ML20210B907

Requests NRC Reconsider 860902 Denial of 860709 Proposed Amend to Tech Specs Allowing Exception to Experience Requirements for Two Senior Reactor Operator Upgrade Applicants

ML20210B907
Person / Time
Site:	Catawba
Issue date:	09/12/1986
From:	Tucker H DUKE POWER CO.
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20210B912	List: ML20210B907 ML20210B915 ML20210B935
References
NUDOCS 8609180199
Download: ML20210B907 (2)

Text

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DuxE POWER GOMPANY j

P.O. BOX 33180 CHARLOTTE, N.O. 28242 HAL B. TUCKER ret.ernorsu (704) 373-4934 September 12, 1986 5

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation

- U. S. Nuclear Regulatory Commission-Washington, D. C.

20555 Attention:

Mr. B. J. Youngblood, Project Director PWR Project Directorate No. 4 Re: Catawba Nuclear Station Docket No. 50-413 and 50-414

Dear Mr. Denton:

I On July 9, 1986, Duke Power Company (Duke) submitted a proposed amendment to the Technical Specifications for Catawba Units 1 and 2.

The proposed change would allow an exception to the experience requirements of Specification 6.3.1 for two Senior Reactor Operator (SRO) upgrade applicants. A similar reguest had been approved on January 24, 1986 for six SRO upgrades at Catawba.

On September 2, 1986, Duke received a response from the Staff denying the requested j

Technical Specification change. The reason given for the denial was the Staff's conclusion that extenuating circumstances do not exist in the current situation since both Catawba units are in operation. This conclusion is apparently in reference to the circumstances that existed approximately one year ago for the group of six SRO upgrades granted waivers by the Staff. At that time, the six SRO's could have been " cold" licensed as SRO's on Catawba Unit 2 which was not yet in operation, but could not be " hot" licensed as SR0s on Catawba Unit I due to the experience requirements of Technical Specification 6.3.1.

These circumstances were noted in the Federal Register Notice (50 FR 46212) that preceded the January 24, i

1986 amendment, but were not cited as a basis for granting the requested waiver in the Safety Evaluation that accompanied the amendment.

Instead it was noted that waivers may be granted on a case-by-case basis if the NRC staff determines that an equivalency to the standard guidelines exists.

In an effort to demonstrate that the two current SRO upgrade candidates possessed an equivalent amount of experience to that required by the Technical Specification reqdirement, Duke Power supplemented the License applications of K. W. Beaver and i

T. S. Ramseur on August 4, and August 27,~1986. Copies of these letters to l

NRC/ Region II are attached (home addresses have been deleted). As demonstrated by i'

these supplements and the original applications both candidates have been highly trained at Catawba, each has held a reactor operator license for approximately 2 years (27 months and 22 months, respectively). Both candidates have greater than 8 1/2 years of experience on-site at Catawba, during which each has been actively involved in preoperational testing and checkout, startup testing, and operator training.

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Mr. Har:1d R. D:nt:n, Dirceter September 12, 1986

- Page Two It is therefore our conclusion that each applicant's work-related experience and training more than offsets the amount by which his experience falls short of the stated guidelines. It is therefore requested that the NRC reconsider the denial of the July 9, 1986 amendment and proceed expeditiously to process the requested Technical Specification change.

Very truly yours, 1

g I

Hal B. Tucker ROS/14/ sib Attachment xc:

Dr. J. Nelson Grace, Regional Administration U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Catawba Nuclear Station l

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