ML18045A843

Responds to NRC 800731 Ltr Re Interim Criteria for Shift Staffing.Response Outlines Plans & Schedule for Adhering to Various Criteria,W/Discussion on Special Problems,Including Personnel Shortage & Legal Union Agreement

ML18045A843
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	10/31/1980
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfiled D Office of Nuclear Reactor Regulation
References
NUDOCS 8011040128
Download: ML18045A843 (4)

Text

G~I Offlc*:* 212 W- Michigan Avenue, J11c:kson, Michigan 49201 * (517) 788-0850 October 31, 1980 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No. 5 US Nuclear* Regulatory Commission Washington, DC 20555 DOCKETS 50-155 AND 50-255 - LICENSES DPR-6 AND DPR BIG ROCK POINT PLANT AJ.'ID PALISADES PL&'IT - RESPONSE TO INTERIM CRITERIA FOR SHIFT STAFFING NRC letter dated October 30, 1979, "Discussion Of Lessons Learned Short Term Requirements," provided special requirements regarding the utilization and qu~lification of an On-Shift Technical Advisor (STA) and Shift Supervisor (SS). Our letters dated. March 4, 1980 for the Palisades Plant and March 14, 1980 for the Big Rock Point Plant provided our response for the STA's and SS's programs.

Your letter dated May 7, 1980, "Five Additional TMI-2 Related Requirements To Operating Reactors," introduced additional requirements whicl:i evolved from the TMI accident of March 28, 1979. In that letter, it was stated that the requirements for item (1) shift manning would be provided through separate correspondence. This was accomplished by your July 31, 1980 letter on ~terim criteria for shift manning.

Consumers Power Company has performed an in-depth review of the criteria versus our present staffing, future plans, restrictions and difficulties expected in achieving your criteria. The responses below outline our plans and. schedule for adhering to the various criteria together with a discussion on special problems where appropriate. These responses apply to both Big Rock and Palisades Plants:*

Item A A Shift Supervisor with a Senior Reactor Operator's license, who is also a member of the Station Supervisory staff, shall be on site at all times when at least one unit is loaded with fuel.

8011040 1 28

Dennis M Crutchfield, Chief 2 Palisades and Big Rock Point Plants October 31,"1980 Response to Item A The Shift Supervisors (SS) at both the Palisades and Big Rock Point Plants do hold Senior Reactor Operator's licenses and are members of the Station Supervisory staff. An SS is on site at all times. These practices always existed at our nuclear facilities and will continue in the future.

The addition of a second Senior Reactor Operator per shift will be accomplished by July 1, 1982 through the addition of an SRO-licensed engineer as part of our effort to meet the overall post-TMI staffing requirements referenced above. Due to restrictions imposed by your operator licensing branch over the past several years, we have. no staff SRO holders outside the operating group. We are now correcting that situation by developing an SRO program (to start within the next few months) for our shift engineers.

Item 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, from time to time, act as relief operator for the licensed Senior Reactor Operator assigned to the control room.

Response to Item B We will have a licensed Senior Reactor Operator in the control .room/SS office area at all times while the reactor is being operated (we consider the SS office area adjacent to the control room to be an extension of the control room). This commitment will be met by July 1, 1982.

Item C For any station with more than one reactor containing fuel, the number of licensed Senior Reactor Operators on site shall, at all times, be at least one more than the number of control rooms from which the reactors are being operated.

Response to Item C The Palisades and Big Rock Point Plants are single unit stations; therefore, this item is not applicable.

Item 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 to Item D A licensed Reactor Op~rator (RO) is in the control room at all times.at our nuclear stations. If, for some reason, the RO must leave the control room,

Dennis M Crutchfield, Chief 3 Palisades and Big Rock Point Plants October 31, 1980 another RO or SRO will assume those responsibilities until he returns to the control room (reference plant Technical Specifications Table 6.2-1).

Item E In addition to the operators specified in a, b, c and d above, for each control room from which a reactor is being operated, an additional licensed Reactor Operator (RO) shall be on site at all times and available to serve as relief operator for that control room. As noted above, this individual may serve as relief operator for each unit being operated from that control room provided he holds a current license for each unit.

Response to Item E The shift complement for both Palisades and Big Rock Point Plants presently consists of two ROs on site except when the plant conditions are as follows:

- Cold Shutdown

- Refueling Operations The additional RO may serve as a relief operator as well as perform various other duties.

Item F Auxiliary (nonlicensed) operators shall be properly qualified to support the unit to which assigned.

Response to Item F The term "properly qualified" carries many different interpretations and implications; therefore, a blanket commitment will not be made for this item ..

Our Auxiliary Operators do obtain appropriate training and valuable experience to assist the ROs as needed to maintain the safe operation of the plant.

Therefore, we consider them to be "properly qualified."

Item 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 the core alterations. This licensed Senior Reactor Operator may have fuel handling duties but shall not have other concurrent operational duties.

Response to Item G IE Circular No 80-21, issued on September 19, 1980, has provided later guidance (later than the July 31, 1980 Darrel G. Eisenhut letter) and interpretations of app~icable regulations. B9th Big Rock Point and Palisades Plants perform core alterations in accordance with the interpretations

Dennis M Crutchfi~, Chief Palisades and Big Rock Point Plants October 31, 1980 ** 4 provided with IE Circular No 80-21. The plant Technical Specifications are also consistent with those requirements.

The Palisades. and Big Rock Point Plants have administrative procedures for staffing requirements. These procedures will be revised in the future so they will be consistent with the commitments made above.

Procedures for movement of key plant personnel about the plant is specified for emergency response conditions only. Restricting the movements of these personnel during other than emergency conditions is neither necessary nor prudent and could.result in hampering the safe operation of the plant.

Your letter also addresses overtime limitations for SRO, RO and STA positions.

We concur with the intent of these guidelines and, if fact, already strive to limit the successive hours/days for individuals within the restrictions of our union contract. Strict adherence to your overtime criteria would cause direct conflict with our legal union agreement, which will require resolution ..

Additional problems with strict adherence are:

- Disruption of our fifth-shift training program.

- The 12-hour/day limit conflicts with the 14-day limitation by forcing call in of off-duty personnel.

- Recruiting of additional personnel has become increasingly difficult, industry wide.

- The increased time and requirements to obtain RO/SRO licenses, due to new NRC criteria, causes a reluctance to commit on a long-term basis.

A present shortage of RO licenses at Palisades makes it impossible to commit fully to your overtime guidelines at this t.ime (additional personnel are being trained to take the licensing exam in January 1981).

• In the meantime, every effort will be made to comply within the limitations of available people and union contract provisions.

~U#&-

David P Hoffman

• Nuclear Licensing Administrator CC Director, Region. III, USNRC NRC Resident Inspector-Palisades and Big Rock Point Plants