ML20004F652
| ML20004F652 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/08/1981 |
| From: | Kay J YANKEE ATOMIC ELECTRIC CO. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| FRY-81-89, NUDOCS 8106190334 | |
| Download: ML20004F652 (2) | |
Text
n YAMKEE ATOMIC ELECTRIC CEPANY e--
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1671 Worcester Road, framingham, Massachusetts 01701
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FYR 81-89 June 8, 1981
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@!fP 6 'g s/4 United States Nuclear Regulatory Commission 4
dU,y A Washington, D. C.
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l' Attention:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 4
Division af Licensing s c,A p
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) YAEC Letter to USNRC dated March 19, 1981, FYR 81-43 (c) YAEC Letter to USNitC dated April 10, 1981, FYR 81-59 (d) YAEC Letter to USNRC. dated October 27, 1980, WYR 80-116
Subject:
Fire Brigade Leader
Dear Sir:
In reference (b) above, Yankee Atomic Electric Company committed to the removal of the Shif t Supervisor f rom the role of fire brigade leader. This commitment was to bring Yankee Rowe into compliance with Section III H of Appendix R to 10CFR 50, dealing with fire protection. We informed you that the Shift Technical Advisor (STA) had assumed the responsibility of fire brigade leader in place of the Shif t Supervisor, as we f elt that he was the next most qualified person on shif t not immediately needed in the control room during a fire. The Shif t Technical Advisors have received fire brigade training and we re immediately available for duty.
In recent telephone conversations with the staf f, we have been informed that although our plan to use the Shif t Technical Advisor as fire brigade leader is consistent with Appendix R requirements, other staff acting under diff erent guidelines do not believe our use of the STA is acceptable. We do not agree with the staff's position, and feel that the Shift Technical Advisor is the best person to assume the position of fire brigade leader. Our position is based upon the f ollowing:
The STA is the most qualified individual on shif t not immediately needed in the control room during a fire.
The STA is hired based on his ability to make judgements and could reasonably be expected to adjust the response to the fire according to the level of hazard.
The STA would have an understanding of the potential impact of the fire as well as his corrective actions on plant.
8100100334 l?
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United Stct:0 Nuclear Regultt0ry Commic31:n Juna 8, 1981
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Attention:
Mr. Dennis M. Crutchfield, Chief Page 2 i
The time frames associated with a fire scenario allow initial reaction to the' fire by the STA._ If necessary, supplemental personnel can be called in time b'efore unusual plant conditions require STA presence in the control room for Shif t Supervisor consultation.
This assignment would increase the credibili(E of the STA with other shif t _ members because he would now make a specific contribution to the group in terms they know and respect.
would increase the liklihood of reliance on the STA by the utt Supervisor in the event that an occasion requiring his consultation ever did arise.
At this time and after much discussion, it has become apparent that our observations influenced by years of experience are not acceptable to the staff and that our position is viable only as an interim.
It is therefore our intention to continue to use the Shift Technical Assistant as fire brigade leader through December 31, 1982. The interim period will enable us to hire and train personnel to the level necessary to function as fire brigade leaders. At the end of this interim period we will provide a f ull compliment of replacements in accordance with our shif t staff development program described in Referencas (c) and (d).
During this interim period, we will be assessing the effectiveness of the STA in his combined role as fire brigade leader and technical advisor. We will be specifically looking at how his credibility is enhanced as a result of the specific contribution he will be making as part of the shift team. We would be most happy to keep NRC staff apprised of our review to assist them in future regulatory actions in this area.
We trust that you will find this request acceptable and will approve it.
If you have any questions or comments, please contact us.
Very truly, ANKEE ATOM C ELECTRIC COMPAN'i
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J. A. Kay Senior Engineer - Licensing L~~l -
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