ML18102A739

Requests Exemption from 10CFR55.59(a)(2),wherein Licensed Operator Must Pass Annual Operating Test to Maintain Qualification of License

ML18102A739
Person / Time
Site:	Salem
Issue date:	01/06/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N97001, NUDOCS 9701100290
Download: ML18102A739 (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 JAN 0 6 1997 LR-N97001 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 REQUEST FOR EXEMPTION FROM 10CFR55.59(a) (2)

SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

In accordance with 10CFR55.11, Public Service Electric and Gas (PSE&G) requests an exemption from 10CFR55. 59 (a) (2), wherein a Licensed Operator must pass an annual operating test to maintain the qualification of their license.

Specifically, (PSE&G), in accordance with 10CFR55.11, "Specific Exemptions," requests an exemption from the requirements of 10CFR55.59 (a) ( 2) for the Salem licensed operators listed in Attachment 1. PSE&G requests an exemption from 10CFR 55.59(a) (2) which requires licensed operators "pass . . . . an annual operating test. " and that these operators be allowed to maintain their operator's license. PSE&G believes these individuals are capable of performing all the requirements and responsibilities of an operator; however, until they have successfully completed the Restart Training Program, PSE&G will ensure that the Group 3 operators will not fill the Technical Specification required licensed positions at Salem Units 1 and 2. The operators listed in Attachment 1 will be supporting other activities in the station, although they will not have completed an annual operating test for 1996.

BACKGROUND As described in Letter LR-N96255 dated November 7, 1996, PSE&G has developed a comprehensive Restart Training Program to address deficiencies identified in operator performance. The Restart Training Program is an integral part of the Salem restart plans, and is designed to improve the knowledge and skills of the Licensed Operators in order to achieve event free operation. At the conclusion of the Restart Training Program, an operating test and a comprehensive written examination is administered. To ensure that the maximum improvement benefit in the licensed 9701100290 970106 PDR ADOCK 05000272 V PDR f.jf\ Printed on

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Document Control Desk LR-N97001 operator's knowledge and skills is achieved from the Restart Training Program, the operators were divided into three groups.

Group 1 and Group 2 have completed the program; however, Group 3 is currently scheduled to complete their Restart Training in the second quarter of 1997. This schedule ensures that the Group 3 operators will complete their written requalification examination ,.

within 24 months of their last written requalification examination; however, the schedule does not allow for the Group 3 operators to complete an annual operating test for 1996, contrary to the requirements of 10 CFR 55 (a) (2). Accordingly, PSE&G is requesting a one time exemption from the annual operating test requirement for the operators listed in Attachment 1 that will allow these operators to maintain their licenses.

BASIS FOR EXEMPTION Based on a review of the requirements of 1 OCFR55. 59 (a) ( 2) , PSE&G has determined that the requested exemption to the regulations can be granted pursuant to 10CFR55.11, in that it is authorized by law and will not endanger life or property.

As a result of feedback and assessment of the progress of the operators in Group 1, additional training time was added to the original schedule for the Restart Training program. This additional training time, further enhancements developed after Group 2 completed the program, and activities in support of the Salem restart, extended the original Group 3 completion of the Restart Train Program beyond the end of 1996. The enhancements to the Restart Training Program were implemented to ensure the continuous improvement of the knowledge and skills of the licensed operators.

While the Group 3 operators are completing the Restart Training Program, these operators will continue to support Salem Restart activities; however, they will not fill the Technical Specification required licensed positions for either Salem Units 1 or 2.

The requested exemption will allow the Group 3 operators to complete their required annual operating test as part of the Restart Training Program, while maintain-ing their existing operating license. This request is limited to a one time exemption until Group 3 completes Restart Training in the second quarter of 1997. After the Group 3 operators have successfully completed the Restart Training Program, they will be enrolled in operator continuing training for 1997 and be permitted to fill licensed positions at Salem Units 1 and 2.

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~AN 0 6 1997 Document Control Desk LR-N97001 As the April 30, 1992 Statements of Consideration for revision to 10 CFR 55 states, one of the purposes of the revision was to "improve the safety of nuclear power plant operations by improving the operator licensing process ... " PSE&G believes that the operators listed in Attachment 1 are capable and knowledgeable, and that the Restart Training Program is an effective program. This program has been developed to enhance the operator's skills and knowledge, in order to achieve event free operation. By not granting an exemption and requiring these operators to be re-licensed, the underlying purpose of the regulation would not be served, in that the safety of nuclear power plant operations would not be improved.

The continued operation and the event-free startup of Salem Unit 2 is of critical importance to PSE&G. These operators are necessary to enhance the Salem Unit 1 restart activities, allowing operators who have completed Restart Training to support the restart of Unit 2. Application of this regulation, as PSE&G goes into the final phase of startup of Unit 2, and continues with restart activities for Unit 1, without the services of these operators to support additional restart activities associated with restart plans and additional testing activities, constitutes an undue hardship on PSE&G. Such: a hardship was not intended nor considered when the regulation was adopted, and has no corresponding benefit to the public.

Please note that PSE&G will not consider the approval of this exemption as precedents for future operator licensing requalification activities. This request is based strictly on the unique situation at Salem, and is intended to apply only until the Licensed Operators can complete the Restart Training Program developed as an integral part of the Salem Restart Plan.

Should you have any questions with this submittal please do not hesitate to contact us.

S.incerely, ~. . .-

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,Jr-\ 1\1 0 6 1997 Document Control Desk LR-N97001 cc Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road -

King of Prussia, PA 19406 Mr. L. N. 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. Glenn W. Meyer, Chief Operator Licensing and Human Performance Branch Division of Reactor Safety U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr .. K. Tosch, Man~ger, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

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e JAN 0 6 1997 ATTACHMENT 1 LR-N97001 GROUP 3 RESTART TRAINING LICENSED OPERATORS REQUIRING REQUALIFICATION Name License Number Docket Number Edward S. Bak, Jr. OP-10990 55-61522 Patrick L. Dennery OP-10703 55-61075 Richard J. Dunn OP-10704 55-61076 Mark A Giacini SOP-11232 55-61759 Marios C. Kafantaris SOP-10700 55-60993 John Konovalchick III SOP-10775 55-61074 Arthur D. Lounsbury SOP-10832 55-8915 Gary M. Matera OP-10422 55-60716 Glenn J. Mellot SOP-11306 55-61077 William C. Murr OP-10989 55-61520 David B. Myers OP-10861 55-61331 Phillip P.J. O'Donnell SOP-11015 55-08918 Stephen J. Sauer SOP-4562 55-7194 William 0. Wallace OP-10423 55-60719