ML20079N303
| ML20079N303 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/26/1984 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| JPN-84-05, JPN-84-5, NUDOCS 8401300163 | |
| Download: ML20079N303 (3) | |
Text
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tv Authority January 26, 1984 JPN-84-05 i
Director of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 j
Division of Licensing l
Subject:
James A.
FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for a Schedular Exemption from the Provisions of 10 CFR 50.54(m)
References:
- 1. PASNY letter, J.
P.
Bayne to T.
A.
- Ippolito, dated July 31, 1981 (JPN-81-57).
- 2. NRC letter, D.
B. Vassallo to G.
T.
- Berry, dated January 18, 1982.
- 3. NRC letter, D.
B. Vassallo to L.
W.
- Sinclair, l
dated January 25, 1983.
Dear Sir:
10 CFR 50.54(m) requires the Power Authority to have a minimum of two Senior Reactor Operators on shift at all times at the James A.
FitzPatrick Nuclear Power Plant.
The Authority hac-met the requirements of this rule for the FitzPatrick plant since September of 1983, although the rule did not become effective until January 1, 1984. Consequently, the Authority i
has not previously requested an exemption from the rule for the FitzPatrick plant.
I The Authority has recently identified, and has arranged for, a Lpecial training program for Senior Reactor Operators (SROs).
This program is INPO approved and would be conducted on-site by an accredited college.
The program would provide SROs with I
engineering education and training that meets or exceeds the Draft Commission Policy for engineering on shift (Federal Register Vol. 48 No. 143, July 25th, 1983).
However, the Authority cannot effectively implement this program and simultaneously satisfy the requirement for two SROs on shift.
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8401300163 840126
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Therefore, in accordance with the provisions of 10 CFR 50.12, the Authority requests a schedular exemption from the requirements of 10 CFR 50.54(m) for the purposes of reactor operator training.
The Authority specifically requests an exemption from the rule for the period of February 20, 1984 to June 1, 1985.
The requested exemption would make it possible for the Authority to remove one of the two SROs from shift duty to participate in the accredited training program.
The Authority considers that the upgrade in SRO training would result in an overall improvement in plant safety for the following reasons.
This SRO training would allow elimination of the separate STA position and would consolidate on shift expertise and responsibilities into the SRO position.
The SRO would have the necessary engineering knowledge to make an informed decision on his own, based on his technical knowledge and experience.
The Authority considers that the following factors will adequately compensate for having a single SRO on shift.
The Authority has upgraded all operator training programs and provided all operators with special training for mitigating core damage.
The NRC has reviewed these programs and concluded that the Authority has met the requirements of NUREG-0737 Items I.A.2.1.4 - Upgrading of Reactor Operator and Senior Reactor Operator Training and II.B.4.1 - Training for Mitigating Core Damage (Reference 3).
Additional senior reactor operators will be readily available during the day shift since all training classes will be held on site.
The Authority will also implement an additional compensatory measure during the time there is one SRO on shift.
During this period, an additional SRO will be on call at all times during the back shifts.
The NRC published five criteria that would be used to evaluate exemption requests in the July ll, 1983 Federal Register (Vol.
48 No. 133, page 31611).
Criteria 1 through 4 address the licensee's comaitment and ability to recruit, hire and adequately train sufficient operators to meet the requirements of the rule within a reasonable time period.
The Authority demonstrated that we meet these criteria by virtue of the fact that the FitzPatrick plant was in compliance with the rule prior to its effective date.
The Authority is only requesting this exemption in order to upgrade SRO training.
Approximately 15 months is required to do this since the program takes seven months and will have to be conducted twice in order to train all SROs.
t
The fifth criteria addresses the potential for adverse effects on licensee training programs, overtime practices, the number of shifts, and the length of shifts.
As stated above, the Auttority considers this enemption request necessary to effectively implement this additional training. In the absence of an exemption, this training program could be implemented-only by placing the SROs on a revised shift schedule which reduces the number of shifts and increases their length. There is also the possibility that SRO overtime would have to be
. increased.
The Authority considers these circumstances to be less desirable than removing one SRO from shift duty.
The James A.
FitzPatrick tra'ining staff will have the in-house capability to continue this program for all future SROs after e
the initial two sessions are complete.
If you have any questions regarding this exemption request, please contact Mr.
J.. A.
Gray, Jr. of my staff.
Very truly yours,-
W-an
[
Executive Vice President f
Nucleat Generation i
t cc:
Office of the Resident Inspector U.S.
Nuclear Regulatory Commission P.O. Box 136
- Lycoming, N.Y.
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