ML20137L915

Comments on 851028 Commission Policy Statement on Engineering Expertise on Shift,Per NUREG-0737,Item I.A.1.1 Re Shift Technical Advisor.Util Pleased W/Incorporation of Technical Advisor Position in Operating Staff

ML20137L915
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/20/1986
From:	Gahm J PUBLIC SERVICE CO. OF COLORADO
To:	Berkow H Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-578, RTR-NUREG-660, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM P-86047, TAC-61635, NUDOCS 8601280136
Download: ML20137L915 (4)

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16805 WCR 19 1/2, Platteville, Colorado 80651 January 20, 1986 Fort St. Vrain Unit No. 1 P-86047 Director of Nuclear Reactor _ Regulation U.S. Nuclear Regulating Commission Washington, D.C.

20555 ATTN: Mr. H.N. Berkow, Project Director Standardization and Special Projects Directorate Docket No. 50-267

SUBJECT:

COMMISSION POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT

REFERENCES:

(1 ) P-79305, Warembourg to Varga, December 18, 1979 (2 ) G-80049, Speis to Fuller, Received March 31, 1980 (3 ) P-80444, Warembourg to Eisenhut, December 30, 1980 (4 ) G-81142, Miller to Lee, August 6, 1981 (5 ) G-81175, Miller to Lee, October 2, 1981 (6 ) P-81271, Lee to Miller, October 30, 1981 (7 ) G-81223, Kuzmycz to Lee, November 9, 1981 (8 ) G-82080, Clark to Lee, March 19, 1982 (9 ) P-82112, Lee to Clark, April 20, 1982 (10) G-83369, Wagner to Lee, October 13, 1983

Dear Mr. Berkow:

On October 28, 1985, the Nuclear Regulatory Commision published in the Federal Register (43621), the " Commission Policy Statement on Engineering Expertise on Shift."

The purpose of this policy statement was to present the Commission's policy "with respect to ensuring that adequate engineering and accident assessment expertise is possessed by the operating staff at a nuclear power plant."

This policy presents licensees with two options for providing the requisite engineering expertise on shift.

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~2-Option 1 of this policy statement provided for a " combined SR0/STA-Position" in order to meet this need, and option 2 allowed the

" continued use of the STA position." The purpose of this letter is to discuss the position of Public Service Company of Colorado with regard to the aforementioned policy statement.

Public Service Company of Colorado intends to continue its use of a Technical Advisor (TA) position to meet this ongoing need.

The Technical Advisor position has been in use at Fort St. Vrain since early 1980, when, in response to NUREG-0578 Item 2.2.1.b and NUREG-0660 Item I.A.1.1, three engineers were placed on call to the Operations Department with a one hour maximum response time as-discussed in Reference 1.

On March 20,

1980, the Commission staff transmitted to PSC the results of their evaluaticn of the implementation of " Category A"

Lessons Learned requirements (Reference 2).

In the discussion of Item 2.2.1.b, the Fort St. Vrain Technical Advisor position was found acceptable as follows:

"The program that the licensee has implemented to satisfy the STA accident assessment function utilizes three engineers who are placed on-call to respond to potential accident conditions at the

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plant. The licensee has committed to a one-hour response time for the on-call STA, in contrast to the staff's position for a 10 minute response time. We have considered the licensee's argument.

for the relatively long times (i.e.,

hours) for accident conditions to develop' in a gas cooled reactor versus a

significantly shorter time for light water reactors. Considering this unique feature of a gas cooled reactor the staff finds the one-hour response time acceptable.for Fort St. Vrain. The three STA engineers will also fulfill the required operating experience assessment function required by NUREG-0578.

"We have reviewed the licensee's October 29 and December 12, 1979, submittals describing their STA program.

In addition, during the site visit we discussed the program with the licensee and determined that a satisfactory STA program is in operation.

We find that their STA program satisfies the staff's requirements described in Section 2.2.1.b of NUREG-0578 and is therefore acceptable."

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4 In November 1980, the Nuclear Regulatory Commision issued NUREG-0737 which, in Item I.A.1.1, endorsed the Shift Technical Advisor position as a requirement for the operating staff as described in Item 2.2.1.b of NUREG-0578 and Item I.A.I.1 of NUREG-0660.

Public Service Company of Colorado responded to the NUREG-0737 Item I.A.I.1 in detail via correspondence to the Commission (Reference 3).

In that letter, the Fort St. Vrain training program for Technical Advisors was discussed, as well as the duties, responsibilities, accountability, and qualification requirements for the Fort St. Vrain Technical Advisor position.

In addition, the long range plans for the Technical Advisor position at Fort St. Vrain were clarified, as required by NUREG-0737. Public Service Company of Colorado stated its intent to:

"1.

Retain the TA's as permanent Fort St. Vrain staff for the duration of operating license in lieu of upgrading SR0's to a college level engineering degree.

"2.

Upgrade the operator and SRO training and requalification requirements to include courses in heat transfer, fluid flow, and thermodynamics as well as other upgrading as outlined in Attachment 5 [to P-80444], but retain the Technical Advisors as the college level expertise rather than providing this expertise to the operator."

On August 6,

1981, the Commission issued an Order confirming PSC's commitments to Three Mile Island Action Plan related items (Reference 4).

In that letter, the Commission granted acceptance of the Fort St. Vrain Technical Advisor position _as follows:

"The licensee has agreed to the requirements of Item 1.A.1.1 (sic), ' Shift Technical Advisor' with the exception that instead of the staff's position for a 10 minute response time, the-licensee has committed to a one hour response time for the on-call STA.

Considering the unique features of gas cooled

reactor, i.e., long times for accident conditions to develop, the staff finds the one hour response time acceptable for the Fort St. Vrain Nuclear Generating Station."

The Commission staff, on October 2, 1981, via Reference 5 transmitted the determination that the " Shift Technical Advisor section should be included in the Technical Specifications...The bases for this determination is contained in our" (the NRC's) " March 20,

1980, letter to Public Service."

In response to that request, PSC submitted a request for an amendment to the Fort St. Vrain Technical Specifications (Reference 6) to include the Technical Adviso'r position in section AC 7.1.1 as part of the operating staff, and to place a requirement for a one hour response time capability. This amendment was issued by the Commision as Amendment No.24 to the Facility Operating License on November 9,1981 (Reference 7).

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. On March 19,

1982, PSC was advised of the results of a post-implementation review of Shift Technical Advisor training programs (Reference 8).

In that letter, PSC was advised:

"Our review indicated that your STA training. program is acceptable in meeting the intent of the guidelines set forth in the above referenced letters.

You are requested to propose a-Technical Specification change incorporating the following qualification requirements for the STA as paragraph 6.3.2:

'The Shift Technical Advisor.shall have a bachelor degree-or equivalent in a scientific or engineering disc'.pline with specific training in plant design and response and analysis of the plant for transients and accidents.'"

PSC responded on April 20, 1982, via Reference 9 with a request for an amendment to section AC 7.1, as requested in G-82080. This change was implemented as Amendment No. 36 to the Facility Operating License upon receipt of G-83369 (Reference 10).

PSC has been pleased with the results of the incorporation of the Technical Advisor position into the operating staff at Fort St.

Vrain, and is continuing to explore areas ;nto which Technical Advisor manpower and experience can be utilized to e, hance operations of Fort St.

Vrain.

'A large scale review of the Technical Advisor training program was recently completed at the suggestion of the Institute of Nuclear Power Operations (INPO) relative to the INP0 accreditation program, and new candidates for the Technical Advisor program are presently being trained in accordance with that enhan~ced program.

Early feedback from that effort has been good, and we anticipate that the level of preparation of these candidates will be superior.

If you have questions regarding this matter,' please contact Frank Novachek of my staff at (303) 785-2224.

l Sincerely,.

l ahm Manager, Nuclear Production Fort St..Vrain Nuclear Generating Station JWG:JMS/jlr

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