ML20202H888

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Clarifies Intent of RAI Re Plant Staff Qualifications & Reg Guide 1.8,Rev 2, Qualification & Training of Personnel for Nuclear Power Plants, Dtd Apr 1987.Staff Position on Issue Neither New Nor Different Position from Previous Position
ML20202H888
Person / Time
Site: Fermi 
Issue date: 02/04/1999
From: Carpenter C
NRC (Affiliation Not Assigned)
To: Gipson D
DETROIT EDISON CO.
References
RTR-REGGD-01.008, RTR-REGGD-1.008 IEIN-98-037, IEIN-98-37, TAC-MA1465, NUDOCS 9902080269
Download: ML20202H888 (3)


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o WASHINGTON, D.C. seess.com February 4, 1999 Mr. Douglas R. Gipson Senior Vice President Nuclear Generation Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

RESPONSE TO FERMI 2 REPLY TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO PLANT STAFF QUALIFICATIONS (TAC NO. MA1465)

Dear Mr. Gipson:

The NRC staff received your letter, dated October 19,1998, in reply to the September 3,1998, NRC request for additional information (RAl) regarding plant staff qualifications and Regulatory Guide (RG) 1.8, Revision 2, " Qualification and Training of Personnel for Nuclear Power Plants,"

dated April 1987. Your letter presented a concern that the RAI might be expressing a new or different staff position from a previously applicable staff position. This letter clarifies the intent of the RAI as discussed in the subsequent telephone conversation with your staff on November 20,1998. In particular, this letter confirms that the staff position on this issue is neither a new position nor a different position from a previously applicable staff position. In addition, this letter points out that NRC Information Notice (IN) 98-37, " Eligibility of Operator License Applicants," not the review of the technical specifications conversion, is the primary -

method the NRC used to inform licensees of this issue.

" Operators' Licenses," 10 CFR Part 55, was revised in March 1987 to establish upgraded requirements for licensed reactor operators as a result of the experience gained from the accident at Three Mile Island, Unit 2. RG 1.8, Revision 2, describes methods acceptable to the staff for complying with the revised rule. In particular, in RG 1.8, Revision 2, the staff endorses,

'g with conditions, certain parts of American National Standards Institute / American National Standard (ANSI /ANS)-3.1-1981, " Selection, Qualification, and Training of Personnel for Nuclear Power Plants," as an acceptable approach for complying with the qualification and training n

requirements of 10 CFR Parts 50 and 55. This endorsement applies to the positions identified I[O as shift supervisor, senior operator, licensed operator, shift technical advisor, and radiation protection manager. For positions other than those identified, the regulatory guide finds acceptable the approach provided in ANSI N18.1 1971, " Selection and Training of Personnel i

for Nuclear Power Plants." The Statements of Consideration for the Part 55 rule change state that,'Those facility licensees that have made a commitment that is less than that required by the new rules must conform to the new rules automatically." -It is the staff's understanding that Fermi 2 confirms that it comp lies with 10 CFR Parts 50 and 55 with respect to these qualification and training requirements.

As bacimrpund for the RAI, the staff recently denied some applications for senior reactor operator licenses at another plant in Regien lil because the applicants did not meet the necessary prerequisite experience. A factor related to this problem was the reference in the TT, ["U D

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D. Gipson February 4, 1999 licensee's technical specifications (TSs) to the 1971 ANSI standard. During its review of the Fermi 2 application to convert its current TSs to the format of the improved standard TSs, the staff noted that Fermi 2 proposed to retain the current reference to ANSI N18.1-1971 for plant personnel, with the exception of the radiation protection manager. The NRC staff issued the subject RAI to Fermi 2 to ensure the mutual understanding of this issue, confirm compliance with 10 CFR Part 55, and ensure you were aware of the opportunity to update the aforementioned commitments in an efficient manner through revision of your conversion submittal if you determined such action was necessarv. Such a change to your current submittal regarding this issue is not an NRC requirement and will not affect timely issuance of the amendment to convert the Fermi 2 TSs. The RAI did not impose, nor was it intended to imply the need for, a backfit. Similar requests were sent to other licensees in the process of converting their TSs Subsequently, the NRC issued IN 98-37, dated October 1,1998, to explain the recent problems and remind all reactor licensees that the regulatory position on eligibility for applying for an operator's license has not changed since 10 CFR Part 55 was amended in 1987.

If you should have any questions regarding this issue, please contact Andrew Kugler of my staff at 301-415-2828.

Sincerely, ORIGINAL SIGNED BY Cynthia A. Carpenter, Director Project Directorate ill-1 Division of Reactor Projects -Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-341 cc:

See next page DISTRIBUTION:

Docket File (50-341)

PUBLIC C. Jamerson E. Adensam (EGA1)

A. Kugler OGC ACRS A. Vegel, Rlil B. Boger S. Collins M. Tschiltz, EDO J. Arildsen DOCUMENT NAME: G:\\PD3-1\\WPDOCS\\ FERMI \\LTRA1465 WPD *See previous concurrence To,eceive e copy of this document, Indicato in the box: 'C*. Copy wthout attachment / enclosure

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l DATE 02/3 /99 \\l 02/ 3 /99 /

02/ Ll /99 01/26/99 OFFICIAL RECORD COPY

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Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company cc:

i John Flynn, Esquire Senior Attorney Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological Protection Division t

Michigan Department of 4

knvironmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909 8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Monroe County Emergency Management Division

- 963 South Raisinville Monroe, Michigan 48161 Regional Administrator, R6gion lli U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Norman K. Peterson Director, Nuclear Licensing Detroit Edison Company Fermi 2 - 280 TAC 6400 North Dixie Highway Newport, Michigan 48166 December 1998

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