ML18227D156

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Referring to Phone Conversation on 12/22/1975, Request Several Changes to Requalification Program
ML18227D156
Person / Time
Site: Turkey Point  
(DPR-031, DPR-041)
Issue date: 12/23/1975
From: Yaeger H
Florida Power & Light Co
To: Collins P
Office of Nuclear Reactor Regulation
References
Download: ML18227D156 (6)


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NRC DISl'UTION FOR P/hRT GO DOCKET

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Paul F. Collins DATE Of'OC 12 23 75 ORIG Signed DATE R EC'D CC OTHER LTR TWX XXX RPT SEr TnRC rDR SENT LOCAL PDR OTI.IE fl CLASS

UNCLASS, PROP INI=O XXX INPUT NO CYS REC'D L'QCKE7 NO:

50-25 25 DESCRIPTION:

Regarding several changes to requaliiication

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Mr. Paul P. Collins 4

Directorate of Licensing

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S. Nuclear Regulatory psalm Washington, D.

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AL Bn a talepTTone conversation Between Messrs,.Ked~-Beatty (FPL) and Jerry Holmah (USNRC) on December 22, 1975, it was determined that we need to formally request several changes to our requalification program.

The first item to be changed is the annual start-finish date of our program..

Last year we r'equested to have the annual examination extended into March.

This was because our program actually began in March, 1974, rather than in

January, 1974.

Since that time we have scheduled our program to run from March to March, however, our last request could be construed to apply only to the first year.

We hereby request that our program cy'cle be considered to rotate from March to March in accordance with our original intent.

The second request is being initiated as a result of an NRC 'compliance audit recently held at the Turkey Point Plant.

Rather than change the requalification procedure at this 'time, we would prefer to obtain a waiver.

now and then after. this cycle ends in March, submit for approval a revised requalification procedure, The section of our existing procedure on which we need to obtain a waiver appears on page 6, paragraph 8.2.4, "Non-Shift Licensee on-watch duty".

It appears that a poor choice of words was used in this section.

We first say that'ach non-shift licensee "should" perform licensed duties in the Control Room.

This as a recommendation is fine, but then in the next sentence we say, "The minimum requirement shall be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> within any 4 month period."

This is where we run into some problems.

There are a couple of non-shift personnel in supervisory positions who by Tech.

Spec's.

are required to hold a license'.

One, of these individuals is the Operations Superintendent Nuclear.

In this position he does not routinely stand nuclear plant supervisor watches,

however, by virtue of his position, he makes decisions and directs overall plant operations, which wq contend is performing in a licensed. capacity'.

The other position in which we have..

a similar situation is the Plant Superintendent Nuclear.

The Operations Sup'erintendent reports to him, and by virtue of his position, directs the overall licensed activities of the facility. All other non shift licensed personnel do log their time spent on watch in the Control Room as per our requalification procedure.

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Mr. Paul P. Collins l Il We request a relaxation of this paragraph for those individuals who by virtue of their p'ositions do not stand scheduled watches in the Control Room, but do exercise their license in directing overall plant activities.

Xf you have any questions regarding these requests, or require any additional information, please feel free to call on us.

Sincerely, lf. E.

aeger.

'Plant Madager HEY:KHS:

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