RS-02-129, Revision to Request for Exemption from 10CFR 55.59
| ML022110573 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/08/2002 |
| From: | Jury K Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-02-129 | |
| Download: ML022110573 (6) | |
Text
Exelons.
Exelon Generation www.exeloncorp.com Nuclear 4300 Winfield Road Warrenville, IL60555 RS-02-129 July 8, 2002 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Revision to Request for Exemption from 10 CFR 55.59
Reference:
Letter from K. R. Jury (Exelon Generation Company, LLC) to U. S. NRC, "Request for Exemption from Certain Requirements of 10 CFR 55.59,"
dated July 2, 2002 In the referenced letter, Exelon Generation Company (Exelon), LLC requested NRC approval of a one-time exemption from the requirements of 10 CFR 55.59, "Requalification," paragraphs (a)(1) and (a)(2) for 54 licensed individuals named in the referenced letter. The requested exemption would allow for a one-time extension of the comprehensive requalification written examinations from the required 24-month interval to an interval of approximately 30 months.
As discussed in teleconferences on July 3, 2002, between members of Exelon and members of the NRC, Exelon is revising the referenced letter via this letter to specify that the exemption is being requested from 10 CFR 55.59, paragraph (c)(1) for the facility licensee (i.e., Exelon), rather than for the named licensed individuals. The attachment to this letter provides the revised request.
On July 3, 2002, also as a result of the above teleconferences, Exelon requested enforcement discretion on behalf of the licensed individuals named in the referenced letter. Verbal approval for this enforcement discretion was granted by the NRC on July 3, 2002, and Exelon is submitting a written follow-up to this request under separate cover.
The NRC also requested that Exelon provide a commitment regarding the scheduling of the next requalification written examinations at DNPS. These examinations will be conducted during January and February 2004, and will cover the material presented in the current requalification training cycle that extends from February 2002 through February 2004.
July 8, 2002 U. S. Nuclear Regulatory Commission Page 2 As explained in the attachment to this letter, the requested exemption from 10 CFR 55.59(c)(1) is authorized by law, does not endanger life or property, and is otherwise in the public interest.
We are requesting expedited NRC review and approval of this exemption in order to restore compliance with the referenced requirements until DNPS completes comprehensive requalification written examinations for all licensed individuals. These examinations began during the week of June 24, 2002, and are scheduled to be completed for all licensed personnel on shift and the senior station license holder (i.e.,
Shift Operations Superintendent) by July 17, 2002, and for all remaining licensed individuals by August 2, 2002.
If you have any questions concerning this letter, please contact Mr. Allan R. Haeger at (630) 657-2807.
Respectfully, Keith R. Jury Director - Licensing Mid-West Regional Operating Group
Attachment:
Description and Analysis of Proposed Exemption cc: Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station
Attachment Request for Exemption from Certain Requirements of 10 CFR 55.59 Dresden Nuclear Power Station Description and Analysis of Proposed Exemption A. Requested Exemption and Circumstances Leading to the Request In accordance with 10 CFR 55.11, "Specific exemptions," Exelon Generation Company (Exelon), LLC is requesting NRC approval of a one-time exemption from the requirements of 10 CFR 55.59, "Requalification," paragraph (c)(1) for the Dresden Nuclear Power Station (DNPS). The requested exemption would allow for a one-time extension of the comprehensive requalification written examinations required in paragraph (c)(4)(i) from the 24-month interval required by paragraph (c)(1) to an interval of approximately 30 months. DNPS plans to complete the examinations for all licensed personnel on shift and the senior station license holder (i.e., Shift Operations Superintendent) by July 17, 2002, and for all remaining licensed individuals by August 2, 2002.
This exemption is being requested due to circumstances which led DNPS to erroneously schedule the comprehensive requalification written examinations at an interval greater than the required 24 months. During January - February 2000, DNPS administered a comprehensive requalification written examination for all licensed individuals as required by 10 CFR 55.59. This examination covered training material for the period from April 1998 to February 2000. The next comprehensive requalification written examination to meet the requirements of 10 CFR 55.59 was scheduled to occur in June - July of 2002.
This examination was to cover training material for the period from February 2000 to February 2002. Thus, the examination scheduled for 2002 addresses all of the training material covered during the applicable requalification training period. However, the scheduled time interval for the 2002 examination exceeds the required 24-month interval. DNPS is performing an evaluation to determine the root cause of this scheduling error and will implement corrective actions to prevent recurrence. Exelon will apply corrective actions resulting from this evaluation to our other licensed facilities as applicable.
B. Basis for Exemption Request The criteria for granting specific exemptions from 10 CFR 55 regulations are stated in 10 CFR 55.11. In accordance with 10 CFR 55.11, the NRC is authorized to grant an exemption upon determining that the exemption is authorized by law and will not endanger life or property and is otherwise in the public interest.
As detailed in the following paragraphs, the requested exemption will not endanger life or property and is otherwise in the public interest.
Individuals requesting exemptions have demonstrated knowledge and performance capabilities.
The individuals requesting this exemption are currently enrolled in an operator requalification program that was developed through a systems approach to training as Page 1 of 4
Attachment Request for Exemption from Certain Requirements of 10 CFR 55.59 Dresden Nuclear Power Station defined in 10 CFR 55.4, "Definitions." During the training program, operator knowledge and skills have been evaluated using "out of the box" simulator dynamic evaluations and periodic written quizzes. These out of the box simulator evaluations are given near the beginning of the requalification training weeks and measure the retention and application of skills and knowledge. The results of these evaluations are as follows.
"* During the time period from July 2001 through June 2002, the six operating crews were examined with four out of the box evaluations for each crew. Each crew is divided into two sub-crews for the evaluations. Thus, a total of 48 out of the box evaluations were performed. Of these 48 evaluations, two sub-crews failed. These sub-crews were remediated and successfully re-evaluated. This performance indicates sound operator retention of operational knowledge and skills.
"* As part of simulator training during the time period from July 2001 through June 2002, 267 individual evaluations were performed. There were seven individual failures. Each of these individuals were remediated and successfully re-evaluated.
"* In 2002, 64 written quizzes were administered with no failures.
Licensed individuals satisfactorily completed an annual operating examination in November - December 2001, as required by 10 CFR 55.59, paragraph (c)(4)(i). This examination was prepared and conducted in accordance with the guidance in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors," Revision 8, and included simulator dynamic examinations and job performance measures (JPMs). All individuals successfully completed the dynamic and JPM examinations.
During January - February 2001, licensed individuals successfully completed a comprehensive written examination on the recently implemented conversion to improved technical specifications (ITS).
Licensed individuals satisfactorily completed a comprehensive written examination in July - September of 2001. This examination was not intended to satisfy the requirements of 10 CFR 55.59, but was scheduled in order to cover a representative sample of material for the previous two years of instruction, with the exception of the ITS material described above. This examination was developed from a sample plan that included selected topics presented from August 1998 to August 2000. Of 54 licensed operators examined, one senior reactor operator (SRO) failed the written examination.
The SRO was remediated and successfully re-evaluated. The scope of the combination of the evaluations described above is similar to the scope of examinations required by 10 CFR 55.59.
The requalification written examinations required by 10 CFR 55.59 (c)(1) and (c)(4)(i) were begun during the week of June 24, 2002. These examinations cover training material for the period from January 2000 to February 2002, and have been administered to one crew consisting of ten licensed operators with no failures. The average examination score was 96.3%.
The results of these evaluations indicate sound retention of knowledge and skills, and that the licensed individuals are fully capable of performing their duties.
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Attachment Request for Exemption from Certain Requirements of 10 CFR 55.59 Dresden Nuclear Power Station In addition, members of the DNPS and Exelon Nuclear Oversight staffs performed augmented on-shift oversight at DNPS during the period June 21 - June 26, 2002, to specifically review operator performance, including operator skills and knowledge.
Personnel performing the oversight included previously licensed individuals. No issues related to operator knowledge and skills deficiencies were identified during this augmented oversight period.
On-shift licensed operator staffing at DNPS exceeds the minimum required.
10 CFR 50.54, "Conditions of licenses," paragraph (m), requires a minimum staffing of two SROs and three reactor operators (ROs) for a single control room with two operating units. At DNPS, all operating crews have at least three SROs and four ROs. These additional resources reduce the workload that would be present given the minimum staffing and allow each DNPS crew to take advantage of the additional knowledge and skills of these extra individuals.
Each operating shift crew includes at least one individual that has successfully completed the requirements of the requalification program.
Ten DNPS licensed individuals received their licenses in 2001, and thus have not exceeded the 24-month interval for the requalification written examination. Additionally, as of June 30, 2002, an additional five (i.e., beyond the ten recently-licensed individuals) on-shift licensed individuals successfully completed the requalification written examinations that began during the week of June 24, 2002. Each of the DNPS operating crews contains at least one licensed individual from among these fifteen individuals.
Exelon has minimized the number of plant activities that have the potential to cause unplanned unit shutdowns or deratings.
Due to the expected high electric power demand during the summer period, Exelon has minimized the number of plant activities that have the potential to cause unplanned unit shutdowns or deratings. This action minimizes the potential challenges faced by licensed individuals.
In summary, the individuals requesting the exemption have demonstrated knowledge and performance capabilities similar to those demonstrated in the comprehensive requalification written examinations. Further, on-shift licensed operator staffing at DNPS exceeds the minimum required by the Code of Federal Regulations. Additionally, each operating shift crew includes at least one individual that has successfully completed the requirements of the requalification program. Finally, due to the expected high electric power demand during the summer period, Exelon has minimized the number of plant activities that have the potential to cause unplanned unit shutdowns or deratings. This action minimizes the potential challenges faced by licensed individuals.
Based on the above, Exelon considers that the exemption is authorized by law and will not endanger life or property and is otherwise in the public interest.
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Attachment Request for Exemption from Certain Requirements of 10 CFR 55.59 Dresden Nuclear Power Station C. Environmental Assessment In accordance with 10 CFR 51.30, "Environmental assessment," and 10 CFR 51.32, "Finding of no significant impact," the following information is provided in support of an environmental assessment and finding of no significant impact for the proposed action.
The proposed action would grant an exemption from the requirements of 10 CFR 55.59(c)(1). The requested exemption would allow for a one-time extension of the comprehensive requalification written examinations required in paragraph (c)(4)(i) from the 24-month interval required by paragraph (c)(1) to an interval of approximately 30 months. DNPS plans to complete the examinations for all licensed personnel on shift and the senior station license holder (i.e., Shift Operations Superintendent) by July 17, 2002, and for all remaining licensed individuals by August 2, 2002.
The requested exemption is needed due to circumstances which led DNPS to erroneously schedule the comprehensive requalification written examinations at an interval greater than the required 24 months.
The principal alternative to the proposed action would be to deny the requested exemption. This would significantly reduce the number of individuals meeting the requirements of 10 CFR 55.59 and would require significant operating crew re alignment. Denial of the exemption request would result in no change in environmental impacts.
The proposed action (i.e., granting the exemption) will not increase the probability or consequences of accidents, no changes are being made in the types or quantities of any radiological effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.
The proposed action does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed action.
The environmental impacts of the proposed action and the alternative action are similar.
Based on the assessment above, the proposed action will not have a significant effect on the environment.
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