ML19339A602

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Responds to NRC 800731 Interim Criteria for Shift Manning. Supports NRC Position on Importance of Maintaining Adequate Operating Personnel.Program for Upgrading Shift Manning Encl
ML19339A602
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 10/30/1980
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Clark R
Office of Nuclear Reactor Regulation
References
NUDOCS 8011040395
Download: ML19339A602 (3)


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'W 1623 HARNEY e O M AH A, NESRASKA 63102 s TELEPHON E 536-4000 AREA CODE 402 October 30, 1980 Director of Nuclear Reactor Regulation ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 U. S. Nuclear Regulatory Comission Washington, D. C. 20555

Reference:

Docket No. 50-285 Gentlemen:

Omaha Public Power District received the Comission's letter dated July 31, 1980, regarding interim criteria for shift manning. The Dis-trict has initiated administrative procedures to ensure compliance with the Commission's criteria for overtime regarding Senior Reactor Oper-ators, Reactor Operators, and Shift Technical Advisors. In response to the general staffing criteria, the District's position is attached. The District supports the Commission's position on the importance of main-taining adequate operating personnel, and we believe the attached infonn-ation adequately meets the Commission's criteria.

Sincerely,

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,v b j\'d V W. C. Jones Divisi'n9 Manager Production Operations WCJ/KJM/TLP:jm Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C. 20036

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i Attachment FORT CALHOUN STATION'S PROGRAM FOR UPGRADING SHIFT MANNING Currently, shift manning requirements for the Fort Calhoun Station during operating or hot shutdown modes are as follows:

i 1 Shift Supervisor (SRO) 1 Reactor Operator (RO) 1 Assistant Reactor Operator (RO) 2 Equipment Operators-Nuclear 1 Auxiliary Operator-Nuclear -

T Total i These shift' personnel rotate on a six section shift work rotation so as _to provide relief personnel for scheduled and unscheduled absences and to provide adequate time for training and retraining requirements.

In addition to these shift personnel are the Shift Technical Advisor, the Shif t Health Physicist, and additional shift guard personnel who are qualified fire brigade members. This manning exceeds that currently required by the plant's license for operating and hot shutdown modes, which is:

1 Shift Supervisor (SRO) 2 Operator Licensed Personnel (RO) 2 Non-Licensed P-::r.nel 5 Total The interim criteria for shift staffing outlined in the Commission's July 31, 1980, letter for operating and hot shutdown modes is as follows:

1 Shift Supervisor (SR0) 1 Senior Reactor Operator (SR0) 2 Reactor Operators (RO) 2 Non-Licensed Personnel 6 Total As can be seen, the Fort Calhoun Station normally during operating and hot shutdown modes has a sufficient number of personnel to meet this new requirement on each shift and still maintain the six section shift work rotation desired by management for training and retraining and for i relief personnel. Six shifts of personnel have also allowed for com-pliance with IE Circular.80-02 (limitations on overtime). Deviations i from this circular have been rare (primarily during refueling outages) and deviations are documented, justified, and authorized by management i as allowed by the circular.

The District concurs with the Commission's concern that a Senior i

Reactor Operator be present in the control room at all times the plant

is in operating or het shutdown modes. Accordingly, the District will initiate a program, as described below, to ensure that two qualified j Senior Reactor Operators will be onsite at all times (Shift Supervisor i cnd an additional Senior Reactor Operator). However, the District takes exception to the requirement for two licensed Reactor Operators onsite.

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The District believes that the Shift Supervisor, as a qualified Senior Reactor Operator, could relieve either the Senior Reactor Operator or Reactor Operator for a short period of time to ensure two qualified personnel are in the control room under all circumstances. The Dis-

trict's experience has been such that we have never violated the exist-ing manning requirements. Additionally, the District has always main-tained a pool of additional licensed operators above the minimum re-quirements to provide a cushion for attrition due to job changes or sickness. The requirement to have two Senior Reactor Operators and two Reactor Operators would burden the plant's training programs and deplete our pool of qualified personnel such that we could not readily respond to personnel losses without overtime. Accordingly, the District proposes to meet the following shif t manning requirements by July 1,1982:

1 Shift Supervisor (SRO) 1 Senior Reactor Operator (S10) 1 Assistant Reactor Operator (RO) 2 Non-Licensed Personnel Y Total To meet the District's proposed manning requirements, the District proposes to train and recomend for Senior Reactor Operator examination two additional individuals by mid-1981. Management is committed to ,

achieve this schedule and if any unavoidable delays occur the NRC will be advised.

As stated above, no Technical Specification violations have occurred due to violation of daimum staffing requirements and it is management's intent to ensure that none occur in the future. However, the current and proposed license requirements could be violated if a member of the shift crew became suddenly ill or required immediate release from work due to other personal reasons. A qualified relief could be obtained promptly by call-out, either by the Shift Supervisor or Duty Supervisor, but in the interim a violation of the Technical Siecifications would occur. The District understands that a license change to allow call-out for sucn a situation, not onl designated Shif t Supervisor)but y for forlicensed personnel other key (including(e.g.,

shift personnel the the Shift Technical Advisor), is to be included by the Fort Calhoun Station's NRC Project Manager in the District's Amendment Application submitted in response to the NUREG-0578 Category "A" modifications. The license change, in conjunction with our proposed upgrade program, should ensure adequate manning of the control room.

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