SBK-L-10121, Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-01, Operations Manager Qualification Requirements
| ML101960051 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/09/2010 |
| From: | Freeman P NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LAR 10-01, SBK-L-10121, TAC ME3585 | |
| Download: ML101960051 (5) | |
Text
NExTera ENERQ Y f
SEABROOK July 9, 2010 10 CFR 50.90 SBK-L-10121 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request (LAR)
.10-01, "Operations Manager Qualification Requirements"
References:
- 1. NextEra Energy Seabrook, LLC letter SBK-L-10010, "License Amendment Request 10-01, Operations Manager Qualification Requirements," March 16, 2010.
- 2. NRC Draft Request for Additional Information Regarding License Amendment Request to Modify Operations Manager Qualification Requirements (TAC No. ME3585), June 22,2010 In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed amendment modifies the requirements for the Operations Manager by allowing certification for equivalent knowledge in lieu of having held a senior operator license.
In Reference 2, the NRC requested additional information in order to complete its review of the LAR. The Enclosure contains NextEra's response to the request for additional information.
Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.
V0O5 NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874
United States Nuclear Regulatory Commission SBK-L-10121 / Page 2 Sincerely, NextEra Energy Seabrook, LLC.
Paul Freeman Site Vice President Enclosure cc:
S. J. Collins, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Senior Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
SaPL L Seabrook Station AFFIDAVIT I, Paul Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this response to request for additional information regarding License Amendment Request 10-01 are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed before me this q
dayof 2010 Paul Freeman Site Vice President
Enclosure Request for Additional Information (RAI) 10 CFR 50.54 requires that the licensee designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators pursuant to part 55 of that chapter. Clarify if the possibility exists that, due to delegation of authority, the Operations Manager would be directing licensed activities of the Shift Managers or other licensed operations personnel. If it is possible that the Operations Manager may be in a situation where he is directing licensed activities, please clarify how this situation would be handled in the event that the Operations manager did not hold a senior operator license.
Response
Seabrook Station's current technical specifications (TS) require that the Operations Manager shall have held a senior operator license for Seabrook prior to assuming the position of Operations Manager. Because the Operations Manager is not currently required to hold a senior operator license, the Assistant Operations Manager, who is required by TS 6.2.2.g to hold a senior operator license, is the individual designated to direct the licensed activities of the Shift Managers. The Shift Managers then direct the activities of the on-shift licensed operators. Designating the Assistant Operations Manager as the individual responsible for directing the licensed activities of the licensed operators and requiring the individual in this position to hold a senior operator license satisfies the requirements of 10 CFR 50.54. Further, this approach prevents a situation involving delegation of authority such that the Operations Manager would be directing licensed activities of the Shift Managers or other licensed operations personnel, which would be contrary to 10 CFR 50.54.
The Assistant Operations Manager retains responsibility for directing the licensed operators and this responsibility cannot be delegated to a non-licensed individual. In the event that the licensed individual in the position of Assistant Operations Manager vacates this position, NextEra will continue to meet the requirements of 10 CFR 50.54. This situation was previously addressed with the NRC staff in response to a RAI [Reference 1]
regarding Amendment 20 [Reference 2] to the Seabrook Station TS, which removed the requirement for the Operations Manager to hold a senior operator license. In the event that the individual in the position of Assistant Operations Manager moves to another position, the most likely course of action would be to promote one of the Shift Managers to the position and conduct a turnover, as the station has done previously. In the event of death, disability, or other condition that would cause an immediate vacancy in the position, NextEra would take prompt action to fill the position as part of the normal management function. The availability of additional personnel that hold senior operator licenses, such as a spare Shift Manager and Work Control Supervisors, ensure the ability to fill a vacancy that requires a senior operator license.
References
- 1. North Atlantic Energy Service Corporation letter NYN-93032, "Request for Additional Information (TAC No. M84896)," February 26, 1993
- 2. "Amendment No. 20 to Facility Operating License NPF-86: Deletion of Requirement for Operations Manager to Maintain Senior Operator License -
License Amendment Request 92-04 (TAC M84896)," April 26, 1993