ML021990151
| ML021990151 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/17/2002 |
| From: | Grant G Division Reactor Projects III |
| To: | Skolds J Exelon Generation Co, Exelon Nuclear |
| References | |
| Download: ML021990151 (6) | |
Text
July 17, 2002 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR DRESDEN STATION LICENSED OPERATORS
Dear Mr. Skolds:
By letter dated July 8, 2002, Exelon Generation Company, LLC (Exelon) informed the NRC that certain conditions of the Dresden Nuclear Power Station operator licenses were not being met.
Specifically, Title 10 of the Code of Federal Regulations (10 CFR), Part 55, Section 55.53(h),
requires the operators to complete a requalification program as described by 10 CFR 55.59.
Title 10 CFR 55.59(a)(1) and (a)(2) require the operators to successfully complete a requalification program not to exceed 24 months in duration, and to pass a comprehensive requalification written examination as part of that requalification program. As discussed in the Exelon letter, 54 of the stations 64 licensed operators had not completed a comprehensive requalification written examination since January/February of 2000, and thus exceeded the maximum allowed 24-month written examination periodicity.
The Exelon letter documented information previously discussed with the NRC in a telephone conference on July 3, 2002. The NRC participants included staff from Region III and the Office of Nuclear Reactor Regulation. At the time of the telephone conference, Dresden Station Units 2 and 3 were operating in Mode 1.
Exelon, on behalf of the 54 licensed operators, requested enforcement discretion to allow the operators to continue to operate the Dresden Nuclear Power Station. Exelon indicated that a Dresden Training Department scheduling error resulted in the comprehensive written examination being scheduled at an interval greater than the required 24 months. Specifically, the Dresden Training Department previously administered a comprehensive written examination pursuant to 10 CFR 55.59 to the stations operators during the period of January through February 2000. The next written examination to meet the requirement of 10 CFR 55.59 should have occurred during January 2002. However, through a scheduling error, the examination was deferred until July 2002. Because of the delay, the 24-month time limit was exceeded and the operators did not complete a comprehensive written examination in accordance with the conditions of their individual licenses imposed by 10 CFR 55.53(h).
J. Skolds During the July 3, 2002 telephone call, Exelon requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to Section VII.C of the General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The enforcement discretion was requested on behalf of the 54 licensed operators to allow them to continue to operate the station while completing the required comprehensive requalification written examinations to restore compliance with 10 CFR 55.53(h) and 10 CFR 55.59(a)(1) and (a)(2). Exelon requested that the NRC suspend the enforcement of the requirements of 10 CFR 55.53(h) until July 17, 2002, for current on-shift control room licensed operators and August 2, 2002, for all other licensed operators. NRC Region III verbally granted enforcement discretion at 6:20 p.m. on July 3, 2002, to suspend the enforcement of the requirements of 10 CFR 55.53(h) until the specified dates, in order to allow the station's 54 licensed operators sufficient time to complete the written examination requirement.
Subsequent to the July 8, 2002 letter from Exelon requesting enforcement discretion, your staff provided information to the NRC staff that indicated that 7 of the 54 operators did not require enforcement discretion because they had satisfactorily completed a comprehensive written requalification examination prior to July 3, 2002, when the request for enforcement discretion was made. Consequently, on July 10, 2002, the NRC issued the requested NOEDs to 47 operators. The NRC also issued letters to the other seven operators informing them that issuance of a NOED was not necessary. A list of the seven licensed operators that were not issued a NOED is enclosed.
In a separate letter dated July 2, 2002, Exelon requested the NRC extend the 24-month interval required by 10 CFR 55.59(c) to an interval of approximately 30 months. This extension would allow the Dresden Station Training Department to be in regulatory compliance while completing the requirement to administer a comprehensive written examination. To accomplish this within the prescribed time extension, we understand that the station's training department plans to complete examinations for all licensed operators and senior operators on shift by July 17, 2002, and for all other remaining licensed personnel by August 2, 2002, before they are scheduled to resume licensed activities. The NRC Office of Nuclear Reactor Regulation (NRR) will respond to this request for an exemption from the requirements of 10 CFR 55.59 by separate correspondence.
You should be aware that enforcement action may be taken for violations that occurred during the period of time between closure of the station's 24-month training program (January 2002) and the time when NRC granted the NOED.
J. Skolds In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by Steven A. Reynolds Acting for/
Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
List of Licensed Operators Not Issued NOED cc: Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing M. Aguilar, Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission F. Cerovac, Training Manager
J. Skolds In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by Steven A. Reynolds Acting for/
Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
List of Licensed Operators Not Issued NOED cc: Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing M. Aguilar, Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission F. Cerovac, Training Manager DOCUMENT NAME: C:\ORPCheckout\FileNET\ML021990151.wpd
- See Previous Concurrence To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy OFFICE RIII
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- NAME DMcNeil/sd MRing SBajwa per BClayton RCaniano for email JGrobe DATE 7/15/02 7/15/02 7/15/02 7/15/02 7/16/02 OFFICE RIII NAME SReynolds for GGrant DATE 7/17/02 OFFICIAL RECORD COPY
J. Skolds ADAMS Distribution:
ADAMS (PARS) Public W. Travers, EDO W. Kane, DEDR C. Paperiello, DEDMRS F. Congel, OE J. Luehman, OE D. Dambly, OGC J. Dixon-Herrity, OE B. Boger, NRR S. Collins, NRR T. Quay, NRR D. Trimble, NRR L. Dudes, NRR J. Dyer, RIII R. Lickus, RIII D. Holody, RI C. Evans, RII G. Sanborn, RIII AJM DFT LWR RidsNrrDipmIipb GEG HBC DRC1 DRPIII DRSIII PLB1 JRK1 M. Bies (concurrence copy)
Enclosure LIST OF LICENSED OPERATORS NOT ISSUED NOED Thomas S. Cisco Daniel G. Daly Gerard A. Gates Christopher A. Keebaugh Raymond D. Laboda Steven E. Mattson Daniel M. Potochnic