DCL-05-121, Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. Unit Staff Qualifications
| ML060050325 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/23/2005 |
| From: | Oatley D Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-05-121, DCL-05-148, OL-DPR-80, OL-DPR-82 | |
| Download: ML060050325 (8) | |
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Pacific Gas and Electric Company-David H. Clatley Diablo Canyon Power Plant Vice President and General Manager P. 0.Box 56 Avila Beach, CA 93424 December 23, 2005 F805.545.4350 PG&E Letter DCL-05-148 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Correction of Information Contained in License Amendment Request 05-04.
"Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications"'
Dear Commissioners and Staff:
Pacific Gas and Electric Company (PG&E) Letter DCL-05-121, dated October 19, 2005, submitted License Amendment Request (LAR) 05-04, "Revision to Technical Specification 5.3.1, 'Unit Staff Qualifications."' LAR 05-04 proposes to update the Technical Specification (TS) 5.3, "Unit Staff Qualifications," minimum operator qualification requirements from those contained in the March 28, 1980, NRC letter to all licensees to the more recent NRC-approved operator qualification requirements contained in American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.1-1993. In addition, the proposed changes remove the TS 5.3.1 plant staff retraining and replacement training program requirements which have been superseded by requirements contained in 10 CFR 50.120.
Diablo Canyon Power Plant (DCPP) TS 5.3.1 presently requires that the licensed reactor operators and senior reactor operators (SROs) meet or exceed the minimum qualifications of 10 CFR 55 and the supplemental requirements specified in Section A of Enclosure 1 of the March 28,1980, NRC letter to all licensees.
Letter DCL-05-121 stated that PG&E has used Form 398 since 1987 to certify the experience for SRO candidates who have never previously held a reactor operator license; however, DCPP TS 5.3.1 requires that the licensed SRO operators meet or exceed the supplemental requirements specified in Section A of Enclosure I of the March 28, 1980, NRC letter to all licensees. DCL-05-121 also stated that this TS condition has existed since 1984, when the DCPP Unit 1 TS became effective, and that this condition was entered into the DCPP corrective action program on December 24, 2004.
A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- South Texas Project
- Wolf Creek
Document Control Desk PG&E Letter DCL-05-148 December 23,2005 Page 2 At the time an issue concerning past compliance with TS 5.3.1 was discovered by PG&E on December 24, 2004, and at the time that Letter DCL-05-121 was written, PG&E mistakenly interpreted the Enclosure 1, Section A.1, Item b, requirement of the March 28, 1980, NRC letter to mean that all applicants for a SRO license must have held an operators license for one year. In fact, based on further evaluation, PG&E has now determined that additional guidance from the NRC interpreting the requirements was applicable and, therefore, that no noncompliance with TS 5.3.1 has existed in this regard.
Specifically, on December 6, 2005, PG&E reviewed NUREG-0737, "Clarification of TMI Action Plan Requirements," dated November, 1980, which clarified the requirement contained in Enclosure 1, Section A.1, Item b, of the March 28,1980, NRC letter. NUREG-0737, Enclosure 3, "Clarification of TMI Action Plan Requirements," contained clarification of certain Three Mile Island action items.
NUREG-0737, Enclosure 3, Section l.A.2.1, "Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications," pages 3-16 to 3-17, explained various paths to provide experience equivalent to one year experience as a licensed operator. NUREG-0737, Enclosure 3, Section l.A.2.1, is contained in Enclosure 1.
The subsection, 'Clarification," in NUREG-0737, Enclosure 3, Section l.A.2.1, contained, in part (emphasis added), the following statements which clarified the March 28, 1980, letter requirement for an applicant for an SRO license to have been a licensed operator for one year:
"Applicants for SRO either come through the operations chain (C operator to B operator to A operator, etc.) or are degree-holding staff engineers who obtain licenses for backup purposes.
Applicants for SRO licenses who possess a degree in engineering or applicable sciences are deemed to meet the above requirement. provided they meet the requirements set forth in sections A.1.a and A.2 in enclosure 1 in the letter from H. R. Denton to all power reactor applicants and licensees, dated March 28. 1980, and have participated in a training program equivalent to that of a cold senior operator applicant."
The NRC further confirmed its understanding of the requirement contained in, Section A.1, Item b, of the March 28, 1980, NRC letter on page 1-6 of NUREG-0675, Supplement No. 12, "Safety Evaluation Report Related to the Operation of Diablo Canyon Nuclear Power Plant, Units 1 and 2," dated March 1981. NUREG-0675, Supplement 12, addressed items in the Commission's Safety Evaluation Report, Supplement 10, that required followup confirmation and review against the requirements contained in NUREG-0737. NUREG-0675, A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- South Texas Project
- Wolf Creek
Document Control Desk PG&E Letter DCL-05-148 December 23, 2005 Page 3 Supplement 12, Section l.A.1, "Operating Personnel and Staffing," subsection l.A.2.1, "Immediate Upgrading of Operator And Senior Operator Training and Qualifications," stated in part-(emphasis added):
"Applicants for SRO license shall have 4 years of responsible power plant experience, of which at least 2 years shall be nuclear power plant experience (including 6 months at specific plant) and no more than 2 years shall be academic or related technical training. After fuel loading applicants shall have one year of experience as a licensed operator or equivalent."
All applicants for SRO licenses at DCPP have either held an operator license for one year, been cold license applicants, or have obtained equivalent experience to one year of experience as a licensed operator. Applicants for SRO licenses with equivalent experience possessed either a degree in engineering or applicable sciences and met the requirements set forth in sections A.1.a and A.2 in in the March 28, 1980, letter, or had actual operating experience in a position that is equivalent to a licensed operator or senior operator at military propulsion reactors. These SRO experience requirements are captured in DCPP procedure TQ2.DC2, "Licensed Operator and Shift Technical Advisor Initial Training Program," page 6. Therefore, PG&E has concluded that all SRO candidates at DCPP have met the experience requirements of TS 5.3.1.
Accordingly, our prior statements made in Letter DCL-05-121 interpreting Section A of Enclosure 1 of the March 28, 1980, NRC letter as strictly requiring one year of licensed reactor operator experience for all SRO candidates were incorrect. As reflected in the above discussion, NUREG-0737 clarified the Commission's understanding of such requirement as being met by individuals who possess a degree in engineering or applicable sciences. Therefore, PG&E amends its Letter DCL-05-121 and requests that all statements containing the mistaken interpretation be disregarded.
Moreover, PG&E wishes to inform the Commission that the action request that was entered into the corrective action program regarding a potential noncompliance with TS 5.3.1 will be closed as a result of our newly acquired understanding of Section A of Enclosure I of the March 28, 1980, NRC letter. Therefore, there shall be no further action on this action request.
This information does not affect the results of the technical evaluation or the no significant hazards consideration determination previously transmitted in PG&E Letter DCL-05-121.
If you have any questions, or require additional information, please contact Stan Ketelsen at (805) 545-4720.
A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- South Texas Project
- Wolf Creek
'a-'
Document Control Desk December 23, 2005 Page 4 PG&E Letter DCL-05-148 Sincerely, David H. Oatley Vice President and General Manager kjse/4328 Enclosure cc:
Edgar Bailey, DHS Bruce S. Mallett Terry W. Jackson Diablo Distribution cc/enc: Alan B. Wang A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- South Texas Project
- Wolf Creek
PG&E Letter DCL-05-148 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY)
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Diablo Canyon Power Plant
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Docket No. 50-275 Facility Operating License No. DPR-80 Docket No. 50-323 Facility Operating License No. DPR-82 Units 1 and 2 3I AFFIDAVIT David H. Oatley, of lawful age, first being duly sworn upon oath states that he is Vice President and General Manager of Pacific Gas and Electric Company; that he has executed this correction of information contained in License Amendment Request 05-04 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.
David H. Oatley Vice President and General Manager Subscribed and sworn to before me this 23rd day of December, 2005, by David H. Oatley, personally known to me or proved to me on the basis of satisfactory evidence to be the person who appeared before me.
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a zdd Notary Public County of San Luis Obispo State of California lTERI A. BEIXEL 3OMSSo 1477781
- ;~SW lt*Obispoou l-E21omm01X PG&E Letter DCL-05-148 NUREG-0737, Enclosure 3, "Clarification of TMI Action Plan Requirements,"
Section I.A.2.1, "Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications," pages 3-16 to 3-17
ti I.A.2.1 IMMEDIATE UPGRADING OF REACTOR OPERATOR AND SENIOR REACTOR OPERATOR TRAINING AND QUALIFICATIONS Position Effective December 1, 1980, an applicant for a senior reactor operator (SRO) license will be required to have been a licensed operator for 1 year.
Changes to Previous Requirements Changes to the previous requirements will permit various paths to provide experience equivalent to 1 year's experience as a licensed operator.
Clarification Applicants for SRO either come through the operations chain (C operator to B operator to A operator, etc.) or are degree-holding staff engineers who obtain licenses for backup purposes.
In the past, mady individuals who came through the operator ranks were admini-stered SRO examinations without first being an operator.
This was clearly a poor practice and the letter of March 28, 1980 requires reactor operator experience for SRO applicants.
However, NRC does not wish to discourage staff engineers from becoming licensed SROs.
This effort is encouraged because it forces engineers to broaden their knowledge about the plant and its operation.
In addition, in order to attract degree-holding engineers to consider the shift supervisor's job as part of their career development, NRC should provide an alternate path to holding an operator's license for 1 year.
The track followed by a high-school graduate (a nondegreed Individual) to become an SRO would be 4 years as a control room operator, at least one of which would be as a licensed operator, and participation in an SRO training program that includes 3 months on shift as an extra person.
The track followed by a degree-holding engineer would be, at a minimum, 2 years of responsible nuclear power plant experience as a staff engineer, participation in an SRO training program equivalent to a cold applicant training program, and 3 months on shift as an extra person in training for an SRO position.
Holding these positions assures that individuals who will direct the licensed activities of licensed operators have had the necessary combination of education, training, and actual operating experience prior to assuming a supervisory role at that facility.
The staff realizes that the necessary knowledge and experience can be gained in a variety of ways. Consequently, credit for equivalent experience should be given to applicants for SRO licenses.
3-16
-I.A.2.1-1
4 Applicants for SRO licenses at a facility may obtain their 1-year operating experience in a licensed capacity (operator or senior operator) at another nuclear power plant. In addition, actual operating experience in a position that is equivalent to a licensed operator or senior operator at military propulsion reactors will be acceptable on a one-for-one basis.
Individual applicants must document this experience in their Individual applications in sufficient detail so that the staff can make a finding regarding equivalency.
Applicants for SRO licenses who possess a degree in engineering or applicable sciences are deemed to meet the above requirement, provided they meet the requirements set forth in sections A.1.a and A.2 in enclosure 1 in the letter from H. R. Denton to all power reactor applicants and licensees, dated March 28, 1980, and have participated In a training program equivalent to that of a cold senior operator applicant.
NRC has not imposed the 1-year experience requirement on cold applicants for SRO licenses.
Cold applicants are to work on a facility not yet in operation; their training programs are designed to supply the equivalent of the experience not available to them.
Applicability This requirement applies to all operating reactors and applicants for operating licenses (after initial criticality).
Implementation This requirement applies to applicants for senior reactor operator licenses received after December 1, 1980.
Type of Review A postimplementation review will be performed.
Documentation Required No-documentation is required from the facility. Information will be contained in individual applications.
Technical Specification Changes Required Changes to technical specifications will not be required.
Reference Letter from H. R. Denton, NRC, to All Power Reactor Applicants and Licensees, dated March 28, 1980.
I.A.2.1-2 3-17