ML17255A810

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Exemption from 10CFR50.54,permitting Operation W/Only One Senior Reactor Operator Who Can Be Absent from Control Room During Portions of Shift.Exemption Effective Until 840521
ML17255A810
Person / Time
Site: Ginna Constellation icon.png
Issue date: 05/04/1984
From: Eisenhut D
Office of Nuclear Reactor Regulation
To:
ROCHESTER GAS & ELECTRIC CORP.
Shared Package
ML17255A811 List:
References
NUDOCS 8405090044
Download: ML17255A810 (9)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ROCHESTER GAS AND ELECTRIC

)

CORPORATION

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)

(R.

E. Ginna Nuclear Power PLant)

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Docket No.

50-244 EXEMPTION Rochester Gas and Electr ic Corporation (the licensee) is holder of Provisional Operating License No.

DPR-18 which authorizes operation of the R.

E. Ginna Nuclear Power Plant (Ginna).

This provides, among other things, that it is subject to all rules, regulations, and orders of the Commisssion now or hereafter in effect.

The facility is a pressurized water reactor rated at 1520 megawatts (thermal) and is located at the licensee's site located in llayne County, New York.

A change to the regulation 10 CFR 50.54, issued on July ll, 1983, requires A

that, effective January 1,

1984, the minimum shift staffing for'n operating, single unit nuclear power plant include:

(1) an individual holding a senior reactor operator (SRO) license who is assigned responsibility for overall

'405090044 840504;.,

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  • DOCK 05000244 P

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2 plant operation (the Shift Supervisor);

(2) a second SRO who must be present

't all times in the control room from which the nuclear unit is being operated (this SRO may be relieved by the Shift Supervisor or another qualified SRO, but an SRO presence in the control room must be maintained);

(3) an individual with a reactor operator (RO) license or an SRO license at the plant controls; and (4) an additional RO assigned to the unit.

Previously, individual plant technical specifications had established the minimum shift crew staffing for each nuclear unit, 'and generally required one SRO and two ROs to be present on shift when the unit was operating.

The rule change codifies the previously established general requirements and, for most plants, adds the requirement for the second SRO to be stationed in the control room.

The licensee initially met the regulation.

However, as a result of defi-ciencies noted in the licensee's requalification program identified during a

I programmatic review of the program conducted by the NRC Region I office, the licensee decided that some of the Ginna operators should receive additional training and reevaluation, which would require. more than the normal number of operators to be off shift; On February 10,

1984, Rochester Gas and Electric Corporation, (RG&E) the licensee for Ginna, requested a temporary exemption from the requirement to have two SROs on shift and from the requirement for the continuous presence of an SRO in the control room while the plant was being operated.

The requested exemption would have permitted reactor operation, during plant conditions other than cold shutdown or refueling, with only one SRO who would be permitted to be absent from the control room during portions of the shift.

All other requirements of 10 CFR 50.54(m)(2) would continue to be met.

The requested exemption was for the period until July 3, 1984.

After discussions between the staff and the licensee, it appeared that fhe additional operator training

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7590-01 could be accomplished during the Spring-1984 refueling outage, when the regulations would require only one SRO to be on shift.

Accordingly, on February 22, 1984 a letter was sent to the licensee confirming that no action was required at that time on the exemption request, but leaving open further consideration of an exemption should the licensee request it.

At that time, the licensee had initiated an intensive training program, designed to run for three four-week cycles to accommodate three groups of operators.

The program start on March 5, 1984, coincided with the start of the refueling outage (March 3, 1984) and it was anticipated that the first two groups of operators would have completed the training prior to the scheduled Nay 3,

1984, end of the refueling outage, which would have allowed

. the plant to restart with operating crews in conformance with the requirements of 10 CFR 50.54(m)(2).

However, upon completion of the first four-week cycle, it appeared that an additional week was necessary to enable the operators to thoroughly assimilate the training.

Accordingly, each cycle was extended to five weeks.

This extended training cycle meant that the second class could not be completed by the end of the refueling outage.

Accordingly, on April 3, 1984, the licensee reinitiated a request for an exemption.

The April 3, 1984, letter requested the same exemption conditions as the earlier, February 10, 1984 letter, but requested that the exemption be effective only until May 21, 1984

'nstead of July 3,

1984, as requested by the earlier letter.'he requested May 21, 1984, date allows one week for contingencies following the scheduled completion of the second five-week training cycle and *it coincides with a normal shift rotation.

If granted, the exemption would allow the licensee

7509-01 to operate the Ginna plant with one SRO on shift, instead of the two SROs required by the regulation, for a period of about two and one-half weeks following completion of the refueling outage.

Alternatives to the exemption, considered by the licensee, include a

four-shift operation instead of the established five-shift operation, and using SRO-licensed plant staff members on shift.

However, the licensee

believes, and the staff agrees, that reduction to a four-shift operation would adversely impact the current requalification and retraining program.

It could also result in considerable overtime requirements.

The staff does not believe that adoption of this alternative would be in the overall interest of plant safety.

The licensee also indicated that the licensed plant staff

members, in general, are intimately involved in various facets of the Spring refueling outage and that their involvement in these matters will continue for some time following restart from the outage.

Assignment of these individuals to shift duties would detract from their ability to perform their normal assignments.

The staff agrees that these individuals are needed in their regular assignments and should not be assigned shift duty.

As compensating

measures, the licensee proposes that when only one SRO is on shift, three ROs will be assigned instead of the required two ROs thus maintaining the minimimum number of licensed operators.
Further, the licensee notes that during periods of plant operation a shift technical advisor (STA) will be on shift.

Of the ten, STAs at Ginna, three currently hold SRO licenses and a fourth has taken the SRO examination but has not yet received the results.

The STAs at Ginna work 24-hour duty watches rather than rotating with the shift crews.

During normal day shifts and during some back shifts immediately

7590-01 5-following the outage, additional SRO licensed individuals will be present at the plant and available to assist the shift crew if necessary.

Thus, the total time during which the plant might have only one SRO available at the site during the period of the requested exemption would be limited.

Finally, the licensee states that the Ginna ROs generally have significant experience such that highly experienced and dedicated ROs will be in the control room at all times.

The licensee considers that during the period of the requested exemption when only one SRO (the shift suprevisor) might be on shift, the SRO must have freedom to move about the plant where his services may be needed.

The staff agrees; The licensee's letter states that absence of the SRO from the control

. room would be minimized and that it would be expected not to exceed 105 of the time, although this is not a firm number.

Further, the licensee notes that the SRO could return to the control room within five to ten minutes from any point in the plant.

In the Statement of Consideration accompanying the July ll, 1983 changes to 10 CFR 50.54, The Commission stated that any licensee unable to meet the January 1,

1984 deadline for implementation of the shift staff criteria was to submit a request for an extension which would address five criterion.

These five criterion are addressed as follows:

Criterion 1 - Whether the licensee is firmly committed to hire and train the necessary number of operators.

The licensee is committed to hire and train the necessary number of operators, as evidenced by the fact that the licensee did comply with the

'I rule on January 1,

1984.

Granting of this exemption will permit'the licensee to provide additional training to which the licensee has committed.

The

The current period of non-compliance is only a.temporary one created by the upgrading of the operator training.

Criterion 2 - Whether the licensee has set a reasonable target date by which it would meet the requirements.

The length of this exemption is approximately 2$ weeks, until May 21, 1984.

This target date is reasonable in that it occurs one week after com-pletion of the second training class.

It also coincides with a scheduled shift change so that there is a smooth transition between shifts.

Criterion 3 - Whether the licensee has an active recruitment program to hire the necessary number of operators.

'he licensee has taken the initiative to hire sufficient numbers of operators, as evidenced by its compliance with the rule. on January 1,

1984.

Criterion 4 - Whether the licensee has an adequate training program to assure that it has well-trained operators readily available.

As mentioned previously, this exemption request resulted from questions raised during a staff review of the training program.

The licensee has taken interim measures, which have been discussed with the staff, to upgrade the training program.

Long term modifications to the training program are being developed.

The staff considers the interim measures to be acceptable.

The long term changes will be reviewed by the staff when they are submitted.

Criterion 5 - Whether implementation of the rule would adversely affect the licensee's training program, overtime practices, number of shifts, or length of shift.

7590-01 The licensee considered alternatives to the exemption request including a reduction to a four shift operation and the use of overtime.

The licensee'oncluded and the staff agrees that such alternatives would not be beneficial to the overall safety of the plant.

Accordingly, the staff concludes that the aforementioned criteria weigh in favor of granting the exemption request.

The staff has evaluated the licensee's request and has concluded that granting the temporary exemption would be in the overall interest of increased plant safety since 'it will allow the licensee to fully staff the operating shifts at an early date with operators who have been through an intensive training and re-evaluation

program, and who, therefore, should be better able to cope with both normal and off-normal plant conditions.

During the period of

. the exemption, when the plant is operating, the staff requires that the third RO be present in the control room to perform duties as normally would be performed by the SRO in the control room.

Absences of the Shift Supervisor from the control room during this period should be limited to the extent feasible

and, when the Shift Supervisor must leave the control area, the STA must be present and immediately available to advise the operator at the controls.
Further, to the extent feasible, during the period of the exemption, the licensed STAs should be assigned the STA duti,es.

During periods of planned plant evolutions involving a change of power level, the Shift Supervisor must be present in the control room.

7590-01 Accordingly, the Commission has determined that, pursuant to 10 CFR

50. 12, an exemption is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest.

Therefore, the Commission hereby approves the exemption described in Section II above.

n The NRC Staff has determined that granting of this exemption will not result in any significant environmental impact and that pursuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with this action.

This exemption is effective upon issuance.

Dated g Bethesda, Maryland this K day of~q FOR THE NUCLEAR REGULATORY COMMISSION I

'wl, Darrell.Q. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

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