AECM-85-0304, Application for Amend to License NPF-29,supplementing 850812,23 & 30 Submittals,To Provide Justification for Exemption from Tech Spec 6.3.1 & 6.4.1 Requirements for Senior Reactor Operator Qualifications

Application for Amend to License NPF-29,supplementing 850812,23 & 30 Submittals,To Provide Justification for Exemption from Tech Spec 6.3.1 & 6.4.1 Requirements for Senior Reactor Operator Qualifications

ML20133A754
Person / Time
Site:	Grand Gulf
Issue date:	09/25/1985
From:	Kingsley O MISSISSIPPI POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20133A758	List: AECM-85-0304, Application for Amend to License NPF-29,supplementing 850812,23 & 30 Submittals,To Provide Justification for Exemption from Tech Spec 6.3.1 & 6.4.1 Requirements for Senior Reactor Operator Qualifications ML20133A761
References
AECM-85-0304, AECM-85-304, TAC-59440, TAC-59536, TAC-59644, NUDOCS 8510020302
Download: ML20133A754 (5)

Text

i

.. o j MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi EndhblMAME P. O. B O X 164 0, J A C K S O N, MIS SIS SIP PI 39215-1640 September 25, 1985 O. D. KINGSLEY, JR.

YtCE PREllDENT - NUCLE AR OPE R AflONS U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 Attention: Mr. Harold R. Denton, Director

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 File: 0260/0840/L-860.0 Additional Information on PCOL-85/11 and PCOL-85/14 AECM-85/0304 This letter provides information that supplements previous requests for an amendment made by Mississippi Power and Light (MP&L) by submittals on August 12, 23 and 30, 1985.

In accordance with the provisions of 10 CFR 50.30, three (3) signed originals and forty (40) copies of the requested supplement to an amendment are enclosed. The attachment provides the complete technical justification and discussion to support the requested supplement to an amendment. This attached information has been reviewed and accepted by the Plant Safety Review Committee (PSRC) and the Safety Review Committee (SRC).

Based on the guidelines presented in 10 CFR 50.92, it is the opinion of MP&L that this proposed supplement to an amendment involves no significant hazards considerations.

In accordance with the requirements of 10 CFR 170.21 an application fee of $150 was included with each of the original submittals made on August 12, 23 and 30, 1985. Sitze this letter provides information that supplements these original submittals, MP&L has determined that no additional application fee is required.

MP&L requests NRC Approval of item one (1) of this submittal as soon as possible. The two individuals referenced in this submittal will be utilized as Shift Supervisors and these additional SRO licenses will allow progression toward a six shift rotation, provide for enhanced shift maintenance coordination and allow contractor phase out.

g 8510020302 850925 PDR ADOCK 05000416 \

P PDR qo D

J13AECM85091701 - 1 Member Middle South Utilities System

AECM-85/0304 Page 2 Items two (2), three (3), and four (4) of this submittal are expansions or supplements to previously submitted items which are needed to support design changes currently scheduled to be performed during an outage planned to commence in October 1985.

As a matter of good operating practice, we will maintain frequent contact with your staff during the review period to ensure that the date of issuance of these changes will coincide with completion of the proposed modifications.

Yours t 11y, s

ODK:vog Attachments: Additional Information on CGNS PCOL-85/11 and PCOL-85/14 cc: Mr. J. B. Richard (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Mr. James M. Taylor, Director (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 Dr. Alton B. Cobb (w/a)

State llealth Officer State Board of Health Box 1700 Jackson, Mississippi 39205 J13AECM85091701 - 2

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and MIDDLE SOUTH ENERGY, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, O. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of Mississippi Power & Light Company; that on behalf of Mississippi Power & Light Company, Middle South Energy, Inc., and South Mississippi Electric Power Association I am authorized by Mississippi Power & Light Company to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of Mississippi Power & Light Company; and that the statements made and the matters set forth therein are true and correct to th est of my .

knowledge, information and belief.

\ ./

STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN TO befo me, a Notpfy Publ c, in and for the County and State above named, thisc 25 ay of .h

, 1985.

v (SEAL) y Notary Public My commission expirest M/ Commbshn Ighs S4 U. N J13AECM85091701 - 4 m

1. NLS-85/09 (PCOL-85/14 additional information) i l

SUBJECT:

Technical Specification 6.3.1, page 6-6 DISCUSSION: It is proposed to add a "#" footnote to the March 28, 1980 NRC letter reference in Technical Specification 6.3.1.

l This proposed "f" footnote'will read as follows:

I f.Except that the experience and other training information provided in a letter to the NRC dated July 29, 1985 are acceptable for the individuals listed in l- that letter.

Mississippi Power & Light (MP&L) Company submitted a proposed change to Facility Operating License. NPF-29, in a letter from O. D. Kingsley, Jr to Mr. Harold R. Denton dated August 30, 1985. During discussions with your staff, it was determined l~

that the proposed "#" footnote was also required in Technical

! Specification 6.3.1. This proposed change supplements the l previous submittal. ,

' JUSTIFICATION

Present Technical Specification 6.3.1 and 6.4.1 endorses

! Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter concerning qualifications of reactor operators. Section A states that " Applicants for senior reactor operator license shall have 4 years of responsible power plant experience.

Responsible power plant experience should be that obtained as a control room operator (fossil or nuclear)". For plants'like

' Grand Gulf, these regulations do not adequately consider the situation where a plant has not held an operating license for 4 years so that operators can obtain this required experience.

Grand Gulf Unit I was issued an operating license in June 1982 and a full power operating license in August 1984.

Section A of the March 28, 1980 NRC letter allows exceptions to experience requirements for precritical applicants to accommodate the fact that their facility has not yet been in '

' operation. The proposed technical specification change is similar to this exception in that Grand Gulf has not been in operation long enough for its operators to obtain four years of control room experience.

MP&L is requesting this technical specification exception for two individuals whose experience and training is provided in '

a letter dated July 29, 1985 from Mr. L. F. Dale to Dr. J.

Nelson Grace. These two candidates were selected as senior reactor operator candidates because of their proven performance working as licensed control room operators. They '

have demonstrated strong supervisory abilities as they have directed activities of non-licensed personnel. These two i individuals have been determined to be qualified to fill a .

I supervisory role in the Grand Gulf Operations Department and if licensed will be promoted to Shift Supervisors to allow i staffing for a six shift rotation.

J13AECM85091701 - 5

SIGNIFICANT HAZARDS CONSIDERATIONS:

There is a need at Grand Gulf to upgrade certain reactor operators to senior reactor operators in order to meet and maintain shift manning requirements, move into a six-shift rotation, and provide for attrition. Staffing projections and plans are predicated on the ability to upgrade reactor operators to senior reactor operators. The proposed exception for these two individuals is based on their licensed operator experience on Grand Gulf, their completion of an extensive training protcam, and their demonstrated supervisory skills.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the two individuals seeking the technical specification exception are highly trained on Grand Gulf and each has held a reactor operator license on Grand Gulf for more than two years.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed exception will apply to individuals that.are experienced licensed operators on Grand Gulf and who have demonstrated supervisory skills in directing the work of other operators.

The proposed change does not involve a significant reduction in a margin of safety because the two individuals involved have extensive experience on Grand Gulf as licensed and unlicensed operators..

Therefore, the proposed change involves no significant hazards considerations.

J13AECM85091701 - 6