, WCNOC, 'Wolf Creek Generating Station - Amendment No. 54 to Facility Operating License No. NPF-42 (TAC NO.

M79886)," December 24, 1991.

3.

WCNOC Letter WO 01-0038, "Docket No. 50-482: Revision to Technical Specification 5.3, "Unit Staff Qualifications"," September 27, 2001.

4.

Letter J. N. Donohew, USNRC, to 0. L. Maynard, WCNOC, 'Wolf Creek Generating Station - Issuance of Amendment Re: Unit Staff Qualifications (TAC NO. MB3017),"

November 26, 2002.

5.

WCNOC Letter WO 04-0031, "Docket No. 50-482: Revision to Technical Specification (TS) 5.3, "Unit Staff Qualifications," and Correction to Various TSs," October 7, 2004.

Attachment I to WO 11-0015 Page 10 of 10

6.

Letter from J. N. Donohew, USNRC, R. A. Muench, WCNOC, 'Wolf Creek Generating Station - Issuance of Amendment Re: Revisions to Technical Specification 5.3 (TAC NO. MC4795)," January 31, 2005.

Attachment II to WO 11-0015 Page 1 of 2 Markup of Technical Specification Pages

Attachment ISI toWO 11Q-0015 Page 2 of 2 Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

5.3.1.1 5.3.1.2 5.3.1.3 The edu ion and ex rience eligi lity requirem ts for operator licen applicants, d changes ereto, shall those prev sly r iewed and a roved by th RC, speci ally those r renced in letter date ctober 7, 4 (WO 04-3 1). The pitions of Shift Man er and C on I Room S rvisor shall eet or e ed the u caion of I/AN 3.-1981.

The Radiation Protection Manager shall be a supervisor with line responsibility for operational health physics who meets or exceeds the qualifications of Regulatory Guide 1.8, September 1975 for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the plant manager.

The position of operations manager shall hold or have previously held a senior reactor operator license for a similar unit (PWR).

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and

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Attachment III to WO 11-0015 Page 1 of 2 Retyped Technical Specification Pages

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 with the following exceptions:

5.3.1.1 Licensed Operators and Senior Operators shall meet or exceed the qualifications of ANSI/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2, and 10 CFR 55.

5.3.1.2 The Radiation Protection Manager shall be a supervisor with line responsibility for operational health physics who meets or exceeds the qualifications of Regulatory Guide 1.8, September 1975 for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the plant manager.

5.3.1.3 The position of operations manager shall hold or have previously held a senior reactor operator license for a similar unit (PWR).

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

Wolf Creek - Unit 1 5.0-4 Amendment No. 123, 149, 150, 159,