ML17193A535
| ML17193A535 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion, LaSalle  |
| Issue date: | 11/05/1980 |
| From: | Janecek R COMMONWEALTH EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8011120492 | |
| Download: ML17193A535 (5) | |
Text
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5' 19 80 Mr. Darrell G. Eise.o_h,u!t.,,_. Q.ire:.c\\~o;r 07 Div i s ion o f L ice n s i r'i g' : *..:' '<.
U.S. Nuclear Regulatory Commission Washington, DC 20555
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Subject:
.Dresden Stati~ Units l, 2, and 3; Quad Cities Station Units 1 and 2; Zion Station Units l and 2; LaSalle County Station Units 1 and 2.
Response to NRC Request Concerning Interim Cri-teria for Shift Staffing NRC Docket Nos. 50-10/237/249, 50-254/265, 50-295/304 and 50-373/374 Reference (a):
D. G. Eisenhut letter to'All OL's, OL Applicants, an.d CP's dated July 31, 1980.
Dear Mr. Eisenhut:
Reference (a) provided intetim requirements for shift staffing and requested our schedule for compliance with those requirements.
Re-Ference (a) also provided guidelines for overtime restrictions and required th~t station administrative procedures be implemented to address those gui~elines and the shift staffing requirements.
The attachment to this letter provides crur response to the requirements of Reference (a) for Dresden, QLlad Cities, Zion,*and LaSalle County Stations, and identifies our plans and schedules to comply in those areas in which we do not fully meet the requirements.
Pleass address any questions concerning this matter to this office.
One (1) signed original and ninety-nine (99) copies of this trinsmittal are provided for your use.
cc:
RI II Inspector -
RI II Inspector -
RII I Inspector RI I I Inspector -
7891A 8011120 Dresden Quad Cities Zion LaSalle
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Very truly yours,
'~{~Jr:ta_*~J}
Robert F. Janecek Nuclear Licensing Administrator Boiling water Reactors
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ATTACHMENT
- The following responses are pr~vided regarding the Interim Criteria for Shift Staffing as stated in the July 31, 1980, D. G.
Eisenhut letter:
Requirement a:
A shift supervisor With a senior reactor operator's license, who is also a member of the station supervisory staff, shall be onsite at all times when at least one unit is loaded with
.fuel.
Response
Technical Specification requirements for our operating and near-term operating plants already place us in. compliance with this requirement.
Regu1rement b:
A licensed senior reactor operator (SRO) shall, at all times, be in the control room from which a reactor is being operated.
The shift supervisor may frbm time to time act as relief operator for the licensed senior reactor operator assigned to the control room.
Response
The Shift Control Room Engineer (SCRE) position has been created and personnel are being trained for this position in order to meet the requirements for an STA.
The SCRE (or relief SRO) is also the SRO who would be assigned to the control room per this interim criteria requirement.
The minimum number (5) of licensed SCRE's required to cover each shift are currently available at* Zion (Ref. also w. F. Naughton
. letter to H. R. Denton dated March 28, 1980).
At LaSalle, this minimum number will be available at fuel load (Ref. L. 0. DelGeorge letter to 8. J. Youngblood dated October 20, 1980).
At Dresden and Quad Cities, this minimum number will not be available until July li 1982.
This. delay is primarily due to the one year's wait which is required after receiving an RO license before an examination for SRO can be taken.
.It should be noted that this minimum number allows us no flexibility should illness or personnel attrition cause a loss of personnel.
In order to account for possible reductions and to comply with limitations on overtime, it will be necessary to train and license additional personnel.
This need for further selection and training of technical perso~nel to staff additional SCRE's will probably ~ot be fully met before July l, 1983, although we are attempting to complete this ta~k by January 1, 1983.
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Reguire~ent c:
For any station with more than one reactor containing fuel, the number of licensed senior reactor operators onsite shall, at all times, be at least one more than the number of control rooms from which the reactors are being operated.
Response
At present staffing levels w~ meet this requirement at this time.
Ho~ever, plant Technical Specifications could allow operation below these limits under certain conditions and will require rev1s1on.
These revisions will be submitted after final NRC criteria are established.
In the interim, an administrative order or procedures will be issued by each station requiring compliance in this area.
Requirement d:
In addition to the licensed senior reactor operators specified in a, b, and c above, for each reactor containing fuel, a licensed reactor operator (RO) shall be in the control room at all times.
Response
Technical Specification requirements for our operating and near term operating plants already place us in compliance with this requirement.
Requirement e:
. In addition to the operato~s specified in a, b, c, and d
~bove for each control room from which a reactor is being operated, an additional licensed reactor 6perator (RO) shall be onsite at all times and available to serve as relief operator for that control room.
As noted above,_ this.individual may serve as relief operatDr for each unit being operated from that ~antral room, provided he holds a current license for. each unit.
Response
Same response as to Requirement c.
Requirement f:
Auxiliar~ (non-licensed) ooerators shall be properly qu~lified to support the unit to which assigned.
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Response
Au~iliary operators are presently trained and qualified before assignment.
We are in compliance with this;requirement at this time.
Requirement g:
In addition to the staffing requirements stated above, shift crew assignments during periods of core alterations shall include a licensed senior reactor operator (SRO) to directly supervise core alterati~ns.
This licensed senior reactor operator may have fuel handling duties but shall not have other concurrent operational duties.
Response
Core alterations are performed under the supervision of individuals with SRO or limited SRO licenses.
No concurrent operational.duties e~ist during these alterations.
We are presently in compliance with this requirement.
Requirement (Additional):
Licensees of operating plants and applicants for operating licenses shall include in their administrative procedures provisions governing required shift staffing and movement of key ihdividuals about the plant.
Response
Administrative procedures addressing shift relief and turnover will be reviewed and revised as necessary to incorporate the staffing levels as stated in the above Requirements c and e.
Procedures addressing the movement of key shift supervisory personnel (SRO) about the plant will be reviewed and revised as necessary to assure a qualified supervisor, preferrably the Shift Engineer, is always within ten (10) minutes of the control room.
These procedure re~iews and any required revision will be completed by 1-1-81.
Requirement (Additional):
The administr~tive procedures shall also set forth a policy concerning overtime work for the senior reactor operators, reactor operators, a0d shift technical advisor required by these interim criteria.
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Response
It is Station policy to maintain an adequate number of personnel ~n the *Station payroll in the Shift Engineer, Shift Foreman, Station Control Room Engineer, and Nucleat Station Operator job classifications such that the use of overti~e is not routinely required to compensate for inadequate staffing.
Administrative procedures exist at our operating stations and will be prepared at LaSalle to document the policy concerni~g this work.
These administrative procedures reiterate our long standing policy that overtime not be routinely required.
The administrative proced~re~ also stipulate that work
.schedules for the Shift Engineer, Shift Foreman, Station Control Room Engineer and Nutlear Station Operator shall be established in advance to ensure that the potential for exceeding the following guidelines is minimized when filling the minimum shift ~anning requirements previously defined; that is~
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No individual should work more than 12 consecutive hours.
This does not include time netessary for shift turnover.
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No indi~idual should work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period.
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No individual should work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period.
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.No individual should work more than 14 consecutive days without having 2 consecutive days off.
It shoul~ be noted that vacancies due to resignation,
~remotion, extended illness, or other uncontrollable factors may create situations requiring extended overtime outside these guidelines.
Such deviations shall be corrected as soon as possible.
Furthermore, there may be short term unforseen circumstances such as unexpected illness or time off for personal business which may result in the guidelines being exceeded.
Both of the variances (i.e~, long term and short term) will be rectified in accordance. with the rules of the Commonwealth Edison Collective Bargaining Agreement.
Those instances resulting in deviations will.
be documented and reviewed by the Station Suµerintendant or his desighee as soon as practicable followin~ the occurrence.
We are working with the union in order to make our call-out policy for overtime to be more consistent with the guidelines.
We do not expect any results before 1-1;81.