ML20040G399
| ML20040G399 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/03/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20040G398 | List: |
| References | |
| NUDOCS 8202120270 | |
| Download: ML20040G399 (6) | |
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- jo, UNITED STATES NUCLEAR REGULATORY COMMISSION o
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E WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
SUPPORTING AMENDMENT NO. 44 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 67 TO FACILITY OPERATING LICENSE N0. DPR-62 CAROLINA POWER AND LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-3?5 AND'50-324 Author:
L. P. Crocker s
8202120270 820203 PDR ADOCK 05000324
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SAFETY EVALUATION By letter dated January 8 1982, Carolina Power & Light Company (CP&L),
the licensee, requested revisions to the Technical Specifications for its Brunswick Steam Electric Plant, Units 1 and 2.
The requested revisions involve the appointment of Mr. Ronald C. Knobel to fill the position of Manager-Operations at the Brunswick Plant during an interim period in advance of his completion of the NRC examination process for a Senior Reactor Operator (SRO) license on the Brunswick nuclear units.
The circumstances surrounding this request, as stated in the CP&L letter, are that Mr. Knobel has been in training to take an SR0 license examination on the Brunswick nuclear units. By letter dated October 13,1981, the licensee requested that the examination for Mr. Knobel be scheduled during January 1982. However, the licensee has been advised that the NRC Operator Licensing Branch cannot schedule the requested examination before May 1982.
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The licensee asserts th'at appointment of Mr. Knobel as Manager-0perations will enhance the safe operation of the Brunswick facility because it would (1) provide coverage of the Manager-Operations position by a highly qualified individual and (2) would allow Mr. William Tucker, the Manager-Technical i
Support, to return to full time duties as Manager-Technical Support.
i Mr. Tucker has been filling the duties of Manager-Operations.
The licensee in effect, requests a waiver of the technical specification l
requirement that Mr. Knobel possess an SR0 license for the Brunswick units l
l before assuming duties as Manager-0perations.
The NRC requirement that a plant manager of operations have a valid SR0
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license on the unit he supervises comes from.DaraoraDhs 3.2.1 and 4.2.2 of
. ANSI Standard N18.1-1971, as endorsed by Revision 1 to Regulatory Guide 1.8.
The ANSI Standard has recently been superseded by ANS 3.1-1981, which will soon be endorsed by Revision 2 to Regulatory Guide 1.8.
Guidance pertaining to the requirement that a Senior Operator license be hAld -
by the plant operations manager is the same in these documents.
Based upon the definitions and descriptions of paragraph 3.2.1 of the ANSI Standard and the qualifications and training requirements set forth in paragraph 4.2.2 of the ANSI Standard, both endorsed by Regulatory Guide 1.8, the NRC requires that plant operations managers hold valid SR0 licenses on the units they supervise.
In the case of this request by the licensee, there are several factors which warrant consideration:
1.
Except for the lack of the SR0 license on the Brunswick units, Mr. Knobel is exceptionally well qualified. For example, where the ANSI Standard calls for a bachelor's degree in engineering or science, Mr. Knobel holds both a BS and MS degree in mechanical engineering and, in addition, is a registered professional engineer; while the Standard specifies a minimum of four years experience, three of which are nuclear experience, Mr. Knobel has 21 years of nuclear experience, much of it related to operation of boiling water reactors (BWRs) such as the Brunswick units; while the Standard specifies a minimum of two months experience with plant operation above 20% power, participation in a refueling outage and participation in plant startup testing or post-refueling startup testing, Mr. Knobel has served during the last 12-1/2 years
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. in successive positions as a BWR startup engineer, BWR training manager, BWR outage manager, technical supervisor of BWR projects, manager of BWR operations engine'ering, principal engineer on the General Electric Internal Three Mile Island Task Force, and principal engineer consultant to Carolina Power & Light Company on the Three Mile Island Review at the Brunswick plant. Mr. Knobel has held a license as an SRO on the Dresden nucidar plant. Mr.
Knobel has spent 16 months at the Brunswick plant as the General Electric representative supervising response to the Three Mile Island action items.
We conclude that the chance of erroneous instructions being issued by Mr. Knobel during the period before he receives his NRC license 1
on the Brunswick plant is insignificant. His educational and experience credentials, his previous experience at the Brunswick plant and the fact that he has trained to take the SRO examination at Brunswick lead us to conclude that he is sufficiently qualified to carry out the responsibility of Manager-Operations.
2.
The Brunswick Steam Electric plant is a two-unit station with a common control room shared by the two units. The minimum staffing by licensed operators required by the NRC for such a configuration is, per shift:
1 Shift Supervisor (SR0 license) 3 Reactor Operators (R0 license)
In July of 1982, this minimum staffing will increase by an additional SRO on each shift, to be stationed in the control room in accordance with the July 31, 1980 letter from D. G. Eisenhut to all licensees and
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- i holders of construction pennits, and confirmed by item I.A.1.3 of NUREG-0737.
In accordance with NRC staffing guidance, each of the Shift Supervisors would report normally 'through an operations super-visor (day shift only) to the operations manager.
In such a staffing arrangement, the Shift Supervisor could well be the senior person on site during back shift operation.
The staffing plan used by the licensee for the Brunswick plant involves a five shift operation. Each shift has a Shift Operations Supervisor (SR0 licensed), thus providing 24-hour coverage at the olant by a person with operations supervisor qualifications, as contrasted to the normal case where there is one operations supervisor providing day shift coverage only. Four of the five shifts also have two Shift Forem'en (SR0 licensed) assigned, while the fifth shift has a single Shift Foreman. All shifts also have either three Control Operators (R0 licensed) or two Control Operators and one Senior Control Operator (SR0 licensed) assigned.
In summary, three of the five shifts at Brunswick have three SR0s and three R0s assigned while two of the shifts have four SR0s and two R0s assigned.
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We conclude that the staffing at the Brunswick plant is considerably in excess of minimum NRC requirements and is such as t5 provide assurance that senior licensed personnel are readily available to I
supervise plant operations.
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. Thus, we conclude that the CP&L request for.a change to the Technical Specifications allowing Mr. Knobel to carry out the duties of Manager-Operations without an SR0 license until he completes the SR0 examination scheduled by the NRC should be granted. There is adequate assurance that such an exemption would not adversely impact plant safety or jeopardize the health and safety of the public.
ENVIRONMENTAL CONSIDERATION We have determined that the amendments do not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR SSI.5(d)(4) that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of the amendments.
CONCLUSION We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of the amendments will not be inimical to the connon defense and security or to the health and safety of the public.
Date: February 3, 1982' e
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