Text

Proposed Tech Specs,Amending Table 6.2-1 Re Dual Role Senior Reactor Operator (SRO) & Shift Technical Advisor (STA)
	ML20149L522
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	02/17/1988
From:	; CONNECTICUT YANKEE ATOMIC POWER CO.
To:	;
Shared Package
ML20149L446	List: ML20149L445; ML20149L522;
References
	GL-86-04, GL-86-4, TAC-67187, TAC-67188, TAC-67189, NUDOCS 8802240268
	Download: ML20149L522 (63)
	v • d • e

. . . - . . . . - . . ~ . . . . . . .-

Docket No. 50-213 '

B12820 1

4 Attachment 1 Haddam Neck Plant Proposed Technical Specification Change Request .

, Dual-Role SR0/STA Position I :

i d

l 1

i 1 I l

t 4

i February, 1988 ;

8802240268 880217 ;

PDR ADOCK 05000213 '

. .P pcp

TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION (I) )

Personnel Number Condition Cateaory Reauired of Unit i S0P 2' Normal Operating R0P 2 Condition Except l

A0P 2 Cold Shutdown !

l STA(2) 3 l

l S0P 1 Cold Shutdown R0P 1 Conditions t

AOP 2 i

Abbreviations: S0P -

Licensed Senior Reactor Operator

, R0P -

Licensed Reactor Operator A0P -

Additional Operator i STA - Shift Technical Advisor a

f (I) Shift crew composition may be one less than the minimum requirements l for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition to within the

minimum requirements of Table 6.2-1. This provision does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent.

(2) The Shift Technical Advisor position can be filled by either of the two Senior Reactor Operators (a dual-role individual), if he meets the requirements of Specification 6.3.1.2.1. '

6-4 l

l i

ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF OVALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions.

6.3.1.1 The position of Health Physics Supervisor shall meet the following minimum qualifications:

a. Academic degree in an engineering or science field or equivalent as per Section 6.3.1.1.c.

b. Minimum of five years professional technical experience in the area of radiological safety, three years of which shall be in applied radiation work in a nuclear facility dealing with problems similar to those encountered in a nuclear power reactor.

c. Technical experience in the area of radiological safety beyond the five year minimum may be substituted on a one-for-one basis towards the academic degree requirement (four years of technical experience being equivalent to a four year academic degree).

d. Academic and technical experience must total a minimum of nine years.

6.3.1.2 The Shift Technical Advisor (STA) who shall meet the requirements of Specification 6.3.1.2.1 or 6.3.1.2.2.

1. Dual-role individual: Hust hold a senior reactor operator's license at the Haddam Neck Plant, meet the STA training criteria of NUREG-0737, item I. A.1.1, and meet one of the following educational alternativos:

a. Bachelor's degree in engineering from an accredited !

institutio..; j

b. Professional Engineer's license obtained by the i successful completion of the PE examination;

c. Bachelor's degree in engineering technology from an accredited institution, including course work in the physical, mathematical, or engineering sciences;

d. Bachelor's degree in a physical science from an accredited institution, including course work in the '

physical, mathematical, or engineering sciences; 65

ADMINISTRATIVE CONTROLS

e. Successful completion of the Memphis State University (MSU)

STA program. (Note: This alternative is only acceptable for individuals who have completed the program prior to December 31, 1986); or

f. Successful completion of the Thames Valley State Technical College associate's degree in Nuclear Engineering Technology program, provided that the individual was enrolled in the progr&m by October 1, 1987.

2. Dedicated STA: Must meet the STA training criteria of NUREG-0737, Item I.A.1.1, and have received specific training in plant design, and response ar.d ar.alysi s of the plant for transients and accidents.

6.4 TRAltMQ 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Training Coordinator assigned program responsibility and shall be in accordance with Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CF'l Part 55.

6.4.2 A fire brigade training program shall be maintained under the direction of the training dapartment and shall meet or exceed the intent of Section 27 of the NFPA Code-1976 except that drills / training shall be conducted at least quarterly. The effective date of this specification is March 1,1978.

6.5 REVIEW AND AUDIT ,

6.5.1 PLANT OPERATIONS REVIEW COMMITTEE QQACl ,

FUNCTION 6.5.1.1 The PORC shall function to advise the Station Superintendent on

all matters related to nuclear safety. i COMPOSITION ,

6.5.1.2 The PORC shall be composed of the: l 1

Chairperson: Station Superintendent Member: Unit Superintendent Member: Operations Supervisor i Member: Maintenance Supervisor '

Member: Instrument and Control Supervisor Member: Reactor Engineer !

Member: Engineering Supervisor 1 Member: Station Services Superintendent !

Member: Quality Assurance Supervisor Member: Chemistry Supervisor l Member: Health Physics Supervisor Member: Security Supervisor 6 Sa

-,. i * -

Docket No. 50-245 i B12820 !

i j

9 5

1 i

1 I

Attachment 2 ,

t

. Millstone Unit No. 1

, t Proposed Technical Specification Change Request [

Dual Role SR0/STA Position :

t i

l l

i ,

4 I

1 i

1

.J ,

s .

i i l.

1 i i

! I f

}

February, 1988

~

i

)

v 1 I

ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum !

qualifications of ANSI N18.1-1971 for comparable positions, except for:

a. The Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1.

b. The Shift Technical Advisor (STA) who shall meet the requirements of Specification 6.3.1.b.1 or 6.3.1.b.2.

1. Dual-role individual: Must hold a senior reactor operator's license at Millstone Unit No.1, meet the STA training criteria of NUREG-0737, Item I.A.1.1, and meet one of the following educational alternatives:

a. Bachelor's degree in engineering from an accredited institution;

b. Professional Engineer's license obtained by the successful completion of the PE examination; ,

c. Bachelor's degree in engineering technology from an .

accredited institution, including course work in the physical, mathematical, or engineering sciences;

d. Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, or engineering sciences;

e. Successful completion of the Memphis State University (MSU) STA program. (Note: This alternative is only acceptable for individuals who have already completed the program prior to December 31, 1986); or

f. Successful completion of the Thames Valley State Technical College associate's degree in Nuclear Engineering Technology program, provided that the individual was enrolled in the program by October 1, 1987.

2. Dedicated STA: Must meet the STA training criteria of NUREG-0737 Item I.A.I.1, and have received specific training in plant design, and response and analysis of the i plant for transients and accidents. l l

l 4

Millstone Unit 1 64

TABLE 6.2-1(5) l MINIMUM SHIFT-CREW COMPOSITION (2) l APPLICABLE MODES _

i LICENSE CATEGORY 1, 2, & 3 I} 4 & 5(4)

Senior Reactor Operator 2 I II)

Reactor Operator 2 1 l i Non-Licensed Operator 2 1 l Shift Technical Advisor 1(6) None Required III Does not include the licensed Senior Reactor Operator or Senior Reactor l ,

l Operator Limited to Fuel Handling individnal supervision CORE ALTERATIONS after the initial fuel loading.

l (2) The above shift crew composition and the qualified health physics l technician and/or fire brigade members of Section 6.2.2 may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence provided expeditious actions are ,

taken to fill the required positions.

(3) Reactor Mode Switch Position is in RUN (any average coolant temperature) !

STARIUP/ HOT STANDBY (any average coolant temperature), and HOT SHUTDOWN (average coolant temperature greater than 212*F), respectively.

(4) Reactor Mode Switch Position is in SHUTDOWN (average coolant temperature !

less than 212'F) and REFUELING (average coolant temperature less than 212*F),respectively. '

(5) Requirements for minimum number of licensed operators on shift during !

operation in modes other than cold shutdown or refueling are contained in 10 CFR 50.54(m).

(6) The Shift Technical Advisor psition can be filled by either of the two Senior Reactor Operators (a dual-role individual), if he meetc the requirements of Specification 6.3.1.b.l.

Millstone Unit 1 6-5

, .s .c. ,

. i i

Docket No. 50-336 !

B12820 :

i i

f l

1 i

l Attachment 3 e Millstone Unit No. 2 -.

Proposed Technical Specification Change Request Dual-Role SRO/STA Position i 6

l i

i i

, February, 1988

n '

g lSTRATIVE CONTROLS 6.1 RESPONSIBillTY 6.1.1 The Station Superintendent shall be responsible for overall operation of the Millstone Station Site while the Unit Superinter. dent shall be responsible for operation of the unit. The Station Superintendent and Unit Superintendent shall each delegate in writing the succession to these responsibilities during their absence.

6.2 ORGANIZATION OFFSITE 6.2.1 The Facility organization for facility management and technical support shall be as shown on Figure 6.2-1.

FACILITY STAFF 6.2.2 The Facility organization shall be as shown on Figure 6.2-2 and:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b. At least one licensed Operator shall be in the control room when fuel is in the reactor,

c. At least two licensed Operators shall be present in the control room during reactor start-up, scheduled reactor shutdown and during recovery from reactor trips.

d. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. (Table 6.2-1) l

e. ALL CORE ALTERATIONS after the initial fuel loading shall he directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

f. A site Fire Brigade of at least 5 members shall be maintained onsite at all times. (Table 6.2-1) The Fire Brigade shall not l include 2 members of the minimum shift crew necessary for safe shutdown of the unit or any personnel required for other essential functions during a fire emergency.

g. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions. These procedures should follow the general guidance of the NRC Policy Statement on working hours ,

(Generic Letter No. 82-12). l l

l Millstone - Unit 2 6-1 i

i

l ADMINISTRATIVE CONTROLS l

6.3 FACILITY STAFF OUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for:

a. The Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1,

b. The Shift Technical Advisor (STA) who shall meet the requirements of Specification 6.3.1.b.1 or 6.3.1.b.2.

1. Dual-role individual: Must hold a senior reactor operator's license at Millstone Unit No. 2, meet the STA training criteria of NUREG-0737, Item I.A.1.1, and meet one of the following educational alternatives:

a. Bachelor's degree in engineering from an accredited institution;

b. Professional Engineer's license obtained by the successful completion of the PE examination;

c. Bachelor's degree in engineering technology from an accredited institution, including course work in the physical, mathematical, or engineering sciences;

d. Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, or engineering sciences;

e. Successful completion of the Memphis State University

(MSV) STA program. (Note: This alternative is only acceptable for individuals who have completed the program prior to December 31, 1986); or l

f. Successful completion of the Thames Valley State Technical College associate's degree in Nuclear Engineering Technology program, provided that the individual was enrolled in the program by October 1, 1987.

2. Dedicated STA: Must meet the STA training criteria of NUREG-0737, Item I.A.I.1, and have received specific training in plant design, and response and analysis of the plant for transients and accidents.

Millstone - Unit 2 6-la

TABLE 6.2-1(3) l MINIMUM SHIFT-CREW COMPOSITION (2)-

APPLICABLE MODES LICENSE CATEGORY 1, 2, 3 & 4 5&6 Senior Reactor Operator 2 1(I) l Reactor Operator 2 1 Non-Licensed Operator 2 1 Shift Technical Advisor 1(4) None !

Required II) Does not include the licensed Senior Reactor or Senior Reactor Operator !

l Limited to Fuel Handling individual supervision CORE ALTERATIONS after the initial fuel loading, i (2) The above shift crew composition and the qualified health physics !

technician and/or fire brigade members of Section 6.2.2 may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence provided expeditious actions are taken to fill the required positions.

(3) Requirements for minimum number of licensed operators on shift during l operation in modes other than cold shutdown or refueling are contained in 10CFR50.54(m).

i (4) The Shift Technical Advisor position can be filled by either of the two

~

, Senior Reactor Operators (a dual-role individual), if he meets ~ the requirements of Specification 6.3.1.b.l.

l r

Millstone - Unit 2 6-4 t

Docket Nos. 50-213 .

50-245 !

IE3.3.ft B12820 ,

i

)

l J

Tf Attachment 4 l t

Handouts from January 27, 1988 Meeting

. with NRC Staff .

t 9

i 1 ;

i ;

i i

i I

February, 1988 6 t

I 5

I

, ..s .

)

CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY DOCKET NOS. 50-2I3, 50-245, 50-336 JANUARY 27, 1988 MEETING WITH NRC STAFF MINIMUM SHIFT CREW COMPOSITION AND IMPLEMENTATION OF DUAL-ROLE SRO/STA AT NORTHEAST UTILITIES i

. 1 .

l PURPOSE l l

i 01 PROVIDE INFORMATION IN RESPONSE TO STAFF REQUEST REGARDING COMPLIANCE WITH TECHNICAL SPECIFICATION REQUIREMENTS FOR MINIMUM SHIFT CREW COMPOSITION 0

RESULT IN NRC CONCURRENCE THAT OUR SHIFT STAFFING COMPLIES WITH ALL APPLICABLE NRC REGU.LATIONS AND LICENSE REQUIREMENTS 0

CLARIFYING AMENDMENT WOULD ELIMINATE EXISTING CONFUSION J

i s

1

,y

. t-3 NORTHEAST UTILITIES ATTENDEES l

R. M. KACICH -

LICENSING MANAGER Rc J. PALMIERI - MILLSTONE UNIT NO. 1 OPERATIONS SUPERVISOR J. R. BARNETT -

LICENSING ENGINEER ;

5 i

f I

6 F

i l

l s

.--.--..--_--,,,,-.,-,.,,,,_,-sy_-,_---_-_,--,r-,_ -

~

1 .

4 DVERVIIW 0 ;. NU COMPLIES WITH CONFIRMATORY ORDER CONCERNING STA COVERAGE, TRAINING, AND LONG-TERM PROGRAM 0 NU COMPLIES WITH LICENSED OPERATOR STAFFING FINAL RULE (10CFR50. 54 (M) ) , AS REAFFIRMED BY TECHNICAL SPECIFICATION TABLE 6.2-1 L

I I

I i

l l

I I

s

- . < ~

_5 1

iY NU IMPLEMENTED DUAL-ROLE l 0 NRC AKNOWLEDGED OPTION POST-TMI O

NU STATED PLAN IN 1979

~

O NU DEVELOPED A CUSTOM PROGRAM l O TECH SPECS DID NOT PROHIBIT 0 NU ADVISED NRC 0F ITS INTERPRETATION PRIOR TO IMPLEMENTATION 0 NU APPLIED FOR CLARIFYING AMENDMENTS 0 NRC (PROJECT MANAGER) STATED THIS WAS ACCEPTABLE, THAT THEY CONFERED WITH THE RESIDENT INSPECTOR, AND THAT NO ENFORCE-MENT ACTION WOULD RESULT 0 NRC ACTION ON AMENDMENT REQUESTS WAS DEFERRAL, NOT REJECTION 0 THE THEN-CURRENT DRAFT OF THE EE05 POLICY STATEMENT HAD LANGUAGE MORE IN KEEPING WITH OUR PROGRAM 0 NUMEROUS INSPECTION REPORTS REAFFIRMED NRC ACCEPTANCE OF THE i DUAL-ROLE O FOLLOWING A SEPTEMBER, 1986 MEETING, THE STAFF RECOMMENDEO COMMISSION ACCEPTANCE OF OUR PROGRAM AS MEETING THE INTENT OFTHE POLICY STATEMENT i

! O A 1987 LETTER FROM THE STAFF STATED THAT THE COMMISSION i

AGREES THAT CURRENT DUAL-ROLE PERSONNEL CAN CONTINUE TO SERVE f

2

- - - - _ , . , . . . , - . _ , . , - _ - . , - . - _ , - ~ . . _ . -

q

-' .g.

i 1

RECURRING THEMES i

0 NU KEPT THE NRC WELL INFORMED 0 NRC ACKNOWLEDGED AWARENESS AND ACCEPTANCE 0 NRC STATED THEY WERE UNABLE TO ACT ON OUR AMENDMENT REQUEST BECAUSE THE POLICY STATEMENT WAS NOT FINALIZED 0 CURRENT SITUATION HAS EXISTED FOR OVER FOUR YEARS WITH NO CHANGES IN REQUIREMENTS

~

0 NU EXPLORED EVERY AVAILABLE OPTION IN ATTEMPTING TO GAIN NRC CONCURRENCE THAT OUR PROGRAM MEETS THE INTENT OF THE POLICY STATEMENT 0 WE IMPLEMENTED A RESOURCE INTENSIVE PROGRAM DESIGNED TO OPTIMALLY PROVIDE ENGINEERING AND ACCIDENT ASSESSMENT EXPERTISE ON SHIFT 4

I l I i

t ,

_y.

HISTORY JULY 1979 NUREG-0578, TMI-2 SHORT-TERM RECOMMENDATIONS:

PROMULGATES REQUIREMENTS FOR STAS i

9/;13/79 FOLLOW-UP ACTIONS REGARDING THI-2: REQUESTS IMPLEMENTATION SCHEDULE; i STA ALTERNATIVES SHOULD BE CONSIDERED, I.E., MORE ENGINEERING TRAINING FOR R0s AND SR0s.

10/18/79 NU RESPONSE:

INTERIM STA PROGRAM - DEDICATED STA; LONG-TERM - UPGRADE TRAINING OF AN SRO 10/30/79 CLARIFICATION OF NUREG-0578:

STAS TO BE ON DUTY BY 1/1/80

11/21/79 NU RESPONSE TO 10/30/79 LETTER:

i LONG-TERM STA PROGRAM - WILL ADD AN OPERATOR TO

, EACH SHIFT;

! UPGRADE TRAINING OF AN SRO TO INCLUDE REGUIREMENTS 0F 9/13/79 LETTER - OPTIMUM METHOD 12/10/79 NU LETTER: REAFFIRMS LONG-TERM PLANS 12/27/79 NRC LETTER: ACKNOWLEDGES CATEGORY A PLANS 12/31/79 NU LETTER: DISCUSSES INTERIM AND LONG-TERM PROGRAMS 4/18/80 NRC LETTER: STA PROGRAM MEETS NUREG-0578 AND IS ACCEPTABLE '

i 4/30/80 INPO DOCUMENT: NUCLEAR POWER PLANT SHIFT TECHNI- l i

CAL ADVISOR - RECOMMENDATIONS FOR POSITION DESCRIPTION, QUALIFICATIONS, EDUCATION, AND TRAINING MAY 1980 NUREG-0660: STA POSITION CAN BE ELIMINATED WHEN SS QUALIFICATION UPGRADES ARE ATTAINED.

5/7/80 ADDITIONAL TMI REQUIREMENTS: SHIFT MANNING i REQUIREMENTS FORTHCOMING 7/2/80 NRC LETTER: PROVIDES MODEL TECHNICAL SPECIFICA-TIONS FOR STA POSITION.

l

/ .

I

3. ' ~

7/31/80 NRC LETTER: INTERIM CRITERIA FOR SHIFT STAFFING:

SHIFT CREW SHALL INCLUDE 2 SR0s, 2 Ros, 2 A0s; NOTE: NO DISCUSSION OF STA POSITION (I.E., A 7TH '

PERSON) 9/5/80 PRELIMINARY CLARIFICATION OF THI ACTION PLAN -

REQUIREMENTS:

"THE NEED FOR THE STA POSITION MAY BE ELIMINATED WHEN THE QUALIFICATIONS OF THE SSs AND 50s HAVE BEEN UPGRADED..."

. . .THE DESCRIPTIONS AS SET FORTH IN. . .THE INPO DOCUMENT ARE AN ACCEPTABLE APPROACH FOR THE SELECTION AND TRAINING OF PERSONNEL TO STAFF THE STA POSITION."

"BY JANUARY 31, 1981, PROVIDE. . . A DESCRIPTION OF THEIR LONG-TERM STA PROGRAM INCLUDING... PLANS, IF ANY, FOR THE EVENTUAL PHASE-0UT OF THE STA PROGRAM."

9/16/80 CY, MP1, MP2 LICENSE AMENDMENT REQUESTS TO ADD STA REQUIREMENT (IDENTICAL TO MODEL SPECIFICATION);

EMPHASIZES THAT DEDICATED STA PROGRAM IS INTERIM.

10/1/80 NU COMMENTS Oi! PRELIMINARY CLARIFICATION:

LICENSEE SHOULD DETERMINE EQUIVALENCY CRITERIA TO ENGINEERING DEGREE.

10/22/80 NU LETTER: INTEND TO UPGRADE SHIFT COMPLEMENT TO 2 SR0s, 2 R0s, AND 2 A0s.

WILL PROVIDE TRAINING TO SELECTED OPERATORS TO MEET INPO STA REQUIREMENTS.

10/31/80 NUREG-0737, CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS:

STA POSITION MAY BE ELIMINATED WHEN QUALIFICATIONS !

0F SSs AND 50s UPGRADED; l

4 INPO DOCUMENT (PROVIDED AS APPENDIX C) ACCEPTABLE !

FOR SELECTION AND TRAINING OF STAS. USE FOR !

l GUIDANCE FOR PLANNING LONG-TERM STA PROGRAM; j

! RE00ESTS DESCRIPTION OF LONG-TERM PROGRAM AND PLANS FOR PHASE OUT OF STA PROGRAM. INCLUDE j COMPARISON TO INP0 DOCUMENT; i

t . -

-9 !

i SHIFT STAFFING REQUIREMENTS-SUBJECT OF FUTURE RULEMAKING.

12/31/80 NO RESPONSE TO NUREG-0737:

DESCRIPTION OF INTERIM STA PROGRAM; DESCRIPTION OF LONG-TERM STA PROGRAM, INCLUDING COMPARISON TO INPO DOCUMENT; STA FUNCTION WILL BE PHASED OUT 4/7/81 hRC ISSUES AMENDHENT #66 FOR MP2: ADDS STA.

7/7/81 ORDER CONFIRMING LICENSE COMMITHENTS ON POST-THI i RELATED ISSUES: '

PROVIDE STA COVERAGE BY 1/1/81; SUBMIT DESCRIPTION OF CURRENT TRAINING PROGRAM BY i 1/1/81:

SUBMIT DESCRIPTION OF LONG-TERM TRAINING PROGRAM BY 1/1/81. '

10/6/81 NRC ISSUES AMENDMENT #79 FOR MP1: ADDS STA.

i 10/8/81 NRC ISSUES AMENDMENT #42 FOR CY: ADDS STA.

2/19/82 NU LETTER: PROVIDES ADDITIONAL INFO CONCERNING t

NON-DEGREED STAS. ,

4 2/22/82 NRC LETTER: NU's "STA TRA1NING PROGRAM IS ACCEPT- :

ABLE IN MEETING THE INTENT OF THE GUIDELINES SET !

FORTH..." '

I 3/1/82 NU LETTER: FIRST GROUP OF SSs AND SCOs ATTENDING l

MSU PROGRAM RETURN TO SHIFT IN APRIL, 1982. '

3/31/82 NRC LETTER: ACCEPTS STAS WITHOUT B.S. DEGREES; ,

CONSIDER EXPERIENCE AND SRO LICENSE "ADVANTAGEOUS TO PLANT SAFETY."

)

i 8/6/82 NU LETTER: RE0 VESTS APPROVAL OF 8 MORE INTERIM :

STAS WITHOUT B.S. DEGREE '

8/23/82 PROPOSED RULE ON LICENSED OPERATOR STAFFING: WILL j

REQUIRE 2 SR0s AND 2 R0s ON SHIFT.

9/9/82 NRC LETTER: ACCEPTS 8 STAS "WITHOUT BACHELOR

)

] DEGREES BUT WITH SUFFICIENT TRAINING." '

i l

. O. '

9/27/82 NU LETTER: COMMENTS ON PROPOSED RULE ON STAFFING:

NU STRIVING FOR 2 SR0s, 2 R0s, AND 2 A0s ON SHIFT.

MARCH, 1983 NU LETTER: RESPONSE TO GL 83-02, NUREG-0737 TECHNICAL SPECIFICATIONS.

NU CONSIDERS ITEM I.A. 1.1.3 RESOLVED. i 3/14/83 ORDER CONFIRMING LICENSEE COMMITMENTS ON POST-THI

, RELATED ISSUES:

MINIMUM SHIFT CREW - TO BE ADDRESSED IN THE FINAL RULE ON LICENSED OPERATOR STAFFING AT NUCLEAR POWER UNITS.

7/11/83 FINAL RULE, LICENSED OPERATOR STAFFING:

2 SR0s NEEDED BY 1/1/84; DUAL-ROLE UNDER CONSIDERATION BY COMMISSION 7/25/83 DRAFT POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT: ,

WILL ALLOW DUAL-ROLE, STA POSITION MAY BE ELIMI-NATED; "THE INTENT OF THIS POLICY GUICANCE CAN BE ACCOM- !

PLISHED BY.. 2. ASSIGNMENT OF AN INDIVIDUAL WITH

THE

' FOLLOWING OUALIFICATIONS TO THE OPERATING SHIFT CREW AS ONE OF THE SENIOR OPERATORS REQUIRED 1

BY 10CFR50.50.54(M): A. BACCALAUREATE DEGREE OR EQUIVALENT IN ENGINEERING OR RELATED SCIENCES...

EQUIVALENCY SHALL BE DEFINED AS:...(C) SUCCESSFUL >

COMPLETION OF THE TECHNICAL PORTIONS OF AN ACCRED-ITED, FOUR YEAR ENGINEERING DEGREE PROGRAM."

8/25/83 NU LETTER: COMMENTS ON FINAL RULE ON STAFFING:

NU's LONG-TERM STA PROGRAM UNDER DEVELOPMENT FOR 4 1 YEARS;

OBJECTIVE TO ASSURE APPROPRIATE EXPERTISE AVAIL-ABLE ON SHIFT, NOT TO HAVE B.S. DEGREES; i ADDITIONAL INDIVIDUAL FILLING STA FUNCTION WAS INTERIM MEASURE, UNTIL QUALIFICATION OF ON SHIFT l

PERSONNEL UPGRADED; '

STA FUNCTION WILL BE FILLED BY DUAL-ROLE INDIVID-

{(hSBYg{83ONMILLSTONE1.ANDBY1/1/84ONCY M ((

l CLARIFYING LICENSE AMENDMENT REQUESTS WILL BE SUBMITTED.

l l

s .

11 9/23/83 NU LETTER: COMMENTS ON DRAFT POLICY STATEMENT:

REAFFIRMS OUR LONG-TERM PROGRAM PLANS - DEDICATED I STA POSITION WILL BE ELIMINATED; TECH SPECS DO NOT PRECLUDE DUAL-ROLE:

. DUAL-ROLE POSITION MEETS 10CFR50.54(M);

NO CHANGES TO LONG-TERM PLANS.

10/4/83 LICENSE AMENDMENT REQUESTS FOR MILLSTONE UNIT NOS. 1 AND 2:

l STA POSITION CAN BE FILLED BY DUAL-ROLE INDIVID-UAL; DUAL-ROLE FOOTNOTE PROPOSED.

i 10/24/83 LICENSE AMENDMENT RE0 VEST FOR HADDAM NECK PLANT:

~

STA POSITION CAN BE FILLED BY DUAL-ROLE INDIVID- t UAL; DUAL-ROLE FOOTNOTE PROPOSED.

11/18/83 NU LETTER:

! DEDICATED STA POSITION BEING PHASED OUT; NO SINGLE ENGINEERING DEGREE SATISFIES NU's

REQUIREMENTS OR INP0 GUIDELINES FOR STA POSITION; l IMPLEMENTING TVSTC PROGRAM:

I NU STILL IN COMPLIANCE WITH THE CONFIRMATORY ORDERS ON STAS; l

PROGRAM MEETS OR EXCEEDS NRC's GUIDANCE /INPD GUIDELINES.

1/1/84 10CFR50.54(M) EFFECTIVE: NEED 2 SR0s 2 R0s AND 2 .

A0s. ,

1/3/84 NU TELECON WITH NRC LICENSING PROJECT MANAGER; NRC UNDERSTANDS NU's POSITION CONCERNING DUAL-ROLE: ;

RESIDENT INSPECTOR AWARE OF NU's POSITION; l

t

t 12 i i

NO ENFORCEMENT ACTION WILL RESULT FROM INTERPRETA- ,

TION OF TECH SPECS OR 10CFR50.54(M) 1 2/16/84 AMENDMENTS #95 FOR MILLSTONE 1 AND #92 FOR MILLSTONE 2 ISSUED:

2 SR0s NOW REQUIRED:

REQUEST FOR DUAL-ROLE FOOTNOTE TO TABLE 6.2-1 NOT ISSUED, TO BE HANDLED BY A SEPARATE LICENSING ACTION.

3/9/84 NU INTERNAL MEMO: ADDRESSES TECH SPEC COHPLIANCE:

NOTES THAT NRC DID NOT REJECT OUR PROPOSAL, BUT CHOSE TO DEFER ACTION; NO NRC REQUIREMENT OR PLANT-SPECIFIC CORRESPON-DENCE TO NU PROHIBITS USING ONE OF THE ON-SHIFT SR0s IN A DUAL-ROLE; NRC APPROVED OUR LONG-TERM STA PLANS, IN WHICH WE CLEARLY STATED OUR INTENTION TO FILL STA POSITION WITH UPGRADED ON-SHIFT PERSONNEL:

NRC NEVER OBJECTED TO THESE PLANS OR OUR STATED TECH SPEC INTERPRETATION; NRR DISCUSSED OUR POSITION WITH RESIDENT INSPEC-TORS:

NRR STATED NO VIOLATION WILL RESULT; NRC AGREED NU's STA TRAINING PROGRAM HET DEGREE EQUIVALENCY DEFINITION.

1/15/85 AMENDMENT #61 FOR THE HADDAM NECK PLANT:

2 SR0s REQUIRED; REQUEST FOR FOOTNOTE TO TABLE 6.2-1 NOT ISSUED, TO BE HANDLED BY SEPARATE LICENSING ACTION.

i 3/20/85 NU INTERNAL MEMO: HADDAM NECK TECH SPEC

COMPLIANCE

NU TECH SPEC INTERPRETATION WELL DOCKETED; NRC NEVER OBJECTED TO OUR INTERPRETATION; NRC VERBALLY AGREED NU IN COMPLIANCE WITH ALL '

APPLICABLE LICENSE CONDITIONS; l J

l j NO NRC REQUIREMENT OR PLANT-SPECIFIC CORRESPON- l DENCE PRECLUDES USE OF DUAL-ROLE.

13

, 8/6/85 AMENDMENT #102 FOR MILLSTONE UNIT NO. 2: l ISSUED WITH FOOTNOTE TO TABLE 6.2-1 INCLUDED WHICH

. PERMITS FILLING STA POSITION WITH AN ON-SHIFT SRO.

PAGE NOT DISTRIBUTED TO NU CONTROLLED COPY DOCUMENT

. HOLDERS. '

9/12/85 INSPECTION REPORT 50-245/85-22 AND 50-336/85-27:

SHIFT MANNING REQUIREMENTS REVIEWED AND ACCEPT-l ABLE.

10/28/85 FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON

SHIFT:

a q i

PERMI'S DUAL-ROLE SRO/STA POSITION - SEPARATE STA POSITION MAY BE ELIMINATED, :

"THE COMMISSION PREFERS A COMBINED SR0/STA POSI- !

TION"-

ACCEPTABLE IF PROGRAM MEETS INTENT OF POLICY i ETATEMENT.

i !

2/13/86 GE.1ERIC LETTER 86-04: REQUESTS:

CURRVNT STA PROGRAM; i EQUIVALENCY CRITERIA USED; CHANGES PLANNED.

i

6/13/86 NU RESPONSE TO GENERIC LETTER 86-04.

1 i 8/6/86 SECY-86-231, SURVEY ON EE05 i

l 9/25/86 NU MEETING WITH NRC STAFF: ENGINEERING EXPERTISE

) l ON SHIFT AT NORTHEAST UTILITIES: !

t i

PRESENTED DETAILED DESCRIPTION OF THE EVOLUTION OF i THE EE05 ISSUE. NU's STA PROGRAM, AND THE ,

PRINCIPLES BEHIND THE DUAL-ROLE POSITION AT NU. :

1 NU SOUGHT TO COMPLY WITH THE POLICY STATEMENT BY ,

! HAVING THE NRC ACCEPT CUR PROGRAM "0N A CASE-BY- 1 CASE BASIS" ;

1 i 12/31/86 SECY-86-383, EE05 AT NU:

i I 1

! "THE STAFF CONSIDERS THAT THE NU PROGRAM FOR DUAL ROLE SR0/STA MEETS THE INTENT OF THE COMMISSION

) POLICY STATEMENT, AND WE FIND IT ACCEPTABLE."

i l

(

~

-14 3/6/87 NU MEETING WITH COMMISSIONERS AND THEIR STAFF:

EE05 AT NU.

3/12/87 NU LETTERS TO 5 COMMISSIONERS: EE05 AT NU.

4/22/87 NRC LETTER: DUAL-ROLE POSITIONS AT NU:

, PRESENT DUAL-ROLE PERSONNEL CAN CONTINUE TO SERVE;

... WHILE NOT A REQUIREMENT, FUTURE PERSONNEL IN THE DUAL POSITIONS SHOULD MEET THE CRITERIA IN THE POLICY STATEMENT."

7/28/87 RESIDENT INSPECTION 50-213/87-18:

EE05 IS AN OPEN ITEH; DUAL-ROLE INDIVIDUALS DO NOT HAVE DEGREES.

8/7/87 NU LETTER: RESPONSE TO 4/22/87 LETTER:

WE INTERPRET 4/22/87 LETTER TO ACCEPT ALL DUAL-ROLE INDIVIDUALS WHO ATTENDED TVSTC OR MSU PROGRAM:

NO PLANS FOR CHANGES TO DUAL-ROLE SRO/STA PROGRAM.

i 10/2/87 NU LETTER: RESPONSE TO R.I. 50-213/87-18:

OUR STA PROGRAM IN COMPLIANCE WITH ALL REQUIRE-j MENTS:

NU STUDY CONCLUDED EXISTING STA PROGRAM OPTIMAL.

12/28/87 RESIDENT INSPECTION S0-213/87-27:

STA PROGRAM CONFORMS WITH EXISTING REQUIREMENTS; SHIFT MANNING COMPARED TO REGULATORY REQUIREMENTS i

"N0 UNACCEPTABLE CONDITIONS WERE IDENTIFIED."

{ 1/27/88 NRC/NU MEETING i

6 t

NOTE THAT NUMEROUS INSPECTION REPORTS PUBLISHED THROUGHOUT THE LAST SEVERAL YEARS STATED THAT OUR l SHIFT MANNING WAS ACCEPTABLE.

i

u l

~

6, 15- \

\

SUMMARY

l l

0 NU PROGRAM COMPLIES WITH ALL APPLICABLE NRC REGULATIONS AND LICENSE REQUIREMENTS 0 ADEQUATE ACCIDENT ASSESSMENT AND ENGINEERING EXPERTISE ON SHIFT EXISTS f

0 RECOMMENDED RESOLUTION: ISSUE PREVIOUSLY REQUESTED LICENSE AMENDMENTS

\

~

I

t i ,-

4

{

< \

3 F

Docket Nos. 50-213 t 50-245

, 50-336 i d

112311 l i

i I

4 i

a i >

) t 1 :

, i

) Attachment 5 :

4 i

, Haddam Neck Plant r j Millstone Unit Nos. 1 and 2 l Current Dual Role SR0/STA Individuals 1

i ll f

I 4

I l

i !

f L

l I

i :

1 1

I February, 1988 l i

1 l

Attachment 5 B12820/Page 1 l

Current Dual-Role SRO/STA Individuals Memchis State University STA Procram Graduates [

Haddam Neck Plant Millstone Unit No. 1 Millstone Unit No. 2 M. Hadfield (SS) E. Berry (SS) D. Clark (SS) i D. Heffernan (SS) R. Kraemer (SS) R. Gauzza (SS)

J. Piontkowski (SS) J. Howell (SS) A. Olechnowicz (SS)

R. Reeves (SS) R. Schmidtknecht (SS) W. Strong (SS) l R. Willis (SS) C. Shine (SS)

P. Benyeda (SCO)

J. Lemke (SCO)

R. Warnock (SCO)

Thames Valley State Technical Colleae Graduates Haddam Neck' Plant Millstone Unit No. 1 Millstone Unit No. 2 R. Morgan (SS) D. Latz (SCO) D. Mooney (SS)

J. Hochdorfer (SCO) J. Olson (SCO) M. Mullin (SS)

E. Montalvo (SCO) T. Vernon (SCO) T. Dubay (SCO)

P. Rainha (SCO) D. Kendle (CO) L. Nelson (SCO) l

._m > . _ . _ - . _ . _ . . . - _ . .

{

-1 Docket Nos. 50 213

, 50-245 [

1 50 336 . :

1 11182Q :

1 f

L t

i r

i 4

i !

i F

4 t

i

]

a i J

l i

Attachment 6 !

r t

., Haddam Neck Plant t

[ Millstone Unit Nos. I and 2 l 1 f

Tables of SR0s Currently Enrolled i

! at Thames Valley State Technical College !

, t i :

I !

4 4

4 4 ;

i

-i l i r I

I f 4

i I

1 I i l l

1 t 1 i l

i t

i l- I

, February, 1980 l

. _ _ . _ ~

j l' Attachment 6 :

B12820/Page 1 l 6

! SR0s Currently Enrolled at Thames Valley :

State Technical Co11eae .

l Class of June.1988 .

Millstone Unit No. 1 Millstone Unit No. 2 ,

D. Bergstrom (CO) D. Emborsky (SCO) ,

0, Dvorak (CO) S. Myers (SCO)

H. Williamson (SCO)

Class of June. 1989 ,

Haddam Neck Plant Millstone Unit No. 1 Millstone Unit No. 2 J. Houff (SCO) W. McCollum (CO) C. Nelson (SCO)

J. Bower (SCO) W. Spahn (CO)

D. Reilly (SCO) !

l t

i l 5 i

i t

t r

[

I t

I

?

i I

i i

'l h

Docket No. 50-245 812820 Attachment 7 Millstone Unit No. 1 Technical Specifications Prior to STA Requirement February, 1988

~. _ _ _ _ _ _ _ _ _

December 8,1978 . ,

j s

l."~~/;'4.0 ADMINISTRATIVE CONTROL 5 g .m: 4

- 6.1 RESPONSIBILITY i- .

The Station Superintendent shall be responsible for overall operation l ['>

6.1.1 af the Millstone Station Site while the Unit Superintendent shall be respon-Eel

' ,',;' l sible for operation of the unit. The Station Superintendent and Unit Superin- l tendent shall each delegate in writing the succession to these respcasibilities ad lI se '

during their absence. b,;:n I

~

6.2 ORGANIZATIO_N .

0FFSITE 6.2.1 The offsite organization for facility management and technical support shall be as shown in Figure 6.2-1.

FACILITY STAFF 6.2.2 The Facility ohcanization shall be as shown on Figure 6.2-2 and:

a .- Each on duty shift shall be composed of at least the minimum shif t crew composition shown in Table 6.2-1. - ,

1 l

b. At least one licensed Operator shall be in the control room l is.

i* ,

when fuel is in the reactor.

c. At least two licensed Operators shall be present in the .

control room during reactor start-up, scheduled reactor shutdown and during recovery from reactor trips.

d. An individual qualified in radiation protection procedures shall

- be on site when fuel is in the reactor.

e. All CORE ALTERATIONS after the initial fuel loading shall be directly supervised by either a licensed Senior Reactor !

Operator or Senior Reactor Operator limited to Fuel Handling who has no other concurrent responsibilities during this operation.

f. A Fire Brigade of 3 members shall be maintained onsite at all t!re s. The Fire Brigade shall not include the minimum shift -

{,

crew necessary for safe shutdown of the Unit (2 members) or any personnel required for other essential functions during a fire -

emergency.*

6.3 FACILITY STAFF QUALIFICATIONS .

6.3.1 Each member of the facility staff shall meet or exceed the minian .

qualifications of ANSI N18.1-1971 for comparable positions, except for

( the Health Physics Supervisor who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, after January 1,1978.

- *To be ef f ective by March 1,1978 knenhent so. )d, 28, 7 56' 6-1 .

l

October 28, 1075 TABLE 6.2-1 ,

MINIM'Jw. SHIFT CREW COMPOSITION

~

APPLICABLE MDDES a a set LICENSE CATEGOPY TT 2. & 3**

1 l' 50L 2 1 OL 2 1 Non-Licensed

'Does not include the licensed Senior Reactor or Senior Peactor Operator Lirited to Fuel Handling individual supervision CORE ALTERATIONS after the initial fuel loading.

'Shif t crew composition may be less ther, the minimum requirements for a period of tiee not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to accommodate injury or sickness occurring to on duty shift cres members.

- Eeacter Mode Switch Position is in RUN (any average coolant te perature)

STA5 TOP / HOT STAhD:.Y (any average coolant temperature). Lnd HOT SHUTDOWN (average coolant temperature greater than 212*F), respectively.

1. R eactor Mode Switch Position is in SHVTDOWN (average coolant temperature less than 212*F) and REFUELING (average coolant temperature less than 212'F),

respectively. ,

64 AmendmentNo.)Wlf44 e

- - _ . , --. , , - _ , _ w-- _ - . - - - ,n.

Docket No. 50-245 B12820 i

Attachment 8 Millstone Unit No.1 Technical Specifications Reflecting the STA Requirement .

)

5 1

4 9

4 i

1.

+

t. i 4

February, 1988 .

l 4

t

)

l Millstone Unit 1 october 6, 1981 6.0 ADW.1NISTRATIVE CONTROLS 6.1 RESPONSIBILITY-6.1.1 The Station Superintendent shall be responsible for overall operation of the Millstone Station Site while The the Unit Superintendent Station Superintendent shall and be Unit respon-Superin- l sible for operation of the unit. '

tendent shall each delegate in writing the succession to these responsibilities .

during their absence. .

I' i

6.2 ORCaN12.'sT10N I,

)

OFFSITE 6.2.1 The offsite organizatien for facility management and technical su;;;rt shall be as sh:Nn in figure 6.2-1. .

'l FA !LITY STAFF- 9i 6.2.2 The Fa:ility organization shall be as sho,<n on Figure 6.2-2 and- )

~

a .- I.ach on duty shif t shall be co . posed of at least the minimm shif t crew cec. position shown in Table 6.2-1. l At least one licensed Operator shall be in the control room l

b. )

vhen fuel is in the reactor. )

I

c. At least two licensed Operators shall be present in the' .

control room during reactor start-up, scheduled reactor shutdown and during recovery from reactor trips,

d. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor.

e. Al'. CORE ALTEFdTIONS after the initial fuel loading shall be directly su;ervised by either a licensed Senior Reactor Operater or Senior Reacter Operator lid.ited to Fuel Handling .

who has no other concurrent responsibilities during this operation.

l f.

A Fire Brigade of 3 eer.bers shall be maintained onsite at all l tines. The Fire Brigade shall not include the minimm shift l c ew necessary for safe shutdoim of the Unit (2 re.bers) or any personnel required for other essential functions during a fire emergency.*

6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each eember of the facility staff shall meet or exceed the minimum for comparable positions, except for (1) qualifications of ANSI N18.1-1971the Health Physics Supervisor whd sha Regulatory Guide 1.8, Revision 1, and (2) the Shift Technic discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

" /cendment No. hf , M. H. M/79 ' 6-1 '. ' .

Octobe q TABLE 6.2-1 MINIMUM SHIFT CREV COMPOSITION! l APPLICABL1 M00[5

~

1. 2. & 3" 4 & 58 LICENSE CATEGORY !

1 1' l 50L 2- 1 OL

' 2 1 Non-Licensed ,

1 None Required Shif t Technical Advisor .

' h es not in:19de the licensed Senior Reactor or Senior initial fuel loadin';.

5hift crew cceposition nay be less than the mihimum requirements for a peri of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months te accc enedate injury.or sickness occurring to on duty shif t crew members. '

"Eet: tor Mode Switch Position is in RUN (any average ' coolant temperature)

'5TARTUP/ HOT STAND;Y (any average cociant temperature), and HOT SHUTDO (everage coolant tecperature greater than 212*F), respectively. .

N Reacter Mode S itch Position is in $H'JTDOWN (averag respectively.

)

6-4

/. send.erntN5. 47.0 , .

I I

i 3

Docket No. 50-245 B.11BlQ

(

Attachment 9 l Millstone Unit No. 1 ,

Technical Specification Changes Requested I on October 4,1983, Including Dual-Role Position

)

l February,-1988

g ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Station Superintendent shall be responsible for overall operation of the Millstone Station Site while the Unit Superintendent shall be responsible for operation of the unit. The Station Superintendent and Unit Superintendent shall each delegate in writing the succession to these responsibilities during their absence.

6.2 ORGANIZATION OFFSITE 6.2.1 The Offsite organization for facility management and technical support shall be as shown on Figure 6.2-1.

FACILITY STAFF 6.2.2 The Facility organization shall be as shown on Figure 6.2-2 and:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b. At least one licensed Operator shall be in the control room when fuel is in the reactor.

c. At least two licensed Operators shall be present in the control room during reactor star t-up,. scheduled reactor shutdown and during recovery from reactor trips.

d. An individual qualified in radiation protection procedures shall be on site when fuelis in the reactor.#

e. ALL CORE ALTERATIONS af ter the initial fuel loading shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.

f. A site Fire Brigade of at least 3 members shall be maintained onsite at all times.# The Fire Brigade shall not include 2 members of the minimum shif t crew necessary for safe shutdown of the unit or any personnel required for other essential functions during a fire emergency.

6.3 FACILITY STAFF OUALIFICATIONS I 6.3.1 Each member of the facility stati shall meet or exceed the minimum j

qualifications of ANSI N18.1-1971 for comparable positions, except for (1) the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, and (2) the Shift Technical Advisor who shall have a Bachelor Degree or equivalent in a scientific or engineering discipline l with specific training in plant design, and response and analysis of the plant for {

transients and accidents.

See Note on Page 6-4. Amendment No. 14,38,44,66,79,83 6-1

, N Millstone Unit i TABL E 6.2-l * * '

MINIMUM SHIFT-CREW COMPOSITION #

APPLICABLE MODES LICENSE CATEGORY 1, 2, & 3 ' 4 & 3##

SOL 2 1*

OL 2 1 Non-Licensed 2 1 Shitt Technical Advisor *" 1 None Required

'Does not include the licensed Senior Reactor or Senior Reactor Operator Limited to Fuel Handling individual supervision CORE ALTERATIONS af ter the initial f uel leading.

The above shift crew composition and the qualified health physics technician and/or fire brigade members of Section 6.2.2 may be less than the minimum requirements for a period ot time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence provided expeditious actions are taken to fill the required positions.

"Reactor Mode Switch Position is in RUN (any average coolant temperature)

STARTUP/ HOT STANDBY (any average coolant temperature), and HOT SHUTDOWN (average coolant temperature greater than 2120F), respectively.

1. Reactor Mode Switch Position is in SHUTDOWN (average coolant temperature less than 2120F) and REFUELING (average coolant temperature less than 2120F),

respectively.

* *The Shif t Technical Advisor position may be filled by an on-shif t Senior Reactor Operator only if that on-shif t Senior Reactor Operator meets the Shif t Technical Advisor qualifications of Section 6.3.1

*"Requirements for minimum number of licensed operators on shif t during operation in modes other than cold shutdown or refueling are contained in i 10C FR50.54(m). !

Amendmerit No: 14, 44, 79, 85 j l

l 6-4 l

1

y '

Docket No. 50-245 B12820 Attachment 10 Millstone Unit No. l' Technical Specifications as Amended on February 16,1984

February, 1988 i

l

Tsbru:ry 16. 1984 .

Millstone Unit 1 TABLE 6.2-1 * * * * .

MINIMUM SHIFT-CREW COMPOSITION #

APPLICABLE MODES LICENSE CATEGORY 1, 2, & 3" 4 &3##

SOL ,

2 l' OL 2 1 Non-Licensed 2 1 Shirt Technical Advisor 1 None Required .

l

Does not include the licensed Senier Reactor or Senior Reactor Operator Limited to Fuel Handling individual supervision COR3 ALTERATIONS after the initial fuel leading.

The ebove sh!!t crew composition and the quallfled health physics technician

'andhr fire brigade members of Section 6.2.2 may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommedate unexpected absence provided expeditious acP ; <- taken to fill the required positions.

++ Reactor Mode Switch Position is in RUN ,, average coolant temperature)

STARTUP/ HOT STANDBY (any average coolant temperature), and , HOT SHUTDOWN (average coolant temperature greater than 212cF), respectively.

1. Reactor Mede Switch Position is in SHUTDOWN (average coolant temperature less than 212cF) and REFUELING (average coolant temperature less than 2120F),

resp e:tively.

i

- "Requirements for minimum number of licensed operators on shift during operation in modes other than cold shutdown or refueling are contained in 10C FR50.54(m). ;

Amendment No: J(,f(,M pd 95 i,

6-4

Docket Nos. 50-213 50-245 50-336 B12820 1

Attachment 11 Haddam Neck Plant Millstone Unit Nos. I and 2 E. J. Mroczka letters to the Comissioners ;

Engineering Expertise on Shift l 4

t 4

1 i

4 February, 1988 i

l i

1

-- .- , ,1., ~ , . . _ . - _ _ . . _ _ . . _ _ . _ , _ . . _

PMMtTHEAST UTH.frMf5 v.a ca.=ciu wi mo aom e cem, P O box 270 l u s.ie. uiuc-vie ns taca cow.- H ARTFORD CONNECTICUT 061410270

.a an i e m.i e co-**

wm s, wu u wi coa-(203) 66s s217 a0p'=a 451 mJtd as i mi DG7 ccmp8m-EDWARO J MRoC2KA Sf won vsCf 94t$rOf MF-March 12,1987 Nuct f a # f 43*Nf f 4'4G AND opt 4A f t043 Chairman Lando W. Zech U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Zech:

Engineering Expertise on Shif t On Friday, March 6,19S7, we had the opportunity to discuss the engineering expertise on shift issue at Northeast Utilities with three of your fellow Commissioners. While we were unable to speak with you personally, we did have the opportunity to discuss this issue with your staff. We appreciate the time they spent with us, and we are taking this opportunity to reaffirm some of the key points of those discussions.

Most importantly, we believe that we have a successful program presently in place.

One reason for our characterization that the program is succeeding is our ability to retain a highly-qualified, motivated, and experienced operating staff. As you can see from the attached briefing paper, our dual role SRO/STA qua!ified individuals average in excess of 14 years experience in operations department positions at their respective plants. This asset is one of our most valued resources, given that these people are our first line of defense in the event of a plant incident, and I because they would be most dif ficult to replace once lost. We are deeply concerned that literal compliance with the Engineering Expertise on Shif t Policy Statement could threaten the stability of our operating staffs.

We share your objective of elevating the level of professionalism and overall capabilities of the operating crews. Our commitment to these objectives is evident by the substantial resources we have invested in our operator training programs,

> which included the Thames Valley State Technical College (TVSTC) program as well as the plant-specific sirnulators.

Te recognize that one objective of the Commission's Policy Statement is to create a cadre of degreed individuals with operations experience from which nuclear utilities ultimately can draw to fill senior management and corporate officer positions. This would have the effect over time of upgrading the nuclear experience of nuclear utility management.

This is an objective which Northeast Utilities has already successfully fulfilled. We believe this can only be accomplished by a management commitment to this philosophy, and cannot be realized merely by requiring all shif t supervisors to have bachelor's degrees. As you know, the last five senior executives responsible for our nuclear program all have had substantial experience at our plants. Jim Ferland (now at PSE&G), Bill Counsil (now at TU Electric), John Opeka, Wayne Romberg

Chairman Lando W. Zech B12457/Page 2 March 12,1987 and I share combined commercial nuclear power experience at our plants of approximately 80 years. All of us were SRO-licensed at one of the NU plants.

We believe that our existing programs are successful, and we are hopeful that we will be allowed to continue their use without disruption, if this letter raises any specific questions,I would be pleased to respond to them.

Sincerely, 1

PA .d

E. M%czka f l

1 l

e

, , , , --r-

NORTHEAST UTILITIES o.n.,., On.c.. . s.!e., si, i. B.n.n. Coen.ei,eu eme c. .o. a m ea-9 .is m u.c = i i.ic a c co--. P O BOX 270 H AATFORD. CONNECTICUT 061410270 L L J )' i ,7,' ",in,

. ..$' ". wi * *71ec . (203) 665 5000 ENGINEERING EXPERTISE ON SHIFT EDWARD J. MROCZKA SENIOR VICE PRESIDENT i

l MARCH 6, 1987 l

l

b t

b NU MEETS OR EXCEEDS INTENT OF POLICY STATEMENT o POLICY STATEMENT: "ENSURE THAT ENGINEERING AND ACCIDENT ASSESSMENT EXPERTISE IS POSSESSED BY THE PLANT OPERATING STAFF."

^

o POLICY STATEMENT: "THE COMMISSION PREFERS A COMBINED l

SRO/STA POSITION."

o DEGREE REQUIREMENT HAS NOT BEEN DEMONSTRATED AS ONLY l MEANS TO ACHIEVE OBJECTIVE.

o NU FOCUSED ON INTENT EARLY (DUAL-ROLE SR0/STA POSITION i FULLY IM?LEMENTED 1-1-34). l l

o NU PROGRAM RESPONSIVE TO COMMISSION INTENT. j f

f o NU MADE AGGRESSIVE, GOOD FAITH EFFORT THAT HAS BEEN I SUCCESSFUL.

P 4

4

-n.- ,- , , - -

, 4 I

L :

NU PROGRAM IS A PROVEN SUCCESS :

I I

O COMMENDABLE OPERATING RECORDS o HIGHLY EXPERIENCED AND STABLE ~ STAFF - VALUABLE ASSET !

(SEE ATTACHMENT A) !

0' NU's SSs AND SR0s HAVE INVALUABLE FAMILIARITY WITH f PLANT:

i o GREW UP WITH PLANT i

o PROGRESSED FROM PE0 TO R0 TO SRO TO SS l (SEE ATTACHMENT B) l

o INVOLVED WITH PDCRs, TESTING, PROCEDURES,.

i TRAINING ,

i e

1 :

f I

l

4 a n. , .n- ~ 2 -. a-, a s. s - ,

, 4.

i SPECIFICALLY ADDRESSES NEEDS OF STAS o THAMES' VALLEY PROGRAM CUSTOM DESIGNED FOR STA FUNCTION o DIRECTLY ADDRESSES ISSUE - NOT EDUCATION FOR ITS OWN SAXE o PROVIDES IDENTIFIED EDUCATIONAL NEEDS OF STA POSITION l

(SEE ATTACHMENT C) l l

! O PR0s 0F THAMES VALLEY PROGRAM:

I o EXCEEDS INPO RECOMMENDATIONS I l

l o NEARBY LOCATION i

! o GREATER NU INFLUENCE OVER PROGRAM CONTENT AND. ,

,~ ADMINISTRATION

! o HANDS-ON LABORATORY EXPERIENCE o PROPER ACADEMI: ATMOSPHERE AND PACE i

, . a 6

J DEGREE REQUIREMENT WOULD BE VERY DISRUPTIVE !

o MOTIVATION AND MORALE IS VITAL.

o PROGRESSION OF R0s AND PEOs WOULD BE SEVERELY HAMPERED.

O IM?ORTANT NOT TO IMPAIR TEAMWORK OF SHIFT COMPLEMENT.

o $$s AND SROS NEED SHIFT RESPECT AND ACCEPTANCE.

l 0 STABILITY OF CUR ORGANIZATION WOULD BE JEOPARDIZED.

1 i- !

4 o MANY DEGREED INDIVIOUALS 00 NOT STAY WITH SHIFT WORK. j P

L T

l !

4

1 NU COMMITTED TO SUPERIOR PROGRAM o GOOD FAITH EFFORT TO BE RESPONSIVE TO COMMISSION INTENT.

o NU's APPROACH SETTER ENHANCES SAFE OPERATIONS THAN DEDICATED STA OPTION 2 AVAILABLE.

O CONTINU0US ENROLLMENT OF SR0s.

o MANY SHIFTS HAVE MORE THAN ONE STA-QUALIFIED INDIVIDUAL (SEE ATTACHMENT D).

l l

l

i i

NU's ENGINEERING EXPERTISE ON-SHIFT PROGRAM o NU MEEIS OR EXCEEDS INTENT OF POLICY STATEMENT.

o NU PROGRAM IS A PROVEN SUCCESS.

o SPECIFICALLY ADDRESSES NEEDS OF STAS.

O DEGREE REQUIREMENT WOULD BE VERY DISRUPTIVE.

o NU COMMITTED TO SUPERIOR PROGRAM.

~ATTACIDENT A Pace 1 EXPER!ENCE OF HADDAM NECK STAS ADDIT 10NAL(3)

YRS NLO(l) YRS C0(1) YRS SS/SC0(1)(2) EXPERIENCE TOTAL A --

4 15 --

19 B- 4 2 9 --

15 C 3 1 4 3 11 D 4 2 4 1.5 11,5 E 4 1 4 1 10 F 1 1 12 5 19 G 1.5 1.5 4 3 10 H 3 3.5 12 --

18,5 1 2,5 2.5 7.5 --

12,5 J 2 2 13,5 --

17,5 ;

AVERAGE 14,4 !

-i NOTE 1: THE NUMBER OF YEARS INDICATED IS EXPERIENCE ON THE UNIT FOR WHICH THE INDIVIDUAL IS OVAllFIED STA, i 1 j NOTE 2: THE NUMBER OF YEARS INDICATED IS THE SUM 0F SS AND SCO EXPERIENCE.

NOTE 3: ONLY RESPONSIBLE NUCLEAR EXPERIENCE IS INDICATED, 1

(Updated Since Septe-ber, 1986 Meetin9 with the NRC Staff)

J f

l ATTACHMENT A ,

J Page 2 EL JLut.& ,11LLSTONE UNIT NOS 1 AND 2 STAS MILLSTONE UNIT NO. 1 YRS NLO(l) YRS C0(1) YRS SS/SC0(1)(2) h2fk hk TOTAL A 1 4 10.5 2 1 .5 4

a 2 L "

1 4 '.5

.5 4

"5.5 1 2 0

3 5 5

h 1

h 2

h 1

.h 6.5 1

l

.0 i

J 4 3 7.5 3 .75.5 K 5 .5 9.5 --

.5

~

M h 2 k' 5 AVERAGE 15.8 3

MILLSTONE UNIT NO. 2 :

A 2 .5 13 --

L5.5 i B 4 4 4 -

C 4 2 7 D 5 2 5 .5 .. 5

4 5 --

10 .

G 2 2 lb.5 h.5 N' AVERAGE 14.8 ;

NOTE 1: THE NUMBER OF YEARS INDICATED IS EXPERIENCE ON THE UNIT FOR i WHICH THE INDIVIDUAL IS OUAllFIED STA.

NOTE 2: THE NUMBER OF YEARS INDICATED IS THE SUM 0F SS AND SCO EXPERIENCE.

NOTE 3: ONLY RESPONSIBLE NUCLEAR EXPERIENCE IS INDICATED.

(1pdated Since September, 1986 Meetint with the NRC Staff) a

~

f.

TYPICAL PROGRESSION -

SS/SCO

8.6 YRS A

m SRO

" TRAINING RO

2 YRS A

RO

" TRAINING I

i ENTRY LEVEL NLO (MINIMUM REOT'S)

2.7 YRS 4

HIGH SCHOOL GRADUATE A AND

3 YEARS EXPERIENCE N!_O OR TRAINING

.$i e 2 YEARS TECHNICAL TRAINING OR z

e NAVY NUCLEAR TRAINED "

to

l .#. .

Contact Hours INPO Guidelines TVSTC Courses INPO TVSTC

1. Trigonometry, Analytical MA110 Tech Math I 30 33 Geometry & College Algchra mal 20 Tech Math II l 2. Inorganic Chemistry Cill22 Principles of Chemistry 30-45 44

3. Physics (llea t, mechanics, PtiliI Physics (Mech) 120-150 176 light sound, ciectricity, Pill 21 Physics (IILS) magnetism) ET225 Elect & Electronics MT133 Applied Mechanics

4. Engineering Mathematics M A 130 Calculus I 90 33 MA210 Calculus II

3. Reactor Theory NSil0 Atomic Physics 100 121 NS120 Itcactor Theory i NS210 Itcactor Theory 11

6. Reactor Chemistry NSI30 Reactor Chemistry 30 44

7. Nuclear Materials MF212 Materials of Engineering 40 12I NS220 Nucicar Materials MFil5 Non-Destructive Testing

3. Thermal Sciences MS231 Applied Thermo I 120 132 MT232 Fluid Mechanics MT236 IIcat Transfer

9. Electrical Sciences ET213 AC/DC Machinery 60 33 ET239 Auto Process Control Systems l o>

Nuclear Instrumentation @ H

10. No specialized course, intermixed ~40 -- e 4 and Control with above (Part Rad detection,

reactivity feedback and Rx instrumentation) * ?3 Ei s

9 l u lin I

't.

Contact floors INPO Guidelines TVSTC Courses INPO TVSTC

11. Nuclear Itadiation Protection NS222 Nuclear Radiation IIc.ilth '# 0 fa te '

and llcalth Physics and Salcty ,

12. Plant Specific Fundarnentals NS231 Topics in Nuclear Power 120 33 (also inc. in license prograins) Operations

13. Manage ncr.t/ Supervisory Skills A5221 INychology & Iluinan Itclations '# 0 308 (sonne non-INPO) IM210 Personnel Managernent IM232 Principles of Supervision AS120 liasic Conununication ASI 30 Technical Corninunication DP233 Intto to Prograsnining: 11ASIC l

l l

i

m>

N H to H ID >

l

n Ai: x:

Z t's 2

H O

, .5 ATTACH 5' INT C SCHEDULE A age 3 THAMES VALLEY STATE TECHNICAL COLLEGE NUCLEAR ENGINEERING TECHNOLOGY Effective September 1, 1985 FIRST YEAR SECOND YEAR Weekly otr Weekly r!RST QUARTER CI Lab Cr otr TOURTH QUARTER CI Lab Cr DP 238 Basic ~7 2 3 NS 120 Reactor T 0 4 Theory I MA 110 Tech. Math. I 4 0 4 MA 210 Calculus II 4 0 4 PH 111 Physics (Mech) 3 2 4 MT 231 Appl. Thermo. I 4 0 4 CH 122 Prine. of Chem. 3 2 4 MT 232 Fluid Mechanics 3 2 4 XX XXX NET P01 4/3 0/0 4/3 AS 221 Psych. &

Hum. Rel. 4 2 4 Totals........ 16/15 6 19/18 Totals......... 19 2 20 SECOND QUARTER FIFTH QUARTER ET 225 Elec. & Electr. 3 2 4 NS 210 Reactor TheoryII 4 0 4 MA 120 Tech. Math. II 4 0 4 ET 213 AC/DC Machinery 3 2 4 PH 121 Physics (HSL) 3 AS 120 Basic. Comm. 4 2 4 MT 236 Heat Transfer 3 2 4 0 4 AS 212 Economics 3 0 NS 110 Atomic Physics 4 0 4 MT 133 Appl. Mechanics 4 0 3

4 Totals......... 18 4 20 Totals....... 17 4 19 THIRD QUARTER SIXTH QUARTER XM XXX NET P02 3/4 0/0 3/4 MA 130 Calculus I 4 0 4 NS 220 Nuclear Mat. 3 2 4 AS 130 Tech. Comm. 4 0 4 ET 239 Auto. Proc.

NS 130 Reactor Chem, 3 2 4 4 0 4 cont. Systems Mr 212 Mat. of Engr. 3 3 4 NS 222 Rad. Health 3 2 4 NS 231 Topics in Nuc. 3 0

& Saf. 3 Power Ops.

)

AS 232 Sociology 3 0 3 Totals......... 18 5 20 XX XXX NET P03 3/1 0/3 3/2 .

l Totals...... 18/17 4/7 20/20 PROGRAM OPTIONS (PO)

Reactor Operator (RO)

P01 IM 210 Per Mgt 4 0 4 P02 Mr 115 NDT 3 0 3 1

P03 In 232 Prin of Sup 3 0 3 TOTAL QUARTER CREDITS - 118/117 I I

TOTAL CONTRACT HOURS 131/132 Non-Reactor Operator (NRO) -

P01 NS 221 Nuc Sys 3 0 3 P02 AS 110 Intro to Lit 4 0 4 P03 NS 232 Nuc Reac Sim 1 3 2

,- 4 '

ATTACHMENT D QUALIFIED SHIFT TECHNICAL ADVISORS AT.HADDAM NECK MILLSTONE UNIT NO.1 AND MILLSTONE UNIT NO. 2(1) ;

HADDAM NECK MILLSTONE 1 MILLSTONE 2 OVAllFIED STAS (TOTAL) 10 13 7 SHIFT SUPERVISORS 6 6 6 SENIOR CONTROL ROOM 4 6 1 OPERATORS CONTROL ROOM 0?ERATOR --

1 --

(1) A TOTAL OF SIX SHIFTS ARE UTILIZED AT EACH PLANT, OF THE TOTAL OF 18 SHIFTS,10 SHIFTS HAVE TWO DUAL ROLE QUALIFIED PERSONNEL,1 SHIFT HAS 3 AND 7 SHlFTS HAVE 1.

(Updated Since Septe.ber, 1986 Meetine. with the NRC Staff)

+ . s a

h PKMtTHEAS't' UTHJTNES

.mpcm ewe cm P.O. BOX 270 1 .a n a new.vu % spec co-w H ARTFORD. CONNECTICUT 06141 c270

.aw wt*w*o=== (203) 66s-s217 g w.e e wwi u ca cm w

== amtas s = =c. co-a-toWARO J MRoC2K A SiktCa voci regstcgs t, March 12,1937 kVCLlat GNGe%ttn NG AND Opine TIONS B12460 Commissioner James K. Asselstine U.S. Nuclear Regulatocy Commission Washington, D.C. 20555

Dear Commissioner Asselstine:

Engineering Expertise on Shif t We appreciate the time you spent with us last Friday discussing the engineering expertise on shif t issue and want to take this opportunity to thank you for that time. I thought it might be helpful to reinforce some of key points of our discussion.

Based upon our meeting and your comments on the Advance Notice of Proposed Rulemaking (ANPR) on the proposed degree requirement, we believe that we have very similar views regarding how this issue should be addressed. in particular, as is the case in developing any training program, the specific skills and job requirements for the dual-role SRO/STA function must be identified. From that, candidates with the proper work experience, education, and prior training are selected. Specific additiona! training needs are identified and provided, and are verified to have been successfully communicated to the individuals involved. In brief, that is precisely what we did in the development of our Thames Valley State Technical College (TVSTC) program.

We are firmly convinced that our existing, proven program meets the principal objectives of the Com mission's Policy Statement regarding engineering and accident assessment expertise. We view that literal compliance with the Policy Statement would yield no substantive positive effect on nuclear safetr. At the same time, it has the very real potential to threaten the stability of our experienced operating staff, one of our most valued assets.

Two additional points raised during our meeting warrant specific mention in our l view. First, we recognize the importance of selected non-technical skills for the '

dual-role SRO/STA function. In that regard, you will note that our TVSTC program includes some 303 contact hours involving six management / supervisory courses.

This program, when coupled with the integrated package of experience, education and training provided to these dual-role individuals, results in a shift supervisor who has the required engineering and accident assessment expertise as well as leadership capabilities.

1

Ccmmissionsr Jemas K. Assilstin?

B12460/Page 2 M:rch 12,1987 Secondly, we share the views of those commissioners who believe that operations .

experience in senior management positions is highly desirable. We believe this can only be accomplished by a management commitment to this philosophy, and cannot .

be realized merely by requiring all shif t supervisors to have bachelor's degrees.

The qualifications and credentials of our past and present executive management team confirm this commitment.

We also utilize SRO/STA qualified individuals in other importan; positions outside the operations department on a selective basis. Infusion of this talent elsewhere is highly desirable, but must be accomplished in a controlled manner to ensure that the most acute need for this experience, on shif t, is maintained. Cu: rent examples where this philosophy has been utilized include select positions in our nuclear training department as well as our nuclear safety engineering group.

We appreciate the thne you spent with us. We sought this meeting because of the importance of this particular issue to Northeast Utilities and its operators. We are hopeful that we will be allowed to continue implementing what we believe to be a successful program, if we can provide any additional information that would be helpful to you, we would be pleased to do so.

Sincerely,

!, sa/

E.3.yroczka {/

b P

t f

t

, > . - - ~ , . , . -

, V NORTHi!AST UTIlJTIIES c.,=c.c m s, i .uwecm P.O. BOX 270 9 emie. . macer m tu.=c cwam H ARTFORD. CONNECTICU7 o6141027o

.w. *i e == . c=="**

(203) 66s s217

k. ' d =s =w Amis we.ca aw w ww.sansa.neoc w to* ARO J MRoCZKA sisoon vct entsrotur.

March 12,1987 nacitaa rno,%ttanno awo ortea tions B12456 Commissioner Frederick M. Bernthat U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Commissioner Bernthal:

Engineering Expertise on Shif t On Friday, March 6,1987, we had the opportunity to discuss the engineering expertise on shift issue at Northeast Utilities with three of your fellow Commissioners. While we were not able to meet with you personally, we did have the opportunity to di.< cuss this issue with your staff. We appreciate the time they spent with us, and we are taking this opportunity to highlight some of the key points of our discussion.

Most importantly, we believe that we have a successful program presently in place.

One reason for our characterization that the program is succeeding is our ability to retain a highly-qualified, motivated, and experienced operating staff. As you can see from the attached briefing paper, our dual-role SRO/STA qualified individuals average in excess of 14 years experience in operations department positions at their respective plants. This asset is one of our most valued resources, given that these people are our first line of defense in the event of a plant incident, and because they would be most difficult to repiace once lost. We are deeply concerned that literal compliance with the Engineering Expertise on Shif t Policy Statement could threaten the stability of our operating staffs.

Te share your objr:tive of elevating the level of professionalism and overall capabilities of the operating crews. Our commitment to these objectives is evident by the substantial resources we have invested in our operator training programs, which ir.clude the Thames Valley State Technical College (TVSTC) program as well as the plant-specific simulators.

We believe that our existing programs are successful, and we are hopeful that we will be allowed to continue their use without disruption. If this letter raises any specific questions,I would be pleased to respond to them.

Sincerely,

[ W.

E. J. rjdzka' /

e

MrrHEAST tmLITNES

,. co.= c w . a ,,, P O. 80x 270 l m ean mumwas sac = cc== a H ARTFORD. CONNECTICUT 06141 o270 maas = te mo cr=a== (203) 66s s217 m

k ' J =eme roe =4a.amen w ma

es, cow == cow =

cowanos unocznA March 12,1987 tlkoon vrCg ralsocis t.

uvcu an snamuunma sso o*ena rro~s gg,43, Commissioner Kenneth W. Cerr U.S. Nuclear Regulatory Commission Washington, D.C. 20333

Dear Commissioner Carr:

Engineering Expertise on Shif t I wanted to take this opportunity to thank you for the time you spent with us last Friday discussing the engineering expertise on shif t issue. We know your time is extaemely valuable, and only requested the meeting because of the importan;e of this issue to Northeast Utilities and its operators.

We appreciate and agree with your overall objective of elevating the levels of professionalism and overall abilities of operations personnel. Eviderce of our commitment to accomplish this is clear from our resource 8 estment in the Thames Valley State Technical College (TVSTC),

it appears that our views differ with respect to how this objective can be best reahzed for our facilities. We believe that we are on the right track with our existing programs, and are sincerely concerned that this disruption could, over time, erode our experienced base of licensed operators. Given the importance of these individuals to us (a view which we believe you share), we are compelled to seriously question any change which may erode this important asset.

We recognize that cne objective of the Commission's Policy Statement is to create a cadre of degreed individuals with operations experience from which nuclear utilities ultimately can draw to fill senior management and corporate officer positions. This would have the effect over time of upgrading the nuclear experience of nuclear utility management.

This is an iective which Northeast Utilities has already successfully fulfilled. We believe u.., can only be accomplished by a management commitment to this philosophy, and cannot be realized merely by requiring all shif t supervisors to have bachelor's degrees. As you know, the last five senior executives responsible for our nuclear program all have had substantial experience at our plants. Jim Ferland (rew at PSE&G), Bill Counsil (now at TU Electric), John Opeka, Wayne Romberg and I share combined commercial nuclear power experience at our plants of approximate!y to years. All of us were SRO-licensed at one of the NU plants.

Our motivr.tiun for having this meeting with you was driven by our commitment to nuch .r sciety. We are always open to suggestion as to reasonable steps which can be taen to further that commitment. in this particular case, we remain convinced

,r 4

Commissi ner Ksnneth W. Carr B12459/Page 2 March 12,1987 that our existing approach is the optimum vehicle for Northeast Utilities to achieve our mutual objectives. We thank you for the time you spent with us, and ,

are hopeful that we will be given the opportunity to further demonstrate.that our existing programs will succeed in the long term.

Sincerely, A eo E. J:-f dzka f

a NOltTHEAST UTHJTIIts

.= w.=c,ce w a. , P.O BOX 270 l =sne. sw.vum sacisc oo.w H ART FORD. CONNECTICUT 06141-0270

= = ='s e a e c==== (203) 665 s217

( aw =.sievwau a con ==

a,= w mt i = =. c= -.

EowARD J MRoC2x A sf wsom WCf entssogn7 NvCLE An iNooktintwg ano opt ns rnoens March 12,1987 B12458 Commissioner Thomas M. Roberts U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Commissioner Roberts:

Engineering Expertise on Shif t I am taking this opportunity to thank you again for the time you spent with us last Friday discussing the engineering expertise on shif t issue. It was gratifying to hear someone sympathetic to our views at the Commission level.

To reinforce one of our key concerns, we view our stable and highly-experienced operating staff to be one of our most valued assets. Any issue which has the potential to disturb that stability is of great concern to us, and was the reason we asked you to spend a few minutes with us discussing this issue.

Again, we thank you for the opportunity to discuss our views on this subject, and we look forward to keeping you informed on the status of our operation and continued commitment to nuclear safety in the future.

Sincerely, e

La >

E. 7.}iro'czka f

v t e Letter Sequence Other
TAC:67187, (Open) TAC:67188, (Open) TAC:67189, (Open)
Initiation Request Acceptance... Administration Meeting Questions Answers Results Approval... Other: A05610, Responds to Generic Ltr 86-04 Re Policy Statement on Engineering Expertise on Shift.Comparison of INPO Shift Technical Advisor Guidelines W/Established Bachelors Degree Programs in Engineering Encl, B12611, Comments on NRC Evaluation of Util Program for Training & Qualifying Individuals for dual-role,senior Reactor Operator/Shift Technical Advisor Positions W/Specific Emphasis on Whether Program Meets NRC Requirements, ML20149L522, ML20237D811, ML20244C864
MONTHYEAR1986-06-13 [Table View]

ML20149L522