3F1102-07, Request for Exemption from Certain Requirements of 10 CFR 55.59
| ML023250208 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/18/2002 |
| From: | Franke J Florida Power Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F1102-07 | |
| Download: ML023250208 (5) | |
Text
FloridaEnergy Power Company AProgress Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 55.11 10 CFR 55.59 November 18, 2002 3F 1102-07 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Request for Exemption from Certain Requirements of 10 CFR 55.59
Dear Sir:
Pursuant to 10 CFR 55.11, Florida Power Corporation (FPC) hereby requests an exemption to 10 CFR 55.59(c)(1) in that the current licensed operator requalification program period be extended, on a one-time basis, from 24 to 26 months, ending February 28, 2003.
The current annual simulator operating test and comprehensive biennial written examination encompass the 24-month requalification cycle from January 1, 2001 through December 31, 2002.
This request would allow the current 12-month simulator operating test period to be extended to 14 months and would extend the 24-month requalification period to 26 months (both ending February 28, 2003). The annual simulator operating tests and biennial written examinations would then be completed by February 28, 2003. The next requalification program period would begin on March 1, 2003, and continue for 24 months to February 28, 2005, with successive periods similarly adjusted.
As discussed in teleconferences between members of FPC and the NRC, FPC is currently in negotiations with its bargaining unit, which represents among other personnel, the licensed control room operators at Crystal River Unit 3 (CR-3). This exemption request is a contingency for a possible labor action associated with the negotiations. Should such a labor action occur, CR-3 will be operated by qualified personnel with current NRC licenses not affected by the labor action. These personnel are in operations management, operations support staff, training staff, and others who have assignments in various plant organizations. FPC deems it prudent to allow the licensed personnel operating the plant to remain fully available to stand watch on operating crews and not be distracted by completing the licensed operator requalification program by December 31, 2002. Completing the program during this time would require removing members of the operations staff and some training personnel from active watch to administer the simulator operating test and the written examination, as well as those personnel that would be taking the test and examination.
195 15760 West Power Line Street
- Crystal River, Florida 34428-6708 * (352) 795-6486
U.S. Nuclear Regulatory Commission Page 2 of 2 3F17102-07 In order to address this situation, FPC is requesting this one-time exemption. FPC would like approval of this exemption request by November 27, 2002, in order to make orderly plans to adopt the one-time 14-month simulator operating test and 26-month written examination schedules.
As explained in the Attachment to this letter, this exemption is authorized by law, will not endanger life or property, and is otherwise in the public interest.
This letter establishes no new regulatory commitments.
If you have any questions regarding this submittal, please contact Mr. Sid Powell, Supervisor, Licensing and Regulatory Programs at (352) 563-4883.
Plant General Manager JAF/rmb
Attachment:
Description and Analysis of Request for Exemption from Certain Requirements of 10 CFR 55.59 xc: NRR Project Manager Regional Administrator, Region II Senior Resident Inspector
U.S. Nuclear Regulatory Commission Attachment 3F1l102-07 Page 1 of 3 Description and Analysis of Request for Exemption from Certain Requirements of 10 CFR 55.59 A. Requested Exemption and Circumstances Leading to the Request In accordance with 10 CFR 55.11, "Specific exemptions," Florida Power Corporation (FPC) is requesting NRC approval of a one-time exemption from the requirements of 10 CFR 55.59, "Requalification," paragraph (c)(1) for the requalification program schedule. The requested exemption would allow for a one-time extension of:
"* the annual simulator operating test required in 55.59 (a)(2) from the 12-month interval to an interval of 14 months; and
"* the comprehensive requalification written examinations required in 55.59 (a)(2) from the 24-month interval to an interval of 26 months.
As discussed in teleconferences between members of FPC and the NRC, FPC is currently in negotiations with its bargaining unit, which represents among other personnel, the licensed control room operators at Crystal River Unit 3 (CR-3). This exemption request is a contingency for a possible labor action associated with the negotiations. Since bargaining unit personnel would not be available to participate in requalification training if on strike, it may not be possible to complete their training on the current schedule.
Should such a labor action occur, CR-3 will be operated by qualified personnel with current NRC licenses not affected by the labor action. These personnel are in operations management, operations support staff, training staff, and others who have assignments in various plant organizations. FPC deems it prudent to allow the licensed personnel operating the plant to remain fully available to stand watch on operating crews and not be distracted by completing the licensed operator requalification program by December 31, 2002. Completing the program during this time would require removing members of the operations staff and some training personnel from active watch to administer the simulator operating test and the written examination, as well as those personnel that would be taking the test and examination. The unavailability of bargaining unit Reactor Operators would prevent the annual Operational examination from meeting the intent of NUREG-1021 in regard to conducting evaluations of complete crews for those personnel not on strike.
In order to address this situation, FPC is requesting this one-time exemption. FPC would like approval of this exemption request by November 27, 2002, in order to make orderly plans to adopt the one-time 14-month simulator operating test and 26-month written examination schedules.
B. Basis for Exemption Request The criteria for granting specific exemptions from 10 CFR 55 regulations are stated in 10 CFR 55.11. In accordance with 10 CFR 55.11, the NRC is authorized to grant an exemption upon determining that the exemption is authorized by law and will not endanger life or property and is otherwise in the public interest.
U.S. Nuclear Regulatory Commission Attachment 3F1l102-07 Page 2 of 3 As explained below, the requested exemption will not endanger life or property and is otherwise in the public interest.
All CR-3 licensed personnel are actively enrolled in FPC's National Academy for Nuclear Training accredited training programs. The CR-3 Requalification Operations Training programs all received accreditation renewals in August 2002. The Reactor Operator (RO), Senior Reactor Operator (SRO), and Shift Technical Advisor programs include both periodic written and operational exams throughout the 24-month training cycles. Based on the current schedule, approximately one-third of the CR-3 licensed ROs and SROs will have completed both their annual simulator operating tests and their biennial written examinations prior to December 2, 2002.
This exemption will not endanger life and property since the plant will be operated by experienced and qualified personnel. This exemption is in the public interest since the delay will keep the maximum number of qualified personnel available to stand watch on operating crews in the case of a labor action.
C. Environmental Assessment In accordance with 10 CFR 51.30, "Environmental assessment," and 10 CFR 51.32, "Finding of no significant impact," the following information is provided in support of an environmental assessment and finding of no significant impact for the proposed action.
The proposed action would grant an exemption from the requirements of 10 CFR 55.59(c)(1).
The requested exemption would allow for a one-time extension of the annual simulator operating test required in 55.59(a)(2) from the 12-month interval to an interval of 14 months and the comprehensive requalification written examinations from the 24-month interval to an interval of 26 months.
The requested exemption is needed to allow for minimal interruption of the licensed personnel running the plant in case of a labor action. It would also allow for not having to address this aspect of operator requalification at the end of each subsequent negotiation period.
The principal alternative to the proposed action would be to deny the requested exemption. This would reduce the number of individuals available to run the plant while the remaining personnel are taking annual operating tests and biennial written examinations. Denial of the exemption request would result in no change in environmental impacts.
The proposed action (i.e., granting the exemption) will not increase the probability or consequences of accidents as no changes are being made in the types or quantities of any radiological effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.
The proposed action does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed action.
U.S. Nuclear Regulatory Commission Attachment 3F1l102-07 Page 3 of 3 The environmental impacts of the proposed action and the alternative action are similar. Based on the assessment above, the proposed action will not have a significant effect on the environment.