ML20149L445
| ML20149L445 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 02/17/1988 |
| From: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20149L446 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM B12820, GL-86-04, GL-86-4, TAC-67187, TAC-67188, TAC-67189, NUDOCS 8802240232 | |
| Download: ML20149L445 (13) | |
Text
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NORTHEAST UTILITIES o.ner.i Omc.. s.io.n str..i. Bernn. Connect,cu:
T OR CONNECTICUT 065 41-o270 February 17, 1988 Docket Nos. 50-213 50-245 50-336 B12820 Re:
10CFR50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Proposed Revisions to Technical Specifications Dual-Role SR0/STA Position Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) hereby request amendment of Operating License Nos. DPR-61, DPR-21, and DPR-65, by incorporating the changes identi-fied in Attachment I for the Haddam Neck Plant, Attachment 2 for Millstone Unit No. 1, and Attachment 3 for Millstone Unit No. 2, respectively, into each plant's technical specifications.
Specifically, the proposed changes would amend Table 6.2-1 of the technical specifications, "Minimum Shift Crew Composition," to explicitly recognize the acceptability of the use of qualified individuals in the dual-rcle of senior reactor operator (SR0) and shift technical advisor (STA).
In addition, the specific qualification requirements for individuals serving as the STA in either a dual-role position or as a dedicated STA, are proposed to be added to Technical Specification 6.3.1, "Facility Staff Qualification BACKGROUND AND
SUMMARY
Consistent with our logterm STA program plans which were first submitted to the NRC Staff in 1979, CYAPC0 and NNEC0 have been fufilling the STA func-tion requirements via the dual-role SR0/STA position at Millstone Unit No. I since September,1983, and at the Haddam Neck Plant and Millstone Unit Ns. 2 since January 1, 1984.
All three plants have utilized the dual-role position for over four years.
In January,1988, the NRC Staff verbally informed CYAPC0 (1)
See the "History" section of Attachment 4 to this letter, which is the meeting handout provided by Northeast Utilities personnel during the January 27, 1988 meeting with the NRC Staff.
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U.S. Nuclear Regulatory Commission B12820/Page 2 February 17, 1988 and NNECO of their interpretation that we were in violation of Technical Specification Table 6.2-1, "Minimum Shift Crew Composition."
Specifically, the NRC Staff stated that our use of the dual-role position is not allowed by Table 6.2-1.
The position of CYAPC0 and NNECO is that Table 6.2-1 does not preclude use of the dual-role position.
However, as a result of a meeting in Bethesda on January 27, 1988 and a conference call on February 3, 1988 with the NRC Staff, CYAPCO and NNECO are requesting the enclosed license amendments, which will explicitly recognize the integration of the STA function with an on-shift SR0 (a dual-role individual). When a dual-role individual is used in this capaci-ty, the minimum shift crew will be _six individuals.
The requested license amendments would allow continued use of dual-role individuals who have completed the Memphis State University STA training program prior to December 31, 1986, or have completed or were enrolled in the Thames Valley State Technical College (TVSTC) Associate's Degree in Nuclear Engineering Technology program prior to October 1,1987.
All other dual-role individuals would be required to meet the provisions of(2phe Commission's Final Policy Statement on Engineering Expertge on Shift.
In other words, our current dual-role-quagied individuals and the 11 SR0s currently enrolled in the TVSTC program (upon completion) will be recognized as acceptable for the dual-role position, but all others will be required to meet the provisions of the Policy Statement.
The issuance of the requested license amendments will help prevent any future confusion concerning various interpretatior.s of Technical Specification Table 6.2-1.
HISTORY OF STA POSITION AT NV Throughout the post-THI era, CYAPC0 and NNEC0 have been aggressively develop-ing and implementing programs uniquely designed to be responsive to the engineering expertise on shift issue.
A substantial investment has been and continues to be made to ensure that individuals who are an integral part of the shift complement have adequate engineering and accident assessment exper-tise.
Letter 86-04,gt)ed June 13, 1986,(5) CYAPC0 and NNEC0 responded t In a letter providing a summary of the history of the STA program at Northeast Utilities (NU).
Excerpts from that discussion are repeated below.
(2) 50 Federal Register 43621, October 28, 1985.
(3) See Attachment 5 to this letter.
(4) See Attachment 6 to this letter.
(5)
J. F. Opeka letter to C.
I. Grimes, "Policy Statement on Engineering Expertise on Shift (Generic Letter 86-04)," dated June 13, 1986.
(6)
H. R. Denton letter to All Power Reactor Licensees and Applicants for Power Reactor Licenses, "Policy Statement on Engineering Expertise on Shift (Generic Letter 86-04)," dated February 13, 1986.
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U.S. Nuclear Regulatory Commission B12820/Page 3 February 17, 1988 Interim STA Proaram and Develooment of Lona Term Plans One of the recommendations of the THI Lessons Learned Task Force vas that additional technical, educational, and analytical capability, dedicated to concern for the safety of the plant, needed to be provided in the control room to support the diagnosis of off-normal events and to advise the Shift Sugvi-sor on actions to terminate or mitigate the consequences of such events.
The initial NRC position regarding the STA position was transmitted in letters from (ggg)Eisenhut and H. R. Denton dated September 13, 1979 and October 30, 1979.
The NRC's position was that an individual with a bachelor's degree "or equivalent" and additional training in plant-specific transient and accident response be available to the control room personnel at all times, within 10 minutes. The STA was required to be on duty as of January 1, 1980.
In a December 31, 1979 letter,(10) CYAPC0 and NNEC0 described their plans for meeting this Staff position, utilizing additional personnel (mostly degreed at the B.S. or higher level) who were assigned twenty-four hour rotating duty.
These individuals received the required specialized training and were placed on duty on or before January 1, 1980.
III) the NRC issued NUREG-0737, which Subsequently, on October 31, 1980 contained the set of TMI Action Plan requirements that had been approved by the Commission for implementation at that time.
Item I. A.1.1 required that licensees submit a description of their then-current STA program, along with a description of their longer term plans for upgrading the qualifications of operations personnel and eventual phase-out of the interim STA position.
These plans were required to be submitted by January 1,1981.
It was recognized by CYAPC0 and NNECO (and other licensees) at the time that providing the STA function was best accomplished through an interim program and a longer term technical upgrading program.
In fact, all of our correspon-dence with the Staff regarding the STA issue specifically described both (7) TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations, NUREG-0578, July 1979, Section 2.2.1.b.
(8)
D. G. Eisenhut letter to All Operating Nuclear Power Plants, "Followup Actions Resulting from the NRC Staff Reviews Regarding the Three Mile Island Unit 2 Accident," dated September 13, 1979.
(9)
H. R. Denton letter to All Operating Nuclear Power Plants, dated October 30, 1979.
(10) W. G. Counsil letter to H. R. Denton, "THI - Short-Term Lessons-Learned Implementation," dated December 31, 1979.
(11) D. G. Eisenhut letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, "Post-THI Requirements,"
dated October 31,
- 1980, forwarding NUREG-0737, "Clarification of TMI Action Plan Requirements."
h U.S. Nuclear Regulatory Commission B12820/Page 4 February 17, 1988 interim and longer term plans.
The Staff was informed that our long-term plans consisted of upgrading the qualifications of shift supervisors and supervisory control operators to meet or e for the STA established by INP0 and endorsed by the Staff.g3gquirements 1980gnsetoItemI.A.l.1ofNUREG-0737andasdescribedintheDecember31, In r and subsequent submittals, CYAPC0 and NNECO initially contracted with Memphis State University (MSV) to implement an STA program that met the INP0 guidelines. Docketed submittals since that time have made it clear that once an adequate number of shift supervisors completed this training (and addition-al management and non-technical training specified by CYAPC0 and NNECO), the separate interim STA position would be eliminated and the dual-role (SR0/STA) concept would be utilized.
These plans were in full compliance with NRC's criteria and INP0 guidelines for STAS.
Following a review of CYAPC0's and NNECO's long-term program de(srgy gti) n, the i
y 6
Staff issued Safety Evaluations for NUREG-0737 Item I.A.1.1 which concluded that:
"your STA training program is acceptable in meeting the intent of the guidelines set forth in the above referenced letters."
The "above referenced letters" included NUREG-0737, which clearly referred to the INP0 Standard "Nuclear Power Plant Shift Technical Advisor - Recommenda-tions for Position Description, Qualifications, Education, and Training" as "acceptable for interim guidance for a utility in planning its STA program over the lona term," (emphasis added).
In summary, CYAPCO's and NNEC0's plans were made well known to the Staff in December, 1980 in response to an NRC request for information.
Approximately one year later, in early 1982, the Staff approved these plans, implicitly approving CYAPCO's and NNEC0's proposal to utilize the dual-role concept.
Even though the MSU program was found acceptable by the Staff, after some experience had been gained in its implementation we identified several areas where the program could be improved. As a result, CYAPC0 and NNEC0 elected to (12) Ibid.
(13) D. G. Eisenhut letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, "Preliminary Clarification of TMI Action Plan Requirements," dated September 5, 1980.
(14) W. G. Counsil letter to D. G. Eisenhut, dated December 31, 1980.
(15) D. M. Crutchfield letter to W.
G. Counsil, "NUREG-0737 Item I. A. I.1, Shift Technical Advisor (STA) for Haddam Neck and Millstone 2,"
dated March 31, 1982.
(16) J.
Shea letter to W.
G.
Counsil, "NVREG-0737 Item I.A.I.1, Shift Technical Advisor (STA) - Millstone Station Unit 1," dated February 22, 1982.
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U.S. Nuclear Regulatory Commission B12820/Page 5 February 17, 1988 custom-design, in conjunction with a local technical college, an educational program specifically tailored to nuclear power plant operation.
This program was developed to meet the existing NRC and INP0 criteria, with an additional objective of qualifying personnel for other than STA positions at our nuclear facilities.
This program was developed in conjunction with the Thames Valley State Technical College (TVSTC) as a two year, Associate's Degree Program in Nuclear Engineering Technology.
The curriculum was developed jointly between NU and TVSTC, and the program has received formal licensure from the State of Connecticut.
The Staff was ed of the details of this program in a letter dated November 18, 1983 Implementation of the TVSTC program began in December, 1983.
One of the primary objectives in developing the TVSTC program was to structure a curriculum that would provide a thorough education in the areas of kncwledge that are important to safe nuclear power plant operation.
This program was specifically designed as a tailor-made Associate's Degree Program in Nuclear Engineering Technology and was developed with substantial utility nuclear operations input. We are not aware of any comparable custom-made program. We believe that this developmental effort is what makes the TVSTC program unique, and when combined with an SR0 license, is the optimal approach to providing engineering expertise on shift.
Imolementation of Dual-Role Position Consistent with our leng-term STA program plans and our belief that a better perspective and integration into the shift crew results if the STA is one of the on-shift SR0s, the separate STA position was eliminated upon the implemen-tation of the dual-role position at Millstone Unit No.1 on September 1,1983.
The dual-role position was fully implemented at the Haddam Neck Plant and Millstone Unit No. 2 by January 1, 1984. A list of the 30 dual-role-qualified individuals currently serving in the Operations Departments at these three plants is provided in Attachment 5.
HISTORY OF TECHNICAL SPECIFICATION RE0VIREMENTS FOR STAS Cateaory A TMI-2 Lessons-Learned Reouirements in a letter dated July 2. 1980,(18) the NRC Staff provided model technical specgations related to the augmentation of the STA.
On September 16, 1980 CYAPC0 and NNECO submitted license amendment requests to add STA qualification requirements to Technical Specification 6.3.1 and to add the requirement for an STA during plant operation to Table 6.2-1, "Minimum Shift (17) W. G. Counsil letter to D. G. Eisenhut, "NUREG-0737, Item I.A.1.1, Shift Technical Advisor," dated November 18, 1983.
(18) D.
G.
Eisenhut letter to All Boiling Water Reactor Licensees, dated July 2, 1980.
1 (19) W. G. Counsil letter to D. G. Eisenhut, "Proposed Revisions to Technical Specifications, THI-Related Requirements," dated September 16, 1980.
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U.S. Nuclear Regulatory Commission 812820/Page 6 February 17, 1988 wer$21)ubsequently issued to 2,ff0) license T
amendments Crew Composition."
8 1,
and the Haddam Neck Millstone Unit No.
Millstygg) Unit No.
- Plant, in 1981. Attachment 7 shows relevant technical specification pages prior to the addition of the STA requirement, and Attachment 8 shows the amended technical specification pages reflecting the STA position.
In each case, Millstone Unit No. l's Technical Specifications are shown.
(The Haddam Neck Plant and Millstone Unit No. 2 changes were essentially identical to Millstone Unit No. I's.)
Licensed Operator Staffina Final Rule On July 11, 1983, the Commission pgi)shed the final rule on Licensed Operator Staffing at Nuclear Power Units.
The rule, which is incorporated in 10CFR50.54(m) and became effective on January 1,
1984, established the requirement to have a syd SR0 on-shift during plant operation.
In a letter
- 1983, CYAPC0 and NNEC0 responded to the final rule on dated August 25, licensed operator staffing, stating our intention to fully comply with its provisions by January 1, 1984.
It was also stated that the STA position would be filled by SR0s who had completed the STA training program (dual-role individuals) starting on September 1, 1983 at Hillstone Unit No. 1, and by January 1,1984 at the Haddam Neck Plant and Millstone Unit No. 2.
We empha-sized that this was consistent with our long-term STA program plans, which had Policy Statement on Enginesing Expertise on Shift.(2f the Draft Commission been approved by the NRC Staff, and with the intent Our August 25, 1983 letter further stated that it was our determination that license amendments were not required to utilize qualified individuals in the dual-role position, but amendment requests would be submitted for the purpose of clarity, to eliminate the potential for misinterpretation.
In a letter dated September 23,1983,(26) CYAPC0 and NNECO commented on the Draft Policy Statement, and restated our long-term program plans (elimination of the dedicated STA position) and our interpretation that the existing technical specifications did not preclude the dual-role.
(20) R. A. Clark letter to W. G. Counsil, "TM1 Lessons Learned Category "A"
Items - Haddam Neck Plant," dated April 7, 1981.
(21) D. M. Crutchfield letter to W. G. Counsil, dated October 6,1981.
(22) D. M. Crutchfield letter to W. G. Counsil, "THI Lessons Learned Category "A" Items - Haddam Neck Plant," dated October 8,1981.
l (23) 48 Federal Register 31611, July 11,1983.
(24) W. G. Counsil letter to D. G. Eisenhut, "Final Rule on Licensed Operator
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Staffing at Nuclear Power Units (48FR31611)," dated August 25, 1983.
(25) 48 Federal Register 33781, July 25,1983.
1 (26) W. G. Counsil letter to S. J. Chilk, "Draft Policy Statement Regarding i
Engineering Expertise on Shift (48FR33781)," dated September 23, 1983.
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U.S. Nuclear Regulatory Commission B12820/Page 7 February 17, 1988 License amendments were requested in letters dated 1983(27) for Millstone Unit Nos. I and 2, and October 24,1983,(gober 4, for the Haddam Neck Plant.
The proposed changes were requested to explicitly recognize the acceptability of our use of qualified individuals in the dual-role position, and to change the minimum number of SR0s required during plant operation from 1 to 2. shows the requested changes to Table 6.2-1 for Millstone Unit No. 1.
P During the subsequent months, we maintained periodic contact with the assigned NRC Project Manager.
During every conversation, the Staff stated that they understood our plans, our technical specification interpretations, and raised no objections.
One example of this ongoing dialogue took place on January 3, 1984. On that day, a telephone conversation was held between NU personnel and the NRC Staff concerning our requested license amendments.
Our records show that we were assured by the NRC Project Manager that the NRC Staff was aware of our implementation of the dual-role, and that "we need not worry about any enforcement action resulting from a different interpretation of Section 6 and 10CFR50.54(m)."
Licenggymendments were issued to Millstone Unit Nos. I and 2 ogbruary 16,
- 1984, and to the Haddam Neck Plant on January 15, 1985 providing some, but not all of the requested changes.
The requirement for a second SR0 was added to Table 6.2-1, but the proposed footnote that would explicitly recognize the acceptability of the dual-role position was not included.
The j
NRC Staff stated that the dual-role "issue" would be handled by a separate j
licensing action.
10 shows Table 6.7-1 as it was amended on 16,1984,(3 pptachment February and has remained ever since.
(27) W.
G.
Counsil letter to J.
R.
- Miller, "Proposed Revision to Administrative Technical Specifications," dated October 4, 1983.
(28) W.
G.
Counsil letter to D.
M.
Crutchfield, "Proposed Revision to Administrative Technical Specifications," dated October 24, 1983.
(29) D.
M.
Crutchfield letter to W.
G.
- Counsil, "Changes to Technical Specifications to Comply with Final Rule on Licensed Operator Staffing,"
l dated February 16, 1984.
r i
(30) J.
A.
Zwolinski letter to W.
G.
- Counsil, "Changes to Technical Specifications to Comply with Final Rule on Licensed Operator Staffing,"
dated January 15, 1985.
(31) It is noteworthy that a prior version of this letter characterized the requested provision for explicit recognition of the dual-role position as "unacceptable."
However, the final version of this letter deleted any i
reference to the term "unacceptable," and merely indicated that it would be the subject of a separate licensing action. This shift in terminology clearly indicates that the Staff was not formally objecting to our interpretation.
In fact, we were advised that the Staff decided they would not act on this amendment request until the then draft Policy l
Statement on Engineering Expertise on Shift was finalized.
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U.S. Nuclear Regulatory Commission B12820/Page 8 February 17, 1988 Interoretation of Table 6.2-1 In January, 1988, after over four years of implementation of the dual-role position at the Haddam Neck Plant and Millstone Unit Nos. I and 2, the NRC Staff informed CYAPC0 and NNECO of their view that we did not comply with Technical Specification Table 6.2-1.
Since the NRC Staff was well aware of our implementation of the gaf-role position and had acknowledged this verbal-ly, in inspection reports, and in other correspondence many times, CYAPC0 and NNEC0 were very surprised at the emergence of a new NRC Staff interpre-tation of compliance with Table 6.2-1.
While we believe that our long-stated interpretation of Table 6.2-1, that the dual-role is not precluded, is still valid, CYAPC0 and NNEC0 are requesting the enclosed amendments in recognition of the recent Staff interpretation, and to eliminate any confusion concerning the acceptability of the dual-role.
This request is essentially an updated version of those proposed in October of 1983, whi;h have yet to be acted upon by the NRC Staff.
The substance of these amendmnt requests is identical.
NU's Pursuit of Clarification of Table 6.2-1 CYAPC0 and NNEC0 have diligently pursued revisions to Table 6.2-1 and NRC acceptance of our implementation of the dual-role position.
After review of our license amendment requests submitted in October,1983, which would have given explicit approval of the dual-roh position, the NRC Staff advised us in their February 16, 1984 letter that disposition of the amendment requests would await issuance of the Final Policy Statement.
NU personnel were active-ly involved in the NUMARC Working Group established for this issue, including chairing this Working Group.
Further, the NRC Staff-recommended version of the Policy Statement had language more closely aligned to the program we had previously implemented.
However, the final version of the Policy Statement did not embrace the NU program, except for acknowledging that alternatives would be considered "on a case by case basis." With the intention of having our program found acceptable by the NRC on a case-specific basis, we had a September,1986 meeting with the NRC Staff concerning the acceptability of our STA program and our dual-role in 31, 1986,g dual s.
Following the meeting, SECY-86-383 was issued on December concluding that "The Staff considers that (32) One example which illustrates NRC Staff awareness and acceptance of the dual-role position is the E.C. Wenzinger letter to W. G. Counsil, dated January 25,
- 1985, transmitting Resident Inspection Report No.
50-213/84-28.
A pertinent excerpt from the inspection report dealing with IE Circular 81-04, "The Role of the Shift Technical Advisor and i
Importance of Reporting Operational Events," follows:
"As of January 1,1984, the licensee implemented a new STA program where j
one of two on-shift Senior Reactor Operators is also the STA.
This program alleviates the concern for remoteness of the STA since the shift supervisor and STA are the same person."
(33) V.
Stello letter to The Commissioners, SECY-86-383, "Engineering Expertise on Shift, Northeast Utilities, Haddam Neck and Millstone Unit Nos. I and 2, and Fort St. Vrain," dated December 31, 1986.
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U.S. Nuclear Regulatory Commission B12820/Page 9 February 17, 1988 the NU program for dual role SR0/STA meets the intent of the Commission Policy Statement, and we find it acceptable." We believe it is apparent that we have been diligent in our efforts to seek NRC approval in the form of clarifying license amendments.
RECENT ACTIVITIES NU's Proactive Efforts Concernina Enaineerina Exoertise on Shift CYAPC0 and NNEC0 have taken extensive efforts to keep the Commission and the NRC Staff fully informed with the details of our STA programs.
Our June 13, 1986 response to Generic Letter 86-04 included a syllabus of the TVSTC courses and a comparison of the education provided to our dual-role individuals to the INP0 STA guidelines as well as a comparison of the INPO guidelines to typical bachelor of science in nuclear, electrical, and mechanical engineering degree programs.
TVSTC course descriptions and details of the content of our non-licensed, licensed, and senior licensed operator training programs (both initial and requalification) were provided and explained to the NRC Staff in our meeting on September 25, 1986.
On March 6,1987, E. J. Mroczka, Senior Vice President of Nuclear Engineering and Operations, met with three of the Commissioners and the staffs of the two who were not available, to discuss the engineering expertise on shift issue.
A subsequent letter from E. J. Mroczka was submitted to each of the Commissioners on March 12, 1987, to reaffirm our position on this issue. 1 to this letter provides a copy of each of these letters.
SR0s Currentiv Enrolled at TVSTC Eleven SR0s are currently attending TVSTC, and are candidates to become dual-role individuals upon completion of our STA training program.
Five individuals enrolled in September,1986, and are expected to graduate in June, 1988, and the other six, who enrolled in September, 1987, are expected to graduate in June, 1989.
The NRC Staff has expressed the view that the enroll-ment of the six SR0s in the TVSTC prog g in September of 1987 was inconsis-tent with their April 22, 1987 letter, which stated that the "Commission agrees that the present personnel in dual SR0/STA positions can continue to serve" and that "while not a requirement, future personnel in the dual posi-tions should meet the criteria in the policy statement."
In response to the Staff's April 22 letter, which was received on May 4, 1987, a reassessment of our current STA program and the adequacy of our qualifica-tion requirements for our dual-g individuals was conducted.
As was stated in our August 7, 1987 letter, it was determined that our STA program yields thoroughly qualified individuals for the dual-role position, and that changes were not appropriate.
We also stated our intention to continue to (34) T. E. Murley letter to E. J. Mroczka, dated April 22, 1987.
(35) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Engineering Expertise on Shift," dated August 7, 1987.
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U.S. Nuclear Regulatory Commission 812820/Page10 February 17, 1988 evaluate this matter, including the success of programs at other utilities with degreed operators.
Regarding the September, 1987 TVSTC enrollees, the significance of the long-term planning involved with their selection should be recognized.
The selection of and enrollment plans for the six SR0s were completed prior to our receipt of the NRC Staff's April 22, 1987 letter.
Prior to receipt of the Staff's letter, our Nuclear Training Department was formally notified of the selected STA cantidates in memoranda dated February 10, 1987, April 16, 1987, and April 30, 1n87.
As such, TVSTC, our Nuclear Training Department, our Operations Depart ments, and most importantly, the STA candidates themselves, had planned on the September,1987 enrollment before we received the April 22 letter. We consider our commitment to these individuals to be of great impor-tance, particularly in recognition of the fact that their qualifications and credentials will be virtually identical to other dual-role personnel.
SAFETY SIGNIFICANCE CYAPC0 and NNEC0 are concerned that denial of our proposal to "grandfather" current dual-role individuals, and those now enrolled at TVSTC, would adverse-ly affect the morale, self-esteem and resulting teamwork of our operating crews. Such a result would be counterproductive to the purpose of the Commis-sion's post-THI initiatives, which is to reduce the human error component of nuclear plant risk.
Those now enrolled in the program and those who have recently completed it feel, with complete justification, that they are fully qualified for the responsibilities of the dual-role position.
To prevent them from carrying out these responsibilities, while others with similar training are allowed to do so, would be unfair and highly damaging to morale.
Our proposal to phase in the Policy Statement's program maintains morale and continues the long-term upgrade of our training program.
In our meeting with the Staff on January 27, 1988 and our conference call on February 3,1988, the Staff stated its view that the alleged violation of Technical Specifications was "not a safety issue," but that changes to our program were required.
We believe that our implementation of the dual-role approach has been and continues to be consistent with our Technical Specifica-tions and NRC regulations.
The approach we have taken in the enclosed amend-ments is intended to satisfy the Staff's concerns regarding the language of the Technical Specifications, and at the same time provide a gradual transi-i tion to the options set forth in the Commission's Policy Statement.
We believe that sudden, forced changes to the program, given the absence of a compelling safety basis, could re.< ult in an adverse safety impact on the Haddam Neck Plant and Hillstone Unit Nos. I and 2.
)
We affirm our belief that our current STA program not only ensures adequate engineering and accident assessment expertise is possessed by our operating staffs, but is the optimal program.
E. J. Mroczka's letter to Chairman Zech provided in Attachment 11 includes a discussion of the importance we place in our ability to retain a highly-qualified, motivated, and experienced operating staff.
We believe that the extensive experience in operations department positions that our dual-role individuals possess is one of our most valued resources.
It was also noted that the objective stated in the Policy State-1 ment of filling senior management and corporate officer positions with indi-viduals with operations experience continues to be met at NU.
The last five 1
i U.S. Nuclear Rigulatory Comission B12820/Page 11 February 17, 1988 senior executives responsible for our nuclear program have over 80 years of combined counercial nuc' sear power experience at our plants and were all SRO-licensed at one of th? four NV plants.
The numerous impromments ir our operator initial and requalification training programs should also be noted.
INPO accreditation has been received for all of our operator training programs, including the STA progr6m.
The use of our four plant-specific simulators has greatly enhanced our operator training programs.
Requalification training for the STAS is provided by virtue of their full participation in the licensed operator requalification training program for the unit on which they are SRO-licensed and STA-qualified. As was stated in E. J. Mroczka's March 12, 1987 letters, most of our operating shifts have more than one dual-role-qualified individual.
Therefore, we consider that our current STA program provides assurance that each operating shift has more than adequate engineering expertise.
FUTURE STA PROGRAM AT NV Near Term While we stand by our stated interpretation that our implementation of the dual-role position is not in violation of Table 6.2-1, we are requesting the enclosed license amendments which will provide explicit recognition of the use of the dual-role position.
Lona Term As stated above, all replacements of our "grandfathered" dual-role-qualified individuals will be required to meet the provisions of the Comission's Policy Statement.
In addition, we acknowledge our responsibility to fully address any future requirements (e.g. the Advance Notice of Proposed Rulemaking, "Degree Requirement for Senior Operators at Nuclear Power Plants,"
l (51FR19561)).
i We will continue to evaluate the optimum method of providing adequate engi-neering and accident assessment expertise to our operating staffs.
For example, in late 1987, E. J. Hroczka formally became a member of the INP0 ad hoc comittee whose function is to advise INPO on the content and industry-wide implementation of a guide for enhancing the professionalism of nuclear plant personnel.
The purpose of this guide is to help promote an environment for professionalism.
One of the suggestions (currently in draft form) would recomend the strengthening of career development programs for operators to enhance their ability to earn promotions to key plant and corporate management positions.
SIGNIFICANT HAZARDS CONSIDERATION CYAPCO and NNEC0 have reviewed the proposed changes in accordance with i
10CFR50.92 and have concluded that they do not involve a significant hazards consideration in that these changes would not:
l.
Involve a significant increase in the probability or consequences of an accident previously analyzed.
There are no physical changes to the plants or the way in which they are operated.
The proposed amendments I
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i U.S. Nuclear Regulatory Commission B12820/Page 12 February 17, 1988 would exnlicitly recognize the acceptability of a shift configuration which has been in place for over four years.
2.
Create the possibility of a new or different kind of accident from any previously analyzed.
The potential for an unanalyzed accident is not created because no new failure modes are introduced, and the plant response to previously analyzed accidents is not modified.
3.
Involve a significant reduction in a margin of safety.
There is no impact on the protective boundaries.
The Commission has provided guidance concerning the application of standard in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986).
The proposed changes most closely resemble example (i) a furely administrative change to technical specifications.
The proposed changes will clarify the technical specifications to specifically reflect the implementation of the dual-role position, which has been in effect for over four years, and will add the specific qualification requirements for STAS.
The Haddam Neck Plant and Millstone Site Nuclear Review Boards have approved these proposed amendments and concur with the above determinations.
In accordance with 10CFR50.91(b), CYAPC0 and NNECO are providing the State of Connecticut with copies of these proposed amendments.
Pursuant to 10CFR170.12(c), enclosed with these amendment requests is the application fee of $150.
SlHMARY CYAPC0 and NNEC0 have been operating with the implementation of the dual-role position in good faith with the understanding that we meet our technical specification requirements.
Last month, the NRC Staff informed us of their interpretation of Table 6.2-1, which raised the technical specification compliance issue.
These amendment requests are intended to eliminate any confusion regarding compliance with Table 6.2-1.
Should the Staff require any additional information to process these amendment requests, CYAPC0 and NNEC0 remain available to provide such information.
We are prepared to provide additional information in writing, or to meet with the Staff, if such actions would be helpful in reaching a prompt resolution, i
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY hMVW E. J[.Ero'chk'a
(/
Seni r Vice President
\\.
U.S. Nuclear Regulatory Commission B12820/Page 13 February 17, 1988 Attachments:
1.
Proposed Technical Specification Change Request, Haddam Neck Plant.
2.
Proposed Technical Specification Change Request, Millstone Unit No.1.
3.
Proposed Technical Specification Change Request, Millstone Unit No. 2.
4.
NU Handouts from January 27, 1988 Meeting with the NRC Staff.
5.
Current Dual-Role Individuals.
6.
SR0s Currently Enrolled at Thames Valley State Technical College.
7.
Technical Specifications Prior to STA Requirements.
8.
Technical Specifications Reflecting the STA Requirement.
9.
Technical Specification Changes Requested on October 4, 1983.
- 10. Technical Specifications as Amended on February 16, 1984.
11.
E. J. Mroczka letters to the Commissioners.
cc:
W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 J. T. Shediosky, Resident Inspector, Haddam Neck Plant Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT)
) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he is author-ized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in said information are true and correct to the best of his k wiedge and belief.
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.Nofa'iTFG5 ic My Ccmm:sica Egres Mmh 31,1988 4
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