ML15292A013: Difference between revisions

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{{#Wiki_filter:Pilgrim Nuclear Power StationERO Staffing and TrainingTeleconference with NRC Staff October 20, 201510/15/15 1400 AgendaIntroduction of ParticipantsBackground and HistoryProblem StatementProposed ResolutionBasis for ChangeIntended ActionsNRC Staff Questions and PerspectiveConclusions 2
{{#Wiki_filter:Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400
Introduction of ParticipantsNRC StaffEntergy -Pilgrim 3
 
Background and HistoryJuly 14, 2006 letter from Entergy to NRC Staff oERO substitution: ChemTech for RP Tech oTraining for ChemTechs describedFeb 5, 2007 letter from NRC Staff to Entergy oChange does not decrease effectiveness of plan oNo NRC approval necessary2015: Entergy determined ChemTech trainingnot consistent with July 14, 2006 letterImmediate actions; RP Tech added back to shifts; 4
Agenda
Problem StatementLevel of training for ChemTechs acting for RPTechs described in July 14, 2006 letter exceedsactual requirements of the ERO function.
* Introduction of Participants
5 July 14, 2006 Letter: ChemTech Training 6
* Background and History
Proposed ResolutionEntergy proposal:
* Problem Statement
oReturn to onshiftChemTechs fulfilling the RP TechERO function for first 30 minutes of ERO initiation oReduce the scope of ChemTech training oSubmittal to NRC for review and approval prior toimplementationEntergy has concluded this change is acceptable 7
* Proposed Resolution
Basis for ChangeReduced level of training -consistent with limitedspecific actions of the ChemTechs within 30 minutesSpecific on-shift staffing study supports limited scopeof responsibilities of ChemTech for RP TechsOE review identified similar implementationsFebruary 5, 2007 NRC Staff letter concluded:
* Basis for Change
oPrevious Entergy proposal met requirements of:10CFR50.47(b)(2) -adequate staffing provided10CFR50, App E, IV.A -organization for coping oChemTech training considered an enhancement oNo decrease in effectiveness / no NRC approval required 8
* Intended Actions
Intended ActionsConference call with NRC StaffPreparation and submittal of request for priorNRC Staff review and approvalRevise trainingRevise ERO staffing 9
* NRC Staff Questions and Perspective
NRC Staff Questions and Perspective 10 Conclusions 11Proposed change in Chemistry Technician isappropriate based on ERO assignmentsProposed change is justified by staffing studyEntergy intends on submitting the proposedchange for prior NRC review and approval Pilgrim Nuclear Power StationERO Staffing and TrainingTeleconference with NRC Staff October 20, 201510/15/15 1400 AgendaIntroduction of ParticipantsBackground and HistoryProblem StatementProposed ResolutionBasis for ChangeIntended ActionsNRC Staff Questions and PerspectiveConclusions 2
* Conclusions 2
Introduction of ParticipantsNRC StaffEntergy -Pilgrim 3
 
Background and HistoryJuly 14, 2006 letter from Entergy to NRC Staff oERO substitution: ChemTech for RP Tech oTraining for ChemTechs describedFeb 5, 2007 letter from NRC Staff to Entergy oChange does not decrease effectiveness of plan oNo NRC approval necessary2015: Entergy determined ChemTech trainingnot consistent with July 14, 2006 letterImmediate actions; RP Tech added back to shifts; 4
Introduction of Participants
Problem StatementLevel of training for ChemTechs acting for RPTechs described in July 14, 2006 letter exceedsactual requirements of the ERO function.
* NRC Staff
5 July 14, 2006 Letter: ChemTech Training 6
* Entergy - Pilgrim 3
Proposed ResolutionEntergy proposal:
 
oReturn to onshiftChemTechs fulfilling the RP TechERO function for first 30 minutes of ERO initiation oReduce the scope of ChemTech training oSubmittal to NRC for review and approval prior toimplementationEntergy has concluded this change is acceptable 7
Background and History
Basis for ChangeReduced level of training -consistent with limitedspecific actions of the ChemTechs within 30 minutesSpecific on-shift staffing study supports limited scopeof responsibilities of ChemTech for RP TechsOE review identified similar implementationsFebruary 5, 2007 NRC Staff letter concluded:
* July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
oPrevious Entergy proposal met requirements of:10CFR50.47(b)(2) -adequate staffing provided10CFR50, App E, IV.A -organization for coping oChemTech training considered an enhancement oNo decrease in effectiveness / no NRC approval required 8
* Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
Intended ActionsConference call with NRC StaffPreparation and submittal of request for priorNRC Staff review and approvalRevise trainingRevise ERO staffing 9
* 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
NRC Staff Questions and Perspective 10 Conclusions 11Proposed change in Chemistry Technician isappropriate based on ERO assignmentsProposed change is justified by staffing studyEntergy intends on submitting the proposedchange for prior NRC review and approval}}
* 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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