U.S. Nuclear Regulatory Commission
Significant Finding, Big Rock Point Health Physics Appraisal
Title: Significant Finding, Big Rock Point Health Physics
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