ML20198E687

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Forwards Response to Generic Ltr 86-04, Policy Statement on Engineering Expertise on Shift, Per DG Eisenhut 860213 Memo.Current Program for Providing Engineering Expertise on Shift Program Mods & Degree Requirements Discussed
ML20198E687
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 05/16/1986
From: Williams J
TOLEDO EDISON CO.
To: Stalz J, Stolz J
Office of Nuclear Reactor Regulation
References
1274, GL-86-04, GL-86-4, NUDOCS 8605280179
Download: ML20198E687 (4)


Text

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TOLEDO EDISON Docket No. 50-346 h(Ed (419} e49 2300 License No. NPF-3 (4isie49maa Serial No. 1274 May 16, 1986 Mr. John F. Stolz, Director PWR Project Directorate #6 Division of PWR Licensing-B United States Nuclear Regulatory Commission Washington, D.C.

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Dear Mr. Stolz:

On February 13, 1986 (Log No. 1919), D. G. Eisenhut sent to all licensee Generic Letter 86-04 " Policy Statement on Engineering Expertise on Shift." The purpose of the Generic Letter was to provide a copy of the Federal Register Notice of the NRC policy statement and an opportunity for Toledo Edison to transmit our plans resulting from the options now available as a result of the policy statement. Toledo Edison has reviewed the policy statement on engineering expertise on shift and the attached contains our response for Davis-Besse Nuclear Power Station Unit 1.

Very truly yours, rh,

WTO: GAB:mg Attachment cc:

DB-1 Resident Inspector h

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tt THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 1

Dockat No. 50-346 License No. NPF-3 Serial No. 1274 May 16, 1986 Attachment TOLEDO EDISON RESPONSE FOR GENERIC LETTER 86-04 POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT QUESTION 1:

What is Toledo Edison's current program for providing engineering expertise on shift?

Response :

Toledo Edison's current program is in accordance with Option 2 of the Policy Statement: a dedicated Shift Technical Advisor (STA). Company policy for the position requires that STAS possess a Bachelor's Degree in science or an engineering discipline from an accredited institution. All STAS also meet the STA training criteria of NUREG-0737. The STAS work on a rotating shift schedule that ensures engineering expertise is immediately available to plant operators at all times when the plant is in Modes 1-4.

Additionally, the STA's are directly involved in shift operations. The STAS are required to attend their respective Shift Supervisor's turnover and to review the Reactor Operator Log and the Unit Log. The STAS also review documents, such as the Safety Tagging Log and the Locked Valve Log, as part of their shift relief. The STAS are qualified as Safety Tagging Supervisors to assist the Shift Supervisors in Safety Tagging activities, and the STAS attend the daily planning meeting to maintain an awareness of scheduled maintenance and operations activities. STAS attend Licensed Operator Requalification Training with the operating shifts.

QUESTION 2:

Does the current STA program use " equivalency" criteria to meet the engineering degree requirement?

Response :

Toledo Edison has not defined or accepted an "equivalance". Corporate policy and Administrative Procedures require that STAS have a Bachelor's Degree in science or an engineering discipline from an accredited institution.

D:ckat No. 50-346 License No. NPF-3 Serial No. 1274 May 16, 1986 Attachment QUESTION 3:

Describe the modifications Toledo Edison will propose in order to take advantage of the options identified in the Commission's Policy Statement.

Response :

Toledo Edison's current plans are to continue the dedicated STA position in accordance with Policy Statement Option 2.

Changes are already in progress to refine and upgrade the STA position. These changes are as follows:

1.-

An STA training program began in early 1985 to train the engineers

.who will replace the current STAS.

This training program was upgraded from the level of previous STA training to ensure that all course material was presented and documented to meet NRC Senior Reactor Operator Licensing requirements. This will ensure STAS attain a higher level of plant and system knowledge. Training courses to meet STA-specific requirements in accordance with NUREG-0737 were also reviewed and modified to provide higher quality and more plant-specific information where needed.

2.

The engineers now undergoing STA training (in accordance with paragraph 1, above) are scheduled to complete their STA qualifications and replace the current STAS at.the beginning of 1987. SRO Licensing examinations will be administered as soon as can be arranged after the individuals complete their SRO Licensing requirements.

3.

The staffing has been increased to provide enough STAS from the current training program to assign one to each operating shift at the completion of their qualification.

Each STA will be a full time member of a shift and will rotate with and participate in all functions of that shift. It is TED's intention to upgrade the STA position to that of Shift Manager by March of 1988. The Shift Manager will be responsible for on shift operations (both operations and non-operations) and provide improved management and technical capabilities to each shift.

4.

The training schedule was modified to provide several on-shift periods during the qualification process. This is expected to provide enhanced knowledge of plant layout and development of improved shift interface. This, combined with more stringent training requirements and ultimate permanent assignment to an operating shift, is expected to increase the advisory value of the STA and the confidence the operators place in him.

5.

The minimum experience requirements for an individual to qualify to enter the training program were increased. This makes the position more selective and the training program able to proceed at a faster pace.

- Dock 2t No. 50-346 License No. NPF-3 Serial No. 1274 May 16, 1986 Attachment 6.

Toledo Edison'has adopted the policy that'it is desirable for current STAS to obtain a license at the SRO level. Those STAS currently in place who do not choose to obtain an SRO License will be transferred to other duties and replaced with degreed, SRO Licensed individuals. This further increases the STA's credibility and value to the company in several areas. All STA training is now conducted and documented to support this goal.

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