ML120870140

Licensee Slides for Exelon Fleet Pre-Submittal Public Meeting 4-10-12 Licensed Operator Eligibility Requirements LAR

ML120870140
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Byron, Three Mile Island, Braidwood, Limerick, Clinton, Quad Cities, LaSalle
Issue date:	03/27/2012
From:	David Helker, Ludlam G, Mascitelli F Exelon Nuclear
To:	Joel Wiebe Plant Licensing Branch III
Wiebe, Joel NRR/DORL/LPL3-2, 415-6606
References
Download: ML120870140 (10)

Text

Exelon Fleet Pre-Submittal NRC Public Meeting 4-10-12 Licensed Operator Eligibility Requirements LAR Frank Mascitelli-Licensing Engineer David Helker-Licensing Manager Gregg Ludlam-Operations Training Director

Meeting Agenda 9 Introductions

9 Background

9 Overview of Proposed License Amendment 9 Relevant Precedent 9 Exelon Interpretation of ANSI/ANS 3.1-1978 9 Questions/Discussion 2

Introductions

9 NRC 9 Exelon 9 Teleconference attendees 3

Background

9 Exelon proposes to implement National Academy for Nuclear Training (NANT)

Academy Document, ACAD 10-001, Revision 0, "Guidelines for Initial Training and Qualification of Licensed Operators" without exception 9 Submit a TS amendment to change current requirement which is ACAD 00-003, Revision 1, "Guidelines for Initial Training and Qualification of Licensed Operators" 9 R Remove TS Exception E ti tot TS 5.3.1/6.3.1, 5 3 1/6 3 1 as d described ib d iin E Exelon l L Letter tt RS RS-07-078, dated July 19, 2007 (ML072110212) 9 Fleet Submittal- applies to Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station and Three Mile Island Nuclear Station 9 Third such similar License Amendment Request within last 11 years (2001, 2007, 2012) 4

Overview of Proposed License Amendment 9 Removes the TS Sections 5.3.1/6.3.1, "Unit (or Facility) Staff Qualifications," exception to ANSI N18.1-1971 or ANSI/ANS 3.1-1978 for operator license applicant's education and experience eligibility requirement's reference to Exelon Letter RS-07-078, dated July 19, 2007 ) and reference to 10 CFR 55 (Limerick Generating Station Units 1 and 2) 9 Removal of the education and experience eligibility requirements exception clause will effectively require ANSI N18.1-1971 or ANSI/ANS 3.1-1978 requirements to be fully met for operator license candidate qualifications and allow adoption of ACAD 10-001 9 Clinton, Limerick, Oyster Creek, and Three Mile Island meet the qualifications of ANSI/ANS 3.1-1978, "Selection and Training of Nuclear Power Plant Personnel;"

9 Braidwood, Byron, Dresden, LaSalle, Peach Bottom, and Quad Cities meet the requirements of ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel" 5

Overview of Proposed License Amendment 9 Exelon proposes to implement the operator education and experience eligibility requirements contained in NANT ACAD 10-001, Revision 0, and future changes thereto 9 Operator Licensing Program Feedback (Question 202.20)

• NRC considers the eligibility guidelines for education and experience at existing nuclear power plants promulgated by the NANT iincluding l di th those th thatt were issued i d in i February F b 2010 - ACAD 10-001 as acceptable methods for meeting 10 CFR 55.31(a)(4)

• Noted exception of the Direct SRO for SRO-Certified Instructor eligibility criteria listed in Figure 2-4 (which is no different than the previously stated exception to NANT ACAD 00-003) 9 Comparison of ANSI N18.1-1971, ANSI/ANS 3.1-1978 and ACAD 10-001 requirements

• Revealed potential issue with licensed reactor operator training

• Training/experience equivalency for academic training for reactor operators 6

Relevant Precedent 9 A similar license amendment was approved, in part, for the removal of a specific TS reference to an NMC letter dated March 19, 2003 that contained the education and experience requirements for operator license applicants at the Prairie Island Nuclear Generating Plant Plant, Units 1and 2 on December 1, 2011 (ML112901115) 9 A similar license amendment request was submitted for Wolf Creek Generating Station on April 22, 2011 (TAC NO. ME6151), which, in part, requests the removal of operator license applicants' education and experience requirements from their TSs (ML11123A226) 7

Exelon Interpretation of ANSI/ANS 3.1-1978 9 Section 4.5.1, Operators

• 2 years power plant experience

• 1 year nuclear power plant experience

• 6 months credit granted towards experience requirement for related technical training 9 Section 4.5.1 is silent on granting Operators credit for academic training 9 Section 4.3.1 permits 2 years credit granted towards experience requirement for academic or related technical training for Senior Reactor Operators 9 Exelon position: ANSI/ANS 3.1-1978 standard allows granting maximum 2 years credit towards experience requirement for academic training for Operators 8

Exelon Interpretation of ANSI/ANS 3.1-1978 9 NANT ACAD 10-001allows graded approach for related technical and academic training/experience g p equivalency q y

• 18 months credit for academic training

• 9 months for technical training 9

Summary 9 Exelon follows NUREG 1021 Rev 9 9 Exelon files NRC Form 398, Personal Qualifications Statement: Licensee for each applicant including exemptions as required.

9 Exelon seeks to implement ACAD 10-001 and revisions thereto without future LARs 9 Exelon seeks fleet consistency and to not create additional specific TS exceptions for potential ANSI/ACAD conflicts for 4 sites committed to 1978 ANSI standards 10