ML20059F897
| ML20059F897 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/16/1991 |
| From: | CENTERIOR ENERGY |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| TAC-81850, NUDOCS 9401140212 | |
| Download: ML20059F897 (3) | |
Text
""
i p
~US C mv.n2) m j
GNTE
}C / $/N5'0 i
DenmW 0. Shuhen M IMesi Asunut Vhe PresidsMsener Telub OH OWelM Ds44 sus MHHW Docket Number 50-346 License Number NFF-3 Serial Number 1960 October 16, 1991 T 6 C. S IS TD Dr. Thomas E. Murley Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Vashington, D. C.
20555 Subj ec t :
Exemption Request to Defer Operator Requalification Vritten Examination and Operating Test from November 1991 to December 1991
\\
Dear Dr. Murley:
The purpose of this letter is to request an exemption under 10CFR55.11 to defer the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)
I annual operator requalification written examination and operating test, required by 10CFR55.59(a), from November 1991, to December 1991.
During the week of November 4, 1991, the NRC vas scheduled to administer their annual requalification examination to selected Toledo I
Edison Reactor Operator and Senior Reactor Operator licensees.
Additionally, Toledo Edison was scheduled to administer their annual requalification examinations based on a November requalification examination schedule.
However, based on discussion between the NRC Region III staff and Toledo Edison management on September 18, 1991, the examination schedule was extended to December 9, 1991.- The November 1991 requalification written examination and operating test schedul. coincides with the current DBNPS restart schedule from the seventh refueling outage (September 1 - October 27, 1991) and power escalation / physics testing ending November 5, 1991.
As a result, administering a requalification written examination and operating test during this period could potentially provide significant additional.
operator stress and burden during a critical period of plant operation.
The deferral of the examination and test allove for plant startup and power accession with minimal operator distraction and crev team disruption.
9401140212 911016 I
V PDR y
p[,[]l\\
PDR ADOCK 05000346 P y d, 0>ewg compow
~,,, - -,
S..u
,.e,
~
e Docket Numbar 50-346 License Number NPF-3 Serial Nuabur 1960 Page 2 The seventh refueling outage was scheduled for 57 days (not accounting for any emergent work). The outage schedule requires that the plant operators provide extended shift coverage while concentrating on outage and related shutdovn activities.
During this outage, requalification training vril continue to be conducted along with additional outage-related training topics, such as:
modifications, procedural changes, infrequent operations, startup, physics testing, and low power operation.
Additionally, the operator training prior to commenc~eatnt of the outage included lessons learned from shutdown risk reduction management.
This training during an outage period which is shorter than past outages, together with a requalification examination and operating test, places an increased burden on the operators during a period (startup/ physics testing) that requires their utmost attention.
The operators at the DBNPS are currently participating in the ongoing requalification training program. Their performance has been satisfactory in the required studies, examination, and simulator evaluations.
The Institute of Nuclear Power Operatfors (INPO) through the National Academy for Nuclear Training has evalta!ed, accredited and renewed accreditation of Toledo Edison's operator training programs. Recently, INPO evaluated the DBNPS specific simulator in conjunction with their annual plant evaluation.
For the simulator evaluation, two (2) eperating crevs were evaluated without any significant performance deficiency.
Additionally, the requalification training program was graded satisfactory during previous requalification examinations and operating tests administered by the NRC.
This exemption request to defer administering both the NRC's annual requalification examination and, Toledo Edison's annual requalification examination from November 1991 to December 1991 is a one-time extension.
Future schedules vill then revert to the November examination and test date. The operators vill continue to attend scheduled training and meet the requirements for satisfactory completion of the requalification program.
The training vill also include outage-related activities to ensure continued safe operation of the plant.
This exemption, if granted by the NRC, vill not endanger life or property, nor present an undue risk to the public health and safety.
Toledo Edison believes that this one-time exemption vould result in benefit to the public health and safety that compensates for any decrease in safety that may result from the granted exeeption.
Accordingly, Toledo Edison requests that this exemption be granted by the NRC by November 30, 1991.
-l Docket Number 50-346 License Number NPF-3 3
Serial Number 1960 Page 3 Should you have any questions, please call Mr. R. V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Sincerely, (W/-
GAB / dim
\\
A. B. Davis, Regional Administrator, NRC Region III cci J. B. Hopkins, NRC/NRR DB-1 Senior Project Manager V. Levis, NRC Region III, DB-1 Senior Resident Inspector i
Utility Radiological Safety Board USNRC, Document Control Desk l
a
.