ML18102A214

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Requests Exemption from 10CFR55.31(a)(5).Operator License Applicants Required to Perform at Least Five Significant Control Manipulations Which Affect Reactivity or Power Level on Facility.List of Experience Encl.Encl Withheld
ML18102A214
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/20/1996
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A215 List:
References
LR-N96175, NUDOCS 9607010018
Download: ML18102A214 (5)


Text

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 JUN 201996 LR-N9EJ175 United States Nuclear. Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR EXEMPTIO~ FROM 10CFR55.31(a) (5)

SALEM GENERATING STATION UNIT NOS 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter LR-N96081, dated May 10, 1996, Public Service Electric and Gas Company (PSE&G) requested an exemption from 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.

This letter provides ac;id\\tional information and clarification concerning the basis for the exemption request.

PSE&G is withdrawing the request for a waiver from certain requirements of NUREG 1021 as further review has determined that the changes to the training program which have been implemented are in compliance with PSE&Gs commitments to the NRC.

Specifically, PSE&G requests that, in lieu of the control manipulations on the facility, for the ten applicants identified on the attachment, the NRC accept the following combination of simulator manipulations, experience and commitments:

1)

Each candidate has performed manipulations on the Salem ANSI certified, plant specific simulator.

(Statements by Senior Reactor Operators (SRO) and Reactor Operators (RO) who are licensed on Salem indicate that the Salem simulator does a good job modeling reactivity manipulations with a reactor startup.)

2)

Each candidate has significant experience at other commercial nuclear power plants, ranging from five to twenty-two *years.

ATTACHMENT 1 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

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Document Control Desk LR-N96!75 2

JUN 201996

3)

The applicants for SRO have performed reactivity manipulations at other facilities.

They have all performed shift duties at least as recently as May, 1994.

(Please see the attachment for additional information on the experience of the SRO and RO candidates.)

4)

Each applicant will have completed at least five reactivity manipulations on Salem Unit 2 prior to or at the time of the unit achieving 100% power following the current outage, or they will be removed from licensed duties.

The applicants are experienced in operation and/or supervision at other commercial nuclear power stations within the United States.

As the April 30, 1992 Statements of Consideration for the revision to 10 CFR 55 states, one of the purposes of the revision was to "improve the safety of nuclear power plant operations by

~mproving the operator licensing process... "

PSE&G believes that the operators for whom the exemptions are being requested are as qualified as the currently licensed operators.

Additionally, these individuals have the specific leadership characteristics which are vital for reliable shift performance.

By not granting an exemption and requiring strict compliance with the rule in this particular circumstance, the underlying purpose of the rule would not be served, in that the safety of nuclear power plant operations would not be improved.

The continued operation, and consequently the event-free startup of Salem Unit 2 is of critical importance to PSE&G.

Application of this rule during and following the startup of Salem Unit 2 without the services of the operators for whom the exemption is being sought constitutes an undue hardship on PSE&G, one which was not considered when the regulation was adopted, and without a corresponding benefit to the public interest.

The new operators were hired by PSE&G specifically to provide a higher level of performance for the Salem units.

This exemption is requested for use only for the current applicants, and therefore provides only temporary relief from the regulations.

PSE&G has made a good-faith effort to comply, however with both Salem units shut down for extensive upgrades of both equipment and personnel, performance of the required manipulations is not possible.

In lieu of the required ATTACHMENT 1 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

95-4933

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D.ocum~nt Control Desk LR-N96175 3

JUN 201996 manipulations on the facility, a significantly higher number of manipulations has been performed by each applicant on the plant specific simulator.

Additionally, each SRO applicant has performed manipulations on other operating plants.

This exemption request is based strictly on the unique situation presently at Salem and the qualifications of the applicants described herein.

PSE&G requests that the attachment to this document be withheld from public disclosure in accordance with 10CFR2.790(a) (6).

The attachment has been marked "EXEMPT FROM PUBLIC DISCLOSURE PER 10CFR2.790."

This attachment contains personal information, 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, ATTACHMENT 1 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

95-4933

DGoument Control Desk LR-N96175 4

Mr. T. T. Martin, Administrator -

Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 JUN 2 *o 1996 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 1 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.

Document Control Desk LR-N96175 STATE OF NEW JERSEY COUNTY OF SALEM 5

JUN 2 0 1996 SS.

L. F. Storz, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I am requesting that the attachment to this letter be withheld from public disclosure in accordance with 10 CFR 2. 790 (a) (6).

The basis for this request is that the attachment contains personal information concerning the names, backgrounds and experience of the subject individuals, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.

My Commission expires on l<llYIBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires AprH 21, 199B ATTACHMENT 1 TO THIS LETTER CONTAINS INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10CFR2.790.