ML19340B810

Responds to NRC 800731 Ltr Re Interim Criteria for Shift Staffing.Util Commits to Six Shifts of Eight Personnel Plus Nine Others for Relief by 820701

ML19340B810
Person / Time
Site:	Point Beach
Issue date:	11/03/1980
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
TASK-1.A.1.1, TASK-1.A.1.3, TASK-1.C.5, TASK-1.C.6, TASK-3.A.2.1, TASK-TM TAC-44117, TAC-44118, TAC-46251, TAC-46252, TAC-46259, TAC-46260, NUDOCS 8011120325
Download: ML19340B810 (6)

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Wisconsin Electnc ecuta coursur 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE. WI 53201 Nt" ember 3, E9.80

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Mr. D. G. Eisenhut, Director 3

Division of Licensing U. S. NUCLEAR REGULATORY COMMISSION E: > .;

Washington, D. C. 20555 2 3 "Q 5 a

Dear Mr. Eisenhut:

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OPERATING LICENSES DPR-24 AND DPR-27 INTERIM CRITERIA FOR SHIFT STAFFING POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 This is in response to your letter o' July 31, 1980 regarding compliance with Interim Criteria for hift Staffing.

Point Beach Nuclear Plant (PBNP) is a two-unit PWR with a " common" control room and a " common" primary auxiliaries building. Our present Technical Specification operating shift staff consists of seven (7) employees: one (1) shift supervisor (SRO) , one (1) operating supervisor (RO or SRO) , two (2) control operators (RO), and three (3) unlicensed auxiliary operators (AO).

Up until the TMI-2 incident, PBNP had a total station regular plant organization (exclusive of security personnel) of about 120 employees, and used some 40 additional Company roving maintenance personnel during refueling outages (annual per unit) and also several contractor organizations of up to about 125 personnel for specialty aspects of refuelings. In considering PBNP staffing requirements, it is important to recognize that the Point Beach design incorporates features intended to promote efficient and effective use of personnel.

In the determination of final staffing requirements, recognition should be given to plant design differences; thus, "across-the-board" numbers may be neither necessary nor lesirable.

In this regard, we wish to call to your attention a statemunc on page I-28 of NUREG/CR-1656, " Utility Management and Technical Resources": . . . in over 500 reactor-years of experience, few if any serious incidents have resulted from an inadequate number of operators. The serious incidents that have occurred . . .

developed more from a lack of qualifications . . . than simple

" Therefore, while this letter shows eight persons numbers . . . .

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I Mr. D. G. Eisenhut November 3, 1980 per shift for planning purposes in accordance with your direction, we do not consider that such staffing is necessary for PBNP and intend to pursue this matter further with you for the purpose of maintaining the present successful staffing arrangement.

Although operated for ten years with a total plant complement less than other two-unit plants, PBNP has maintained a superior record in safety, competenca, and performance. We believe that performance is in large part due to selection techniquee, used by the Company for new hires. These selection techniques evaluate appropriate qualifications in mechanical comprehension, intelligence, logical reasoning, and personality. We believe strongly in the advantages of a carefully selected, closely coupled organization. NUREG/CR-1280 endorses and recommends selection processes similar to those used at PBNP. NUREG/CR-1280 criticizes the commercial nuclear industry for not applying Navy-type selection procedures (equivalent to that used at PBNP) for evaluation of personnel. PBNP intends to adhere to these selection processes, although this restricts the number oE qualified job applicants available.

After the TMI-2 accident, PBN?, along with all other nuclear utility organizations, was confronted with the need to respond to the post-TMI requirements involving hundreds of man-years of unanticipated work. All nuclear utility organizations have been confronted with the same need to the extent that they did not alre; have in place personnel over and above that considered to be optimum for their pre-TMI requirements. The NRC post-TMI requirements have caused a need for an estimated 2000 nuclear qualified engineers for our industry and related organizations as NSAC, INPO, EPRI, contractors, and consulting companies. Simul-taneously, the NRC has employed many additional inspectors and other regulatory personnel. This increased need for qualified people and more rigorous qualifications has created extreme difficulties in the industry in trying to meet staffing needs. Among the problems in plant staffing and shift staffing, while trying to maintain personnel quality, integrated relations, and motivation, are:

1. Loss of personnel by terminations, including people leaving the nuclear industry because of what they perceived to be inappropriate or burdensome regulatory impositions.

2. Reluctance or refusal to accept shift work, particularly in those occupations where licensing or professional requirements apply.

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Mr. D.1G. Eisenhut November 3, 1980

3. New requirements which significantly increase the number of people required to be on shift, such as those contained in Table B-1 (Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies). Depending upon how this table is resolved (and we again call to your attention the comment in NUREG/

CR-1656), there may be an additional shortfall

.of.an estimated 2000 qualified people. Besides the overall industry impact, there are additional

, problems created by requirements to acquire, train, and assimilate significant numbers of people into r an operating plant organization within a short period of time.

Wisconsin Electric has attempted to anticipate the NRC position in regard to the staffing situation and' has taken action as follows:

1. Following April 1, 1979, the authorized PBNP Training Group was increased by three full-time personnel, plus an additional two part-time people.

2. Since April 1, 1979, the PBNP Table of Organization for on-site personnel has been increased from about 120 employees to 158 employees.

3. Our headquarters Employment Division has increased its efforts to acquire additional staff by a factor of about six.

The purpose of this description is to demonstrate to you that the people acquisition situation within the nuclear industry has significant difficulties. In addition to shortfalls of people, there are the difficult schedules of new employee training and new criteria for personnel qualifications. In our opinion,.these problems have an adverse impact on nuclear power plant operator motivation and dedication.

In response tc your July 31 letter, our personnel have studied our ability to hire, train, qualify, and license '

operating personnel utilizing the following considerations:

l. The " Interim Required Shift Staffing" table (t'o w units, one control room) complement is used as follows:

1 Shift Supervisor (SRO) 1 Operating Supervisor (SRO) 3 Control Operators '(RO) 3 Auxiliary Operators (AO)

Mr. D. G. Eisenhut November 3, 1980

2. Training requirements for an unlicensed person to qualify for RO licensing are now about 1200 classroom hours and about 80 simulator hours, compared to previous requirements of about 300 classroom hours without simulator hours for an experienced, qualified auxiliary operator.

3. Retraining requirements for licensed persons are now about 150 classroom hours per person yearly and 40

simulator hours, compared to previous experiences of about 50 classroom hours, on the average, per person yearly, and simulator transient training for 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> once every two years.

4. Passing grades have been raised by the NRC to 80%

overall with no one area below 70%.

Please note that shift technical advisor staffing issues are not part of this evaluation.

Items 2, 3, and 4 above, together with new NRC requirements on licensed operator hours of work per day and per week, will require a change from five rotating shifts to six rotating shifts of operations personnel at the PBNP. Item 1 above will require that PBNP increase shift staffing by one person (per shift) holding an RO license and make additional arrangements to assure the availability of an SRO-licensed person for the Operating Supervisor position. Again, while our plans are based on this requirement as you have directed, we do not agree that it is necessary for proper and safe operation of PBNP. The total impact on shift staffing is the addition, training, and qualifying of about six more SRO employees and ten more RO employees than at present. These additional 16 senior staff only meet minimum requirements without spares to deal with potential personnel loss situations. Aggravating the problem is a new NRC requirement which appears to stipulate that an applicant for an SRO license must have held an RO license for one year under some incompletely defined work status condition. Additionally, the requirement for

" extra man on shift" for senior reactor operators in training lacks needed flexibility (see Wisconsin Electric August 7, 1980 letter to H. R. Denton regarding qualification of reactor operators).

Further, NRC license requirements for training instructors causes serious competition with SRO shift staffing.

It is assumed that in hiring and qualifying the new operating shift personnel to achieve a shift complement of eight, as discussed above, that Table B-1 (Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies) will not

l Mr. D. G. Eisenhut November 3, 1980 be imposed during the period of the shift staffing buildup.

Such a traneition can obviously not be accomplished immediately.

Further, it is assumed that other industry activities in the training area will not substantially divert Training Group instructors away from plant training activity. The industry's ability to increase staff also assumes that a supply of applicants from military nuclear operations will continue to be available and that we will be successful in hiring an adequate number of these applicants. The NRC schedule of meeting the new shift staffing requirements by July 1, 1982 would be impossible if new hires are nuclear-inexperienced people. It should be noted that there is a substantial need for increased physical facilities and space for training caused by these new requirements. Space for training activities will have to be increased by the construc-tion of new quarters, and generic simulator training facilities on a rental basis must be obtained.

In summary, to meet new NRC interim requirements PBNP must make substantial increases in shift operating personnel and licensed personnel in a market severely restricted by lack of qualified people and by competitive regulatory requirements, making the qualifying and licensing of shift personnel difficult and lengthy.

We believe that the Point Beach operations staff as presently constituted are entirely appropriate for safe, competent, and reliable operation and does not require any change.

Attached is a development program table showing the PBNP schedule for acquiring, placing in training, and qualifying the required additional shift personnel, using the NRC date of July 1, 1982 for achieving conformance to the " Interim Criteria for Shift Staffing".

Please fc.el free to contact me or Mr. G. A. Reed, Manager -

Nuclear Operations, if you have any questions in this regard.

Your review and reconsideration of the staffing needs for Point Beach is solicited.

Very truly yours,

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C. W. Fay,. Director Nuclear Power Department Attachment Copy to NRC Resident Inspector

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f POINT DEACil NUCLEAR "LANT i-DEVt.LOPMENT SCIIEDULI! TO MEET NEM t OPERATIONS GROUP SilIFT STAFFING REQUIREMENTS g i

(Per NRC Letter of July 31, 1980)  ;

i E E $ 5 $ $ $ $ $ S S A h h > > 2 A A k > >

i f I I I I t i i i I 5 shifts j 4 6 shifts M 4 New 4 New 4 New 3 New 2 New 4 New AO's AO's (O's AO's (O's 40's 15 AO r V I Y Y I 19 AO j

'I 15 5 15.ap ] 15 .ap ]l6 - ap 19 9 ] 219 New 9

4 New 4 New 4 New 3 New j 0 CO 3 COT t 4 7 .) 9-P 12 ap 79 39 Success / Failure 1 CO Lic. 2 CO Lic. 5 CO Lic. 6 CO Lic.

j Rates (1/l) ,_ (2/3) (1/3 + 4/5) (1/5 + 5/6) f' 10 rot M T + t 20 RO ,.

1 CO to Training 10 9 12 ap 2 OT 10+ 15 4 7 14 5 1 SROT 20$ I

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, Group a 3 SROTm if T 0 SROT 14 ]1 Oy 2y ]1 SRO1+Lic. 2y Op

}2 SRO Lic.

2 SRO Lic. SRO Lic.

1 (2/3) (1/1) J,(1/2) 1/1 + 1/1)

2 SROm y '

f y h 7 SRO (Op . SLp . ) (Op.SupJ 4Q 5$ 5Q 73 1 New Sh ft Sup. ,

7 SRO irf 8 SRO (Shift Sup.1 7 LUnitt SupJ 8 ap t

i Note: SIIIFT COMPLEMENT i AO indicates Auxiliary Operator Target for July 1, 1982: 1 Shift Operator COT indicates Control Operator Trainee 6 shifts, 8 per shift 1 Operating Supervisor CO indicates Licensed Reactor Operator = 48 Rotating personnel. 2 Control Operators SRO indicates Senior Reactor Operator plus 9 others for relief, 1 License Auxiliary Operator f SROT indicates Senior Reactor Operator Trainee vacation, testing, etc. 3 Auxiliary Operator l

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