B11862, Advises That Policy Re on-shift Operating Experience Complies W/Nrc Concerns W/Respect to Providing Reasonable Assurance of Adequate on-shift Operating Experience,In Response to Generic Ltr 84-16

Advises That Policy Re on-shift Operating Experience Complies W/Nrc Concerns W/Respect to Providing Reasonable Assurance of Adequate on-shift Operating Experience,In Response to Generic Ltr 84-16

ML20205H193
Person / Time
Site:	Millstone
Issue date:	11/07/1985
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Youngblood B Office of Nuclear Reactor Regulation
References
B11862, GL-84-16, NUDOCS 8511150012
Download: ML20205H193 (5)

Text

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November 7,1985 o

Docket No. 50 423 B11862-Director of Nuclear Reactor Regulation Mr. B. 3. Youngblood, Chief Licensing Branch No. I Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

References:

(1) 3. F. Opeka letter to B. 3. Youngblood, " Millstone Nuclear Power Station, Unit No. 3; Response to Request for Additional Information - Use of Shift Advisors," dated November 1,1985.

(2) 3. F. Opeka letter to B. 3. Youngblood, " Millstone Nuclear Power Station, Ur.it No. 3; Hot Participation Experience,"

dated September 20,1985.

Dear Mr. Youngblood:

Millstone Nuclear Pm Station, Unit No. 3 Hot Operating ExpeQt y 1 Shif t Technical Advisor Over the past several months, ws .. ave _ : amented and had numerous discussions with the NRC staff regarding our compliance with the hot operating experience guidelines of Generic Letter S4-16 and the use of Shif t Technical Advisors (STA) for Millstone Unit No. 3. The purpose of this letter is to summarize our position so that your staff may complete its review of this matter.

Northeast Nuclear Energy Company (NNECO) has committed to provide Shift Advisors for those operating shifts which do not yet have hot operating experience consistent with the guidelines delineated in Generic Letter 84-16.

These Shift Advisors have experience on two of our operating nuclear units, Connecticut Yankee and Millstone Unit No. 2 (both of which are PWRs), and are or have been SRO licensed on their respective units with a minimum of one year of hot operating experience on that unin A resume for each Shift Advisor highlighting his previous operating experience, along with the Millstone Unit No.3 operating procedure describing the duties, responsibilities, and qualifications of the Shift Advisor, was provided to the NRC in Reference (1). A description of the training program for the Shift Advisors was also provided in Reference (1). This training program is considered to be a minimum program, and additional training will be provided based on the individual candidate's

, background and experience.

B511150012 851107 I g PDR ADOCK 05000423 l A PDR

Using Shif t Advisors, Millstone Unit No. 3 will be able to provide operating shifts with significant operating experience in addition to providing Millstone Unit No.

3 licensed individuals on each shif t with extensive prior nuclear experience and experience in the startup test program. We believe that this augmentation of the company policy we explained in Reference (2) fully meets the intent of the guidelines of Generic Letter 84-16.

The attachment to this letter provides a six-shif t rotation schedule based on the results of the recent NRC license examinations, which was prepared to show the typical effects of this commitment in providing well-balanced shifts of experienced personnel. We propose to further address the hot operating experience concerns through the adoption of the following policy:

o A three shif t rotation will go into effect by fuel load and will remain in effect through fuel load, initial criticality, and low power physics testing up to 5% power. There are adequate numbers of experienced Millstone

- Unit No. 3 licensed SROs to support this rotation and meet all the hot operating experience guidelines without the use of Shift Advisors. This three shift rotation was planned to support normal fuel load and startup test activities and is the same rotation schedule used to support refueling outages on our operating units. Based on this actual operating experience, we believe a three shif t rotation provides the best approach during startup and fully protects the health and safety of the general public.

o All Shift Advisors will participate in onshift observation training for the purpose of reinforcing the previous formal training the Shift Advisors have received and for additional familiarization purposes. This will be conducted prior to 5% power for all advisors.

o Once the Shift Advisors have completed the above training, we intend to reconstitute the shifts to utilize Shift Advisors to allow the use of up to a six shift rotation. We believe this level of shift staffing is desirable to allow,in the long term, for training and flexibility of operations and to be consistent with our policy on overtime control. The attachment to this letter provides for a six shift rotation with a typical shift composition.

The operating shif ts will begin accruing hot operating experience from the date the plant enters Mode 3 for the first time. A Shift Advisor will be provided to augment the operating shifts until a shift having the requirement for an experienced advisor accrues at least six months of hot operating experience.

Regarding our position on Shift Technical Advisors for Millstone Unit No. 3, we would like to reiterate that we will provide on each operating shif t:

1) An individual serving in the dual role of SRO/STA who is SRO-licensed on Millstone Unit No. 3 and who holds a bachelor's degree in engineering, ,

engineering technology, or a physical science; or j

. I

2) A dedicated STA who meets the criteria of NUREG-0737, item I.A.I.l.

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4 We believe this policy regarding on-shift operating experience complies with NRC concerns with respect to providing reasonable assurance of adequate on-shift operating experience. Should you have any further questions regarding these two items, please contact our licensing representative.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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BY NORTHEAST NUCLEAR. ENERGY COMPANY Their Agent

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, 3. IWeka b Senior Vice President Attachment cc: Mr. W. T. Russell, Director

-NRC Division of Human Factors Dr. T. E. Murley, Regional Administrator NRC Region I Mr. L. P. Crocker NRC Licensee Qualification Branch Mr. F. R. Allenspach NRC Licensee Qualification Branch STATE OF. CONNECTICUT )

) ss. Waterford COUNTY OF NEW LONDON .)

Then personally appeared before me 3. F. Opeka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, an Applicant herein, that he is authorized to execut: and file the foregoing information in the name and on behalf of the Applicants herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

noi a . sac Notary Public /

ATTACHE NT (Page 1 ef 2)

MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 OPERATING SHIFTS - QUALIFICATIONS AND EXPERIENCE LEVELS (IN MONTHS)

/

EDUCATION C0KiERCIAL OPERATING EXPERIENCE NUCLEAR NAVY EXPERIENCE .

TOTAL Total . . NUCLEAR Licensed Reactor Commercial .

Wighest EXPERIENCE LICENSE Degree - Field Experience Type - Unit

• License Experience Experience Qualification (Note 1) RECEIVED SHIFT A SS - E. Fetterman -

141 PWR-CY SRO 183 77 E0 260 SRO SCO - R. Medeiros -

0 - - 4 69 RO 73 SRO CO - R. Peters -

0 - - 47 0 -

47 R0 CO - P. Lang - 0 - - 6 71 RO -77 R0 STA - (Note 2)

Advisor - Not Required SHIFT 8 SS - R. Walker - 124 BWR-W1 SRO 134 79 -EWS 213 SRO '

SCO - L. Palone -

79 PWR-CY SRO 128 53 R0 181 SRO CO - P. Malzahn - 0 - -

3 72 E0/SR0 75 R0 CO - L. Miller -

0 - - 0 18 (Note 4) 72 R0 STA - (Note 2)

Advisor - Not Required SHIFT C SS - G. Olson MS - Nucl. Eng. 0 - - 1 98 Engineer 99 SRO SCO - J. Jalonski - 80 PWR-W2 SRO 124 57 ERS 181 SRO CO - M. Miner - 0 - - 8 72 EWS 80 SRO CO - (Note 3)

STA - Not Required Advisor - Not Required SHIFT D SS - K. Covin BA - Math / Physics 0 - -

1 92 Engineer 93 SRO SCO - C. Ryan - 0 - - 48 61 EWS 55 SRO CO - D. Brodsky -

0 - -

14 104 ERS 118 R0 CO - (Note 3)

STA - Not Required Advisor - N. Burnett - 252 PWR-CY SRO 294 - - 294 N/A 6

C0ptiERCIAL OPERATING EXPERIENCE NUCLEAR NAVY EXPERIENCE '

EDUCATION __ TOTAL Total NUCLEAR Reactor Commercial Highest EXPERIENCE LICENSE Licensed (Note 1)

Degree - Field Experience Type - Unit *. License Experience EYperience Qualification RECEIVED SHIFT E

- 1 60 Engineer 61 SRO SS - R. Martin B.S. - Math 0 -

129 SRO 0 - - 6 123 EW5 SCO - 0. Ashinghurst A.A. 69 EO 92 R0 0 - - 23 CO - D. Tipple -

0 144 EWS 144 R0 CO - G. Box - 0 - -

STA - Not Required 102 72 E0 174 N/A 75 PWR-CY SRO Advisor - T. Tallman -

SHIFT F

- 1 60 Engineer 61 SRO SS - J. Ruttar B.S. - Oceanography 0 -

SRO SR0 54 74 ERS 128 15 BWR-W1 SCO - 8. Parrish -

0 72 EWS 72 R0 CO - R. Smith - 0 - -

CO - (Note 3)

STA - Not Required 58 70 ERS 128 N/A 40 PWR-W2 SRO Advisor - K. Bragg -

ADDITIONAL

- 0 66 Engineer 66 SRO OA - M. Pearson B.S. - Oceanography 0 -

65 SRO 0 65 Engineer GA - D. Moore B.S. - Chemistry 0 - -

NOTES

• KEY (1) Millstone Ualt No. 3 Experience not credited. As of Septernber 1985, the minimum Unit 3 - Connecticut Yankee (Haddam Neck)

CY time for all operators listed was 2 years. The majority of operators have greater W1 - Millstone Unit No. 1 than 3 years experience on Millstone Unit No. 3. W2 - Millstone Unit No. 2 EO - Electrical Operator (2) A qualified STA will be provided by relief shift 0A, or training instructor. EWS - Engineering Watch Supervisor Engineer - Chief Engineer (3) Additional C0 provided from relief shift or licensed training instructor. R0 - Reactor Operator ERS - Engine Room Supervisor (4) Licensed on Fast Flux Facility. Completed PE0 qualification on Millstone Unit No. 2. SRO - Senior Reactor Operator 6