ML20197J076

Concurs W/Region V Finding That Rescheduling of Annual Requalification Exams Would Not Have Significant Effect on Public Health & Safety.Licensee Can Reschedule Exams to Jan/Mar Time Frame

ML20197J076
Person / Time
Site:	Columbia
Issue date:	09/21/1984
From:	Booher H Office of Nuclear Reactor Regulation
To:	Schwencer A Office of Nuclear Reactor Regulation
References
CON-WNP-0771, CON-WNP-771 NUDOCS 8410020224
Download: ML20197J076 (3)

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SEP 211984 DISTRIBUTI0ft:

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.4Ed0RAllDUM FOR: Albert Schwencer, Chief J. Persensky Licensing Branch #2 D. Shum Division of Licensing FROM: Harold R. Bocher, Chief Licensee Qualifications Branch Division of Hunan Factors Safety

SUBJECT:

WriP-2 AftfiUA! REQJALIFICATI0fl EXAllS - SCHEDULE CHAfiGE

References:

1. Letter frcn G. C. Sorenson to R. J. Pate, "i!uclear Project flo. 2, UtiP-2 Licensed Operator Annual Requalification Exans - Schedule Change," dated July 26, 1984

2. fienoranoun fron R. J. Pate to H. R. Bocher, "WilP-2 Annual Requalification Exans - Schedule Char.ge,"

dated August 2, 1984 By letter (Ref.1) dated July 26, 1984, the licensee of Wr!P-2 indicated that WilP-2 had experienced sone unforeseen mechanical prcblens during the Power Ascension phase of their testing progran. Because of these problens, connercial operation had been delayed. Accordingly, the licensee requested a change to the time frane from Septenber/ October to tiovember/Decenber for the conduct of 1984 licensed operator annual requalification exa"Is. 'le have reviewed the licensees' rationale for the request and agree with the recornendation of Region V (Ref. 2) to grant the waiver for rescheduling the requalification examinations for 1984 as requested.

As the result of the above change, the annual requalification exans for 1935 and each subsequent year would have te be conducted during the nonths of i!ovember and Decer:ber. The licensee further indicated that due to heavy vacation / holiday tine during the ponths of August through December, a Jar.uary/ March tiru frane would be more conducive to accennodating the Operations Department vacation schedule, withcut the use of heavy overtine and would fit in well with their scheduled cutage periods (flid-April through Mid-June). Therefore, the licensee also requested to reschedule calendar year 1985 annual requalification exans to be conducted in the months of January and February 1986. Following the establishment of this schedule, the annual raqualification exans wculd be conducted during the first quarter of each subsequent year. Based on our review, we cc.1 cur with the finding of Region V (Ref. 2) thac it would not have significant effect on the public health and safety to allow the licensee to reschedul.e the mns to the Jaruary/ March tina ~ -

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~ ~": 7 Albert Scnwencer 2 SEP 21 G34 Therefore, we fir.d that the above cited licensee's procosed changes to the schedules for conducting the annual requalification exans are acceptable.

However, the licensee should ensure that the tirae between requalification exans during this period for each operator will noc exceed 14 months. This would minimize the deviation from the current 12 r'anth requirement.

.e Harcld it. Bocher, Chief Licensee Qualifications 3 ranch Division of Hunan Factors Safety cc: R.J. Pate, RV R. Auleck DW/D!iSl/Meno to Schwencer

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] SEP 2 41S84 MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:

Victor Stello, Jr., Deputy Executive Director Regional Operations and Generic Requirements

SUBJECT:

REQUEST BY WASHINGTON PUBLIC POWER SUPPLY SYSTEM (WP FOR CONFIRMATION OF CRGR REVIEW This is in reference to a lette'r dated August 2,1984, from G. C. Sorensen, WPPSS to A. Schwencer, NRR, regarding a request made recently by NRR for additional information from the licensee to affirm conservative treatment of uncertainties applied to WNP-2. in the General Electric instrument setpoint methodology as WPPSS considers the issue involved to be generic and has requested confirmation that the requirement for additional information (made similarly to a number of utilities participating jointly in a study of the setpoint methodology issue) was reviewed by the CRGR as provided in NRC's internal procedures.

The ROGR staff has been in contact with cognizant DL and OSI staff regarding NRR's proposed response to the WPPSS inquiry, and in tha'c context were provided, for infonnation, a memo dated August 30, 1984, from R. W. Houston, DSI to T. Novak, DL.

That memo provided background information for use by DL in responding formally to WPPSS, and expressed DSI's opinion that there is no need for CRGR review in this matter. I understand the DSI view that the additional information requested from WPPSS and the other utilities involved is considered necessary by the staff in this instance to verify compliance with the regulations ,

cited. However, I am not convinced that the request for additional information does not impose or imply new requirements subject to CRGR review. From the background cited by DSI, it is clear that the staff's understanding and scrutiny of the setpoint methodology issue has increased over the years. The amount of detailed information required by the staff to satisfy itself that licensees' approach to establishing setpoints is conservative has also increased. The most step inrecent request for additional information appears to be simply another that process. Such practice does in fact impose new requirements, in the sense that term is applied in the CRGR Charter, if significant costs must be incurred the staff. On by licensees in providing the additional information requested by the basis of inquiries made by the R0GR staff in this instance, it appears that the costs involved to the utilities will range somewhere between $250,000 to $400,000 per plant.

I note here also that at least some of the information requested by the staff in this instance appears to indicate that current staff practice is as described in proposed regulatory positions included in draft Revision 2 to the Reg. Guide 1.105, which the CRGR recomended be deleted during its recent review of that Reg. Guide.

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Contact:

CP ADOCK 050003 7 Jim Conran, 492-4354 ROGR Staff [,  %@

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JEF 2s , y, These points should receive careful consideration by NRR in preparing the -

response to WPPSS in this matter. Additionally, I would ask that in light of the foregoing, you examine the staff practice in this area to determine if it is consistent with NRR procedures and whether CRGR review is warranted prior to

continuance of the staff practice.

01.oinal siCned by

_210t0EStellG,4v' Victor Stello, Jr.

Deputy Executive Director Regional Operations and

Generic Requirements i

cc: A. Schwencer, DL F. Rosa, DSI

. W. Houston, DSI T. Novak, DL M. Virgilio, DSI Distribution:

VStello JHSniezek JConran DEDR0GR cf Central File i

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