ML20024H633
| ML20024H633 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 05/31/1991 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9106070174 | |
| Download: ML20024H633 (4) | |
Text
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1 CFR55.11 PIIILADELPIIIA ELECTRIC CC511%NY NUCLEAR GROUP llEADQUARTERS 955-65 C!IESTERBROOK DLVD.
WAYNE, PA 19087 5691 (215) 640-6000 3_
E-NUCII.AR ENGINEERING & $0RVICES DEPARTMENT May 31, 1991 Docket Nos. 50-352 50-353 50-277 50-278 License Nos. NPF-39 NPF-85 s
DPR-44 DPR-55 Dr. Thomas E. Hurlef, Director Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Peach Bottom Atomic Power Station, Unitt: 2 and 3 Request for Exemption f rom 10CFR55.53 (e)
Related to Maintaining the Active Status of a License for Senior Reactor Operators Limited to Fuel Handling (LSRos) and Proposed Frequency /Durntion of LSRO Requalification Training
Dear Dr. Murley:
We are submi' ting this letter (1) to request an exemption, in accordance with 10CFR55.11, from the requirements of 10CFR55.53(e) with respect to the number of hours and frequency required for a Senior Reactor Operator limited to fuel handling (LSRO) to actively perform the functions of an LSRO, in order to maintain an active LSRO license, and (2) to provide information describing our plans regarding the frequency and duration of LSRO requalification training.
Exemotion Request 10CFR55.53(e) stipulatos that in order to maintain the active status of an operator's license, a licensee shall actively perform the functions of an operator or senior operator on a minimum of seven B-hour (56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br />) or five 12-hour (60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />) shifts per calendar quarter.
This rule makes no distinction I h)\\
between the functions of a Senior Reactor Operator (SRO) and an 3
LSRO.
i 9106070174 L10531 I
PDR ADOCK 05000277 P
r Dr. Thomas E. Murley May 31, 1991 Office of Nuclear Reactor Regulation Page 2 We have implemented a new LSRO program that established LSRos with a dual license applicable at both Limerick Generating Station (LGS), Units 1 and 2, and Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.
The objective of the LSRO program is to maintain a small group of licensed personnel to supervise core alterations (reactor refueling and invessel maintenance activities) during refueling outages at each of the four ISS and PBAPS nuclear units.
There are currently nine (9)
LSRos who hold a dual SRO license limited to fuel handling.
10CFR55.53(e) requires an SRO to actively perform the functions of an SRO for a minimum of 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> per calendar quarter to maintain an active SRO license.
However, the LSRos only perform licensed duties that are associated with refueling-related activities during the refueling outages at LGS and PBAPS.
Our refueling outages for LGF and PBAPS are scheduled on an alternating basis such
- hat there are two (2) units in a refueling outage each y.r; one unit at LGS in the spring and one unit at PBAPS in the fall.
Because of the limited scope of LSRO duties combined with the refueling schedule related frequency during which these duties are performed, the LSROs will not be able to maintain their licenses in an active status in accordance with the requirements of 10CFR55.53(e).
Therefore, we request an exemption from 10CFR55.53(e) such that the hours and frequency required for an LSRO to actively perform LSRO functions in order to maintain an active LSRO license be established at a minimum of 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> semiannually.
This prcposed requirement is commensurate with the scope of LSRO duties and the frequency at which they are performed.
The justification for this exemption request is provided below in accordance with 10CFRSE.11.
In addition, information is provided in accordarce with 10CFn51.30 which supports the conclusion that the approval of this exemption request would not have an effect on the environment.
Justification for the Exemotion Under 10CFR55.11, the NRC may grant exemptions from the requirements of 10CFR55 which are authorized by law and will not endanger life or property, and are otherwise in the public interest.
We are requesting an exemption from the requirement of 10CFR55.53(e) which establishes the hours and frequency required for a licensed operator to actively perform the applicable licensed duties in order to maintain an active license.
The purpose of this requirement is to maintain the proficiency of the operators who are performing the licensed duties.
The scope of LSRO duties is limited relative to the duties of an SRO.
At Philadelphia Electric Company (PECo), the LSRO duties are highly specialized and focus only on those duties associated with refueling-related activities.
As such, the LSRO licensed duties are only performed during the alternating ref'011ng outages at LGS and PBAPS each year.
In other words, the LSRO duties involve a concentrated effort on a periodic basis, and given the nature
l Or. Thomas E. Murley May 31, 1991 Office of Nuclear Reactor Regulation Page 3 of the duties, are performed as often as is possible.
Additionally, because the proposed LSRO program only calls for a small number of LSROs, we expect that these individuals will participate in each LGS and PBAPS refueling outage each year during the time they hold an LSRO license.
Actual experience indicates that LSRO proficiency has increased as a result of participation by the same LSROs in the previous three (3) refueling outages; LGS Unit 1, PBAPS Unit 2, and LGS Unit 2.
Our LSRO program calls for a commitment of four (4) years from each LSRO with personnel rotating through the program on a staggered basis to provide for a change in personnel while maintaining an optimum level of experience among the LSROs.
Therefore, we conclude that establishing a requirement of 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> semiannually to maintain an active LSRO license meets the underlying purpose of 10CFR55.53(c) to maintain the proficiency of the ISROs.
Environmental Assessment Environmental Impact of the Proposed Action Approving this exemption request will not impact the environment since it does not involve the release of radioactive or non-radioactive effluents.
Alternative to the Proposed Action The previous t etion provides the basis for concluding that there are no environmental effects which would result from the approval of the requested exemption.
Accordingly, any alternatives with any environmental impact other than not approving this exemption request, need not be evaluated.
Alternate Use of Resources.
This exemption request, if granted, does not involve the use of any resources not previously considered in the Final Environmental Impact Statements for the LGS and PBAPS facilities.
Proposed Finding of No Significant Impact Based upon the foregoing environmental assessment, we conclude that the approval of our exemption equest will not have an effect on the quality of the human environment.
LSRO Recualification Trainina Frecuency and DuratioB 10CFR55. 59 (c) (1) stipulates that the requalification program must be conducted for a continuous period not to excead two years, and upon conclusion must be promptly followed, pursuant to a continuous schedule, by successive requalification programs.
The purpose of 10CFR55.59 (c) (1) is to ensure that the operator's requalification training is relative to the licensed duties performed and is commensurate with the frequency at which they are performed.
An SRO performs a broad scope of licensed duties on a continuous basis, and therefore, SRO requalification
ths. Thomas E.
Murley May 31, 1991 Office of Nuclear Reactor Regulation Page 4 training is conducted continuously over a two year period.
The requalification training for LGS and P3APS SROs, conducted just prior to a scheduled refueling outage, focuses on the duties to be performed during the outage.
Similarly, the duration and f requency of our proposed LSRO requalification training is commensurate with the scope and frequency of LSRO duties.
The LSRO duties are limited to those associated with refueling-related activities, and are performed as often as is possible (i.e., overy refueling outage with two refueling outages per year).
Therefore, the LSRO requalification training will be conducted over a two year period and will consist of two (2) training cycles per year; one cycle, at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in length, prior to each site's refueling outage.
As a minimum, one cycle will be conducted at each site (LGS and PBAPS) per year.
In other words, LSRO requalification training, relative to LSRO duties, will be conducted just prior to when those duties are required to be performed.
ThereCore, we conclude that the proposed LSRO requalifir,ation training frequency and duration will implement the purpose of 10CFR55.59 (c) (1) and consequently satisfies the requirements of the rule with regard to the conduct of a requalification program for a continuous period not to exceed two years.
If the NRC does not concur with our assessment, please consider the information provided in this letter as a request and justification for an exemption, in accordance with 10CFR55.11, f rom the requirements of 10CFR55.59 (c) (1).
If you have any questions, please do not hesitate to contact us.
Very truly yours,
, hs.*i f
G.
J.
Beck, Manager Licensing Section Nuclear Engineering and Services cc:
T. T. Martin, Administrator, Region I, USNRC T. J.
Kenny, USNRC Senior Resident Inspector, LGS J. J.
Lyash, USNRC Senior Resident Inspector, PBAPS
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