ML20009B636

Suppls 810622 Ltr Re Commonwealth of PA 810515 Proposed Findings of Fact & Conclusions of Law on Mgt Issues & 810629 Reply Findings.Outlines Commitments to Shift Manning Requirements Per NUREG-0737

ML20009B636
Person / Time
Site:	Three Mile Island
Issue date:	07/07/1981
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Adler R PENNSYLVANIA, COMMONWEALTH OF
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8107160498
Download: ML20009B636 (4)

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aCMARD E. E AM LE R GALEN SA N DRA E. FOLSOM RosERT 8. ROSSINS W ARCIA R. NIRENSTEIN STEVEN M. LUCAS JuD:TM A. SANDLER July 7, 1981 D%

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Robert Adler, Esq. Cbq gg@ A Q Assistant Attorney General M:/ k, ecrefey 505 Executive House 8%e Post Office Box 2357 4 6 Harrisburg, Pennsylvania 17120 'N Re: Met. Ed. (TMI-1)

NRC Restart Proceeding NRC Docket No. 50-289

Dear Mr. Adler:

This letter is further to my letter to you June 22, 1981, and will confirm the substance and outcome of continued discussions between Licen'see' and the Commonwealth regarding concerns raised and positions taken by the Commonwealth in its Proposed Findings of Fact and Conclusions of Law on Management Issues, dated May 15, 1981, and in Commonwealth of Pennsylvania's Reply Findings of Fact and Conclusions of Law on Management Issues, dated June 29, 1981. These continued discussions have focused on the subjects of shift staffing and operational personnel which remained open items between the Commonwealth and Licensee at the time of my June 22, 1981 letter (Licensee Ex. 57, at 2).

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SHAW, PITTMAN, POTTS & TROWBRIDGE Robert Adler, Esq.

j July 7, 1981 Page Two

. Based on these further discussions, and the specific License? commitments enumerated below, Licensee understands ,

that the Commonwealth's concerns reflected in paragraphs 118

! through 153 of their May 15 proposed findings and in para-graphs 4 through 10 of their June 29 reply findings have been alleviated and that the Carmonwealth will withdraw these findings upon Licensee's making the commitments a matter of record in the subject proceeding:

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1. Acknowledging that it is making commitments beyond current NRC criteria or guidance, but in view of specific Commonwealth concerns, Licensee makes the following shift

, manning commitments which shall obtain until NRC imposes on Licensee the requirement to man operating shifts at TMI-l with 2 SROs (presently anticipated to be July,' 1982 in accordance with NUREG-0737) :

a. Licensee will at the time of restart of TMI-1, man all shifts at TMI-l with a minimum of one NRC-licensed SRO, who will act as Shift Supervisor or as Shift Foreman, a second individual, either NRC-licensed as an SRO or NRC-licensed as an RO and trained as an SRO, who will act as Shift Supervisor or as Shift ,

Foreman, and a minimum of two NRC-licensed ROs who will 1 act as Control Room Operators.

b. It is anticipated that plant operating shift personnel will be scheduled on a six-shift rotation, so long as there is a sufficient number of qualified individuals who.normally stand shift watches to man

- - six shif ts, each of which meets a. above (6 SROs and 18 ROs, recognizing that SROs may act as either SROs or ROs).

c. In the event.there is an insufficient number of qualified personnel who normally stand shift watches available to meet b. above, Licensee anticipates scheduling its normally on-shift plant operating personnel on a five-shift schedule, each of which meets

a. above.

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July 7, 1981 Page Three

d. In the event there is an insufficient number of qualified operators who normally stand shift watches availe.ble to meet c. above, Licensee anti-cipates employing on shift qualified and licensed individuals from its organizations who do not nor-mally stand shift watches, in addition to those operators who do normally stand shift watches, to meet c. above.

e. In the event there is an insufficient number of qualified operators in Licensee's organization to meet d. above for any period longer than 10 consecutive days, Licensee would inform the Commonwealth and the NRC and seek from the NRC their concurrence to man TMI-l shifts and operate TMI-1 for a limited period of time with availabic qualified and licensed personnel, speci-fically bearing in mind the then-current and applicable NRC criteria or guidance on overtime policies.

. f. At all times when TMI-l is operating at power levels above 201 rated power and there is only one licensed SRO on shift, the SPO-licensed individual

- on shift shall remain within the control room (including the shift supervisor's office) or within the plant at a location from which the control room is accessible in less than five minutes. Further, at all times when TMI-1 is operating at power levels above 20% rated power and the SRO-licensed individual on shift is not in the control room (including the shif t supervisor's office) ,

Licensee shall ensure that the control room (including the shift supervisor's office) is manned by a minimum of 2 ROs, acting as Control Room Operators, a third individual with an RO license and SRO-trained, and by the on-shift STA.

2. Acknowledging that it is making commitments beyond current NRC criteria or guidance, but in view of specific Commonwealth concerns, Licensee makes the following organizational manning commitment for TMI-1:

a. Licensee further commits to employ all reasonable efforts to maintain at all times sufficient numbers of 1

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SHAW, PITTM'AN, POTTS & TROWDRIDGE Robert Adler, Esq.

July 7, 1981 P&ge Four individuals in training to become licensed operators in order to account for possible future attrition of licensed operators. To this end, Licensee shall employ all reasonable efforts to maintain in training at all times that number of trainees which, when combined with the actual numbers of NRC-licensed SRO's and ROs in Licensee's organization, will total at least 30.

Licensee further understands that the Commonwealth is prepared to leave to the NRC the future evaluation and enforcement, as necessary, of Licensee's implementation of commitments contained in paragraphs 1 and 2 above, so long as Licensee does not object to the imposition of any or all of these commitments as license conditions for the restart of TMI-1. In recognition of the Commonwealth's position, Licensee will not object to the commitments identified in paragraphs 1 and 2 above in the event any or all of them are imposed as license conditions for the restart of TMI-1.

Sincerely, SHAW, PITTMAN, POTTS & TROWBRIDGE By: d. [d, 8, Ernest L. Blake,'Jr.

Counsel for Licensee

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TMI-l Restart Service List i

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