ML20195C039

Requests Clarification of Training Requirements for Plant. Rescission of 800305 Order Requested,Because Operator Training Programs Meet 10CFR55 Requirements,Inpo Accredited & Use Sys Approach to Training

ML20195C039
Person / Time
Site:	Davis Besse
Issue date:	10/21/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
1555, GL-87-07, GL-87-7, TAC-69720, NUDOCS 8811020307
Download: ML20195C039 (2)

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TOLEDO .

%sna EDISON

& Cetercr Eren:y C.:n man, DONALD C. SHELTON

w. em.m au..e  !

Docket No. 50-346 "*"  !

i License No. NPF-3 Serial No. 1555 October 21, 1988 United States Nuclear Regulatory Commis,sion Document Control Desk Vashington, D. C. 20555 i L

Subject:

Clarification of Training Requirements (TAC No. 69720) l i

Gentlemen:  !

I The purpese of this letter is to request clarification of training -

requirements for the Davis-Besse Nuclear Power Station, Unit No. 1, Facility >

Operating License No. NPF-3. The March 5, 1980 Order (Log No. 530) i implemented specific training requirements at Davis-Besse which have since '

been superseded by accreditation.  :

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The March 5, 1980 Order required Toledo Edison to make changes in the plant operating staff and have a complete complement of fully trained personnel in accordance with the staffing and qualification levels set forth in draft ANSI Standard 3.1 prior to returning the station to operation from the scheduled April 1980 refueling outage. Subsequent letters clarified the method of '

compliance with the Order: Toledo Edison letter dated March 28, 1980 (Serial No. 1-123) and NRC letter dated June 11, 1980 (Log No. 1-386).

4 As discussed in several inspection reports, the NRC Staff verified Toledo l Edison's compliance with the Order. In an inspection during March 5-24, 1980,

, Report No. 50-34C/80-09 (Log No. 1-347, dated April 21, 1980), the NRC l

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verified compliance with Item 1, a, b, and e of the Order. In a subsequent  !

inspection, Report No. 50-346/81-07 (Log No. 1-515, dated June 5, 1981), the inspector reviewed training records, reactor operator logs, and shift supervisor logs and interviewed personnel on all five shifts to determine l compliance with the Order. Additionally, the inspector verified that [

1 procedure AD 1828.09, Senior Reactor Operator Training, was revised to include i the requirements of the Order. In the Systematic Assessment of Licensee [

Performance for the period of November 1, 1980 through March 31, 19b?, Report j No. 50-346/82-24 (Log No. 1-692, dated September 23, 1982), che NRC Staff  ;

confirmed that Toledo Edison had continued to meet or exceed the minimum level t of qualified and experienced personnel assigned to operating shifts required [

by the Order.  !

es11020307 881021  !

PDR ADOCK 05000346 y PDC pd EDtSON PLAZA 300 MADtSON AVENUE TOLEDO, ORO 43652 ' '

THE TOLEDO EDtSON CnYPANY i f

.t L. (L Dockot Ns. 50-346  ;

> Licens2 No. NPF-3 L Serial No. 1555 r Page 2 l

Additionally, the Davis-Besse Nuclear Power Station, Unit No. 1, Operator l-Training Programs are accredited by the Institute of Nuclear Power Operations (INPO) and use a systems approach to training. As discussed in NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, "

Code of Federal Regulations, Part 55 on Operators' Licenses" (issued by Generic Letter 87-16, dated November 12, 1987, Log No. 2461), facilities can use the accredited training programs to meet the final rule to 10 CFR Part 55 (52 FR 9453-9469, dated March 25, 1987) as INPO guidelines in this area are '

i equivalent to the staff guidelines outlined in Regulatory Guides. Generic ~

J Letter 87-07 outlines that facilities can substitute an accredited training program for the initial and requalification training programs previously approved by NRC Staff upon written notification to the NRC Staff, without any  !

4 Staff review. On March 29, 1988 (Serial No. 1502), Toledo Edison submitted this notification. Consequently, Toledo Edison is substituting the accredited i training programs for both the initial and requalification training programs  ;

l previously approved by NRC Staff. I 4 i.

4 Therefore, because the Davis-Besse Nuclear Power Station, Unit No. 1, Operator  !

Training Programs meet the requirements of 10 CFR Part 55, are INPO l accredited, and use a systems approach to training, Toledo Edison requests  !

l rescission of the March 5, 1980 Order.  !

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j l j Very truly yours, i

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I CAB / tit t l cci P. By on, DB-1 NRC Senior Resident Inspector f 1 A. V. DeAgazio, DB-1 NRC Senior Project Manager j j

A. B. Davis, Regional Administrator, NRC Region III { i l I l

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