ML20196B267
| ML20196B267 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 02/05/1988 |
| From: | Boyle M Office of Nuclear Reactor Regulation |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8802110132 | |
| Download: ML20196B267 (20) | |
Text
_.
FEB 05 W Docket Nos.: 50-213/245/336 MEMORANDUM FOR:
John F. Stolz, Project Director Project Directorate I-4 Division of Reactor Projects I/II FROM:
Michael L. Boyle, Project Manager Project Directorate I-4 Division of Reactor Projects I/II
SUBJECT:
SUMMARY
OF JANUARY 27, 1988 MEETING WITH NORTHEAST UTILITIES CONCERNING THE USE OF A DUAL ROLE SR0/STA On January 27, 1988, the staff met with representatives (Northeast Utilities, NU) of the licensees (Enclosure 1 is a list of attendees) for Millstone Nuclear Power Station, Units I and 2, and the Haddam Neck Plant to discuss the use of a dual role Senior Reactor Operator / Shift Technical Advisor (SR0/STA).
The licensee was informed by the staff that the use of a dual role SR0/STA at these three plants was not currently provided for in the Technical Specifications (TS).
(Millstone Unit 3 also uses the dual role SR0/STA, but has a provision for this position in its TS). The staff stated that the purpose of this meeting was to hear a presentation by NU on a history of the position of the dual role SR0/STA at these three plants, why the licensee is operating in apparent violation of the TS, and, if the licensee was prepared at this time, what remedial actions would be proposed to bring the plants into compliance with.the TS.. is a document prepared by NU that sumarizes the history of the STA/SRO program at the three plants and provides a comprehensive list of NRC and licensee letters, nemoranda and records of conversations. This memorandum sunmarizes some of the background that bears on the dual role issue.
NU stated that in 1979 they informed the NRC of the method by which they were proposing to meet the TMI Action Plan requirement for an STA.
In a November 21, 1979, letter, NU stated that they would add an additional operator to each shift and would upgrade the training of the SR0 to include the requirements of an STA. To accomplish this, the licensee sent each SR0 to be qualified as a STA to a two year technical college for an associate degree based on nuclear engineering and science curricula.
The first group of SR0s to finish the two year training returned to duty at the plants in April 1982.
In July 1983 the draft Policy Statement on engineering expertise on shift was published. The draft Policy Statement stated that a dual role SRO/STA should have a four year baccalaureate degree or the equivalent.
In August 1983 the licensee reiterated its position on the training of the dual role SRO/STA stating that it was its objective to assure the appropriate expertise on shift and that it was not planing to require a B. S. degree for the SR0/STA.
In October 1983 the licensee submitted license arendments for the three plants
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.. to incorporate the dual role position qualified in accordance with the present NU program.
In 1984 the staff did not grant those portions of the license amendments dealing with the dual role position stating that this issue will be handled as a separate licensing issue.
The staff was not in a position at that time to approve the dual role proposed by NU prior to issuance of the final Policy Statement concerning engineering expertise on shift. However, NU has continued to use a dual role SR0/STA at the three plants even.though the required license amendnent was not granted by the staff. Notwithstanding the deferral of licensing approval, NU interpreted the TS as not precluding the dual role. NU cited telephone call, correspondence and inspection reports to document knowledge of and concurrence with this interpretation by the Project Manager and Region I management.
In September 1986, the licensee sought to have the dual role position evaluated "on a case-by-case basis" by the Comenission. Although the staff concluded in SECY-86-383, an Infonnation Paper to the Conrnission, dated December 31, 1986, that the NU program for the dual role SR0/STA meets the intent of the Conmission Policy Statement concerning engineering expertise on shift, the Commission did not agree.
Subsequently, in April 1987, the Comission issued a letter to the licensee indicating that those persons presently qualified under the licensee's dual role training program would be acceptable in that role.
However, the Ccarnission stated that, while not a Tn'quirement, future personnel in the dual role position should meet the criteria re the final policy statement.
In August 1987, the licensee reiterated its position that the current STA program was acceptable and that the training program for the dual role position was considered to be optimal for the three plants and that they would continue with this training program.
The licensee was not prepared at this meeting to state its proposal to remedy the compliance issue. The licensee conmitted to provide information to the staff on February 1,1988, on when a formal proposal would be made and what the proposal would entail. The staff found this conrnitment to be acceptable.
The staff's review and recommendation on NU's proposal will need to be recycled through the Commission for its approval since neither the senior managenent nor the Conmission were aware of the apparent non-compliance issue at the time of SECY-86-383 or at the issuance of the April 1987 letter to NV.
The staff noted that the licensee would continue to operate the three plants while the Conmission and the licensee work on the resolution of this TS issue.
The staff stated that, while the three plants would be operating in apparent violation of the TS, there was no compelling safety reason to take irrediate action to bring the licensee into compliance with the present TS prior to Commission review and approval of a license amendment proposed by NU on this issue.
Michael L. Boyle, Project Manager Project Directorate I-4 i
Divisicn of Reactor Projects I-4
Enclosures:
As stated cc: w/ enclosures Mn page
- See previous concurrence LA:FDI-4 FM:PDI-4 PM:PDI-4 DMPDI-4 PM:PDI-4 SNorris MBoyle:lm RFerguson AWang DJaffe
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6 Mr. Edward J. Mroczka Millstone Nuclear Pcwer Statier.
Northeast Nuclear Energy Company Unit No. 1 i
CC:
Gerald Garfield, Esquire R. M. Kacich, Manager Cay, Derry and Foward Ger,eration Facilities Licensing Ccunselors at Law Northeast Utilities Service Company City Place Post Office Box ?70 Hartford, Connecticut C6103-3499 Hartford, Connecticut 06i41-CE70 W. C. Romberg, Vice President D. O. Nordquist, Director Nuclear Operations Quality Services Department Northeast Utilities Service Company Northeast Utilities Sarvices Corpery Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Adr.inistrator Radiation Control Unit Region I Cepartrent of Environrental Protection U. S. Nuclear Regulatory Comissien State Office Building 631 Park Avenue Harticrd, Correcticut 06106 King of Prussia, Pennsylvania 10406 Dradford S. Chase, Under Secretary First Selectren Energy Division Town of Waterford Office of Pclicy and Managerer.t hail of Records 80 Washington Street 200 Boston Post Road Hartford, Ccnnecticut 06106 Waterford, Cennecticut 0638F S. E. Scace, Station Superintendent W. J. Raymond, Resident Inspector Millstone Nuclear Power Statien Millstone Nuclear Power Statien Northeast Nuclear Energy Company c/o U. S. Nuclear Regulatory Comission Post Office Box 128 Post Office Box 811 Waterford, Connecticut 06385 Niantic, Connecticut 06357 J. P. Stetz, Unit Superintendent Millstone Unit No. 1 Ncrtheast Nuclear Energy Compary Post Office Box 126 Waterford, Connecticut 06385 g
MEETING
SUMMARY
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HBClayton NRC Participants Steven Varga Jack Roe John A. Zwolinski John'F. Stolz L.H. Bettenhausen Mn, H. Regan Gannon West, Jr.
J.J. Persensky Dave Jaffa Michael Boyle Robert Ferguson Alan Wang Lee Dewey Thomas C. Elsasser Wm Troskoski i
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EhCLOSURE 1 ATTENDANCE AT MEETING WITH NORTHEAST UTILITIES ON DUAL ROLE STA/SR0 JANUARY 27, 198E NAME ORGANIZATION Steven Varga NRC/DPI/II Jack Roe NRC/DLPQ Jchn A. Zwolinski NPC/DLPQ Jchn F. Stolz NRC/hRR/PDI-4 L.H. Bettenhausen NRC/ Region 1/PB1 Wr.. H. Regan NRC/DLPQ/HFAB Garron West, Jr.
NRC/DLPQ/HFAB J.J. Fersensky NRC/DPLQ/HFAB Dave Jaffe NRC/PDI-4 Michael Boyle NRC/PDI-4 Robert Fergusen NRC/PD-4 Alan Wang NPC/PDI-4 Lee Dewey NPC/0GC Thomas C. Elsasser NRC/0CP Wm Troskoski NPC/0ED0 Richard Kacich fiU Ray Palmieri hu Jack Earnett NU O
I J
ENCLOSURE 2 CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY DOCKET NOS. 50-213, 50-245, 50-336 JANUARY 27, 1988 MEETING WITH NRC STAFF MINIMUM SHIFT CREW COMPOSITION AND IMPLEMENTATION OF DUAL-ROLE SR0/STA AT NORTHEAST UTILITIES
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PURPOSE O
PROVIDE INFORMATION IN RESPONSE TO STAFF REQUEST REGARDING COMPLIANCE WITH TECHNICAL SPECIFICATION REQUIREMENTS FOR MINIMUM SHIFT CREW COMPOSITION 0
RESULT IN NRC CONCURRENCE THAT DUR SHIFT STAFFING COMPLIES WITH ALL APPLICABLE NRC REGULATIONS AND LICENSE REQUIREMENTS 0
CLARIFYING AMENDMENT WOULD ELIMINATE EXISTING CONFUSION I
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NORTHEAST UTILITIES ATTENDEES LICENSING MANAGER R. M. KACICH R. J. PALMIERI -
MILLSTONE UNIT NO. 1 OPERATIONS SUPERVISOR LICENSING ENGINEER J. R. BARNETT l
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_4 OVERVIEW
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0 NU COMPLIES WITH CONFIRMATORY ORDER CONCERNING STA COVERAGE,
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TRAINING, AND LONG-TERM PROGRAM i
0 NU COMPLIES WITH LICENSED OPERATOR STAFFING FINAL RULE (10CFR50.54(M)),
AS REAFFIRMED BY TECHNICAL SPECIFICATION TABLE 6.2-1
- )
I
________ _ l WHY NU IMPLEMENTED DUAL-ROLE i
O NRC AKNOWLEDGED OPTION POST-TMI 0
NU STATED PLAN IN 1979 0
NU DEVELOPED A CUSTOM PROGRAM 0
TECH SPECS DID NOT PROHIBIT 0
NU ADVISED NRC 0F ITS INTERPRETATION PRIOR TO IMPLEMENTATION O
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 EEOS POLICY STATEMENT HAD LANGUAC-E MORE IN KEEPING WITH OUR PROGRAM 0
NUMEROUS INSPECTION REPORTS REAFFIRMED NRC ACCEPTANCE OF THE DUAL-ROLE O
FOLLOWING A SEPTEMBER, 1986 MEETING, THE STAFF RECOMMENDED COMMISSION ACCEPTANCE OF OUR PROGRAM AS MEETING THE INTENT OFTHE POLICY STATEMENT 0
A 1987 LETTER FROM THE STAFF STATED THAT THE COMMISSION AGREES THAT CURRENT DUAL-ROLE PERSONNEL CAN CONTINUE TO SERVE e
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RECURRING THEMES 0
NU KEPT THE NRC WELL INFORMED 0
NRC ACKNOWLEDGED AWARENESS AND ACCEPTANCE O
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
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HISTORY JULY 1979 NUREG-0578, THI-2 SHORT-TERM RECOMMENDATIONS:
PROMULGATES REQUIREMENTS FOR STAS 9/13/79 FOLLOW-UP ACTIONS REGARDING THI-2:
REQUESTS IMPLEMENTATION SCHEDULE; 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 DE ON DUTY BY 1/1/80 11/21/79 NU RESPONSE TO 10/30/79 LETTER:
LONG-TERM STA PROGRAM - WILL ADD AN OPERATOR TO EACH SHIFT; UPGRADE TRAINING 0F AN SRO TO INCLUDE REQUIREMENTS OF 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 4/30/80 INPO DOCUMENT:
NUCLEAR POWER PLANT SHIFT TECHNI-CAL ADVISOR - RECOMMENDATIONS FOR POSITION DESCRIPTION, QUALIFICATIONS, EDUCATION, AND TRAINING j
MAY 1980 NUREG-0660:
STA POSITION CAN BE ELIMINATED WHEN SS QUALIFICATION UPGRADES ARE ATTAINED.
5/7/80 ADDITIONAL TMI REQUIREMENTS:
SHIFT MANNING REQUIREMENTS FORTHCOMING 7/2/80 NRC LETTER:
PROVIDES MODEL TECHNICAL SPECIFICA-
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TIONS FOR STA POSITION.
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7/31/80 NRC LETTER:
INTERIM CRITERIA FOR SHIFT STAFFING:
SHIFT CREW SHALL INCLUDE 2 SR0s, 2 R0s, 2 A0s; NOTE:
NO DISCUSSION OF STA POSITION (I.E., A 7TH PERSON) 9/5/80 PRELIMINARY CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS:
"THE NEED FOR THE STA POSITION MAY BE ELIMINATED WHEN THE QUALIFICATIONS OF THE SSs AND S0s HAVE BEEN UPGRADED..."
"...THE DESCRIPTIONS AS SET FORTH IN...THE INP0 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'0VT OF THE STA PROGRAM."
9/16/80 CY, MP1, MP2 LICENSE AMENDMENT REQUESTS TO ADD STA REQUIREMENT (IDENTICAL TO MODEL SPECIFICATION);
1 EMPHASIZES THAT DEDICATED STA PROGRAM IS INTERIM.
10/1/80 NU COMMENTS ON 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 INP0 STA REQUIREMENTS.
10/31/80 NUREG-0737 CLARIFICATION OF THI ACTION PLAN REQUIREMENTS:
STA POSITION MAY BE ELIMINATED WHEN QUALIFICATIONS OF SSs AND S0s UPGRADED; INPO DOCUMENT (PROVIDED AS APPENDIX C) ACCEPTABLE FOR SELECTION AND TRAINING OF STAS.
USE FOR GUIDANCE FOR PLANNING LONG-TERM STA PROGRAM; j
REQUESTS DESCRIPTION OF LONG-TERM PROGRAM AND PLANS FOR PHASE OUT OF STA PROGRAM.
INCLUDE COMPARISON TO INP0 DOCUMENT; I
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SHIFT STAFFING REQUIREMENTS-SUBJECT OF FUTURE RULEMAKING.
12/31/80 NU RESPONSE TO NUREG-0737:
DESCRIPTION OF INTERIM STA PROGRAH; DESCRIPTION OF LONG-TERM STA PROGRAM, INCLUDING COMPARIS0N TO INP0 DOCUMENT; STA FUNCTION WILL BE PHASED OUT 4/7/81 NRC ISSUES AMENDMENT #66 FOR MP2:
ADDS STA.
7/7/81 ORDER CONFIRMING LICENSE COMMITMENTS ON POST-TMI RELATED ISSUES:
PROVIDE STA COVERAGE BY 1/1/81; SUBMIT DESCRIPTION OF CURRENT TRAINING PROGRAM BY 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.
10/8/81 NRC ISSUES AMENDMENT #42 FOR CY:
ADDS STA.
2/19/82 NU LETTER:
PROVIDES ADDITIONAL INFO CONCERNING NON-DEGREED STAS.
2/22/82 NRC LETTER:
NU's "STA TRAINING PROGRAM IS ACCEPT-ABLE IN MEETING THE INTENT OF THE GUIDELINES SET FORTH..."
3/1/82 NU LETTER:
FIRST GROUP OF SSs AND SCOs ATTENDING MSU PROGRAM RETURN TO SHIFT IN APRIL, 1982.
3/31/82 NRC LETTER:
ACCEPTS STAS WITHOUT B.S. DEGREES; CONSIDER EXPERIENCE AND SRO LICENSE "ADVANTAGE 0US TO PLANT SAFETY."
8/6/82 NU LETTER:
REQUESTS APPROVAL OF 8 HORE INTERIM STAS WITHOUT D.S. DEGREE 8/23/82 PROPOSED RULE ON LICENSED OPERATOR STAFFING:
WILL REQUIRE 2 SR0s AND 2 R0s ON SHIFT.
- 7 9/9/82 NRC LETTER
ACCEPTS 8 STAS "WITHOUT BACHELOR DEGREES BUT WITH SUFFICIENT TRAINING."
10 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.
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 GUIDANCE CAN BE ACCOM-l PLISHED BY..
- 2. ASSIGNMENT OF AN INDIVIDUAL WITH THE FOLLOWING QUALIFICATIONS TO THE OPERATING SHIFT CREW AS ONE OF THE SENIOR OPERATORS REQUIRED BY 10CFR50.50.54(M):
A.
BACCALAUREATE DEGREE OR EQUIVALENT IN ENGINEERING OR RELATED SCIENCES...
EQUIVALENCY SHALL BE DEFINED AS:...(C) SUCCE3SFUL COMPLETION OF THE TECHNICAL PORTIONS OF AN ACCRED-ITED, FOUR YEAR ENGINEERING DEGREE PROGRAM."
8/25/83 NU LETTER:
COMMENTS ON FINAL RULE ON.tTAFFING:
NU's LONG-TERM STA PROGRAM UNDER DEVELOPMENT FOR 4 YEARS; OBJECTIVE TO ASSURE APPROPRIATE EXPERTISE AVAIL-ABLE ON SHIFT, NOT TO HAVE B.S. DEGREES; ADDITIONAL INDIVIDUAL FILLING STA FUNCTION WAS INTERIM MEASURE, UNTIL QUALIFICATION OF ON SHIFT PERSONNEL UPGRADED; STA FUNCTION WILL BE FILLED BY DUAL-ROLE INDIVID-
. c' UALS BY 9/1/83 ON HILLSTONE 1, AND BY 1/1/84 ON CY AND MILLSTONE 2; CLARIFYING LICENSE AMENDMENT REQUESTS WILL BE SUBMITTED.
9/23/83 NU LETTER:
COMMENTS ON DRAFT POLICY STATEMENT:
REAFFIRMS OUR LONG-TERM PROGRAM PLANS - DEDICATED STA POSITION WILL BE ELIMINATED; 1l TECH SPECS DO NOT PRECLUDE DUAL-ROLE:
DUAL-ROLE POSITION HEETS 10CFR50.54(M);
NO CHANGES TO LONG-TERM PLANS.
10/4/83 LICENSE AMENDMENT REQUESTS FOR MILLSTONE UNIT NOS. 1 AND 2:
STA POSITION CAN BE FILLED BY DUAL-ROLE INDIVID-VAL; DUAL-ROLE FOOTNOTE PROPOSED.
10/24/83 LICENSE AMENDMENT REQUEST FOR HADDAM NECK PLANT:
STA POSITION CAN BE FILLED BY DUAL-ROLE INDIVID-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; IMPLEMENTING TVSTC PROGRAM; NU STILL IN COMPLIANCE WITH THE CONFIRMATORY ORDERS ON STAS; PROGRAM MEETS OR EXCEEDS NRC's GUIDANCE /INP0 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;
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_12 NO ENFORCEMENT ACTION WILL RESULT FROM INTERPRETA-TION OF TECH SPECS OR 10CFR50.54(M) 2/16/84 AMENDMENTS
- 95 FOR MILLSTONE I
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 COMPLIANCE:
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; IN WHICH WE NRC APPROVED OUR LONG-TERM STA PLANS, STA POSITION CLEARLY STATED OUR INTENTION TO FILL l
WITH UPGRADED ON-SHIFT PERSONNLL; 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 MET DEGREE EQUIVALENCY DEFINITION.
1/15/85 AMENDMENT #61 FOR THE HADDAM NECK PLANT:
2 SR0s REQUIRED; RE0 VEST FOR FOOTNOTE TO TABLE 6.2-1 NOT ISSUED, TO BE HANDLED BY SEPARATE LICENSING ACTION.
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
- i, APPLICABLE LICENSE CONDITIONS; 1
NC NRC REQUIREMENT OR PLANT-SPECIFIC CORRESPON-DENCE PRECLUDES USE OF DUAL-ROLE.
- 8/6/85 AMENDMENT #102 FOR MILLSTONE UNIT NO. 2:
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-ABLE.
10/28/85 FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT:
PERMITS DUAL-ROLE SRO/STA POSITION - SEPARATE STA POSITION MAY BE ELIMINATED; "THE COMMISSION PREFERS A COMBINED SRO/STA POSI-TION";
ACCEPTABLE IF PROGRAM MEETS INTENT 0.'
POLICY STATEMENT.
2/13/86 GENERIC LETTER 86-04:
REQUESTS:
CURRENT STA PROGRAM:
EQUIVALENCY CRITERIA USED, j
CHANGES PLANNED.
6/13/86 NU RESPONSE TO GENERIC LETTER 86-04.
8/6/86 SECY-86-231, SURVEY ON EEOS 9/25/86 NU MEETING WITH NRC STAFF:
ENGINEERING EXPERTISE ON SHIFT AT NORTHEAST UTILITIES:
PRESENTED DETAILED DESCRIPTION OF THE EVOLUTION OF THE EEOS
- ISSUE, NU's STA
- PROGRAM, AND THE PRINCIPLES BEHIND THE DUAL-ROLE POSITION AT NV.
NU SOUGHT TO COMPLY WITH THE POLICY STATEMENT BY HAVING THE NRC ACCEPT OUR PROGRAM "0N A CASE-BY-CASE BASIS" 12/31/86 SECY-86-383, EE05 AT NU:
"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."
l 3/6/87 NU NFETING 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 DDAL-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 ITEM; DUAL-ROLE INDIVIDUALS DO NOT HAVE DEGREES.
8/7/87 NU LETTER:
RESPONSE TO 4/22/87 LETTER:
WE IliTERPRET 4/22/87 LETTER TO ACCEPT ALL DUAL-ROLE INDIVIDUALS WHO ATTENDED TVSTC OR MSU PROGRAM:
NO PLANS FOR CHANGES TO DUAL-ROLE SR0/STA PROGRAM.
10/2/87 NU LETTER:
RESPONSE TO R.I. 50-213/87-18:
OUR STA PROGRAM IN COMPLIANCE - WITH ALL REQUIRE-MENTS; NU STUDY CONCLUDED EXISTING STA PROGRAM OPTIMAL.-
12/28/87 RESIDENT INSPECTION 50-213/87-27:
STA PP.0 GRAM CONFORMS WITH EXISTING REQUIREMENTS; SHIFT MANNING COMPARED TO REGULATORY REOUIREMENTS "N0 UNACCEPTABLE CONDITIONS WERE IDENIIFIED."
1/27/88 NRC/NU MEETING NOTE THAT NUMEROUS INSPECTION REPO!.TS PUBLISMED THROUGHOUT THE LAST SE'!ERAL YEARS STATED THAT OUR SHIF HANNING WAS ACCEPTABLE.
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SUMMARY
P 0
NU PROGRAM COMPLIES WITH ALL APPLICABLE NRC REGULATIONS AND LICENSE REQUIREMENTS 0
ADEQUATE ACCIDENT ASSESSMENT AND ENGINEERING EXPERTISE ON SHIFT EXISTS 0
RECOMMENDED RESOLUTION:
ISSVE PREVIOUSLY REQUESTED LICENSE AMENDMENTS
.