ML20041C283

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Provides Addl Info Re Licensee Qualification,Per NRC Request.Info Addresses Seven Issues Dealing W/Contingency Plans Should OLs Not Be Issued Simultaneously
ML20041C283
Person / Time
Site: Midland
Issue date: 02/11/1982
From: Jackie Cook
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Harold Denton
Office of Nuclear Reactor Regulation
References
15506, NUDOCS 8203010048
Download: ML20041C283 (7)


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Vice PressJent - Projects, Engineering and Constructson General Cofices: 1945 West Parnall Road. Jackson. MI 49201 e (517) 788 0453 February 11, 1982 4%

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Harold R Denton, Director U8 3 2 m M :'xn:a r

Office of Nuclear Reactor Regulation

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Division of Licensing

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US Nuclear Regulatory Commission Washington, DC 20555 N

MIDLAND PROJECT REQUESTED INFORMATION ON LICENSEE QUALIFICATION FILE: 0505.813/0505.16 SERIAL: 15506 The intent of this letter is to provide additional information requested by your reviewer for Chapter 13.

The licensee has applied for operating licenses for both units and expects to receive them simultanteously. This expectation is based on the present construction schedule which indicates construction and testing will be completed on both units prior to loading fuel on the lead unit.

In this context, Consumers Power Company was asked to address seven issues, several of which dealt with contingency plans should the operating licenses not be issued simultaneously. The seven areas of interested are detailed below.

Area 1.

SITE AUTHORITY AFTER LICENSE IS RECEIVED: Upon receipt of an operating license for either unit at the Midland Plant the Vice President of Nuclear Operations will become responsible for the site.

Any remaining construction work (which is defined as all work on equipment which has not been turned over to Consumers Power Company) on either unit will proceed in accordance with the Quality Assurance Program now in effect, Topical Report CPC-1A.

All modifications and warranty work will be performed as described in Consumers Power Company's Topical Report CPC-2A which was accepted by the NRC on January 12, 1982. All remaining preoperational testing, if any, will proceed in accordance with Topical Report CPC-1A which is implemented by the Midland Nuclear Plant Testing Program Manual. Administrative control of all construction activities will be treated as modifica-tions under CPC-2A.

Area 2.

UNITS 1 AND 2 STAFFING, OPERATING QUALIFICATION, AND CONTINGENCY PLANS:

It is our intent. to have Senior Reactor Operator license holders (Plant Supervisors, Shift Supervisors and Shift Engineers) fill their respective positions on both units simultaneously and be fully qualified on both units. The bases for this approach includes:

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1 A.

Most major systems are virtually identical on both units from an operating standpoint. These systems include:

reactor coolant nuclear instrumentation containment heat removal incore monitoring containment isolation offsite power combustible gas control onsite power I

emergency core cooling f uel transfer and handling containment spray and service water fission product control I

reactor protection demineralized water ESEAS and ECCAS borated water safe shutdown outside the control room chilled water safety-related display fire protection instrumentation emergency diesel generators non-safety control and auxiliaries 1

(ICS, CRDCS, turbine control, computer, atmospheric main steam steam dump, pressurizer control, loose parts feedwater 4

monitoring, boron monitoring) condensate auxiliary feedwater It may be noted that in the FSAR these systems have a single description which is applicable to both units. The only major systems that are significantly different are the main turbine-generator and transformer, but the controls operate similarly.

As appropriate, operating procedures are designated for the i

applicable unit.

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B.

The on going training the operators receive is applicable to both units and includes differences, similarities, and common or shared features.

t C.

The present schedule provides a relatively short time of approxi-j l

mately five months between the startup of the two units.

Licensing individuals on both units simultaneously will allow us to have all of these individuals involved in the startup of the first unit rather than in a classroom training program. This experience will be invaluable in starting up the second unit.

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b. The design of the plant includes some shared or common features, j

where appropriate, such as the auxiliary building including the control room, spent fuel pool including cooling and purification, services such as HVAC, and systems like service air and auxiliary steam supply.

It would create an u,njustified complex administrative burden for the Shift Supervisor to assign responsibility for control of th6se common or shared features to the operators of one unit or the other.,

E.

The attached meeting summary, dated, November 17, 1980, signed by K N Jabbour and B A Wilson, indicated agreement to simultaneous examinations for both units. This has been the basis for plan-ning and training since then.

If the staff cannot be licensed on both units simultaneously, a contingency plan would call for operators to attend a special class to emphasize similarities and differences between the units just prior to taking the license exams on the second unit. As indicated above, the main core of training on the second unit is conducted simultaneously with the first unit. This alternative would decrease the number of licensed individuals per shift during startup of the first unit since some of the individuals would be in classroom training at all times. This would also lessen each individual's involvement in the startup program due to the, time spent in the classroom during significant operating events. -

Area 3.

'N' UMBER AND SIZE OF SHIFTS, ATTRITION, AND EXAM FAILURE RATES: The following table and Attachment A describe our plans for providing an adequate number of licensed operators. Five licensed personnel are required per shift (2 SRO's and 3 RO's) and five shift staffing is t

required. Our goal is to establish six shifts consisting of eight licensed personnel (3 SRO's, 4 RO's, and a Shift Engineer) per shift.

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A 75% NRC exam passing rate and a 15%/ year attrition rate were used after careful consideration of available industry and company data.

This data is presented in Attachment A to illustrate the relationship between the requirements, our objectives and actual staffing to date.

The minimum required and anticipated shift crew staffing are f

addressed above and in the following list:

Minimum l

Required Anticipated 1.

SRO's:

2 3

2.

RO's:

3 4

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3. -Auxiliary Opedat es:

3 19 j

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STA (Shift Engineer):

1 1*

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Chemistry Technician:

1

'5 6.,

Health Physics Technician 1

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3 4,

4 7.

I&C Technicia'as l

8-42 (depending upon shift)

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  • SRO license desirable Y

y In addition, we are currently investigating the availability of contract personnel with previous initial startup' experience on a B&W unit. Our intent is to have these personnel on shift to be available to control room personnel during startup of the first unit.

Area 4.

SIMUIATOR TRAINING OF NON-LICENSED PERSONNEL: Phase E of the Cold License Training Program is described in Subsection 13.2.1.1.1.2 of the FSAR. This subsection specifically outlines simulator training requirements. Attachment "B" provides information on plant personnel who have completed this phase of the training and our present plans for future training.

Area 5.

PROCESS STEAM INTERFACE BETWEEN DOW CHEMICAL COMPANY AND PLANT STAFF:

The interface between the plant staff and Dow will be via the process steam control room, which will be manned.by one or two Consumers Power Auxiliary operators'who will maintain communications with the main control room and Dow.. The process steam control room will normally be manned at all-times and the operators will receive sufficient class room and on-the-job training to qualify at that station. Fifteen Chemistry / Health Physics Technicians will normally be available as needed to support operations of the process steam system.

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Area 6.

CONSUMERS POWER COMPANY PLANS E0R OFF-SITE TECHNICAL SUPPORT: Fol-lowing is a table containing the prelimininary estimated. manpower requirements for the Nuclear Operations Department Technical Support Staf f located in Jackson, Michigan. These numbers thru 1985 do not include available resources in other departments.

PRELIMINAAT ts q wC:.zAs cetma :0ws OtraaTmcr TtAn Prescort renzcasi 1991

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_ 1983 1984 1995 IA4P SE-W EA ? M M M CA4P $E-V EA4P St-J

'5 NUCLEAR AC"!7t*!ES Aadioicgical Services 14 5

15 6

21 8

23 11 23 11 Nuclear Licensing 11 4

12 6

18 8

21 8

21 8

Plant Projects 4

1 4

1 9

1 9

1 9

1 riant Support 26 43 s 10 56 11 61 12 61 13 Reactor Engineering 24 4

30 - 6 40 7

40 8

42 9

TOTAL NUCLEAR ACTIVITIES 79 19 104 29 144 33 134 40 136 42 CUAL:"Y ASSURANC!*

67 14 80 L3 98 13 1C6 14 107 14 TRAI3tNc*

30 14 66

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' '95 21 92 21 92 21 PtA. WING E AOMTNts* RAT!cM 4

10 :6 14 9

16 10 16 10 i'

$ AFT *T 6 AUDI* 'IvtrJ 50AAD 1

1 3

1 9

3 9

3 9

3 TOTAL CINERAL Orft0E 202 $2 2$3 fl 360 81 377 88 280 90

  • Includes personnel located at plant sites.

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The heading "EA&P" includes engineers, supervisors, and managers whil, "SE-W" is in general clerical and technicians.

Area 7.

TRAINING OF NON-LICENSED PERSONNEL:

The Training Department has j

recently increased its staff significan1y to assure that all licensed and non-licensed personnel are trained such that they can perform their work competently and with an understanding of how their actions impact the plant. To assure that this objective is met, a $40 million training center is being built which includes plant-specific simulators for both Midland units.

Generic training will be conducted at this center. Site specific training will be prepared at the plant.

These facilities and personnel will be used to train non-licensed personnel such as I&C technicians, engineers, radiation protection technicians, and chemistry technicians as well as licensed operators.

Some of the training personnel will be dedicated to training only I&C technicians, radiation protection technicians or chemistry technicians thus assuring both specific and general training in their field of interest.

It is also the intent of the Company to provide training for electrical and mechanical repairmen as well as auxiliary operators.

The formalized training programs for these last three groups will be completed after INPO guidelines are finalized. As a minimum the program will consist of learning systems fundamentals and on-the-job training.

JWC/BLll jm CC: RJCook, Midland Resident Inspector RClie rna n, US NRC DBMiller (3), Midland RWifuston, Washington ocl281-0543a131

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ATTACHMENT A Licensed Operator Candidate Resource - Objective Number operator candidates needed for 5 shifts 25 i

Post fuel load objective - six shift schedule (7 licensed operators / shift)(6 shif 2) 42 i

(1 Shift Engineer / shift)(6 shifts) 6 Subtotal 48 i

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Assume 25% NRC license failure rate

+0.7 5 Nubtotal 60 1

Attrition (.85)(.925)

+0 79 i

(1.5 years of attrition)

Required number of license candidates 81 Licensed Operator Candidate Resource - Actual Number SRO certified candidates 7

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Number RO certified candidates 11 i,

Number candidates in certification training 50 Total operator candidates 68

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Number Operator candidates to be hired 13 Required number of license candidates 81 I

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Attachment B s.

e B&W SIMULATOR TRAINING POSITION 77 78 79 80 81 82 83 Note 8 General Manager 1(40) Note 5 Plant Supt Operations Supt 1(120) Note 6 Maintenance Supt 1(40) Note 5 1

Technical Supt.

Plant / Shift. Supv 1, 4(120) 6 Note 2 10, 2(120) Note 7 Control Operators 1, 3(120) 9 Note 3 4

Auxiliary Operators 29 Shift Engineers 2(60) Note 4 2

4 Technical Engineer 1(120) 1 Note 1 i

Engineers (Technical Dept) 1(120) 1, 3(40) Note 5 1 i

SR Technical Analyst.

1(120) 1 Note 1 I

Nuclear Training Instructors 1

4, 1(120)

Operations Coordinator 1

NOTE 1

Same individual who attended 1979 course 2

Three of these individuals attended 1979 course 3

One of these individuals attended 1979 course 4

Course for non-operators 5

Course for Management. personnel 6

IIeld previous license 7

IIeld previous license and attended 1979 course 8

Approximately 15 personnel will attend simulator training in 1983.

It is expected that the group will consist primarily of Plant / Shift Supervisors and back-up Shift Engineers.

l General - All periods of instruct. ion are for 320 hrs unless indicated otherwise as (XX).

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