ML20040E174
| ML20040E174 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/22/1982 |
| From: | Belanger A, Bennett G, Crebs A PORTLAND GENERAL ELECTRIC CO. |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 TAC-46131, NUDOCS 8202030217 | |
| Download: ML20040E174 (2) | |
Text
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SIN January 22, 1982 e
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or of Division of Emergency Preparation 9
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's ington, D. C. 20055
Dear Mr. Grimes:
-According to NUREG 0654 Revision 1 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants), certain technical support groups will be required to implement on-shif t coverage as of July 1,1982.
Anong these are the Elec-trical Maintenance / Instrument and Control group. As representatives of this group at Portland General Electric's Trojan Nuclear Power Plant, we would like to request the NRC to re-examine the reason for having mechani-cal, electrical, and instrument and control maintenance capabilities on shift.
In the Instrument Shop at Trojan, for example, the technical experience in nuclear power ranges from 20 years to 3 years and at no time can any of us think of a situation where an I&C technician on shift could have pre-vented or even minimized the consequences of an accident or transient.
It is the general opinion of this I&C Shop as well as'that of I&C technicians elsewhere, that having an Instrument technician on a 30 minute or 60 min-ute call is an understandable requeat. However, on shift implies immed-iate action and as is.of ten the case, only the worst results are obtained when one tries to prevent the automatic operation of a plant, or questions the accuracy. and/or validity of their instrenentation. A 30 minute or 60 minute call or a page system similar to those already implemented at some utilities seems a more favorable alternative and much more economical.
We are sure you understand that one of the problems that faces all utili-
_ ties and certainly effects the NRC, is the retention of qualified personnel.
It.therefore is evident that unnecessary shift coverage imposed upon people is not going to aid in the retention of these individuals.
We would like to point out that at this plant the Senior Instrument and Control technician has averaged only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per month of overtime due to call outs for situations that the Shif t St.pervisor determined could not wait until the day shift. We would also like to emphasize that these were of a technical specification and not because of any form of emergency sit-untion where a technician could be of any help or assistance.
Our function here is to maintain, calibrate, and insure the proper opera-tion of the electronic controls and associated equipment. We have always been able to do this during the day shift, therefore, our presence has not been required off shift.
Our record of overtime is witness to this fact.
i We are well aware that it would be hard to implement a plant to plant pro-cedure for emergency preparedness, but at the same time feel a class action mandated by the NRC is not the proper approach. Those utilities whose track record requires extra people on shift will take the necessary steps to keep their units on line and producing power.
It would be an economic disaster to their companies if they didn't.
At-the same time, a 30 min-ute or 60 minute call out or pager response is understandable, feasible, 3
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Brian Grimes January 22, 1982 Page Two economical and less devestating to the personnel.
In closing we would like to point out that no one we have conferred with at a plant, utility or NRC level, has agreed with nor da they understand the need for maintenance coverage on shift as is mandated by the NRC.
We would like to invite you or a representative of your office to discuss this with us or our union representatives at any time.
We look forward to hearing from you soon.
Thank you for your time and consideration.
Respectfully, A. P. Belanger ['
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Trojan Instrument and Control Technicians Troj in Nuclear Power Plant P. O. Bov 439 Rainier OR 97048