ML19340B813
| ML19340B813 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/29/1980 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| LAC-7197, NUDOCS 8011120340 | |
| Download: ML19340B813 (5) | |
Text
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.D DA/RYLAND COOPERAT/VE
- PO BOX 817
- 2615 EAST AV SOUTH. LA CROSSE. WISCONSIN 54601 (608) 788 4 000 October 29, 1980 In reply, please refer to LAC-7197 DOCKET NO. 50-409 7
' jj Director of Nuclear Reactor Regulation ATTN:
Mr. Darrell-G. Eisenhut, Director
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Division of Licensing
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SUBJECT:
DAIRYLAND POWER COOPERATIVE E
LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 SHIFT STAFFING
REFERENCES:
(1)
NRC Letter, Eisenhut to All Licensees, dated July 31, 1980.
(2)
LACBWR Technical Specifications Gentlemen:
Your letter (Reference 1 discussed interim criteria for shift manning covering shift supervisor,' senior reactor operator, reactor operator and auxiliary operator.
We were directed to examine our current staffing practices and capabilities in light of the interim criteria and advise you of the date by which our shift. staffing could be in compliance.
A summary of our current staffing practices, estimated capabilities, plans, and commitments with regard to your shift staffing require-ments is presented as follows.
NRC ADJUNCT REOUIREMENTS SHIFT SUPERVISOR a.
A shift supervisor with a senior reactor operator's license, uho is also a member of the station supervisory staff, shall be onsite at all times uhen at least one unit is loaded uith fue I.
DPC RESPONSE Reference 2, Section 3, Table 3.2-1,
" Minimum Shift Crew Composition,"
is consistent with this requirement as part of the minimum shift crew composition.
0011120 SH O 54 y
F' Director of Nuclear Reactor Regulation October 29, 1980 U.
S. Nuclear Regulatory Commission LAC-7197 LICENSED SENIOR REACTOR OPERATOR b.
A licensed conior reactor operator (SRO) shall, at all times, be in the control room from which a reactor is being operated.
The shift supervisor may from time-to-time act as relief operator for the licensed senior reactor operator assigned to the control
- room, DPC RESPONSE LACBWR does not currently assign a licensed senior reactor operator (SRO) to the control room.
This licensed responsibility is main-tained by the Shift Supervisor.
The Shift Supervisor may relieve a licensed operator for brief periods during a given shift.
.The Shift Supervisor is normally stationed in a glass-enclosed office which commands full visual and audible view of the control room and all activities therein.
At random times the Shift Supervisor may be away from the control room or his office, but within or near the plant.
Due to the small physical size of the plant, he can return to the control room in less than three(3) minutes from any normally accessible plant location.
LACBWR is an inherently safe plant of simple design.
The plant safeguards identified in the Safeguards Report insure that the reactor may be operated without undue hazard to the health and safety of the public.
They are as follows:
(1)
Inherent safety of BWR's.
(2)
High degree of stability.
(3)
Three independent means of shutting down the reactor.
Two of these methods are available outside the control room.
(4)- The reactor can be cooled by five independent systems.
In addition, a dedicated cooling system will be added prior to February 25, 1981.
(5)
In addition to normal plant control, primary system over-pressurization is prevented by (a) main steam bypass valve to main condenser (b) shutdown condenser - taking at least 10% full steam flow (c) primary system relief valves. release to containment up to 120% full steam flow (d) rod control and safety system - high pressure scram.
(6)
Partial scram on reactor safety system.
Redundancy in system circuitry.,
Director of Nuclear Reactor Regulation October 29, 1980 U.
S. Nuclear Regulatory Commission LAC-7197 (7)
Radiation detectors for gaseous and liquid effluents.
(8)
Containment integrity leakage limits of 0.1%/ day of contained volume.
l In addition, the relative simplicity of the design of the plant per-
~
.mits nearly all control functions for startup and continuous operation to be conducted from the control room.
The reactor can be shut down from within or outside the control room.
l All_LACBWR plant operators have previous formal nuclear training and experience prior to hire.
This is a prerequisite condition for em-ployment.
It is also a condition of employment that all operators attain an operator license as soon as practicable.
All current LACBWR plant operators, both licensed and unlicensed, are former Navy enlisted l
technicians.
At the present time, the total experience of the Opera-l tions Department in the nuclear power field is 327 man years.
This is equivalent to an average of 12 man years per man.
The total LACBWR licensed experience is 114 ran years, with an average of 4 licensed l
man years per man.-
Plant operators perform the duties of four distinct positions on s l
rotating basis.
These are I
l Reactor Operator (license required) l Turbine Operator Switchyard Operator-Auxiliary Operator The plant operator in training for a license functions as a reactor operator under the supervision of a licensed operator.
In fulfilling l
all four of these positions on a rotating basis, the plant operator l
becomes intimately familiar with all aspects of reactor and generator plant operation.
The Training and Relief Crew, which is normally on duty during the daytime and provides scheduled relief, is usually comprised of licensed senior operators.
This crew provides the cadre of trained and experienced personnel for promoticn to shift supervisor and in-sures that scheduled relief is accomplished with more experienced personnel.
Additionally, all plant operators are invc1ved in maintenance and refueling activities.
Past operating experience has shown that our shift staffing is adequate and it has demonstrated the capability to function safety through more than 200 scrams.
'Furthermore, LACBWR has incurred a lesser number of reportable occurrences than larger plants with much larger staffs, which attests to an above average compliance record.
Director of Nuclear Reactor Regulation October 29, 1980 U.
S.. Nuclear Regulatory Commission-LAC-7197 The Shift Technical Advisors are drawn from the management, supervisory and engineering on site staff.
These persons are senior level, know-ledgeable and experienced plant personnel who are normally responsible for the overall direction, maintenance, operation, engineering and modification of the plant.
They serve to assist the Shift Supervisor on a shift-by-shift basis while on duty as STA.
Finally, great credit can be taken for the presence of two full-time NRC resident inspectors who function to deter the development of unsafe plant conditions.
Because of all the reasons presented above, it is our opinion that the requirement for a licensed senior operator to be present at all times in the LACBWR control rocm is not necessary.
For any station uith more than one react >r containing fuel, the c.
number of licensed senior reactor operators onsite shall, at all times, be at least one more than the number of control rooms from Uhich the reactors are being operated.
DPC RESPONSE This item does not apply to LACBWR.
LICENSED REACTOR OPERATOR d.
In addition to the licensed senior reactor operators specified in a.,
b.,
and c.
above, for cach reactor containing fuel a licensed reactor operator (RO) chall be in the control room at all times.
DPC RESPONSE Reference 2, Section 3.2.2.b, requires a licensed reactor operator (RO) to be in the control room when fuel is in the reactor.
e.
In addition to the operators cpecified in a.,
b.,
c., and d.
above, for each control room from Uhich a reactor is being operated, an additional licensed' reactor operator (RO) shall be onsite at all times and available to serve as relief operator for that control room.
As noted above, this individual may serve as relief operator for each unit being operated from that control room, provided he holds a current license for each unit.
DPC RESPONSE The Shift Supervisor or another licensed operther normally on site is available for.short-term relief during a given shift.
Therefore, an additional licensed reactor operator is not needed to serve as relief operator for the control room, l
_.4-
2 Director of Nuclear Reactor Regulation Cctober 29, 1980 U.
S.
Nuclear Regulatory Commission LAC-7197 AUXILIARY OPERATOR f.
Auxiliary (non-licenced) operators chall be properly qualified to cupportlthe unit to uhich accigned.
DPC RESPONSE The qualifications of LACBWR plant operators were discussed in our response to requirement (b).
All unlicensed plant operators are i
given on-the-job training prior to being assigned auxiliary operator duties.
LICENSED SENIOR REACTOR OPERATOR g.
In addition to the staffing requiremento stated above, shift crev assignmento during periods of core alterationc shall include a licensed cenior reactor operator (SRO) to directly supervice the core alteratione.. This licenecd senior reactor operator may have fuel handling duties but chall not have other concurrent operational duties.
+*
DPC RESPONSE Reference-2, Section 3.2.2.e, requires that all core alterations be directly supervised by either a licensed Senior Reactor Operator or Senior 'Vactor Operator Limited to Fuel Handling who has no other concurrent' responsibilities during this operation.
AUXILIARY OPERATOR Your letter.also contains the requirement for two unlicensed auxiliary operators to be onsite during Operating Conditions 1-3.
As discussed in answer to requirement b, LACBWR's operators are all considered
" PLANT OPERATOPS" and perform the duties of reactor operator, turbine operator, and auxiliary operator interchangeably.
LACBWR's Technical l
Specifications require three plant operators,in addition to the Senior Reactor Operator, to be onsite at all times.
Therefore, this requirement will~be fulfilled by either licensed or unlicensed plant
' operators performing auxiliary operator duties.
If you have any questions, please contact us.
i Very truly yours, i
DAIRYLAND POWER COOPERATIVE M n) L.
Frank Linder, General Manager cc - J. Keppler,. Reg. Dir.,NRC-DRO III-
-NRC Resident' Inspectors-.
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