ML20002A259

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Submits Plans,Schedules & Commitments for Meeting Interim Criteria for Shift Staffing in Response to NRC . Recent NRC Requirements Hinder Util Ability to Conform to Mandated Changes in Staffiing Levels
ML20002A259
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 10/31/1980
From: Trimble D
ARKANSAS POWER & LIGHT CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
100-01, 100-1, NUDOCS 8011050463
Download: ML20002A259 (2)


Text

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ARKANSAS POWER & LIGHT COMPANY PCST CFACE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4000 October 31, 1980 100-01 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Com.

Washington, D.C.

20555

SUBJECT:

Arkansas Nu: lear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Interim Criteria for Shift Staffing (File: 1510.3, 2-1510.3)

Gentlemen:

In respons to your July 31, 1980 letter to all licensees concerning

" Interim C 'teria for Shift Staffing", Arkansas Power & Light Company has examinca the current staffing practices and capabilities in light of the intirim criteria for shift staffing provided and herein provides the follow'ng plans, schedules, and commitments to meet these staffing cri teria.

Current AP&L administrative requirements and staffing levels satisfy the adjunct requirements of items (a), (d), (f), and (g). Action was initiated in June,1980, to achieve a staffing level and organization which would meet the remaining requirements, items (b), (c), and (e).

AP&L is aggressively recruiting personnel to achieve a staffing level to support the interim criteria operating organization. Training and recruiting is scheduled to achieve the required shift staffing level by the stated July 1,1982 date.

Several recent NRC requirements have a substantial impact on utilities' ability to respond quickly to mar. dated changes in staffing levels. These are basically condensed as follows:

(1) Pre-examination requirements for operator license candidates 0(

have been stiffened and lengthened. This extends the time 0

for licensing an operator.

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n (2) Operator requalification requirements have been upgraded.

This requires considerably more time dedicated to retraining.

MEMBEA M! COLE SCUTH U':UTIES SYSTEM 8 01105 0'/b5

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Mr. narrell G. Eisenhut October 31, 1980 (3) Limitations on overtime have been imposed, which, when coupled with above requirements, force utilities to opt for a six-shift rotaticn schedule to ellow adequate con-trol over overtime for vacations and for licensing and requalification training.

(4) Interi

.nift staffing criteria require substantial increases in shift staffing levels above the levels indirectly required to control overtime and supply upgraded requalification training.

In order to adequately treat all staffing-related requirements, an increase in overall shift staffing level is required; from approximately 50 (both units) to a minimum of 96 shift workers, and from 30 licensed shift operators to a minimum of 48 licensed shift operators, or a 60% increase in the licensed onshift operating staff.

To achieve our schedule, a total of fourteen NRC license exams must be administered from now through July, 1982.

It also requires four license training programs to run simultaneously from August,1980 through June, 1982, to administer required training and examination to our current seven groups of license candidates per unit.

Provided NRC Operator Licensing Branch can support our efforts, and a 75% success rate for Reactor Operator licensing and a 66% success rate for Senior Reactor Operators licensing are achieved, all staffing and administrative requirements can be met by the July,1982 date.

Your letter also addressed the overtime work for senior reactor operators, reactor operators, and shift technical advisors. As noted in the letter, Reid to Cavanaugh, dated March 10, 1980, AP&L utilizes site engineering staff personnel (i.e., degreed engineers) to be the Shift Technical Advisors (STA). The STA serves a 24-hour duty day on a rotating basis and is onsite at all times during this duty day. Sleeping quarters are available onsite and the STA is available to the control room within ten minutes of being called. The 24-hour duty day may appear to be in conflict with the recomended overtime restrictions. However, it must be realized that during a duty day, the STA does not work the entire twenty-four hour duty day.

In fact, it is highly unlikely that the STA would work more than twelve hours straight or more than twent -four hours f

in a forty-eight hour period. The present AP&L method of STA duty days in in agreement with the recomended overtime restrictions. Therefore, AP&L will continue to provide STA coverage in this manner.

Very truly yours, O&Df David C. Trimble, Manager, Licensing DCT:DVH:1p