ML20198S211

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Forwards Appeal from Ld Guthrie Request for Reconsideration of Requirement That Min of 6 Months at Facility Necessary Before Administration of Senior Reactor Operator License exams.NUREG-1021 Does Not Include Requirement
ML20198S211
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 06/05/1986
From: Leblond P
COMMONWEALTH EDISON CO.
To: Russell W
Office of Nuclear Reactor Regulation
Shared Package
ML20198S215 List:
References
RTR-NUREG-1021 1753K, NUDOCS 8606100364
Download: ML20198S211 (2)


Text

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_ s} Commonwealth Edison

_ - 72 West Adams Street, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago,Illinoin 60693 0767 June 5, 1986 Mr. William T. Russell Director, Division of Human Factors Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

Braidwood Station Units 1 and 2 Licensed Operation Examination Waiver NRC Docket Nos. 50-456 and 50-457

Reference:

May 20, 1986, letter from C. W. Hehl to L. D. Guthrie, Jr.

Dear Mr. Russell:

Attached is an appeal from Mr. Lester D. Guthrie, Jr., Docket No.

55-30431, requesting that reconsideration be given to the requirement that a minimum of six months at Braidwood Station is necessary before being administered an examination for a Senior Reactor Operator's license.

The Operator Licensing Examiner Standards (NURBG 1021), Section ES-109 Paragraph E, Eligibility Requirements for Cold Examinations, do not include a requirement to have six months at the site for which the license is sought. That requirement applies to hot license candidates only. The request for waiver of the six month on-site requirement was unnecessarily requested in Mr. Guthrie's application for a Braidwood Unit One Senior Reactor Operator license. Thus, it is Commonwealth Edison Company's understanding that the referenced letter denied a waiver that was not required in this instance.

In fact, at Braidwood there is a precedent where a license examination has been administered to another Braidwood Station license candidate (already previously NRC instructor certified) who did not have six months on-site at the time of the examination.

In that case, the individuc.

took the written examination three months after arriving on-site. No waiver of the on-site time requirement was requested as none was deemed necessary.

Since Mr. Guthrie is to report to Braidwood Station in early August, he will have been able to accumulate slightly over 3 months of on-site experience prior to taking the simulator and oral examinations scheduled for November 1986.

(This exam is our last cold examination and a hot license examination could be up to a year later.)

8606100364 860605 PDR ADOCK 0500 6

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Mr. W. T. Russell June 5, 1986 Mr. Guthrie's experience as a Station Control Room Engineer in the startup phases of a now currently operating plant which is basically a duplicate of Braidwood Station would be invaluable in his role as a Shift Engineer at Braidwood Station. The advantages of including Mr. Guthrie in our operating crew during startup far outweigh the consideratiots of requiring six months on-site prior to administering a license examination.

If this position is not acceptable, Commonwealth Edison requests an opportunity to further discuss this issue with you. Please direct any responses or questions regarding this issue to this office.

Yours truly, PA, 4M

p. LeBlond Nuclear Licensing Administrator la cc:

L. Guthrie 1201 Hillcrest Rd., Rockford, Illinois 61108 C. W. Hehl - Region III Chief, Operations Branch, Region III, USNRC, 799 Roosevelt Road, Glen Ellyn, Illinois 60137 J. G. Keppler - Region III I

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