Letter Sequence RAI |
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Results
Other: ML20202H611, ML20239A178, NRC-98-0123, Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 1999, NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions, NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS, NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev, NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev
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MONTHYEARML20239A1781998-09-0303 September 1998 Requests Addl Info Re Licensee Commitments Related to Plant Staff Qualifications.Response Requested within 45 Days of Receipt of Ltr Project stage: Other NRC-98-0123, Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 19991998-10-19019 October 1998 Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 1999 Project stage: Other ML20155B7191998-10-26026 October 1998 Forwards RAI Re Conversion to Improved STSs for Plant,In Order to Complete Review of Util 980403 Amend Request Project stage: RAI ML20196F5701998-11-20020 November 1998 Forwards RAI Re Licensee 980403 Amend Request to Convert to Improved Std TSs for Fermi 2.Mutually Agreeable Completion Schedule of 45 Days for Response Was Established Project stage: RAI ML20198B8741998-12-0404 December 1998 Forwards RAI Re 980403 Amend Request to Convert Improved Std TSs Sections 3.4 & 3.9.Completion Schedule of 60 Days for Response Established Per Discussion with G Ohlemacher on 981109 & 10 Project stage: RAI NRC-98-0150, Forwards Response to NRC 981026 RAI Re Fermi 2 Conversion to Improved Std Ts.Responses Reflect Results of Series of Meetings Between Util & NRC1998-12-10010 December 1998 Forwards Response to NRC 981026 RAI Re Fermi 2 Conversion to Improved Std Ts.Responses Reflect Results of Series of Meetings Between Util & NRC Project stage: Meeting ML20198J6761998-12-22022 December 1998 Forwards Request for Addl Info Re Conversion to Improved STS Section 3.8.Response Requested within 60 Days Project stage: RAI NRC-99-0001, Forwards Response to NRC 981120 RAI Re Fermi 2 Conversion to Improved Std Tech Specs.Plant ITS Submittal Will Be Revised to Reflect Response to RAI Following Completion of Remaining RAIs Re ITS Submittal,As Agreed Upon in Meetings with N1999-01-0808 January 1999 Forwards Response to NRC 981120 RAI Re Fermi 2 Conversion to Improved Std Tech Specs.Plant ITS Submittal Will Be Revised to Reflect Response to RAI Following Completion of Remaining RAIs Re ITS Submittal,As Agreed Upon in Meetings with NRC Project stage: Response to RAI ML20199G7561999-01-14014 January 1999 Forwards Request for Addl Info Re Conversion to Improved Stds Tss,Section 3.3 for Plant Project stage: RAI ML20202H6111999-01-25025 January 1999 Requests Addl Info Re Conversion to Improved Std Tss, Section 3.5 for Fermi 2 Project stage: Other ML20202H8881999-02-0404 February 1999 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 Project stage: RAI ML20203F6761999-02-11011 February 1999 Forwards Request for Addl Info Re Conversion to Improved Standard Ts,Section 3.6 for Fermi 2 Project stage: RAI NRC-99-0032, Forwards Rev 4 to Fermi 2 Its,Per Submittal .Rev Provides Responses to NRC RAI Re ITS Sections 3.4 & 3.9 Contained in Ltr1999-03-30030 March 1999 Forwards Rev 4 to Fermi 2 Its,Per Submittal .Rev Provides Responses to NRC RAI Re ITS Sections 3.4 & 3.9 Contained in Ltr Project stage: Response to RAI NRC-99-0033, Submits Initial Responses to RAIs Re Conversion to Improved Tech Specs Contained in Noted Refs 1-5.Util Has Found Extensive Dialog with NRC That Has Taken Place to Date to Be Extremely Fruitful in Effectively Managing Fermi 21999-04-0808 April 1999 Submits Initial Responses to RAIs Re Conversion to Improved Tech Specs Contained in Noted Refs 1-5.Util Has Found Extensive Dialog with NRC That Has Taken Place to Date to Be Extremely Fruitful in Effectively Managing Fermi 2 Project stage: Response to RAI NRC-99-0044, Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses1999-04-30030 April 1999 Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses Project stage: Response to RAI NRC-99-0045, Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl1999-05-0707 May 1999 Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl Project stage: Response to RAI NRC-99-0046, Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 11999-06-0202 June 1999 Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 1 Project stage: Response to RAI NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions1999-07-0707 July 1999 Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions Project stage: Other NRC-99-0054, Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal1999-07-13013 July 1999 Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal Project stage: Request NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS1999-07-26026 July 1999 Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS Project stage: Other ML20211C4761999-08-0606 August 1999 Forwards Draft Safety Evaluation Re Proposed Conversion of Current TS to Improved Standard TS Project stage: Draft Approval IR 05000341/19990061999-08-0606 August 1999 Insp Rept 50-341/99-06 on 990712-0716.No Violations Noted. Major Areas Inspected:Review of Various Aspects of Licensee Chemistry & Radiation Protection Programs,Specifically in Listed Areas Project stage: Request NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-08-17017 August 1999 Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev Project stage: Other ML20211C0521999-08-17017 August 1999 Forwards Tables for Sections 3.6 & 3.7 of Draft Safety Evaluation of Proposed Conversion of Current TS to Improved Standard TS Project stage: Draft Approval NRC-99-0078, Rev 14 to Application for Amend to License NPF-43,providing Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Brief Abstract of Changes Included in Rev & Revised Pages for Submittal & Rev Instructions,Included1999-08-25025 August 1999 Rev 14 to Application for Amend to License NPF-43,providing Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Brief Abstract of Changes Included in Rev & Revised Pages for Submittal & Rev Instructions,Included Project stage: Request NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-09-0808 September 1999 Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev Project stage: Other 1999-02-04
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'[p UNITED STATES NUCLEAR REGULATORY COMMISSION g,,, y j
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
'E'. Copy with attachment /encbsure "N'. No copy l OFFICE PM:PD31 E
LA:PD31 lE D:PD31 l5 C:HOLB*
l l NAME AKugler:db fL CJamerson OM/ CACarpenter d RGallo I
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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