ML17174A233

Forwards Supplementary Response Re Commitment to Meet short-term Requirements of Lessons Learned Task Force

ML17174A233
Person / Time
Site:	Dresden, Quad Cities, Zion
Issue date:	11/30/1979
From:	Reed C COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578 NUDOCS 7912120411
Download: ML17174A233 (7)

Text

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November. 30, 1979 Dr. Harold R. Denton, Director Office of Nuclear Reactor Regulation*

.U.S. Nuclear RegulatoryCommission Washington, D.,.

20555

Subject:

Dresden Station Uriits 1, 2 and 3 Quad-Cities Station Units 1 and 2 Zion Station Units 1 and 2 Commitments to Meet Near-Term Re q u i re r'n en ts of t h.e Les son s Le a r n e d T ask Force NRC Docket Nos.

50~10/237/24B, 50-254/265, and 50-295/304 References (1):

H. R. Denton letter to all operating plants.dat~d Octo~~r 30, 1979

( 2) :

( 3) :

( 4) :

Dear Dr. Denton:

C. Reed letter to D. G. Eisenhut dated October 18, 1979 D. G. Eisenhut letter to all operating plants dated September 13, 1979 C. Reed 1 et t er to.H. R. Denton* dated November 21, 1979 Th~ e~clos~d suppJementary response should be.

incorporated i~ta our October 18,.1979 letter on Lessons Learned commitments One (1) signed original and 'seventy-nine (79) copies of t h i s t r an s m i t t a l are. p r o v ; de d f or.yo u r u s e *.

enclosure V e r y t r u::1 y yo u r s,

Cordell Reed Manager of Nucl~ar Operations Ao39

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Supplement. our response to Section 2. 2.*.l. b. with the following:

Based on discussions with the' Staff, the information provided in the October 30, 1979, Harol*d Denton letter and our internal review, it appears that clarification is needed regarding our approach to requirements of Sectiori 2.2.1.b.

Following is a discussion of 9ur plans in this area and differences that we perceive between the Staff's requirements and our approach with jus~ification for the difference.

Long-Term Approach Our ultimate goal is to provide on each shift, a technical graduate licensed at the Senior Reacto~ Operator (SRO) level.

This individual will have the training necessary to perform the accident assessment function and will be in excess of the minimum shift SRO requirement identified in current plant; Technical Specifications.

We expect to fill these positions no earlier than.mid-1981.

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Interim App~oach Until our long-term goal can be met, we will provide the accident assessment functioh by the following interi~ approach.

For those stations which carry more SROs on shift than are required by current plant Technical 1Specifications the accident assessment function will be fulfilled by one of the shift SROs who has completed an augme,nted training program or one of the shift SROs who is a technica.l graduate~

Fc:i~ th6se stations which do n6t'carry extra SROs on shift, the accident assessment function will bE7 provided by a technical graduate assigned to the shift.

Either interim approach will provide an individual, on shift and able* to* report to the control *:room within 10 minutes, to advise* the shift* supervisor during an accident.

This interim approach will be implemented by January :1, 1980.

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STA Degreed Engineer Requirement It is the staff's position tha*t the STA individual required to be functioning by January l,' 1980, have a Bachelor's Degree or equivalent.

This position is outlined on Page 55 of the attachment to the"October 30, Denton letter which indicates that a degreed person is acceptable without specification for any additional minimum training for the near term (i.e., 1/1/80 to 1/1/81).

Our interim approach is to provide augmented training to at least one of the* shift SROs not al*l of whom will have an Engineering Degree.

The following discu:ssion illustrates how the augmented SRO, coupled with the SRO training, accomplishes the equi valency requirement.

The object of the SRO augmentation program was to provide 6~r operating shifts with an additional measure of capability to deal with off-normal events and to do so. within a time frame that is relatively short compared to that required for more permanent solutions..

• .modules:

The content of the SRO augmentation training is four

1.

Cri'sis Management

2.

Applied Science

3.

Plant Instrumentation Design and Response.

4.

Plant Transient and.Accident Behavior

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Supplement our response to Section 2.2.1.b with' the following:

(Continued)

The duration of the respective modules is:

Module BWR PWR 1

2 Days

( 16 Hrs.)

2 Days

( 16 Hrs.)

2 3 Days (24 Hrs.)

4 D~ys (32 Hrs.)

I 3

2 Days (16 Hrs.)

3 Days (24 Hrs.)

4 2 Days* (16 Hrs.)

4 Days* (32 Hrs.)

• TOTALS 9 Days (72 Hrs.)

13 Days ( 104 Hrs.)

• Includes 1 Day (8 Hrs.) on Simulator Module 1 - Crisis Management Consists of:

a.

Objective:

. b. *Application:

To present the trainee with.'a method of sorting,

~ttathing significance to and processing i~forma tion, and taking potential problems into account in ord*r to arrive at quality decisions while under time pressu~e; The techniques learned hete :(and practiced in Module 4) wi 11 help the trai~nee make better and faster:'decisions in all type:s of problem situations, especially those, where groups of people are involved.

• • Module 2 - Applied Science Consists of:

a.

Objective:

Jo give the trainee *a p~actical feel for he~t and mass flow, feactor beh~vior,.material prope~ties, and plant themistry, all as ~irectly ~pplied t6 plant ope~ations, ~ithout a confusing amount of pure theory.

b.

Application: Having a working feel for plant theoretical concepts is a vafuable asset wh~n evaluating off~normal plant conditions and considering alternatives for action~ This is especially true when the situation'.invclves combinations of problems that are not within the scope of prior traiMing or station pr~cedures.

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tr. * ) Supplement our response to Section 2..2.1.b with the fol lowing:. (Continued)

Module 3 - Plant Instrumentation Desi~n and Response Consists of:

a.

Objective:

To refresh the t ta i nee on,.the design and function of important plan~ instrumentation system~, givfng an idea o~ how these systems may respond under abnorma F conditions.

b.

Appl !cation:

Bl in.Ct fa'tth in instrumenta:tion may lead to trouble under certain abnormal circumstances.

Knowing when not to take an instrument reading at face valueWill help the trainee assess problems more quickly and accurately.

Module 4 - Plant Transieni and Accident Behavior Consists of:

a.

Objective:

b.

App l i cat i on :

• To ~ive the.trainee additional gu1dance and practlce in handling abnormal operating situations, especially for, multiple ~mall failures, while applying the crisis management techniques learned earlier.

The role of the SRO, rather than that of the RO, Is emphasized.

It is not expected that th~ trainee will have to deal wi.th the exact combinations of problems prese~ted. However, learning how to handle

.certain types of events and, most* importantly,

. pract1clng the thought pro~ess used to make

~uality decisions will. hel~ the trainee handle whatever abnormalities actually do occur; In evaluating the appropriateness of this interim measure in satisfying the intent at handr attention should be drawn to the final

• product.-- the augmented SRO.*

Cenimonweaith Edison's nuclear operations training program has been accredited by Joliet Junior College toward'.an Associate of Applied Science De~ree, and.accredidation toward a fou~+i~ar degree a~ Governor'~

State University is currently in progress with favorable results expected.

The credits given for various phases of our training can be used as guide 1 i nes.

Supplement our response to Section 2.2.1.b with the fol lowing:

(Continued)

General Area (Used in 9-13-79 Eisenhut Letter)

Mathemat I cs Reactor Physics Reactor Thermodynam.i cs Electrical Enginee~1n~ & Rx Control Theory Reactor Operations Transient and Accident Res~onse Other

• Source SRO Tra i.:n i ng SRO Augmentation SRO Training SRO Augmentation SRO Training SRO Augmentation SRO Training SRO Augmen tat ion.

SRO Trai.ning SRO Augmen tat ion SRO Training SRO Augmentation SRO Training SRO Augmentation TOTAL 856 Credit Ho.urs"' 42.8 Semester Hours (An Associate. Degree Requires 67 Semester *.

• Hours)

(A Four-Year Degree Requires 128 Semester Ho~rs)

Equivalent Credit Hours N.A.

0 160 24 64 8

80 24 320 0

36 8-24 100

-11 856 Credit Hours It can be seen that the augmentation program strongly address~s 4 of the 6 areas of training recommended for the STA.

Mathematics is covered, to some degree, in SRO training but is not accr~dited as such and could not be evaluated in terms of credit hours~

In su1m1ary, the final augmented trained SRO has an equivalent 42.8 semester hours.

Further; the SRO program without the augmentation phase has already been accredited for 38 technical semester hours towards.

an Associate Applied Science Degree at Joliet Jqnior Col leg~.

Thus, it's our opfnion that the augmented trained SRO who ~ill be utilized until we

. can implement the long~term phase of degreed SROs is sufficient to cover

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.;t'. I Supplement our response to Section 2.2.1.b with the following: * (Continued)

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the equivalent requirement.

The only technical courses not covered in the 67 semester hours required *for a full Assdciate Applied Science Degree are 8 semester hours in technical !!mathe-matics.

Operating*oExperience Assessment Function I

The previous discussion addressed how we intend! to meet the accident assessment function requirement of the STA. \\ It. is not our intent to have the STA conduct the opera ting expe:rience function.

Instead, evaluation of operating experience atl our seven opera ting nuclear uni ts is performed by: the Off-Site Revi.ew Group, I

a part of the Nuclear Licensing Department.

The Off-Site 1 Review Group is staffed full-time with experienced opera tors andi engineers (all college graduates) many of whom ho+,d or have held Senior Reactor Operators:licenses.

These personnel visit the st~tions to I

communicate with station management and,to assess the equ;ipment and personnel interactions* which are reflected in operating e~perience assessment.

Procedures are being developed to ensure the! timely transmittal of operating experience ass~ssment to stationt operations personnel.

.These procedures will be implemented by Janua!ry 1, 1980.

Summary I

In summary, we have been developing an approachi that will address the concerns identified at TMI in parallel with tpe NRC efforts.

Whereas both the staff and.Commonweal th Edison !identified the same concern,.*our approach iS*.Slightly different. than\\ that out-lined by the staff.

The concern. we botq are trying to adp.ress.is assurance.that a well-trained individual will be dedicated during a transient:, specifically to maintenance, of core cooling ~nd more generally to the: overall safety of the plant.

In our view, Commonw.eal th Edison's approach.is better in*that it* utilizes our available per-sonnel more efficiently,.*ensures that the indi victual prov~ding the accident assessment function has the experience and knowl~dge to react quickly with respect to correcting any errors*made by the oper-ator, and ensures the advisor has the credibility necessa!ry to carry out his role.*

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