ML18030B219
| ML18030B219 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/26/1986 |
| From: | Muller D Office of Nuclear Reactor Regulation |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8604070508 | |
| Download: ML18030B219 (6) | |
Text
Docket Nd:" 50-259/260/296 Mr. S.
A. White Manager of Nuclear Power
'Tennessee-Yalley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
Dear Mr. White:
MAR 3g 1986
SUBJECT:
MINIMUM PLANT STAFFING AT BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2
AND 3 WHILE UNITS 1
AND 2 ARE DEFUELED AND UNIT 3 IS IN COLD SHUTDOWN In your letter dated January 28, 1986 to Mr. Muller you provided us with your interpretation of the minimum staffing requirements for licensed operators at Browns Ferry Nuclear Plant, Units 1, 2 and 3.
Specifically, you indicated the desire to reduce the number of licensed operators at Browns Ferry to one operator and one senior operator during the period that Units 1 and 2 are defueled and Unit 3 is in cold shutdown.
We cannot accept the interpretation you have presented for the reason given below.
As of January 1984, licensees of nuclear power units are required to meet the requirements specified in 10 CFR 50.54(m)(2).
These requirements supersede the minimum shift crew requirements for licensed operators listed in Section 6.8 of the Browns Ferry technical specifications.
According to the table in 10 CFR 50.54(m)(2)(i), the minimum requirements per shift for on-site staffing by operators and senior operators for facilities like Browns Ferry, which is a
,three-unit plant with two control rooms, are one senior operator and three operators when none of the three units is operating.
Therefore, if TVA wishes to reduce the minimum licensed operator staffing levels at Browns Ferry during the period that Units 1 and 2 are defueled and Unit 3 is in cold shutdown, then an application for exemption from the substantive requirements of the rule is necessary.
The rule allows for temporary deviations from the required minimum staffing levels to provide for unexpected situations such as illness of an operator during a shift.
The first footnote to the table in 10 CFR 50.54(m)(2)(i) allows for the establishment of criteria tor such deviations in the unit's technical specifications; however, in our opinion, defueling, as it pertains to the current situation, cannot reasonably be interpreted as a "temporary deviation."
8604070508 860326 PDR ADOCK 05000259,.
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Mr. S. A. White The rule also states that for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times.
This means that for fueled units the operator must remain at the controls and not elsewhere in the control room.
This regulation would apply only for Unit 3 since Units 1 and 2 are defueled.
Regulatory Guide 1. 114, "Guidance on Being an Operator at the Controls of a Nuclear Power Plant," provides 'guidance on this subject.
The operators for Units 1 and 2 would not be limited to the area at the controls, but they must still be present within the protected boundary of the Browns Ferry site.
In summary, we interpret the rule to require the senior operator and three operators be on site, one of which must be at the controls of Unit 3 and with the Senior Operator assigned responsibility for all three=-units.
In addition we agree with your intent to substitute unlicensed operators at the controls of Units I and 2 under the direction of a licensed operator.
Sincerely, Qri-,ln.l~an:d bY Gabriel A. f8ullor, g Daniel R. Muller, Director BWR Project Directorate ¹2 Di ision of BWR Licensing cc:
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CC:
H. S. Sanger, Jr.,
Esouire General Counsel Tennessee Valley Authority 400 Commerce Avenue E 1')B 330 Knoxville, Tennessee 37902 Nr.
Ron Rogers Tennessee Valley Authority 5N 130B Lookout Place Chattanooga, Tennessee 37402-2801
- Chairman, Limestone County Commission Post Office Box 188
- Athens, Alabama 35611 Ira L ~ Neyers, N.D.
State Health Officer State Department of Public Health State Office Building Nontgomery, Alabama 36130 Nr. K. t!. llhitt E3A8 400 Hest Summit Hill Drive Tennessee Valley Authority Knoxville, Tennessee 37902 Regional Administrator, Region II U. S. t/uclear Regulatory Commission 101 Narietta Street, Suite 3100 Atlanta, Georgia 30303 Nr. Steven Roessler U. S. Nuclear Regulatory Commission Reactor Training Center Osborne Office Center, Suite 200 Chattanooga, Tennessee 37411 H.
C Bibb Site Director, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602 Resident Inspector U. S. !'luclear Regulatory Commission Route 2, Box 311
- Athens, Alabama 35611 Mr. Donald L. Hilliams, Jr.
Tennessee Valley Authority 400 liest Summit Hill Drive, l!10BB5 Knoxville, Tennessee 37902 Robert L. Lewis, Manager, RFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602