ML20214F251

Requests Consideration of Listed Comments Re Prior to NRC Acting on Proposed Change to 10CFR50.54.No Need Exists to Become Prescriptive within Law to Working Location of Personnel Nor Deadline for Establishing Staff Levels

ML20214F251
Person / Time
Site:	Rancho Seco
Issue date:	09/24/1982
From:	Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
TAC-44123, NUDOCS 8705230009
Download: ML20214F251 (6)

Text

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$ SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S street. Box 15830, Sacramento, California 95813; (916) 452-3211 September 24, 1982 SECRETARY OF THE COMMISSION US NUCLEAR REGULATORY COMMISSION WASHINGTON D C 20555 ATTENTION DOCKETING AND SERVICE BRANCH i

DOCKET 50-312 RANCHO SEC0 NUCLEAR GENERATING STATION UNIT N0 1 PROPOSED CHANGE TO 10CFR50.54

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The Sacramento Municipal Utility District proposes that the comments in the following discussion be seriously considered prior to the NRC acting on the

, proposed change to 10CFR50.54 as published in the Federal Register, Volume l

47, No. 168 of August 30, 1982. This letter is a correction to a previous letter dated September 17, 1982.

All operating nuclear power plants are required to operate and staff within the requirements of the Technical Specifications issued uniquely for each plant. The Technical Specifications provide flexibility for the NRC to con-sider unique features at each facility when establishing minimum conditions for operation. Historically, the Technical Specifications have established -

the minimum staffing requirements for a particular unit and the requirements have frequently been more restrictive than the law required. There is abso-lutely no need to become prescriptive within the law to the working location of personnel ( (proposed 10CFR50.54 (m)(2)(ii) and 10CFR50.54 (m)(2)(iii) )

nor the deadline for establishing staffing levels ( (proposed 10CFR50.54 (m)

(2)(i) ). To do so, removes the flexibility to consider other alternatives and may penalize a utility which has made good faith efforts to comply with the wide range of uncoordinated guidance recently issued by the Coninission.

This guidance includes staffing levels, experience requirements prior to g licensing and overtime limits.

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$@@ The Darrell G. Eisenhut letter of July 31, 1980, discussed Interim Criteria gg for Shif t Staffing. The District's response to that letter dated November 3, em 1980, established two realistic schedules for meeting the criteria. One j

• schedule optimistically assumed no attrition and projected a compliance date W of November, 1983. The other schedule provided for a more realistic 30%

@S attrition and provided for a compliance date of June,1985. The NRC made no

@Q response to the schedules and the District proceeded accordingly with staffing N actions. On January 15, 1982, the NRC letter from John'F. Stolz, again l Se requested the District's schedule for meeting the Interim Criteria for Shif t

@@c. Staffing. The District reiterated the same schedule by letter dated l

Ah ELECTRIC SYSTEM SERVING MORE THAN 600.000 IN THF HEART OF CALtF0PhiA

o- o SECRETARY OF THE COMMISSION Page 2 September 24, 1982 February 11, 1982. The proposed rule change completely disregards the District's previous responses and fails to recognize that operating personnel cannot be licensed " overnight".

Historically, the District's Operator Licensing Program has been deliberate and extensive. Normally, a qualified candidate spends a minimum of eighteen to twenty-four months as an unlicensed operator in the plant prior to beginning reactor operator training. The license training program then takes approxi-mately sixteen months to complete. In addition, the NRC has imposed a one year experience requirement as a licensed reactor operator prior to taking the Senior Operator Examination, and the District's upgrade training program for Senior Operator requires approximately seven months. Candidates put uo for licensing by the District have been 100% successful in passing the NRC examination on the first attempt under the post-TMI 80%-70% criteria. This is in stark con-trast to the experience of many other utilities. We firmly believe that any

, attempt to speed up the District program can only lead to adverse safety impli-cations for the General Public.

IE Circular No. 80-02, of Febraury 1,1980, established overtime guidance to assure that operating personnel are physically prepared to stand a competent duty. The District, as a result of this guidance, has committed to establish

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-_ . a_six-shift rotation to minimize. overtime and._in particular, to eliminate the_ . ,

requirement to conduct ~ training'on an' overtime basis.~ As'a result of industry's commitment to INPO, the required operator requalification program has expanded, making the nonovertime training goal even more important. This commitment to six shifts was enhanced by INPO comments resulting from the 1981 audit and more recently by an outside consultant review conducted as a commitment given to the NRC Regional Director during an enforcement conference. This six-shift rotation commitment would have to be delayed for many months if a requirement is made to increase the licensed operator staffing per shift in 1983.

Discussions with other utilities indicate that many other plants would have to meet the increased shift staffing by scheduled overtime and by less than six shift rotations. In light of industry experience and IE Circular No. 80-02, this action seems contrary to the best interest of safety. It would seem that if in fact utilities do take these steps because of the proposed rule change, the NRC is guilty of enforcing one requirement without thoroughly evaluating its resulting impact on other guidance the industry is trying to meet. Here is an excellent example of how a rule change removes flexibility which the Technical Specifications allow.

Amendment No. 31 to the Rancho Seco Operating License prescribed in the Technical Specifications that a Shift Technical Advisor (STA) be available to shift crew personnel. The District has embarked on a training program to license Shift Technical Advisors currently on staff. This program, voluntary in nature, is being pursued as a means of strengthening the overall capability of the operating crew and support staff. Two of the District's STA's are currently licensed as Reactor Operators and four others are in training with an anticipated licensing date of March 1,1983.

A final comment that should be considered deals with a serious situation which the NRC guidance has caused. The p,roposed rule and earlier guidance is promoting personnel piracy within the industry, t

o.

SECRETARY OF THE COMMISSION Page 3 September 24, 1982 Enclosed is a letter that has been sent directly to the homes of numerous District employees. This is typical of several such piracy attempts which  !

are known to District management. In addition, the local media in areas '

where experienced nuclear personnel are concentrated as well as industry publications are comonly used to advertise opportunities. The direct home I mailing generally comes about from concentrated programs aimed at particular individuals. In the case of the example we have enclosed, we feel that it  !

represents recognition that the District has acquired and trained excellent l operating personnel. However, it also illustrates the extent to which some hiring firms will go to meet their employer's requests. These requests are undoubtedly a direct result of the NRC's mandated staffing requirements and the proposed deadline dates which we fear are to become law without benefit of seriously looking at each facility's unique situations. What is particu-larly distressing about this solicitation is that the salary offers from the '

investor owned utility sponsoring the recruiter exceed the District's salary structure by 15%-32%, and the license bonus by 43% or more. Since the i i District is municipally owned, it has many of the same type of fiscal restraints and public responsibilities with respect to salary and benefits with which 1 U.S. Federal organizations are faced. I It should also be pointed out in this context, that piracy of licensed personnel actually decreases the supply of licensed operators at U.S. Nuclear power stations. Not only do many of these individuals leave the utility industry, many that join other utilities do so in nonshif t operations capacities. Even those licensed personnel who join a new utility to remain in shift operations are removed from licensed duty for one to two years while they train and license on the new facility. ,

If due consideration is given the above comments, the District is confident that the Commission will see the merits in dealing with power station staffing levels and deadlines for those levels on a case by case basis and rescind the l

proposed change to 10CFR50.54. The Technical Specification conditions for oper-ation certainly provide for establishing Commission requirements and at the same time provide for much more flexibility than does the proposed rule change.

!{WA Jo n J. Mattimoe General Manager t Enclosure i e cc: R. DeYoung I J.F.Stolz/ ' 1 ( , l

VARO Ab D LUb D CORPORATIOb ( i p\mt i f 4 Nim If I \t 4\ 4(,l \ll NI II\ I)()%tl%Il{ 4 \f 3 INIllf \ 4Ilf)\ 41 ( \lfl'Il\ l %IL IIIl()\ f%e Our finn is providing consulting services to ,

                       , the largest power producer in                                                     .           is in the midst of a very major nuclear power expansion and will shortly be bringing                                                         MWe on stream.

The difficult and frustrating period of licensing, hearings and construction is essentially completed. This expansion and their plans for the future have opened key career opportunities, which we would like to discuss with you, is one of the largest invester-owned utilities in the U.S. and has an excellent reputation in the community at large. It has low employee turnover and a finn comitment to promotion from within. The wann, sunny climate here in provides an ideal setting for working, living and outdoor activities. We want to attract an experienced individual who is excited by new challenges and really en, joys being involved in nuclear plant operations or in the engineering, safety or health physics aspects of nuclear power generation. I have attached specific information on some of these career opportunities and starting salaries for yoQr consideration. Also described is the excellent reloca-tion program and comprehensive company benefits. If you would like to explore thi: career situation further on a confidential basis, I would be pleased to receive a copy of your resume or simply a handwritten outline of your background and experience. There is obviously no financial obligation on your part. After it arrives here, we will get back in touch with you to discuss the situation further and answer any questions you may have. However, if you would prefer to first dis-cuss the situation by phone, please call collect at 213/469-3109. If this opportunity is not of interest, I would be pleased if you would discuss this with others who might like to investigate this situation. Sincerely,

                 !                                                                              VAR 0 AND LilND CORPORATION J. Kenneth Lund Senior Vice President JKL/rbi
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 . . . , ,           CORPOR ATE Of flCE: 1800 NORTH HIGHLAND AVENUE * $UITE 412

• LOS ANCILES. CALIFORNf A 90028
• U.S.A.

Cb TELEPHONE: (213) 469 3109 CA8tf ADDRESS: VAKCOR

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 ;                                                                              VARO AND LUND CORPORATION j                                                                                            Consultants 4                                                                                1800 North Highland Ave,

! Los Angeles, CA. 90028 j 213/469-3109 I' NUCLEAR CAREER OPPORTUNITIES AT I ' is a large investor owned utility provid- Another important position is that of I Ing electric service to a 500,000 squa re COORDINATOR. Responsible for di recting

 !                  mile area. Peak generating capacity in 1981                                        and coordinating programs on equipment
!                   totaled over 13,000 megawatts (MW) . During                                        status and outage control, and providing

) the next two years, MWe of new nuclear technical' support to ensure' optimum plant power will be added. One of two new pressur- performance, maintain compliance and safe j iz:d water reactor (PWR) nuclear plants is opera t ions . Requires at least four years about to go intoi full power testing. Con- of nuclear operating experience. Although

struction of the second is almost complete. not required, an SRO or R0 license, or i in addition to nuclear and fossIIe fuel-fired nuclear navy experience at the engineer j generating units, is deeply involved in officer or E00W level, would be a strong j developing alternative and renewable energy plus. Starting Salary can go up to $41,000,

 !                  sources such as hydroelectric, cogeneration,                                      plus a yearly bonus of $6,000 if you already wind, geothermal, solar and fuel cells,                                            have an SRO license, or-a yearly bonus of-.
                                                                                                                                            ~

i $4,800 if you already hase an R0 Ilcense. l LOCATION ] Corporate headquarters and staff depart- In Engineering and support divisions, there j ments are located in a " campus" setting in are the following important positions. The a suburban area. The nuclear

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starting salary of each can go up to , j power facIIIties and operations staff are $46,000 for highly qualified and experi-l situated - enced Individuals. LICENSLNG ENGINEER in-l volved in establishing design criteria for all nuclear work and working closely with CAREER OPPORTUNITIES the NRC. Requi res a 8.S. or M.S . In nuc-j There are selected openings in the Nuclear lear, mechanical or electrical engineering

;                  Engineering and Operations Department,                                            plus at least several years of nuclear                                     .

i described below. In essentially all cases power plant experience or Navy nuclear I there is a need for more than one indiv- trained of ficer experience. 2 idual in each position. The starting

 ;                 salaries are attractive and are more than                                         SAFETY ENGINEER involved in preparing and

! competitive. Depending on background and maintaining plant safety and environmen-j experience, they can go up to the numbers tal specifications, monitoring plant per-

shown below. formance, reconnending modi fIcations,etc.

i Required background is similar to that-l In plant Operations, there is a most for the LICENSING ENGINEER. a impo(tant need for ASSISTANT SHIFT SUPER- ) VISORS, requiring el ther a Senior Reactor COMPLIANCE ENGINEER to coordinate regula-

 !                 Operator (SRO) license with PWR experience                                        tory-related activi ties with NRC inspec-j                   or non-SRO license with PWR ravy nuclear                                          tors and the                    ti,ta f f, and impl ement experience.               Starting salary can go up to                            regulatory requirements. Requires a B.S.

! $41,000 plus a yearly bonus of $6,000 if degree in engineering, science or related you already have an SRO license, or a discipline with experience in licensing , yearly bonus of $4,800 if you already have ' or comnercial nuclear operations. l an RO IIcense. 1 i

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CONFIGURATION _ CONTROL ENGINEER to estab- NUCLEAR TRAINING INSTRUCTOR which requires lish and maintain a large scale comput- technical instruction experience and ei ther erized system for technical information a PWR-SRO license or a BWR-SRO license wi th s torage, update and retrieval . Requires PWR experience, or a " certified" SRO in degree in engineering or computer science PWR or BWR. Starting salary for this and experience in configuration control in position can go up to $40,000. either power plant operation, aerospace, shipbuilding or heavy construction. RELOCATION Applicable military or gbvernment exper-ience may be acceptable. There is an excellent relocation program - which includes a "home purchase" plan. In FIRE PROTECTION ENGINEER to establish and essence, will buy your current home and maintain fi re protection /supression, fi re pay closing costs on that home and the new hazard analysis and prepare emergency pre- one you purchase, and will pay a generous paredness procedures. Requires degree in portion of any increased mortgage interest mechanical, nuclear or fire protection payments for the first three years of your engineering, or related field plus solid employment. The cost of moving, a house-experience. hunting trip and up to $2000 of miscellan-eous expenses on moving into the new home STARTUP ENGINEER to prepare pre operational will also be paid for. and initial startup testing, conduct start-up tests and evaluate results. Requi res COMPANY BENEFITS ' degree in nuclear, mechanical or electrical engineering plus at least several years There are comprehensive and excellent com-experience in a recent nuclear startup pany benefits, including life, medical, program or plant operation, dental and disability insurances, a stock purchase plan with company contribution, HEALTH PHYSICS ENGINEER to advise on the vacations and 12 paid holidays, and a com-radiation protection program, participate pany paid retirement plan. in audi ts and reviews, and assist in the respi rator protection, dosemetry and radi- l ation waste programs and materials control l activities. Requires degree in heal th l physics, chemistry, nuclear engineering or related discipline plus experience in nuclear operation radiation programs. s t i _ . _ _ . _ . _ __ - . ~ . .- . _ _.}}