ML17320B146

Requests That NRC Reconsider Position Re Shift Technical Advisor Training Program Requirements,Per NUREG-0737,Item I.A.1.1 & Delay Final Decision Until Issuance of Rule. Interim Requirement Not in Best Interest of New Hires

ML17320B146
Person / Time
Site:	Calvert Cliffs
Issue date:	01/04/1983
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Clark R Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM NUDOCS 8301070329
Download: ML17320B146 (6)

Text

REGULA' INFORMATION DISTR IBUTIO YSTEM ('RIDS)

ACCESSION NBR18301070329 DOC DATE: 83/01/00 NOTARIZED! NO DOCKET

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'AUTHNAME 'UTHOR AFFILIATION LUNDVALLiA~ E< Baltimore Gas & Electr ic Co ~

RECIP ~ NAME RECIPIENT AFFILIATION

'CLARKi'Re A i, Operating Reactors Branch 3

SUBJECT:

>Requests that NRC reconsider pos)tfon .re ~shrift technical

-advisor <<<<training <<prdgr am requirementsiper NUREG 0737iItem I ~ A ~ 1'1 & idelay fina) decision until issuance of "rule.

Interim -requirement =-not-"$ n best interest of "new hires" ~

DI'STRIBUTION <<CODE! "A046S 'COPIES <<RECEIVED! LTR ".ENCL, "SIZE!

TI<<TLE! OR 'Submjttal'! >TMI Action 'Plan 'Rgmt NUREG 0737 & NUREG-0660 NOTES!

RECIPIENT <<COPIES RECIPIENT <<COPIES ID 'CODE/NAME l",TTR ENCL ID CODE/NAME- LT<<TR ENCL

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,NRR/DSI/ADRP 26 1 1 NRR/DSI/ADRS 27 1 NRR/DSI/AEB 1 1 N AB 1 1 NRR/DST DIR 930 1- REG F LE 04 1

'RGA1 1 EXTERNAL! ACRS 3Q 10 10 FEMA~REP DIV 1 INI OiJ;STARNES 1 1 LPDR 03 1 NRC,PDR 02 1 NSIC 05 1 1 NTIS 1 1

)TOTAL NUMBER OF <<COPXES REQUIRED: UTTR 44 ENCL 03

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PP BALTIMORE GAS AND ELECTRIC CHARLES CENTER ~ P.O. BOX 1475 ~ BALTIMORE, MARYLAND21203 ARTHUR E. LUNDVALL.JR.

VICL PACSIOENT Su> S LV January 0, 1983 U.S. Nuclear Regulatory Commission Division of Licensing Washington, DC 20555 ATTENTION: Mr. Robert A. Clark, Chief Operating Reactors Branch 83

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. 1 R 2; Docket Nos. 50-317 R 50-318 Shif t Technical Advisor (STA)

REFERENCE:

(a) Letter dated July 9, 1982, to A. E. Lundvall, Jr., from R. A. Clark on NUREG-0737, Item I.A.1.1 Shift Technical Advisor Gentlemen:

In reference (a) you found that our STA training program met the intent of your previous correspondence on the same subject. However, you also indicated that "new hires" to the STA program are expected to have a bachelor's degree or equivalent in a scientific or engineering discipline.

As you are aware, the STA training program was given to all Shift Supervisors and Senior Control Room Operators (SCROs) who were incumbent in their positions at the time the program was conducted. The SCROs who successfully completed the program were then utilized on shift as STAs, in addition to the SCRO normally required for shift staffing.

After the start of the original STA training, four additional individuals were promoted to SCRO and were incumbent in that position at the time of your July 9, 1982, letter was issued. It had been planned to conduct STA training for these persons beginning in early 1983. Since these four SCROs are not "new hires" to the program, unless otherwise notified by your staff, we intend to continue with their training and to include them in the shift rotation as STAs after successful completion of the course.

To further address the question of degreed "new hires", we are aware of the efforts of the staff in drafting the "Integrated Plan for the Development of a Rule for Shift Crew Qualifications" which proposes a final rule in FY-80. To shift our training resources at this time to support the training of degreed individuals as STAs would have a major impact on our ability to provide initial and requalification training for Operator Licensed (OL) and Senior Operator Licensed (SOL) individuals. It is our goal to train and license enough OL and SOL personnel to support a six-shift rotation by the end of 1983. To do so, we are conducting concurrent classes for OL candidates, staggered by approximately six months. Included in these plans, is licensing enough individuals to staff the full scale simulator scheduled for operation in early 1980. This schedule was developed two years 830i070329 830i04 PDR ADOCK 05000317 P PDR

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Mr. Robert A. Clark 3anuary 0, 1983 Page 2 ago and has been a major priority of the Baltimore Gas R Electric Company. To interrupt this schedule by interposing a requirement for additional, intensive training for degreed STA candidates would delay the attainment of the six-shift goal and could impact our ability to test and place into operation our full scale simulator on time.

Since the staff has found our present STA program to be acceptable in meeting currently published guidelines, and the study of a proposed rule which will make a final determination regarding the need for degreed individuals on-shift is in progress, we do not feel that the imposition of an interim requirement for degreed "new hires" to the STA program is in the best interests of safe plant operation. In our opinion, the dedication of our training resources to the six-shift goal and support of the simulator will be of much greater long-term value than the implementatoin of the interim measures set forth by your letter. We, therefore, request that you reconsider your position and delay any final decision in this area until the issuance of a rule on this matter.

Should you require further information regarding these matters, we would be pleased to meet with you at your convenience.

Very truly yours, Vice Presiden - Supply AEL/RED/gla cc: 3. A. Biddison, Esquire G. F. Trowbridge, Esquire D. H. 3affe, NRC

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