ML20198E712
| ML20198E712 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/25/1997 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM ESK-97-153, GL-86-04, GL-86-4, NUDOCS 9708080030 | |
| Download: ML20198E712 (6) | |
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c-Qu.al Cttits (erncrating Mation JJ'IO 21Uth A\\ ClinC Nittll Conh n a.11 til 2 4 2 9' 60 ic u m (>si2n i ESK-97-153 July 25,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Attention:
Document Control Desk
Subject:
Quad Cities Station Units 1 and 2 Commonwealth Edison Company (Comed) Resision to Response to Generic Letter (GL) 86-04,
" Policy Statement on Engineering Expertise on Shin "
dated February 13,1986 NRC Dockets 50-254 and 50-265 The purpose of this letter is to change a commitment in the responses provided by Commonweri!th Edison for Quad Cities Station (References (c) and (f) of Attachment A) regarding the implementation of the requirements for providing engineering expertise on shiR.
Cities Station will place a qualified STA who is not required to be lic Consistent with Option 2 of Reference (e), " Continued Use of STA Position," Quad consistent with the shin manning requirements. The STA will meet the requirements of NUREG-0737, Item I. A. l. l.
Attachment A to this document contains the salient historical information with regards to our original commitments and provides details regarding the STA qualifications and training at Quad Cities Station.
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July 25,1997 Ifyou have any questions concerning this letter, please contact hir. Charles Peterson, Regulatory Affairs Manager, at (309) 654. 2241, extension 3609.
Respectfully, N.
I E. S. Kraft, J Site Vice President Quad Cities Station o
Attachment:
Attachment A, " Historical Summary and Basis for Compliance with NUREG-0737, Item I. A. I.1" A. B. Beach, Regional Administrator, Region 111 cc:
R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident inspector, Quad Cities W. D, Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
M, E. Wagner, Licensing, Comed
ATTACIIMENT A "Ilistorical Summary and Basis for Compliance with NUREG-0737, Jtem 1.A.1.1" ESK-97-153 Page1 oft
References:
(a): NUREG-0737," Clarification of Thil Action Plan Requirements," Item I.A.l.1
- Shift Technical Advisor (b): NUREG-0660,"Th11-2 Action Plan," Item I.A.l.1 - Shin Technical Advisor (c): L S. Abelletter to D. G. Eisenhut,"SupplementalInformation Concerning Shin Technical Advisor Long Term Program," dated h1 arch 17,1981 (d): D. hl. Crutchfield letter to L. D. George, "NUREG-0737 Item 1. A. l.1, Shin J
Technical Advisor (STA)- Dresden Units 1,2, and 3; Quad Cities Station, Units 1 and 2," dated January 27,1982 (e): NRC Generic Letter 86-04, " Policy Statement on Engineering Expertise on Shia," dated February 13,1986 (f): P. C. LeBlond letter to H. R. Denton, "NUREG-0737, t. i 1.1 - Shifl Technical Advisor," dated hiay 9,1986 (g): NRC Information Notice (IN) 93-81, " Implementation of Engineering Expertise on ShiR," dated October 12,1993 Reference (a) was published November of 1980 to set forth the requirements regarding approved Thil Action Plan Items. This document set forth the requirement for the position of ShiR Technical Advisor:
Each licensee shallprovide an on-shift technicaladvisor to the shift supervisor. The shift technical advisor (S7A) may serve more than one unit at a multinnit site if quahfied toperform the advisorfemctionfor the various units.
7he SIA shallhave a bachelor's degree or equivalent in a scientipe or engineering discipline and have received specific training in the response and analysis of the planfor transients andaccidents. 7he STA shallalso receive training inplant design andlayout, inchuling the capabilities ofinstrumentation and controls in the control room. 7he licensee shall assign normalduties to the STAS that pertain to the engineering aspects of assuring safe operations of the plant, including the review and evaluation of operating experience.
NITACllMENT A "llistorical Summary and liasis for Compliance with NUREG-0737, Item I.A.I.1" ESK-97-153 Page 2 of 4 in referenced letter (c), Commonwealth Edison summarized previous submittals regarding the "long-term" Shin Technical Advisor program:
... a technicalgraduate licensed at the senior reactor operator (SRO) levelis intended to be provided on each shift at all times when a nuclear unit is in power operation, startup or hot shutdown. Candidatesfor thisposition, termedStation ControlRoom Engineer (SCRE), were selected and training was initiated in conformance with the guidance of NUREG-0578 and its early clarification statements, in referenced letter (d), based on the review of Comed's submittals, the NRC concluded that the Quad Cities Station Units 1 and 2 STA training programs were acceptable in meeting the intent of the guidelines set forth in references (a) and (b).
I in February of 1986, the NRC issued the Referenced letter (e) to provide licensees with a copy of the Federal Register notice of the Policy Statement on Engineering Expertise on Shin, and to give l
I the licensees the opportunity to transmit their plans regarding modifications to their program for meeting the requirements for providing engineering expertise on shin in light of the options
(
available as a result of the Policy Statement.
i In Reference (e), the NRC requested that all licensees provide a response describing the following information:
i 1.
Your currentprogramforproviding engineering expertise on shift:
- 2. Ifyour current SIA program utili:es an " equivalency" criteria to an engineering degree, a description of the criteria used; and,
- 3. A description ofany modificationsyou intend topropose toyour current program in order to take admntage of the options identified in the Commission 's Policy Statement.
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' ATTACllMENT A "llistorical Summary and Basis for Compliance with NUREG-0737, item I.A,1,l"
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Page 3 of 4 By Referenced letter (f), Commonwealth Edison provided the information requested in GL 86-04, stating that:
Commomrealth Edison meets the requirements ofNUREG-0737 (item I.A. J.1) through the use of a Station Control Room Engineer (SCRE). This is an individual u ho meets the following requirements:
possesses a technical degree in an engineering or science field as described in enclosure 1 l
possesses a Senior Reactor Operator's license has completed the post-SRO training requirements as described in reference (b)
The purpose of this letter is to change the commitment in the responses provided by Commonwealth Edison for Quad Cities Station, including Referenced letters (c) and (f), regarding i
the implementation of the requirements for providing engineering expertise on shift.
Consistent with Option 2 of Reference (e), " Continued Use of STA Position, " Quad Cities Station will place a qualified STA who is not required to be licensed on each shift consistent with the shift manning requirements. The STA will meet the requirements of NUREG-0737, Item I. A.I. l.
The STA will possess a technical BS degree or equivalent background for understanding the design and operation of nuclear power plants. Additionally, combined with other related trening, the STA will receive:
a) Functional Assessment and Evaluation Training to enable the STA to assess the effectiveness of the various plant systems in controlling plant critical parameters, b) Routine Evolutions Training on the knowledge necessary to assess integrated plant evolutions conducted by the Operations Team. An understanding of plant procedures and technical specifications is emphasized, c) Abnormal Operations Training to expose the STA to plant transients addressed in the abnormal procedures. The training is designed to prepare the STA to perform an independent assessment of plant conditions during or following an abnormal event. The focus is on monitoring system response (i.e., comparing actual versus expected conditions), diagnostics, concurrent events, and making recommendations for plant safety, and
4 i
A'ITACllMENT A "llistorical Summary and Hasis for Compliance with l
NUREG-0737, item I.A.l.1" 1
Page 4 of 4 l
d) Casualty Operations /EOP Training including classroom training and simulator training.
Classrocm tiaining includes a step by step review of each procedure with an emphasis on the bases for the step and the expected outcome. It consists of FSAR design basis, Transient and Accident Analysis, and Mitigating Core Damage. Simulator training suppons th classroom training and may include demonstration training and " super static" discussions concerning the i
event and expected STA response. Possible topics include plant response, expected progression, key and redundant indications, prioritizati n of events, and the evaluation of 3
corrective actions.
j Previously qualified STAS will maintain position cenification provided an evaluation has been performed within 12 months of the imp!cmentation of the non licensed STA program. The i
evaluation willidentify any differences between the non licensed STA training program and the i
- previously quali0ed STAS level orknowledge. Previously qualified ST nust receive differences training to maintain certification. Once differences training is com;
..:u, the STA will be i
evaluated in a simulator session where the STA role is assumed.
1 i
The STA will be assigned normal duties that pertain to the engineering asnects of assuring safe operations of the plant. The STA will assume an active role in shift activities including the review of plant logs and participation of shift turnover activities.
4 The implementation of the STA position at Quad Cities Statici Units I and 2 as discussed herein j
is consistent with the criteria specified in Refeiences (a), (e) and (g). Additionally, the implementation is consistent with Section: 6.2.C and 6.3 of Quad Cities Station Technical Specifications regarding the STA position.
An update to the applicable sections of the Quad Cities Station Updated Final Safety Analysis Report (UFSAR) to reflect this change has been completed and reviewed consistent with the requirements of 10 CFR 50.59. The 10 CFR 50.Ste review concluded that the change does not 4
i involve an unreviewed safety question.
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