ML20005A356
| ML20005A356 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/25/1981 |
| From: | Randazza J Maine Yankee |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 FMY-81-96, NUDOCS 8106300243 | |
| Download: ML20005A356 (4) | |
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2.C.2.1 MAIRE *5HARHEE niom/C P0n'ER COMPARS
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[f{ M (207) 623-3521 O
J;ne 25, 1981 FMY 81-96 f
United States Nuclear Regulatory Commission
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8 Washington, D. C.
20555 8/
Attention: Office of Maclear Reactor Regulation d
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Reference:
(a) License No. OPR-36 (Docket No. 50-309) 47M '
(b) USNRC Letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits dated July 31, 1980 (c) USNRC Letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits dated October 31, 1980 (NUREG 0737)
(d) Maine Yankee Letter to the USNRC dated October 21, 1980 (WHY-80-142)
Subject:
Interim Criteria for Shift Staffing
Dear Sir:
Reference (b), endorsed by Reference (c), requires Maine Yankee to increase its licensed shift staffing levels so as to provide two (2) licensed Reactor Operators (RO) and two (2) licensed Senior Reactor Operators (SRO) on each shift. Reference (d) described the program whereby Maine Yankee intended to meet the criteria. Although it is not effective until July 1,1982, the purpose of this letter is to provide early notification of possible difficulties in meeting that date, anc to express our view that an increase in shift licensed operator staffing levels is unnecessary and undesirable.
Difficulties:
We have exerted a major effort to increase the number of licensed operators in recent years. We have increased our personnel recruiting efforts and authorized staffing levels, and expanded our training department and l
facilities. Our efforts are analogous to rowing ever harder against an ever quickening counter current. While some progress is being made we are being frustrated by many factors:
1.
The entire nuclear industry is short of personnel so the rate of attrition continues des;:ite efforts to hold employees.
(The NRC's major advertisement campaign for personnel bears evidence that you are aware and affected by this problem.)
8106300AD i
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f MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission Page Two Attn: Office of tbclear Reactor Regulation June 25, 1981 2.
The available quantity and qualifications of new candidates has decreased over the years because' of the national shortage of technically competent individuals.
Given a choice, most individuals would not opt for shift work.
The attractiveness of nuclear power as a career path has been nearly obliterated by political opposition, media sensationalism, greater regulatory demands upon the individuals involved, and stifled career path growth opportunities.
3.
The increased qualification and training requirements for operator license candidates has doubled the time necessary to train a class of candidates and increased the possible failure rate.
Commission license examiners are overburdened therefore unwilling to travel to the plant site to examine small numoers of candidates and often must set dates for qualification examinations that are not timely to the completion of a training program.
4.
The ever increasing burden of retraining requires licensed operators to spend more time off shift in the classroom and at the simulator.
This means that more licenses must be obtained to provide the same shift coverage. The increased regulatory burden on licensed operators, political opposition and stifled career opportunities serves to increase the exodus of licensed operators to other positions or other industries.
5.
Recently imposed requirements relative to the experience that must be obtained before a license can be upgraded have greatly increased the time necessary to upgrade an individual license.
6.
The increase in the requirements for licensed operator retraining, candidate training and STA training must be met with an increase in the training staff who, in turn, must also be licensed, adding to the number of personnel that must be acquired, and the training / retraining workload.
We are not stating with certainty that we will not be able to meet the July 1,1982 criteria. We have just completed the tRC examination stage of an R0 and SRO license training program, and will immediately commence another program to be completed in May of 1982.
However, if the number of licenses obtained from these progros is not sufficient, then it will be another six months to a year before additional training programs can be completed. All of this, of course, will be further complicated by any additional losses which may be experienced from the existing staff or other problems that may occur in this time frame.
Necessity and Desirability:
As stated in the opening paragraph, Maine Yankee also takes this opportunity to express strong reservations as to the necessitu and desirability of the proposed staffing level requirements.
The current Maine Yankee Technical Specifications requires the maintenance of at least three licenses per shift, one SRO and two RO.
It is our current practice to attempt to maintain two SRO and one R0 license per shift.
The seco.d SRO license holder functions, under the direction of the Plant Shift
MAINE YANKEE ATOMIC POWER COMPANY l
United States Nuclear Regulatory Commission Page Three Attn: Office of tbclear Reactor Regulation June 25, 1981 Superintendent, as a Shift Operating Supervisor.
This provides the license holder with experience as a supervisor while permitting the Plant Shift Superintendent the flexibility to leave the Control Room. Occasionally, the Shift Operating Superviser position is held by a senior R0 license holder who has been determined by plant manager to be qualified in terms of experience, knowledge and demonstrated supervisory capabilities, and who is in the process of upgrading his license from RO to SRO. We feel that this approach meets the intent of our policy relative to two SRO licenses per shift, while still providing some degree of flexibility relative to personnel replacement, timing of promotions, etc.
Maine Yankee has operated the Maine Yankee plant successfully for almost nine years with the above described staffing.
We consider the requirement to maintain an additional licensed RO on shift as unnecessary, nonproductive and without justification with regard to any measurable safety gain.
In the past nine years at Maine Yankee, and the prior twelve years at Yankee Rowe, no situation has ever been encountered, either steady state or transient, during which an additional licensed RO would have served any useful purpose.
Furthermore, while there was criticism regarding shift operator training and qualifications as a result of THI, this aspect has been addressed directly and in the requirement for an STA. We have seen nothing in any of the reports that in61 cates that an additional licensed operator would have made any difference whatsoever.
A requirement to maintain an additional license on each shift is especially burdensome in view of the need for large Fire Brigades, Shift Technical Advisors and others on each shift.
The need to maintain additional licensed personnel on each shift would require that additional supervisory personnel also be licensed so that plant operation could continue in the event of a strike by licensed bargaining unit personnel. Otherwise, a strike caused forced plant outage would impose severe economic penalties on our ratepayers and could jeopardize the region's power supply.
The need for additional supervisory licensed personnel exacerbates the problem.
Given the constraints previously enumerated, regairements for additional licenses on shift must be met by the existing licensed staff.
This increases the necessity for overtime work which further decreases the attractiveness of these cositions, and wnich we all seek to limit because of its postible detrimental effect on performance.
We concur that operators should be well trained in system interactions and upset conditions and that they should be thoroughly drilled in casualty procedures. Our resources should be directed toward better trained personnel, not more personnel, on each shift.
Our objections regarding the necessity justification or desirability of the shift staffing criteria, notwithstanding, Maine Yankee is reluctantly willing to adopt Refe';ence (b) as an " objective criteria".
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MAINE YANKEE ATOMIC POWER COMPANY tk11ted States W clear Regulatory Commission Page Four Attn: Office of Nclear Reactor Regulation June 25, 1981 We are pleased that the Commission has recently instituted rulemaking proceedings relative to all the TMI Action Plan items. We hope that as a result of these hearings counterproductive requirements are softened or eliminated.
If as a result of these proceedings the criteria in Reference (b) do become requirements; we shall, of course, comply.
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Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY Lpw John B. Randazza Vice President, Manager of Operations cc: Stephen H. Hanauer e
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