ML20091D754
| ML20091D754 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 10/18/1991 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9110290003 | |
| Download: ML20091D754 (8) | |
Text
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- k' 10CFR55.11 10CFR55.5 PIIILADELPIIIA ELECTRIC COMPANY O'
NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD, WAYNE, PA 1 % 87 5691 (215) 640 6000 1
NUCLEAR ENGINEERING & SERVICE'S DEPARTMENT October 18, 1991 Docket Nos. 50-352 55-61455 50-353 55-61456 50-277 55-61457 50-278 55-61459 55-61452 55-63461 55-61453 55-61454 License Nos. NPF-39 SOP-10935 NPF-85 SOP-10934 DPR-44 SOP-10933 DPR-56 SOP-10932 SOP-10938 SOP-10930 SOP-10937 SOP-10936 Dr. Thomas E. Murley, Director Office'of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Peach Bottom Atomic Power Station, Units 2 and 3 Submittal of the Proposed Requalification Program Plan for Licensed Senior Reactor Operators Limited l
to Fuel Handling, and a Request for Exemption from 10CFR55.59(a)(2) and 10CFR55.59(c)(4)(1) Related to Annual Operating Tests for These Operators l
Dear Dr. Murley:
l We are submitting this letter to provide the attached proposed requalification training program plan for licensed Senior Reactor-Operators limited to fuel handling, i.e.,
Limited Senior Reactor Operators (LSROs), along with associated requests for exemption,
.a accordance with 10CFR55.11, from the requirements of 10CFR55.59(a)(1) and 10CFR55.59(c)(4)(1) related to annual requalification operating tests fcr the LSROs.
The individual LSRO licensees are identified below.
9110290003 oi1018
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r2 PDR ADOCK 05000277 T' COD PDR y
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p Dr. Thomas E. Murley October 18, 1991 Office of Nuclear Regulatory Commission Page 2 i
l Docket License Name Number Number Berry, Patrick J.
55-61452 SOP-10938 Fuehrer, Mark D.
55-61453 SOP-10937 Johnston, Gordon L.
55-61454 SOP-10936 Levenite, Arthur E.
55-61455 SOP-10935 Nunn, Nick H.
III 55-61456 SOP-10934 Oliver, Bradley S 55-61457 SOP-10933 Risteter, Joel A.
55-61459 SOP-10932 Stott, Joseph R.
55-61461 SOP-10930 The proposed LSRO requalification training program plan provides a description of the proposed requalification training program for LSROs which is based on a systems approach to training, and is consistent with our accredited requalification training program for Senior Reactor Operators and Reactor Operators.
The associated exemption requests concern (1) a one-time schedular exemption to conduct the first annual requalification operating test for the current multi-site licensed LSROs in January 1992 instead of the end of 1991, and (2) conducting the annual requalification operating tests for multi-site licensed LSROs at alternating sites, i.e.,
one year at Limerick Generating Station (LGS), the next year at Peach Bottom Atomic Power Station (PBAPS), and so on instead of an annual requalification operating test at each site (i.e.,
The proposed LSRO requalification training program, including the training program content and these associated exemption requests, was discussed with NRC representativos in a meeting at the NRC Region I office on May 22, 1991.
Exemotion Requests We have imolemented a new LSRO program that established LSROs with a multi-site license applicable at LGS, Units 1 and 2, and PBAPS, Units 2 and 3.
The objective of the LSRO program is to maintain a small group of licensed personnel to supervise core alterations (i.e.,
reactor refueling and invessel maintenance activities) during refueling outages at each of the four LGS and PBAPS nuclear units.
There are currently eight (8) LSROs who hold an active multi-site SRO license limited to fuel handling.
The LSROs were initially licensed at LGS, Units 1 and 2, on September 10, 1990.
The licenses were amended on January 9, 1991, to include PBAPS, Units 2 and 3, based on successful J
'Dr. Thomas E. Murley October 18, 1991 Office of Nuclear Regulatory Commission Page 3 completion of training on the differencen between LGS and PBAPS, and written and operating examinations on these differences.
10CFR55.53(h) stipulates that a licensee, as a condition of the license, shall complete a requalification program as described by 10CFR55.59.
10CFR55.59(c)(4)(1) stipulates that the requalification program must include annual operating tests, and 10CFR55.59(a)(2) stipulates that each licensee shall pass an annual operating test.
NRC Generic Letter (GL) No. 89-03, " Operator Licensing National Examination Schedule," issued March 24, 1989, specified two examination months for each facility during which operator licensing examinati
- would be conducted each year.
The purpose af the national exan-ation schedule is to provide a consistent time period for conducting the examinations at each facility so that the facility can establish a standard schedule for conducting the required licensed operator training, and so that the NRC can schedule the resources required for conducting the examinations.
The national examination schedule months for LGS, Units 1 and 2, are January and July.
Therefore, we request a one-time schedular exemption frcm the requirements of 10CFR55.59(a)(2) 'lth regard to each individual licensed LSRO to conduct the first ennual requalification operating test for the melti-site licensed LSROs in January 1992 in conformance with the national examination schedule for LGS instead of the end of 1991.
Additionally, each LSRO's license is applicable to both LGS and PBAPS, i.e.,
two sites with units of a common vendor.
The refueling equipment, support systems, Technical Specifications (TS), and plant procedures are similar for each site.
Therefore, we also request an exemption from the requirements of 10CFR55.59(c)(4)(1) regarding the requalification program such that the first annual requalification operating test for the LSROs be conducted at LGS, Units 1 and 2, only, and that all subsequent annual requalification operating tests for multi-site licensed LSROs be conducted at alternating sites, i.e.,
the next annual operating test would be conducted at PBAPS, the following annual operating test would be conducted at LGS, and so on.
2 e
The justification for these exemption requests is provided below in accordance with 10CFR55.11.
In addition, information is provided in accordance with 10CFR51.30 which supports the conclusion that the approval of these exemption requests would not have an effect on the environment.
Justification for the Exemption Under 10CFR55.ll, the NRC may grant exemptions from the requirements of 10CFR55 which are authorized 'ay law and will not endanger life or property, and are otherwise in the public interest.
l Dr. Thomas.-E' Murley October 18, 1991 Office of~ Nuclear Regulatory Commission Page 4-We_are_ requesting exemptions from the requirements of
' 10CFR55. 59 ( c ) ( 4 ) (-1 ) and 10CFR55.59(a)(2) which stipulate that the
- requalification program must include an annual operating test, and that a_ licensee must pass an annual operating test.In order j
to perform.llcensed duties.
The Philadelphia Electric Company i
(PECo) annual requalification operating test is based on-job performance measures.(JPMs) which, for LSROs, are designed to demonstrate their knowledge of refueling equipment and systems, their ability-to execute normal, abnormal, and emergency l
procedures associated with fuel handling, and their ability to supervise the operation of equipment and systems to safely handle irradiated fuel _ The purpose of the 10CFR55.59 annual operating test requirements for LSROs is to determine whether retraining is needed to upgrade the LSRO's knowledge and abilities in the areas described above.
Currently, there is no NRC guidance regarding the administration of LSRO requalification examinations.
As indicated in the proposed program plan, and discussed with the NRC during the.
meeting on May 22, 1991, the LSRO requalification training program at-PECo consists of at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant specific training prior to each refueling outage at LGS and PBAPS, with a minimum of-two training cycles per year (i.e., one cycle at each site per year).
Each training cycle includes in plant JPM
' training, and each participant is required to successfully pass an examination at the end'of each training cycle which includes JPM evaluations.
If an LSRO fails this examination, the individual will be removed from licensed duties until remediated and successfully re-examined.
Therefore, the LSRO's operating skills and abilities are ootermined at the end of each requalification training cycle through the JPM evaluations.
The-LSROs have successfully completed reoualification training and passed the associated examinations in March 1991 for LGS and in
-September 1991 for PBAPS.
Additionally, the LSROs' licenses were amended to include PBAPS, Units 2 and 3, in January 1991 based on successfully passing the initial operating test at PBAPS in December 1990.
A January 1992 annual operating test would be within one
-year from when the LSRO licenses were amended, and the LSROs' operating skills and abilities have been-evaluated twice within that one year period during-the requalification training cycles identified above.
Therefore, conducting a January 1992 annual requalification operating test-for the current LSROs meets the underlying purpose of 10CFR55.59(a)(2).
Also, because the units at LGS and PBAPS are of a common vendor, and the refueling equipment, support systems, TS, and plant procedures are similar for each site,__and because the operating skills and abilities of g
the LSROs are evaluated at the-end of each of the two retaalification training cycles each year (i.e.,
one cycle per site per year), conducting the annual requalification operating test-at alternating sites for multi-site licensed LSROs meets the underlying purpose of 10CFR55.59(c)(4)(1).
Dr. Thomas E. Murley October 18, 1991 Office of Nuclear Regulatory Commission Page 5 Environmental Assessment Environmental Impact of the Proposed Action Approving these exemption requests will not impact the environment since it does not involve the release of radioactive effluents.
Alternative to the Proposed Action The previous section provides the basis for concluding that there are no environmental effects which would result from the approval of the requested exernptions.
Accordingly, any alternatives with any environmental impact other than not approving these exemption requests, need not be evaluated.
Alternate Use of Recources These exemption requests, if granted, do not involve the use of any resources not previously considered in the Final Environmental Impcct Statements for the LGS and PBAPS facilities.
Proposed Finding of No Significant Impact Based upon the foregoing environmental assessment, we conclude that the approval of our exemption requests will not have an effect on the quality of the human environment.
Due to scheduling constraints, we request a response from the NRC on these exemption requests by December 1, 1991 so that, if the exemptions are not granted, we have sufficient time to pursue alternate plans for conducting the first annual requalification operating test for the multisite licensed LSROs by the end of 1991 to avoid non-compliance with the requirements of 10CFR55.59.
If you have any questions, plesse do not hesitate to contact us.
Very truly yours,
(
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&t G.
J.
Be c k',
Manager Licensing Section Attachment cc:
T. T. Martin, Administrator, Region I, USNRC T.
J.
Kenny, USNRC Senior Resident Inspector, LGS J.
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Lyash, USNRC Senior Resident Inspector PBAPS a
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Attachment Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 50-353 Peach Bottom Atomic Power Station,-Units 2 and 3 Docket Nos. 50-277 50-278 m
Limited Senior Resactor Operator Requalification Program Plan l
l PHILADELPHIA ELECTRIC COMPANY j
LIMITED SENIOR REACTOR OPERATOR REQUALIFICATION PROGRAM PLAN 1.0 PROGRAM TITLE:
Limited Senior Reactor Operator Requalification Training Program
' 2. 0 PREREOUISITES:
Hold a Senior Reactor Operator limited to i
fuel handling license.
-3.0-SCOPE AND DESCRIPTION:
3.1 Limited Senior Reactor Operator (LSRO) tasks requiring retraining are identified on the LSRO site specific Cross Reference Matrix.
3.2 ISRO requalification training consists of classroom instruction and in-plant tours necessary to maintain required LSRO knowledge and skills, and also to keep the LSRO cognizant of plant physical and procedural changes, lessons learned from industry and in-house events, and areas determined by site management to be deficient through operating' experience or quality assurance findings.
3.2.1 To maintain the knowledga and skills of the LSRO current, the following training will be provided.
o Systems o
Procedures (normal, abnormal, and emergency) o Technical Specifications (appropriate for topics selected) o Plant modifications related to the refueling 4
floor o
Related refueling operational events 3.2.2 Attendance and participation in the LSRO requalification training program is required.
-This includes classroom instruction, in-plant job performance measure (JPM) training, cycle examinations, and required reading.
Failure to attend requalification training will result in the individual being removed from licensed duties until the individual has completed this training requirement.
PECO LSRO R qual Program Plcn Pcgo 2 of 2 l
3.2.3 Following each LSRO requalification training cycle, each LSRO will be required to satisfactorily pass an end of cycle examination.
This examination will consist of a written section and a JPM evaluation.
3.2.4 Annutlly, each LSRO will be required to tal.3 and successfully pass an operating examination.
This examination will consist of LSRO JPMs.
3.2.5 Biennially, each LSRO will be required to take and successfully pass a comprehensive LSRO written examination.
4.0 CONTENT / DURATION:
4.1 Prior to a refuel outage at either site, a LSRO requalification training cycle shall be conducted.
Each cycle will consist of, at least, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant specific training.
This training will consist of:
26 to 28 houre of classroom instruction, 4 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> si in-plant JPM training, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for written examination and JPM cvaluatien.
4.2 As a minimum, two (2) cycles of LSRO requalification training shall be conducted each year; one cycle per site per year.
5.0 EXAMINATION CRITERIA:
5.1 Passing criteria for the LSRO requalification training cycle examination, the annual LSRO operating examination, or the biennial comprehensive LSRO written examination is an overall grade of 80% or greater.
5.2 Failure to pass either the LSRO requalification training cycle examination, the annual LSRO operating examination, or the biennial comprehensive LSRO written examination will result in the LSRO being removed from licensed duties until remediated and successfully re-examined.
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