ML15292A013: Difference between revisions

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| number = ML15292A013
| number = ML15292A013
| issue date = 10/20/2015
| issue date = 10/20/2015
| title = Pilgrim Nuclear Power Station - ERO Staffing and Training Teleconference with NRC Staff
| title = ERO Staffing and Training Teleconference with NRC Staff
| author name =  
| author name =  
| author affiliation = Entergy Nuclear Generation Co
| author affiliation = Entergy Nuclear Generation Co
Line 13: Line 13:
| page count = 11
| page count = 11
}}
}}
=Text=
{{#Wiki_filter:Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400
Agenda
* Introduction of Participants
* Background and History
* Problem Statement
* Proposed Resolution
* Basis for Change
* Intended Actions
* NRC Staff Questions and Perspective
* Conclusions 2
Introduction of Participants
* NRC Staff
* Entergy - Pilgrim 3
Background and History
* July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
* Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
* 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
* Immediate actions; RP Tech added back to shifts; 4
Problem Statement
* Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.
5
July 14, 2006 Letter: Chem Tech Training 6
Proposed Resolution
* Entergy proposal:
o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation
* Entergy has concluded this change is acceptable 7
Basis for Change
* Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
* Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
* OE review identified similar implementations
* February 5, 2007 NRC Staff letter concluded:
o Previous Entergy proposal met requirements of:
10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8
Intended Actions
* Conference call with NRC Staff
* Preparation and submittal of request for prior NRC Staff review and approval
* Revise training
* Revise ERO staffing 9
NRC Staff Questions and Perspective 10
Conclusions
* Proposed change in Chemistry Technician is appropriate based on ERO assignments
* Proposed change is justified by staffing study
* Entergy intends on submitting the proposed change for prior NRC review and approval 11
Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400
Agenda
* Introduction of Participants
* Background and History
* Problem Statement
* Proposed Resolution
* Basis for Change
* Intended Actions
* NRC Staff Questions and Perspective
* Conclusions 2
Introduction of Participants
* NRC Staff
* Entergy - Pilgrim 3
Background and History
* July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
* Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
* 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
* Immediate actions; RP Tech added back to shifts; 4
Problem Statement
* Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.
5
July 14, 2006 Letter: Chem Tech Training 6
Proposed Resolution
* Entergy proposal:
o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation
* Entergy has concluded this change is acceptable 7
Basis for Change
* Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
* Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
* OE review identified similar implementations
* February 5, 2007 NRC Staff letter concluded:
o Previous Entergy proposal met requirements of:
10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8
Intended Actions
* Conference call with NRC Staff
* Preparation and submittal of request for prior NRC Staff review and approval
* Revise training
* Revise ERO staffing 9
NRC Staff Questions and Perspective 10
Conclusions
* Proposed change in Chemistry Technician is appropriate based on ERO assignments
* Proposed change is justified by staffing study
* Entergy intends on submitting the proposed change for prior NRC review and approval 11}}

Latest revision as of 06:33, 31 October 2019

ERO Staffing and Training Teleconference with NRC Staff
ML15292A013
Person / Time
Site: Pilgrim
Issue date: 10/20/2015
From:
Entergy Nuclear Generation Co
To:
Office of Nuclear Reactor Regulation
Venkataraman B
References
Download: ML15292A013 (11)
v • d • e


Text

Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400

Agenda

  • Introduction of Participants
  • Background and History
  • Problem Statement
  • Proposed Resolution
  • Basis for Change
  • Intended Actions
  • NRC Staff Questions and Perspective
  • Conclusions 2

Introduction of Participants

  • NRC Staff
  • Entergy - Pilgrim 3

Background and History

  • July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
  • Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
  • 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
  • Immediate actions; RP Tech added back to shifts; 4

Problem Statement

  • Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.

5

July 14, 2006 Letter: Chem Tech Training 6

Proposed Resolution

  • Entergy proposal:

o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation

  • Entergy has concluded this change is acceptable 7

Basis for Change

  • Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
  • Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
  • OE review identified similar implementations
  • February 5, 2007 NRC Staff letter concluded:

o Previous Entergy proposal met requirements of:

10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8

Intended Actions

  • Conference call with NRC Staff
  • Preparation and submittal of request for prior NRC Staff review and approval
  • Revise training
  • Revise ERO staffing 9

NRC Staff Questions and Perspective 10

Conclusions

  • Proposed change in Chemistry Technician is appropriate based on ERO assignments
  • Proposed change is justified by staffing study
  • Entergy intends on submitting the proposed change for prior NRC review and approval 11

Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400

Agenda

  • Introduction of Participants
  • Background and History
  • Problem Statement
  • Proposed Resolution
  • Basis for Change
  • Intended Actions
  • NRC Staff Questions and Perspective
  • Conclusions 2

Introduction of Participants

  • NRC Staff
  • Entergy - Pilgrim 3

Background and History

  • July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
  • Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
  • 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
  • Immediate actions; RP Tech added back to shifts; 4

Problem Statement

  • Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.

5

July 14, 2006 Letter: Chem Tech Training 6

Proposed Resolution

  • Entergy proposal:

o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation

  • Entergy has concluded this change is acceptable 7

Basis for Change

  • Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
  • Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
  • OE review identified similar implementations
  • February 5, 2007 NRC Staff letter concluded:

o Previous Entergy proposal met requirements of:

10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8

Intended Actions

  • Conference call with NRC Staff
  • Preparation and submittal of request for prior NRC Staff review and approval
  • Revise training
  • Revise ERO staffing 9

NRC Staff Questions and Perspective 10

Conclusions

  • Proposed change in Chemistry Technician is appropriate based on ERO assignments
  • Proposed change is justified by staffing study
  • Entergy intends on submitting the proposed change for prior NRC review and approval 11
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