ML18101B357

Requests Exemption from 10CFR55.31(a)(5) Requiring OL to Perform Min of 5 Significant Control Manipulations Affecting Reactivity or Power Level on Facility for Which License Is Sought.Encl Resumes Withheld

ML18101B357
Person / Time
Site:	Salem
Issue date:	05/10/1996
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101B358	List: ML18101B357
References
RTR-NUREG-1021 LR-N96081, NUDOCS 9605160113
Download: ML18101B357 (7)

Text

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Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations MAY 101996 E1r-N96081 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR EXEMPTION FROM 10CFR55.3l(a) (5)

SALEM GENERATING STATION UNIT NOS 1 AND 2 DOCKET NOS. 50-272 AND 50-311 In accordance with 10CFR55.11, Public Service Electric and Gas Company (PSE&G) requests an exemption from the provision 10CFR55.31 (a) (5), wherein operator license applicants are required to perform at* least five significant control manipulations which affect reactivity or power level on the facility for which the license is sought.

Specifically, PSE&G requests that the NRC accept the performance of the required manipulations by each applicant on the Salem ANSI certified, plant specific simulator. In addition, PSE&G requests that the NRC accept additional training on the Salem simulator and/or on-the-job ~raining/evaluation in lieu of all or some portion of the NUREG-1021 requirement for the applicants to have spent 13 weeks on shift. This training is performed within the bounds of an NRC approved training program.

The applicants for whom this exemption is being sought are experienced in operation and/or supervision at other commercial nuclear power stations within the United States. Attachment 1 provides the bases for the exemption request. Attachment 2 contains brief resumes of all applicants involved.

Obtaining Hot Licenses for these individuals will significantly contribute to the restart efforts of Salem Units 1 and 2. These applicants will add to the breadth and depth of management and operations experience in the control rooms. Inclusion of these individuals on the Operations staff for restart will facilitate the increased level of safety consciousness, coordinated shift management, and commitment to event free operation PSE&G has committed to achieve as part of the Salem Restart Action Plan.

ATTACHMENT 2 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

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MAY 101996

.Document Control Desk 2 LR-N96081 Please note that PSE&G will not consider the approval of this exemption and approval of these waivers from NUREG-1021 requirements as precedents for future operator licensing activities. These requests are based strictly on the unique-situation presently at Salem and the qualifications of the applicants described herein.

We request that Attachment 2 to this document be withheld from public disclosure in accordance with 10CFR2.790(a) (6). This document has been marked "EXEMPT FROM PUBLIC DISCLOSURE PER 10CFR2.790." This attachment contains personnel files (personal resumes of the license applicants), the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.

Should you have any questions with this submittal or our request for withholding from public disclosure, please do not hesitate to contact us.

Sincerely,

~~

C All without Attachment 2 Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 ATTACHMENT 2 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

LR-N96081 ATTACHMENT 1 DESCRIPTION AND BASIS FOR EXEMPTION FROM 10CFR55.31(a) (5)

INTRODUCTION Public Service Electric and Gas Company (PSE&G) requests, in accordance with 10CFR55.11, "Specific exemptions," an exemption from certain requirements of 10CFR55.31, "Requirements for Applications for Operators' Licenses," for Salem Generating Stations Unit Nos. 1 and 2. PSE&G requests an exemption from the provisions of 10CFR55.31(a) (5), which requires in part that operator license applicants perform at a minimum five significant control manipulations which affect reactivity or power level on the facility for which the license is sought.

10CFR55.31(a) (5) specifies that for applicants at facilities that are in an extended shutdown (such as the Salem Units) which precludes manipulation of the control of the facility in the Control Room, the NRC may process the application and may administer the written examination and operating test required by 55.41 or 55.43 and 55.45 of this part, but may not issue the license until the required evidence of control manipulations is supplied.

PSE&G requests that the NRC accept the performance of the required manipulations by each applicant on the Salem ANSI certified, plant specific simulator. In addition, PSE&G requests that the NRC accept additional training on the Salem simulator and/or on-the-job training/evaluation in lieu of all or some portion of the NUREG-1021 requirement for the applicants to have spent 13 weeks on shift. This training is performed within the bounds of a NRC approved training program.

CURRENT QUALIFICATION/TRAINING REQUIREMENTS 10CFR55.31(a) (5) requires that applicants for operators' licenses perform five significant control manipulations which affect reactivity or power level on the facility for which the license is sought.

NUREG-1021, Revision 7, references ANSI/ANS 3.1-1981 and Regulatory Guide (RG) 1.8, Revision 2, dated April, 1987. As identified in the Salem Updated Final Safety Analysis Report (UFSAR), Appendix 3A, PSE&G Position on USNRC Regulatory Guides, PSE&G is committed to RG 1.8, Revision 1, dated September, 1975, which endorses ANSI N18.1-1971. The requirements of ANSI/ANS 3.1-1981 exceed the requirements of ANSI N18.1-1971.

YR-N96081 2 ATTACHMENT 1 For applicants for operators' licenses, NUREG-1021, Revision 7, requires the following: 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of classroom training, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training on the simulator, and 13 weeks spent on shift. For Senior Reactor Operator (SRO) applicants only, 6 of the 13 weeks on shift should occur during operation above 20% power.

PROPOSED ALTERNATE QUALIFICATION/TRAINING REQUIREMENTS The applicants for whom this exemption is being requested have been separated into Groups A and B based on differences in their existing qualifications and the alternate training they will receive. Group A applicants have passed their examinations and need only to satisfy the at-power operation and/or significant manipulations requirements to be qualified for their licenses.

Group B applicants are currently completing their formal training at this time.

GROUP A The applicants in Group A, both SRO and Reactor Operator (RO) ,

have passed their NRC examinations. Of the two SRO applicants, one has held an SRO license previously and the other has previously completed the training for an SRO certification at another plant. The three RO applicants have all had significant plant operations experience as equipment operators. They were chosen by plant management as the top RO applicants in their class to sit for their NRC examinations, and all three were successful.

The specific 10CFR55 or NUREG-1021 requirement is listed below together with the specifically applicable alternative training received by the Group A applicants. -

10CFR55 requirement for at least five significant control manipulations on Salem shall be met via the following alternative:

o at least five significant control manipulations which affect reactivity or power level performed on Salem's plant-specific simulator.

NUREG-1021 requirement for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of classroom training shall be met via the following alternative:

o approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> of classroom training as part of an INPO-accr~dited training program.

~R-N96081 3 ATTACHMENT 1 NUREG-1021 requirement for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training shall be met via the following alternative:

o approximately 580 hours0.00671 days <br />0.161 hours <br />9.589947e-4 weeks <br />2.2069e-4 months <br /> (approximately 14 weeks) of training and evaluation on Salem's plant specific simulator as part of an INPO-accredited training program. (This time is applied to both simulator training and on shift training.)

NUREG-1021 requirements to spend 13 weeks on shift, with 6 of the 13 weeks on shift occurring during operation above 20% power for SRO applicants, shall be met via the following alternatives:

o approximately 580 hours0.00671 days <br />0.161 hours <br />9.589947e-4 weeks <br />2.2069e-4 months <br /> (approximately 14 weeks) of training and evaluation on Salem's plant specific simulator as part of an INPO-accredited training program, (This time is applied to both simulator training and on shift training.),

and o 480 hours0.00556 days <br />0.133 hours <br />7.936508e-4 weeks <br />1.8264e-4 months <br /> (12 weeks) as an extra person on shift in Cold Shutdown or Refueling, and o a special 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at-power program on the Salem simulator specifically designed to facilitate at-power reactivity manipulations under the direct guidance of a Salem Licensed Reactor Operator.

The objective of this program was to provide the applicants with real-time normal operations training under the direction of an experienced reactor operator.

This type of training in the day-to-day routines of performing power changes, surveillance testing, adjusting nuclear instrumentation, and rotating plant equipment has significantly improved the applicants understanding of these types of activities. It also provided the SRO applicants with operational experience from the perspective of the RO.

GROUP B Group B applicants are currently participating in the INPO-accredited SRO training program. The seven Group B applicants have all held SRO licenses previously. When the applicants in Group B have passed their examinations, they will have completed the following training.

The specific 10CFR55 or NUREG-1021 requirement is listed below together with the specifically applicable alternative training received by the Group B applicants.

10CFR55 requirement for at least five significant control manipulations on Salem shall be met via the following alternative:

o at least five significant control manipulations which affect reactivity or power level performed on Salem's plant-specific simulator.

--1

~R-N96081 4 ATTACHMENT 1 NUREG-1021 requirement for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of classroom training shall be met via the following alternative:

o approximately 575 scheduled hours of classroom training as part of an INPO-accredited training program.

NUREG-1021 requirement for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training shall be met via the following alternative:

o approximately 470 scheduled hours (in excess of 11 weeks) of training and evaluation on Salem's plant specific simulator as part of an INPO-accredited training program. (This time is applied to both simulator training and on shift training.)

NUREG-1021 requirements to spend 13 weeks on shift, with 6 of the 13 weeks on shift occurring during operation above 20% power for SRO applicants, shall be met via the following alternatives:

o approximately 470 scheduled hours (in excess of 11 weeks) of training and evaluation on Salem's plant specific simulator as part of an INPO-accredited training program, (This time is applied to both simulator training and on shift training.) and o approximately 270 scheduled hours (in excess of 6 weeks) of on-the-job training and evaluation completing the RO and SRO qualification cards during the current extended shutdowns.

BASIS FOR EXEMPTION Based on a review of the requirements of 10CFR55.3l(a) (5), PSE&G has determined that the requested exemption to the regulations can be granted pursuant to 10CFR55.ll, in that it is authorized by law and will not endanger life or property.

PSE&G is confident that the applicants, for which this exemption from 10CFR55.31(a) (5) and waiver from the NUREG-1021 requirement to spend 13 weeks on shift applies, are qualified to perform their duties as either an SRO or RO, as appropriate. Previous experience identified on Attachment 2 and extensive classroom and simulator training defined previously, provide a satisfactory alternative to the control manipulations required by 10CFR55.31(a) (5) and the on-shift requirements of NUREG-1021.

With respect to the experience of the RO applicants in Group A, all have had significant plant operations experience as equipment operators. They were chosen by plant management as the top RO applicants in their class to sit for their NRC examinations, and all three were successful.

4R-N96081 5 ATTACHMENT 1 With respect to the experience of the SRO applicants in Groups A and B, all, except one applicant, have held SROs at Pressurized Water Reactors (PWRs) other than Salem. The applicant's years of experience as an SRO range from three to over fifteen. These SRO applicants were chosen based on a rigorous screening/interview process. The process supported the selection of applicants with previously demonstrated strong leadership and operations skills.

Also, the process focused on the skills of the individual applicant; the overall operating record of the PWR where the prior experience was gained was a contributing, but not primary factor.

Additionally, to improve the level of plant-specific experience, the SRO applicants will be teamed with a Salem experienced crew.

This crew will have the ability to provide historical information that will further enhance the performance of the SRO and his operating crew.

The two Group A SRO applicants will become Senior Nuclear Shift Supervisors (SNSS) for operating crews which will oversee the startup of Salem Unit 2. On each crew, the Unit 2 Nuclear Shift Supervisor (NSS) has been selected based on the individual's capability to enhance the overall performance of the crew by provision of Salem technical input usually best gained from plant-specific experience. Where possible, the Unit 2 crews have been training together in the positions they will occupy on shift. The Group B applicants will be assigned to various SNSS and NSS positions as necessary to support Unit 2 startup (current plans also have Group B applicants filling SNSS and NSS positions for Unit 1, once decisions are made concerning the schedule for Unit 1 restart) .

Obtaining Hot Licenses for these individuals will significantly contribute to the restart efforts of Salem Units 1 and 2. These applicants will add to the breadth and depth of management and operations experience in the control rooms. Inclusion of these individuals on the Operations staff for restart will facilitate the increased level of safety consciousness, coordinated shift management, and commitment to event free operation PSE&G has committed to achieve as part of the Salem Restart Action Plan.

In conclusion, the proposed alternate qualifications and training will not decrease the capabilities of the licensed operators.

For all of the above reasons, PSE&G believes it to be in the public interest to grant the requested exemption and waiver for issuance of the operators' licenses.