ML19241B690
| ML19241B690 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/29/2019 |
| From: | Greg Werner NRC Region 4 |
| To: | Peters K Vistra Operating Co. (VistraOpCo) |
| Werner G | |
| References | |
| Download: ML19241B690 (6) | |
Text
August 29, 2019 Ken J. Peters, Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - RESPONSE TO REQUEST TO CHANGE BIENNIAL REQUALIFICATION TRAINING CYCLE START AND COMPLETION DATES
Dear Mr. Peters:
In a letter dated July 31, 2019, from Mr. Brian F. St Louis, Plant Manager, to me, your station requested approval to change the start and completion dates of your 10 CFR 55.59 required licensed operator requalification training cycle. Specifically, your station requested to change the start date of your current requalification cycle retroactively to November 1, 2018, ending on October 31, 2020. Your station further requested to credit the annual and biennial NRC requalification exams administered between January and March 2019 to satisfy examination requirements, in part, for the proposed new cycle. The details of your request are included in an enclosure to this letter.
Title 10 CFR 55.59(c)(1) requires the following -
(1) Schedule. The requalification program must be conducted for a continuous period not to exceed 2 years, and upon conclusion must be promptly followed, pursuant to a continuous schedule, by successive requalification programs.
Title 10 CFR 55.59(a) requires that each licensee shall -
(1) Successfully complete a requalification program developed by the facility licensee that has been approved by the Commission. This program shall be conducted for a continuous period not to exceed 24 months in duration.
(2) Pass a comprehensive requalification written examination and an annual operating test.
Your stations previous licensed operator requalification training cycle ended on March 31, 2019, and was followed immediately by the start of your current training cycle, on April 1, 2019. If your current requalification cycles start date were to be changed retroactively as requested, then the period from November 1, 2018, to March 31, 2019, would be credited simultaneously to both your previous and your current training cycles. It is the NRCs position that two training cycles cannot exist concurrently and satisfy the requirement that a
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requalification program, upon conclusion must be promptly followed, pursuant to a continuous schedule, by successive requalification programs. Likewise, a single NRC-required requalification examination cannot satisfy two separate requalification cycles.
It is possible, per the regulations, for a requalification program to be less than 24 months long.
NUREG 1262, Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators' Licenses, states the following -
Q. 333. Is there an intent to look at a 24-month period as an isolated section and try to meet certain requirements within a 24-month period?
A. The intent is that at the end of that period we want you to do a comprehensive evaluation of the program and decide how you need to modify it for the next cycle. If you want to do it in 12-month or 18-month cycles, thats also acceptable. If you want to tie it to refueling schedules thats also acceptable.
The cycle cannot be longer than 24 months, however.
Therefore, it is possible that your station could elect to complete the current requalification cycle on October 31, 2020, as requested, so long as the requirement that each licensee shall pass a comprehensive requalification written examination and an annual operating test is met. Since a requalification program must be conducted in accordance with a facility licensees accredited SAT-based training program, your station would need to evaluate the requirements of your own SAT-based program and determine if all such requirements could be satisfied in a compressed timeframe for one cycle.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Gregory E. Werner, Chief Operations Branch Division of Reactor Safety Dockets: 50-445; 50-446 Licenses: NPF-87; NPF-89
Enclosure:
Letter from Brian F. St Louis to Greg Werner dated July 31, 2019
SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: TJF Yes No Publicly Available Sensitive NRC-002 OFFICE OE:OB C:IOLB C:OB NAME TFarina CCowdrey GWerner SIGNATURE
/RA/
/RA-E/
/RA/
DATE 8/29/2019 8/29/2019 8/29/2019
CP-201900468 TXX-19077 U. S. Nuclear Regulatory Commission Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, Texas 76011-4511 ATIN: Mr. Greg Werner ENERGY
TXU I I!
- energy Luminant 7/31/2019
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 LICENSED OPERATOR BIENNIAL REQUALIFICATION TRAINING CYCLE START AND COMPLETION DATE CHANGE REQUEST
Dear Mr. Werner:
Brian F. St Louis Plant Manager Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897.5692 Ref 10 CFR 55.59 NUREG-1021 Pursuant to 10CFR55.59, Requalification and NUREG-1021, Revision 11, Operator Licensing Examination Standards for Power Reactors, ES-605, C. License Maintenance; this correspondence is made to request a change to the start and completion dates for the 24-month continuous licensed operator requalification program at Comanche Peak Nuclear Power Plant (CPNPP).
The 24-month continuous licensed operator requalification program for CPNPP started on April 1, 2019 and will complete on March 31, 2021. In an effort to reduce the workload on the CPNPP exam group, that develops all regulatory exams, CPNPP is requesting NRC approval to adjust the 24-month continuous licensed operator requalification program. The request is to establish a revised 24-month continuous licensed operator requalification program starting on November 1, 2018 and completing on October 31, 2020.
This change credits the Annual Operating Exam administered in the first quarter of 2019. The next Annual Operating Exam will be administered starting on August 24, 2020 and completing on October 1, 2020. This schedule ensures the annual requirement for the Operating Exam is met.
6555 SIERRA DRIVE IRVING, TEXAS 75039 0214-812-4600 VISTRAENERGY.COM Enclosure
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