ML20050A983
| ML20050A983 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/26/1982 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 LAC-8180, NUDOCS 8204020470 | |
| Download: ML20050A983 (4) | |
Text
-
D DA/RYLAND
[k COOPERAT/VE
- PO BOX 817
- 2615 EAST AV SOUTH
- LA CROSSE. WISCONSIN 54601 (608) 788 4 000 March 26,1982 In reply, please refer to LAC-8180 DOCKET NO. 50-409 Director of Nuclear Reactor Regulation ATTN:
Mr. Definis M. Crutchfield, Chief Operating Reactors Branch No. 5 A
p Director of Operating Reactors U. S. Nuclear Regulatory Comaission D
Washington, D. C.
20555 PEC5fMD
SUBJECT:
DAIRYLAND POWER COOPERATIVE F
APR 011982> ;g LA CROSSE BOILING WATER REACTOR (LACBWR)
' u np uurst eman PROVISIONAL OPERATING LICENSE NO. DPR-45
" Ef* "
O MINIMUM SHIFT MANNING - REQUEST FOR 1
/
EXCEPTION TO TABLE B-1 NUREG 0654 4j
/
REFERENCE:
(1) Letter, Keppler (NRC) to Linder (DPC),
dated February 5,1982 (2) Letter, Linder (DPC) to Keppler (NRC) LAC-7197 dated October 29, 1980 (3) Letter, Linder (DPC) to Eisenhut (NRC) LAC-7446 dated April 2,1981 (4) Letter, Linder (DPC) to Keppler (NRC) LAC-7981 dated December 17, 1981 Gentlemen:
A letter (Reference 1) issued by the Regional Administrator for the NRC, J.
Keppler, informed us that until a specific exemption to the guidance in Table B-1 of NOREG-0654 is requested and granted, his staff would be unable to conclude that minimum shif t proposed in our emergency plan (Reference 2) would be acceptable, j
The deficiency which was identified in a 1981 audit of emergency preparedness was revised to address minimum shif t staffing by Reference 1.
Deficiency 2 o
The nininun shift staffing pr:pmed in yatr meponse is umcceptable bemuse it dme n t meet the guidance Mcmmendad in NUREG-0654, Table B-1 i.e., y at do nct pecoide a SRO-Fcmran, a Rad /Chen Tech, non a C antnim tor. We understand that yat intend to monest an e enpticn frm the guidance in Table B-1.
Until t% e enptim is approved, yatr minimun shift staffing is umeceptable and in2decuate expensatory neanuma am in pla ce.
lo46 8204020470 820326 b8 0 PDR ADOCK 05000409 6 P
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Director of Nuclear Reactor Regulation March 26, 1982 ATTN:
Mr. Dennis M. Crutchfield, Chief LAC-8180 The exemption to these requirements has been identified previously and will be fonaally recompiled in this letter.
The minimum on-shift staf fing level identified in NUREG-0654 is ten persons consisting of:
1 Shif t Supervisor (SRO) 1 Shif t Foreman (SRO) 2 Control Room Operators 2 Auxiliary Operators 1 Shift Technical Advisor 1 Health Physics Technician 1 Rad / Chem Technician 1 Communicator The position of Shift Technical Advisor was instituted prior to January 1, 1980 and is incorporated in the staffing level specified by current plant technical speci fication.
The operating crew complement was originally addressed in Reference 2.
The proposal in Table 1 includes a complement of six individuals:
2 Senior Reactor Operators 2 Reactor Operators 2 Auxiliary Operators Current Technical Specifications requires 4 individuals:
1 Licensed Senior Reactor Operator 1 Licensed Operator 2 Additional Operations Personnel LACBWR is a small (165 Mwt) boiling water reactor, its simplicity (controls are less complex than those of a large nuclear plant) and its past operating experience indicates a comparable degree of safety to a larger facility with a smaller operating crew staf f.
LACBWR personnel are all cross-trained in the four watch stations (reactor operator, turbine operator, switchyard operator, and auxiliary operator).
Therefore, a high degree of interchangeable shift results.
This cross qualification also results in a greater depth of knowledge level of the entire facility.
This fact can be verified by the last licensing examination results (1981) in which 80% of the applications were granted.
This licensing examination was conducted under the more rigorous post Three Mile Island standards established by the NRC. Additionally, plant operators are involved in maintenance and refueling activities during outages.
DPC proposes to establish this minimum shif t complement for operations at five (S) individuals, one less than the complement established in Table B-1.
By July 1,1982 a minimum shif t operating crew will concist of one senior reactor operator, two licensed reactor operators and two additional operations personnel which may or may not be licensed.
WP-1
.?
Director of Nuclear Reactor Regulation March 26, 1982 Al iN : Mr. Dennis M. Crutchfield, Chief LAC-8180 I
By July 1,1983 a minimun shif t operating crew will consist of two senior reactor operators, one licensed reactor operator and two additional operations personnel which may or may not be licensed.
t In both cases a senior licensed person will be the shift supervisor. The required time to implement the second senior reactor operator would prevent the excessive use of overtime among existing personnel.
The senior person licensed as a reactor operator would in the event of an emergency which,
(
incapacitated the shift supervisor or required his absence from the control roon, function to:
Observe and coordinate the activities of the operators Reccgnize plant conditions requiring energency operating procedures i
Establish priorities Determine additional equipment and/or support required Determine steps or procedures required to recover from an emergency DPC considers this to be an appropriate compensating action during the interim peri od.
Tne non-operating crew complement listed in Table B-1 consists of a health physics technician, a radiation / chemistry technician and a connunicator.
The current LACBWR staffing provides for one health and safety technician in addition to the operating crew and shift technical advisor.-
DPC will by July 1,1982 train arid assign a member of the security force to function as conmunicator in the event the emergency plan ~is activated.
Then personnel are available on a 24-hour per day basis.
This will serve to assist the operations personnel in this function.
The existing on-shif t health and safety technician is qualified to perform both the radiation protection function and the radiation chemistry function.
No distinction exists at LACBWR in these roles, a boiling water reactor does not have the analytical chemistry requirenents of a pressurized water reactor.
l The assignment of a smaller cmargency planning zone and the simplified chemical analysis tasks required in the initial phase of an activation of the l
emergency plan lend themselves to fewer total personnel for these positions.
DPC proposes to continue its existing staffing of one health and safety technician onsite during operations.
We will also train operations personnel i
by July 1,1982 to provide backup in the radiation protection areas.
WP-1.
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p Director of Nuclear Reactor Regulation Marcn 26, 1982 ATIN:
Mr. Dennis M. Crutchfield, Chief LAC-8180 This training will include:
demonstration of the use of portable monitoring equipment, classroon instruction in the principles of radiation detection and portable instruments and the techniques of sample collections.
NUREG-0654 Section I, Paragraphs 7-10, Table B-1, designates the radiation / chemistry technician as responsible for:
(1)
Inplant sample collection and analysis (2) inplant monitoring (3) Out-of-plant monitoring (4) Decontamination (5) First-aid / rescue The training program for operations personnel will prepare them (with a minimum of instruction) to assist in sample collections (1), inplant monitoring (2), and out-of-plant monitoring (3). Operations personnel are ce rently provided the op7ortunity for first-aid training (5). Therefore, they are able to assist the health and safety personnel in this function.
It is our conclusion that this eight (8) man minimum shift staffing provides the degree of public protection which is the intent of NUREG-0654 which does r.at reflect the dif ferences in plant size or complexity. Our previous communications (References 2-4) are consistent with this formal request for an exemption.
If there are any questions on this letter, please contact us.
Very truly yours, DAIRYLAND POWER COOPERATIVE
/,f/Q4444Itl 66
/ Frank Linder, General Manager FL:JUP:eme cc:
J. G. Keppler, Regional Director, NRC-DRO III Resident Inspector WP-1