Significant Finding, Big Rock Point Health Physics Appraisal
See the memorandum from J. H. Sniezek to J. G. Keppler dated September 11, 1980. Technical Specifications (TS) require that an individual qualified in radiation protection procedures be onsite when fuel is in the reactor. HPPOS-021 contains a related topic.
Guidance was requested on how to proceed with a contested item of noncompliance issued to a licensee. The item of noncompliance was the failure to provide an individual qualified in radiation protection procedures on back shift in accordance with TS requirements. The licensee contended that the "criteria for individuals qualified in radiation protection procedures" contained in DOR's letter of 1977, were not made a part of the license either by license amendment or licensee commitment; therefore, the citation was not valid.
The NRC provides information for the purpose of clarifying the specific meaning and intent of regulatory requirements by numerous means; some examples are Statements of Consideration, Regulatory Guides, NUREG Reports, Bulletins, Circulars, Branch Technical Positions, and Generic Letters.
These documents do not establish regulatory requirements, but simply clarify the meaning and intent of existing requirements or denote acceptable methods of implementing the regulatory requirements. The licensee acknowledged receipt of this clarifying information and did not propose or receive approval for implementing an alternative means of complying with the subject TS. Based on these facts, the citation in question was valid and proper.
Regulatory references: Technical Specifications
Subject codes: 1.1, 1.4, 1.5