NUREG-0853, Requests Review of Acceptability of Shift Technical Advisor Program Change in Amend 29 to FSAR & Conformance W/ NUREG-0737,Item I.A.1.1.Amend Not Explicitly Reviewed in Sser 5 (NUREG-0853).Response by 860315 Requested: Difference between revisions

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{{Adams
#REDIRECT [[NUREG-0853, Discusses Receipt of Recent 10CFR50.59 Evaluations Which Changed Commitments Originally Made to Satisfy Requirements of Item II.B.3 of NUREG-0737]]
| number = ML20137Y831
| issue date = 02/28/1986
| title = Requests Review of Acceptability of Shift Technical Advisor Program Change in Amend 29 to FSAR & Conformance W/ NUREG-0737,Item I.A.1.1.Amend Not Explicitly Reviewed in Sser 5 (NUREG-0853).Response by 860315 Requested
| author name = Norelius C
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name = Bernero R
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000461
| license number =
| contact person =
| case reference number = RTR-NUREG-0737, RTR-NUREG-0853, RTR-NUREG-737, RTR-NUREG-853, TASK-1.A.1.1, TASK-TM
| document report number = NUDOCS 8603120400
| package number = ML20137Y834
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 18
}}
 
=Text=
{{#Wiki_filter:r
-i Bd FEB 28 G86 g
i MEMORANDUM FOR:
R. M. Bernero, Director, Division of Boiling Water Reactor Licensing, Office of Nuclear Reactor Regulation FROM:
Charles E. Norelius, Director, Division of Reactor.
Projects, Region III
 
==SUBJECT:==
REQUEST FOR TECHNICAL ASSISTANCE -
ACCEPTABILITY OF CLINTON POWER STATION'S RESPONSE TO TMI ACTION PLAN ITEM !.A.1.1, SHIFT TECHNICAL ADVISOR This memorandum requests your review of the Illinois Power Company (IP) Shift Technical Advisor (STA) program as it was changed in amendment 29 to the Clinton Power Station (CPS) Final Safety Analysis Report (FSAR). Your review 4
l
.is needed to assure that the Shift Technical Advisor function is properly implemented to support the safe operation of CPS. Recent independent inspectior, results and limited direct observations by the Clinton resident inspectors indicate that the current group of six certified STAS at Clinton Power Station may not be properly qualified to provide on shift engineering and accident assessment advice to the shift supervisor.
i Amendment 29 to the CPS FSAR, Appendix D, page D-3, TMI Action Plan Item I.A.1.1, Shift Technical Advisor, was documented by Illinois Power Company IP) as a " slight" variation from the Institute For Nuclear Power Operations INP0) guidelines for STAS. As such, the amendment was not explicitly reviewed in Supplement 5 to the CPS Safety Evaluation Report (SSERS).
However, SSERS accepted the changes made in the CPS STA program and IP believes that the present STA program is in compliance with their FSAR commitments.
The results of our recent inspection of the IP STA training program indicate that the amendment was a substantive departure from IPs earlier position regarding educational requirements for STAS. Since the change in question has not been explicitly reviewed by your staff, we have concerns regarding the acceptability of IP's current STA program. An NRR review appears appropriate.
The enclosure provides the results of our inspection and the basis for our request for your review of the amendment. The nature of our concern has been previously discussed with Mr. B. L. Siegel of the Division of BWR Licensing and Mr. W. T. Russell of the Division of Human Technology.
In your review, please determine if the change identified above, as discussed in the enclosure,
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R. M. Bernero 2
FEB 281986 provides an STA program for CPS that meets the intent of the TMI Action Plan requirements.
Since CPS is scheduled to load fuel in the near term, I would appreciate your response indicating the acceptability of the CPS STA program before March 15, 1986. Should you have any questions regarding this memorandum or the enclosure, please contact Mr. T. P. Gwynn of my staff at 217/935-9521.
eg;-{ginal $lged by U.G. GEC%D Charles E. Norelius, Director Division of Reactor Projects Region III t
 
==Enclosure:==
Request For Technical Assistance -
Clinton Power Station STA Program dated 2/25/86 cc w/ enclosure:
W. T. Russell, NRR B. L. Siegel, NRR R. F. Warnick T. P. Gwynn A
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a REQUEST FOR TECHNICAL ASSISTANCE - CLINTON POWER STATION (CPS) STA PROGRAM NRR review of the Illinois Power Company (IP) Shift Technical Advisor (STA) program, as it was changed in amendment 29 to the CPS FSAR, is needed to assure that the STA function is properly implemented to support the safe operation of CPS.
Recent limited observations and independent inspection results by the Clinton resident inspectors indicate that the current group of six certified STAS at CPS may not be properly qualified to provide on shif t engineering and accident assessment advice to the shift supervisor.
BACKGROUND The Clinton Safety Evaluation Report (SER), NUREG-0853, dated February 1982, documented the NRC review and conclusion that IP had an STA program that met the requirements of TMI Action Plan Item I.A.1.1, Shift Technical Advisor.
The basis for the staff's conclusion was detailed in the SER, section 13.1.2.1, pages 13-13 through 13-15 (Attachment A).
In the SER, the staff acknowledged the applicant's commitment for a Shift Technical Advisor (STA) program that met both the training and educational guidelines of the Institute for Nuclear Power Operations (INPO) document
" Recommendations for Shift Technical Advisor", revision 1, dated April 1981 (Attachment B) with minor exceptions.
Page 13-14 of the Clinton SER j
(Attachment A) delineates eight exceptions to the INP0 document that IP had taken and the NRC staff accepted.
Those exceptions defined specific educational contact hours the applicant proposed to provide STA candidates in lieu of the INPO guidelines contained in paragraph 6.1.2 of attachment B.
An earlier version (revision 0) of the INP0 document " Recommendations for Shift Technical Advisor" is included as Appendix C to NUREG-0737, Clarification l
of TMI Action Plan Requirements, dated November 1980.
In NUREG-0737, the staff found the education, training, and experience requirements for STAS as described in Sections 5 and 6 of the INP0 document (Appendix C to NUREG-0737) to have been an acceptable approach to the selection and training of personnel to staff the STA positions.
CURRENT APPLICAhT RESPONSE TO TMI ACTION PLAN ITEM I.A.1.1 The CPS Final Safety Analysis Report (FSAR), Appendix D Section I.A.1.1.
(Attachment C) detailed the applicant's revised response to TMI Action Plan Item I.A.1.1, Shift Technical Advisor. Amendment 29 to the CPS FSAR indicated that a " slight" variation from the INP0 educational guidelines was taken in the IP STA program.
NUREG-0853, Supplement No. 5 (SSERS), dated January 1986, detailed the NRC staff's review of Chapter 13 of the FSAR through Amendment 33 (Attachment D).
SSERS does not explicitly address review of the variation IP had taken from the INP0 guidelines but did apparently accept the variation.
IP's position is that their current STA program is in compliance with commitments contained in the FSAR as acc.epted by NRR.
 
INSPECTION RESULTS The following inspection results, which will be documented in Inspection Report 50-461/86008, indicate substantive deviations from the INPO guidelines document which affect the ability of CPS STAS to provide on shift engineering and accident assessment advice to the shift supervisor in the event of abnormal or accident conditions.
1.
Attachment B, FOREWORD, paragraph 2 states "The user is cautioned to ensure that the recomended education and training is conducted in a professional manner by competent instructors and at the proper level.
Institutions and programs accredited by recognized agencies such as ECPD/ ABET and INP0 ensure that adequate standards are met".
The CPS STA Program requires that STA candidates have a B.S. degree in Engineering, Engineering Technology, or the Physical Sciences. The program does not require that the degree be obtained from an accredited institution.
2.
Attachment B, Section 6.1, Education, and subsections 6.1.1, Prerequisites Beyond High School Diploma, and 6.1.2. College Level Fundamental Education, prescribe the educational requirements that a STA must meet in order to provide adequate assurance that he will be able to perform his intended safety function.
The CPS FSAR, Appendix D, TMI Action Plan Item I.A.1.1, Shift Technical Advisor, Amendment 29 dated March 1984, replaced IPs comitment to provide STA candidates the minimum educational requirements delineated in section 6.1 of attachment B with their comitment to have a degreed STA on shift (B.S. degree in Engineering, Engineering Technology, or Physical Sciences). The degreed STA was provided with operator fundamentals reactor theory training. The B.S. degree was the only prerequisite education that was found included in the IP STA program.
There was no requirement to evaluate the B.S. degree course work accomplished by the STA candidate against the educational requirements specified in section 6.1 of the INP0 document.
In addition, there was no requirement in IPs STA program that waivers of the INP0 education requirements be granted only by the Vice President - Nuclear as recomended in attachment B.
3.
The college level fundamental education specified in section 6.1.2 of the INP0 document was not a part of the IP STA training program. The STA training program did provide plant specific applied fundamentals training. The training provided consisted of 4 - 6 weeks of classroom training in certain science and engineering subjects.
Those subjects did not include the subject of nuclear materials as recomended by INP0.
The classroom training provided to the STA candidates was the same fundamentals training provided to the applicant's licensed operator candidates. The inspector was concerned that the training provided was not at the " college level", as specified in the INP0 document, and was not provided by an accredited institution.
2
 
The resident inspectors do not believe that the level at which licensed operators are routinely trained would meet the accreditation standards of the ECPD (Engineers Council For Professional Development) for the course work specified in Section 6.1.2 of the INP0 guidelines. Of particular concern was the application of licensed operator training in reactor theory to the STA training program. The INP0 document specifies that the candidate have 100 contact hours of reactor theory in such areas as reactor statics, reactor dynamics, point kinetics and reactivity feedback at the college level.
Having attended ECPD accredited institutions and having studied the above subjects at the college level, and also having had previous training and experience as Navy nuclear plant operators, the resident inspectors are of the opinion that a reactor theory course designed for. licensed operator training does not meet the intent of the INP0 guideline document by definition.
IP expects that the STA training program will be acceptable for accreditation by INP0. That accreditation was scheduled for November 1987.
The above deviations from the INP0 document guidelines allow individuals with a wide range of educational background and minimal nuclear power plant operating experience to function as a STA at CPS. Because of the lack of program requirements, the resident inspectors were unable to determine that more than two of the six properly certified CPS STAS were in fact qualified to the intent of the INPO guidelines for STAS. The inspectors noted that, by following the minimum requirements of the CPS STA program, an individual with a B.S. degree in geology (one of the physical sciences) from an institution of higher learning could be certified as a CPS STA after a short training period. However, the capability of that individual to meet the intent of TMI Action Plan Item I.A.1.1 (i.e., to provide on shift engineering and accident assessment advice to the shift supervisor) would be less than the least experienced licensed reactor operator.
The intent of TMI Action Plan Item I.A.1.1, STA, as discussed in numerous reference documents and as recently reinforced by a Comission Policy Statement (Attachment E), is to provide on shift engineering and accident assessment advice to the Shif t Supervisor in the event of abnormal or accident conditions. With the requirements imposed by the IP STA training program and the training provided to STA candidates, it was not clearly evident to the Clinton resident inspectors that the intent of the item would be met.
IP believes that their STA training program, as it currently exists, is in compliance with their comitments and meets the intent of the TMI Action Plan.
i l
ATTACHMENTS:
A.
Excerpt from CPS SER, pages 13-13 through 13-15.
l B.
IhPO Document Number GPG-01, Revision 1. April 28, 1981 NUCLEAR POWER PLANT SHIFT TECHNICAL ADVISOR - RECOMMENDATIONS FOR POSITION DESCRIPTION, j
QUALIFICATIONS, EDUCATION AND TRAINING l
C.
Excerpt from CPS FSAR, Appendix D, page D-3 Amendment 29 dated March 1984; THI Action Plan Item I.A.1.1.
l D.
Excerpt from CPS SSERS, pages 13-1 through 13-6.
E.
Comission Policy Statement on Engineering Expertise on Shif t; Federal Register Notice dated October 28, 1985.
3 L.
 
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/
ATTACIDfENT A Supervisor will be assigned to the day shift.
The total number of licensed operators for normal shift manning is:
Shift Supervisors 6
Assistant Shift Supervisors 6
Control Room Supervisors 5
Control Room Operators 15 Total T2 Overtime requirements are contained in 0AP 1401.03N, " Call-out and Recall of Standby Personnel," and meet the I.A.1.3 requirements.
Based on review of the appilcant's letter of November 18, 1981, OAP 1401.03N, and the FSAR, the staff finds that 'the applicant meets the requirements of I.A.1.3.
There are currently 38 persons in training who are dedicated to these 32 positions.
The staff informed the applicant that this number appears to be inadequate because there is little margin for attrition and examination failures, in a {{letter dated|date=November 18, 1981|text=letter dated November 18, 1981}}, the appilcant stated that he will hire an additional 10 Unit Attendants immediately from the Navy nuclear program so that they could be licensed by January 1983, if necessary.
License training for these individuals will begin in February 1982.
The licensed operator training pipeline will eventually be Illied by Richland Community College graduates, preferably f rom the Power Generation-Nuclear curriculum or equivalent.
Beginning in 1982, acceptable graduates will be hired into entry level positions, and the applicant will provide 15 scholarships for local high school graduates to the Richland Community College Power Generation-Nuclear program.
Each licensee shall provide an onsite Technical Advisor to the Shift Supervisor (l.A.1.1).
The applicant had proposed to have the Shift Technical Advisor (STA) function performed by a suitably qualified member of the operating shift.
The staff Informed the applicant that his proposal would not meet the staff position on the STA and that an STA would have to be provided for each shift while in Modes 1-3 until the staff has decided on the changes required in the training of operators and the related control room equipment modifications that would be acceptable for eliminating the STA.
In a {{letter dated|date=November 18, 1981|text=letter dated November 18, 1981}}, the applicant stated that the STA will serve the function of the advisor to the Shift Supervisor on matters of safety, and, if qualified, act as an onshif t nuclear engineer.
As an advisor to the Shift Supervisor, the STA will have no authority to direct the activities of the shift.
As an interim position, the applicant will require that the STA be a graduate of a 4 yr college curriculum in science or engineering, who has received training in the response and analysis of the plant for transients and accidents.
The size of the Technical Department was increased to accommodate this position.
College graduates (4 yr) are being hired to fill this position.
The Clinton STA training program will fulfill the trainina and educational guidelines as delineated in the Institute of Nuclear Pov.er Operations (INPO)
Clinton SF.R 13-13
 
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.1i document " Recommendations for Shif t Technical Advisor," April 1981, with
'j -
exceptions as documented in Appendix D, Item 1.A.1.1. of the FSAR.
These are J
(1) 315 instead of 90 contact hours of mathematics will be taught.
This is required to meet other course prerequisites.
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(2) Reactor theory is not included because all STA candidates will have f
received the reactor physics portion of operator training at the SRO fg.
level.
(3) 45 instead of 30 contact hours of reactor chemistry are provided, f
4o (4) 45 instead of 40 contact hours of nuclear materials are provided.
4 t-(5) 90 instead of 120 hr of thermal sciences are included.
The existing il courses cover the areas specified in the INPO document.
4 (6) Electrical sciences are not specifically included; however, the physics 3
courses included (180 contact hours total) will provide approximately 4
50 contact hours with laboratory for covering basic electrical theory.
j (7) 30 instead of 40 contact hours are included to teach nuclear instrumentation and control.
1 4.
(8) 30 instead of 40 contact hours are provided for nuclear radiation
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protection and health physics because a pre existing nuclear engineering
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course is being used.
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In addition to the above educational requirements, personnel will be trained in i
the following areas:
(1) applied fundamentals plant specific h
(2) management / supervisory skills
.t (3) plant systems
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(4) administrative controls 1
(5) general operating procedures 4
(6) transient / accident analysis and emergency pr ocedures (7) simulator exercises.
The plant-specific applied fundamentals training for STAS will be fulfilled by
]
their participation in the license review course and the licensed operator A
requalification training program.
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All STAS will attend the Illinois Power Company Supervisory Development d,
Program.
This 1-week program is structured to enhance management / leadership y
skills and to provide insight into techniques of motivation and the 4
decisionmaking process.
.r, hl All STAS will actively participate in the license review course and the J) licensed operator requalification program.
This will provide training in the a
areas of plant systems, administrative controls, general operating procedures, y
and transient / accident analysis and emergency procedures.
k Clinton SER 13-14 44
.- k
 
r.
As an integral part of Clinton's training program, licensed operators will participate in annual retraining at a simulator facility.
The STAS will also attend this annual simulator requalification training.
The initial STA training simulator shall be of 100-hr duration (50 hr in the classroom, 50 hr at the panel) with emphasis placed on plant / operator response to simulated plant conditions and events.
STAS who do not perform routine plant activities for 30 days or longer will review the following documents before they receive STA duties:
plant modifications that affect the features of the facility design or its opera, ting characteristics for which the licensee is responsible changes to and newly issued safety-related procedures changes to facility license reportable occurrences where the corrective Action specifies that each licensee shall review the report.
I In a {{letter dated|date=December 1, 1981|text=letter dated December 1, 1981}}, the applicant stated:
"When the NRC's deliberation are concluded and the requirements for elimination of the STA position have been established, IPC expects to eliminate this interim j
commitment."
i
)
l As a result of its review of the foregoing the staff finds that the applicant meets the requirements of Action Plan Item I.A.1.1.
13.1.2.2 Summary and Conclusions The Clinton Power Station is the applicant's first nuclear station.
As a f result, the organization to conduct operation is not completely in place and functioning.
The applicant's present staff has some commercial operating experience including BWR experience.
The applicant has made commitments that would appear to fulfill the minimum requirements in the SRP, the c'irrent staf fing levels were about 78 percent of projections at tim corporate of fice and 65 percent at the plant.
Therefore, a significant portion of ti;e people who will make up the organization were not available for the staf f to meet to determine quality, experience level, and attitudes.
Moreover, the staf f believes that as the applicant approaches Ifcensing and attempts to establish a functional operating organization to fulfill the many diverse requirements placed on the organization, further increpses in the size of the organization will be necessary.
This belief is based on past exp.'rlence and on comparisons of staf fing levels at other single-unit f acilities.
The staff will continue its review at a time closer to licensing when the operating organization i
has filled out and can be observed functioning in more areas.
The staff estimates this will be 6 to 9 mont.hs before fuel loid and will report its findings in a future supplement.
+
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s Clinton SER
'13-15 i
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AnAm u c cp _p An AMENDMRNT 29 MARCH 1984 NRC ACTION PLAN (NUPEG-0660 as clarified by NUREG-0737) 1.A.I.1 Shift Technical Advisor NRC Position Each licensee shall provide an on-shift technical advisor to the shift supervisor.
The shift technical advisor (STA) may serve more thgn one unit at a multiunit site if qualified to perform the advisor function for the various units.
The STA shall have a bachelor's degree or equivalent in a scientific or engineering discipline and have received specific training in the response and analysis of the plant for transients and accidents.
The STA shall also receive training in plant design and layout, including the capabilitities of instrumentation and controls in the control room.
The licensee shall assign normal duties to the STAS that pertain to the engineering aspects of assuring safe operations of the plant, including the review and evaluation of operating experience, CPS Response STA candidates for the Clinton Power Station will possess an engineering, engineering technology or physical science degree.
The STA program will vary slightly from the Institute of Nuclear Power Operations (INPO) guidelines due to the previous education of the candidates.
These variations are as follows:
l The B.S. degree in engineering, engineering technology a.
or' physical science will replace the education require-morts set forth in Section 6.1 of the INPO document,
" Recommendations for the Shift Technical Advisor",
April 1981, except for reactor theory.
Reactor theory training will consist of the operator fundamentals reactor theory section.
b.
The total hours for instruction in the noneducational topics of the INPO Guideline (Sections 6.2 through 6.8) will be a minimum of 520 hours rather than 600 hours.
See Section 13.2 for additional information on the STA training program.
D-3
 
ATTACHMENT D 13 CONDUCT Of OPERAi!0NS During the period May G to June 24, 1985, the staff reviewed FSAR Chapter 11 through Amendment 33 against the July 1981 version of the Standard Review plan (SRP) (HUREG-0800D The staff also met with a representative of Illinois f'ower Company ( the appli-cant) on June D arid 19, 1985, to clarify matters addressed in f5AR Chapter 13 Amendment 33.
The material that follows provides the'results of those meetings and reviews.
13.1 Organizational Structure of Applicant.
13.1.1 Management and Technical Suisport Organizations The corporate organization and lines of responsibility for managbment and tech-nical support of Clinton are shown on revi;ed figure 13.2 of this supplement.
The basic difference affecting Clinton between this support organization and the one accepted in the Clinton SER is the addition of three departments under the Vice President responsibic for nuclear _ projects.
A brief description of the new departments is provided below.
The Startup Department is r sponsible for preoperational and acceptance testing and for providing assistance to the Clinton plant manager for s tar; tup,tes ting.
The Nuclear Pla'nning and Support Department is directly responsible for Clinton budgets and accounting, schedule' coordination and integration, personnel (in-ciuding fitness for duty program), nuclear records, information and computer systems, procurement, and short-and long-term planning.
The Nuclear Training Department is respons.Thle for the development and'imple-mentation of the Clinton training program.
lhis program is intended to ensure safe and efficient operation of the station by developing and maintaining a plant staf f which is fully trained and qualified to safely operate, maintain and support the plant and technical aspects of Clinton.
In addition to adding these three new departments, modifications have also been made to the Nuclear Station Engineering Department (HSED). Ilowever, the overali responsibilities and reporting authority of this department remain essentially the same.
The Manager of the NSED is the designated " Engineer in Charge" de-scribed in Section 4.6.1 of ANSI /ANS Std. 3.1-1978.
1he flanager - NSED meets the qualifications for that position 1s described in ANSI /ANS Std. 3.1-1978.
'The applicant has described the organization for the management and technical support of the Clinton Power Station staf f during operation of the facility.
This organization has been reviewed and the staf f concludes that the applicant has an organization and staff acceptable to ".eet the requirements expressed in SRp Section 13.1.1.
Clinton SSER S 13-1
 
s 13.1.2 Operating Organization 13.1.2.1 Organization (1) Plant Operating Staf f The organization of Clinton is shown on revised Figure 13.3 of this supplement.
The applicant has modified the Clinton organization from that originally reviewed and reported in the Clinton SER.
The most significant change is the establish-ment of a separate organization for radiation protection.
A brief description of the radiation protection group responsibilities follows.
The Radiadon Protection Department is responsible for the planning and develop-ment of the operational. aspects of radiation protection and radiological moni-toring at Clinton.
The Supervisor of Radiation Protection reports to the Plant Manager of Clinton.
The applicant's current plant organization was reviewed against criteria expressed in the'SRP and was judged acceptable.
(2) Plant. Staff Levels and Qualifications The applicant has indicated the' current 1985' approved staffing levels are as shown below.
- Plant Manager's Office 12 Operations Department 148 Maintenance Department 147 Technical Department 44 Radiation Protection Department 43
~ Plant Services Department 31 Compliance and Configuration Control
_12 Total plant staff 43/
The applicant has stated that, as of April 1985, there were 70 open positions, based on the 1985 approved staffing levels.- None of these open positions were for required control room operators, assistant shift supervisors,'or shift supervisors.
The applicant is still planning to use five operating shift crews for normal operation The normal shif t complement will be as follows:
Shift Supervisor (SRO) 1 Asst. Shift Supervisor (SHO) 2 Control Room Operator (RO) 3 Unit Attendant 1
Auxiliary Operator 1
Radwaste Operator 1
Radiation Protection Techniciari 1
ShifL Technical Advisor 1
This shift complement may vary, but will not he less than the minimum specified in the Technical Specifications.
Clinton SSER 5 13-2 L _
 
s Except as noted in FSAR Chapter 1, the applicant has committed to meeting person-nel qualifications as stated in ANSI /ANS Std. 3.1-1978.
Two of the exceptions were discussed with the applicant's representative.
(1) The Supervisor of Chemistry shall possess qualifications as required by ANSI /ANS Std. 3.1-1981, not ANSI /ANS Std. 3.1-1978.
The requirements of ANSI /ANS Std. 3.1-1981 specify that individuals filling this position must have a bachelor's degree in chemistry, or related science, and 2 years of experience in chemistry, of which 1 year shall be nuclear power plant expe-rience in radiochemistry.
ANSI /ANS Std. 3.1-1978 does not require a degree, but does require 5 years of chemistry experience, of which 1 year shall be in radischemistry at an operating nuclear power plant.
The present indi-vidual incumbent in the Chemistry Supervisor position has a B. A. and M.S.
in chemistry, an M.S. In management, and 10 year's of chemistry experience, of which 2 have been at Clinton.
The applicant has committed to provide this individual specific nuclear training by an assignment in a chemistry section of an operating nuclear power plant for a period of 3 months (the plant must be above 20% power for at least 2 of these months), and the suc-cessful completion of the NSSS vendor chemistry and radiochemistry training i
program.
This training is to be in addition to the onsite experience at Clinton.
Since the Supervisor of Chemistry has only completed 2 months of the 3 months of training committed to, the applicant has agreed to retain an experienced consultant who meets the required qualifications of the Supervisor of Chemistry position to assist the current Supervisor of Chem-istry in the performance of his duties for 6 months after receipt of a lower power operating license.
The staff has reviewed the applicant's exception to the qualifications of the Chemistry Supervisor and judges that the individual possesses an adequate back-ground, which when augmented by the additional training committed to by the applicant, will make the exception acceptable.
Future assignments of individ-uals to the position of Supervisor of Chemistry will be reviewed and judged on a case-by-case basis.
(2) The qualifications required by ANSI /ANS Std. 3.1-1978 for the individual as-signed as Supervisor of the instrument and control (I&C) group includes 1 year of nuclear I&C experience at an operating nuclear plant.
The appli-cant has requested an exception for the 1 year of nuclear I&C experience at an operating nuclear plant for the Clinton Supervisor of Control and Instru-mentation.
The individual currently incumbent in this position has extensive electrical experience and specialized instrument and control. training.
The following examples were provided by the applicant to support the requested exception.
Training:
GE Process Instrumentation and Control Course GE Nuclear Instrumentation and Control Course GE Rod Control and Information Systems Course l
Electronics Circuits Course, Lewis and Clark Community College Experience:
Three years as journeyman level electrician at Olin Corporation af ter com-pleting required 4 year apprenticeship with 576 hours of classroom training Clinton SSER b 13-3 y-
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in ac/dc circuit theory, algebra, trigonometry, and advanced circuit anal-ysis, in addition to 8000 hours of on-the-job training on repair and main-tenance of motors, circuit breakers, transformers, and control circuits.
Five years as journeyman level electrician at a fossil fuel power station.
Performed trouble shooting and repair of electrical equipment, motors,
. breakers, control circuits and solid-state equipment.
Five years as control and instrumentation supervisor or assistant super-visor at Clinton.
Directed I&C technicians in the repair, calibration, and testing following repair of plant controls and instrumentation from the time"of installation at Clinton.
Supervised programs for:
calibra-tion of measuring and test equipment, the writing of all I&C maintenance procedures, spare parts determination, and preventive maintenance.
The staf f has reviewed the applicant's' request for exception and judges that the individual's experience and training is acceptable in lieu of the 1 year of experience at an operating plant.
(3) plant Operator Experience Dialogue with the industry was begun in late 1983:to find a way of ensuring that each operating shift at a newly licensed plant.had at least one senior operator with previous hot operating experience. On February 24, 1984, an Industry Working Group, representing. utilities with nuclear power plants under construction or ready for operation, presented a proposal to the staff on the amount of previous operating experience considered to be the minimum desirable on each shift and how that experience could be obtained.
On June 14, 1984, the staff accepted the industry proposal with certain clarifications.
Information regarding this action was forwarded to the industry as Generic Letter 84-16, dated June 27, 1984.
The objective is that, at the time of fuel load (or, at the latest, at least I week before initial criticality), each operating shift will have at least one senior operator with a minimum. of 6 months of hot partici-pation experience on a same type plant, including start 0p/ shutdown experience and at least 6 weeks above 20% power.
liot participation experience is defined as. direct involvement in review and discussions leadleg to decisions relative to operation of a commercial nuclear plant, or direct hands-on operation as a trainee at a commercial nuclear power plant.
For' prospective on-shif t SR0s at the Clinton Power Station, this includes:
on-shift duty as a licensed operator at a large commercial BWR direct hands-on operation as a licensed operator trainee on shif t at a large commercial-BWR direct involvement as an on-shif t observer in review and discussions at the licensed operator level at a large commercial BWR Information from.the applicant regarding the hot participation experience of license candidates is contained in FSAR Chapter 13 and in an'' applicant submittal dated May 10, 1985 (" Summary of Training and Experience of Operations for Clinton Power Station").
The May 10 submittal contains experience summaries for 64 license candidates, including five Shift Supervisors and 12 Assistant Two Shift Supervisors who will staff the on-shift senior operator positions.
Clinton SSER 5 13-4
 
of the Shift Supervisors currently satisfy Generic Letter 84-16 requirements based on previous licensed-operator experience at large commercial BWRs (Cooper and Brunswick).
In order to meet the guidelines of Genoric Letter 84-16 on all operating shift crews, the applicant has established a Supervisory Operating Plant Experience (50PE) program.,Under this pre: gram, selected supervisory personnel (including selected Shift Supervisors and Assistant Shift Supervisors) either have been or will be assigned to Commonwealth Edison Company's LaSalle plant for at least 6 months.
The Clinton personnal work on shift under the direction of LaSalle SR0s and become directly involved in reviews and discussions that lead to oper-ating decfslorfs.
Details of the 50PE program are contained in Nuclear Training Department Procedure 2.1, which outlines the objectives and overall conduct of the program.
The staff concludes that prospective Clinton SR0s who complete the 50PE program will also satisfy the requirements of Generic Letter 84-16.
To ensure that the applicant will have Senior Reactor Operators on shift who meet the generic guidelines for hot operating experience, the staff will condi-tion the license (license condition 17) as follows to require such experience until the applicant's operators have accumulated the requisite hot operating time on their own plant.
At the time of fuel load, the licensee shall have a licensed senior operator on each shif t who has had at least 6 months of hot operating experience on a same type plant, including at least 6 weeks at power levels greater than 20% of full power, and who has had BWR startup and shutdown experience.
This license condition shall be effective for a period of 1 year from fuel load or until the at.tainment of a nominal 100% power level, whichever occurs later.
13.2 Training Program The applicant's training program was found acceptable in.the SER.
: However, since the issuance of the SER, the training program has been further upgraded in revisions to the FSAR through Amendment 34, and in commitments provided by the applicant in a {{letter dated|date=October 29, 1985|text=letter dated October 29, 1985}}.
Following is the staff's l
evaluation of the modifications made to the training program since the SER was issued.
l 13.2.1 Licensed' Operators The SER stated that overall conduct and administration of the plant training pro-gram was the responsibility of the Plant Superintendent who reported directly to l
the Vice-President for plant operations.
By an amendment to FSAR Section 13.2.1, the applicant has reassigned this responsibility to the Director--Nuclear Train-ing, who also reports to the same Vice-President.
The staff finds this change conforms to the acceptance criteria as described in the Standard Review Plan, Section 13.1.1 (NUREG-0800) and is acceptable..
l To ensure that previous nuclear experience is credited properly in exempting an l
individual from.any section of the Reactor Fundamentals Course, the applicant i
has stated in the {{letter dated|date=October 29, 1985|text=October 29, 1985 letter}}, that no individual will be exempted I
from any section of this course without being tested.
This provision applies to IIcense applications submitted to the NRC af ter November 1,1985.
The appli-cant in the {{letter dated|date=October 29, 1985|text=October 29, 1985 letter}}, also committed to incorporate this change Clinton SSER 5 13-5 L..
 
_ = _.
'o 1
into FSAR Amendment 35.
The staff finds that this change conforms to the guidance given in Regulatory Guide 1.8 and is acceptable.
i 13.2.3 Replacement and Retraining To ensure continuity of operating experience, FSAR Section 13.2.2.1.3 has been revised to specify that-each licen' sed operator shall routinely (not to exceed 4 months) perform the duties required to maintain a valid license.
The appli-cant has indicated that, to be qualified to perform licensed duties and to main' tain a valid license, each licensed operator shall participate in licensed duties, as a minimum, one 8-hour shift per calendar month or spend 4 consecutive days on shif t (32 hours) and be considered fully qualified for the next 90 days.
i The applicant further indicated that within the next 30 days the operator will spend another 8 hours on shift'.
Either of these options would ensure that, as a minimum, each licensed operator will spend 3 days (24 hours) on shift per calendar quarter.
The staff finds that this change conforms to the requirements as described in 10 CFR 55.31(e) and is acceptable.
On the basis of its review of the revisions to the FSAR through Amendment 34, and commitments made by the applicant in the {{letter dated|date=October 29, 1985|text=October 29, 1985 letter}}, the staf f finds the appli~ cant's revisions to the training program acceptable.
~
13.3 Emergency Preparedness Evaluation t
13.3.2 Evaluation 13.3.2.8 Emergency Facilities and Equipment (NUREG-0737, Item III.A.1.2)
Supplement No. 4'to' the Clinton SER (SSER 4) stated that the applicant's emer-gency response facilities (ERFs) meet the requirements of the specific planning standard of 10 CFR 50.47(b), the requirements of 10 CFR 50, Appendix E, and the guidance criteria of NUREJ-0654 on an interim basis for licensing.
The staff further stated that the adequacy of the applicant's final ERFs will be confirmed in accordance with the requirements of NUREG-0737, Item III.A.1.2 (Supplement I of NUREG-0737), on a schedule to be developed between the applicant and the' NRC.
8y {{letter dated|date=May 29, 1985|text=letter dated May 29, 1985}}, the applicant requested that the NRC staff perform I'
the appraisal of the Clinton ERFs after fuel load.
The applicant also stated that.the specific date for this appraisal will be determined following the 2-week NRC emergency preparedness implementation appraisal scheduled for October 1985.
The staff has evaluated the applicant's request and finds it acpeptable.
How-ever, a license condition (license condition 18) associated with the NUREG-0737, Item III.A.1.2, will be required which states that the applicant shall commit to a date for completion of the Clinton ERFs that is acceptable to the staff.
13.4 Review and Audit The applicant has established an acceptable safety review and audit program.
The applicant has committed to implement this program in accordance with the Clinton Technical Specifications, Section 6.5.
I 1
Clinton 55fR 5 13-6
 
ATTACllMENT E Federal Register / Vol. So..No. 200 / htonday. October 28. 1985 /. Notices 43621 Reason for closing: The proposals being and what the industry and the NRC restewed includa information of a proprietary could do to prevent the recurrence of the. 33781) a Draft Policy Statement on Engineering Empertise on Shift to or confidential nature. Including technical same or a similar accident.These reassert the Commission's belief that
. Information; financial data, such a s salaries:
studies concluded, among other things, engineering and accident assessment vedu$tUse. ta$e that a number of actions should be wsch iha pr osals.
empertise must be available in the n
lhese matters are weihin enemptions (4) and taken to improve the ability ni shift nperating trew at all nuclear pnwer (6) of 5 U S C. 552b(r). Covernment in the Opernfing p*rsonnel lo ternanlrc.
plante.
Sunshine Act.
diagnose. and effectively deal with plant The Draft Policy Statement on Authority to close meeting This transiente or other abnormal conditions.
Engineering Empertise on Shift offercil determination was made by the Commisie.
To address these recommended ktanasement Officer pursuant to prowlsions improvements. the NRC initiated both licensees of nuclear power plants and of section 10(d) of Pub. L 92-463.The short term and long term efforts.The applicants for operating licenses two 1 satei th auibo" y to [e suj*
sh rt. term effort te utred that as of options for meeting the staffmg determinaisons by the Director. NSF. july 6-January 1,1980 eac : nuclear power requirements of 10 CFR 50 54lm)(2) and gg plant aave on duty a Shift Technical the requirement in NUREG-0737. Item 1.A 1.1 for a Shift Technical Advisor Ad s r (STA) whose function was to ht. Rebecca Winkler' Committee Afonagement Officer, provide engineering and accident (STA) Option 2 gave them the assessment advice to the Shift "E
"i'I '
"bi" 'h' I' '""d lFR Doc. 85-25642 Fded 10-25 85. a 45 arnj Supervisorin the event of abnormalor 8
1$n'ica$dviso STA) un ti ns.
anuno caos rsss-seas accident conditions.The STA was required to have a bachelor's degree in Under Option 1. licensees that did not want to combine the SRO and STA NUCLEAR REGULATORY pe f c training in p nt tes onse to COMMISSION transients and accidents. The STA 8PPr v program in accodance with the descr ption in NUREG-o737 Commission Policy Statement on
)s
..Clanfication of TMI Action Plan.
sees R
78 uly 79)
Engineering Espertise on Shilt NUREG-0737 (November 1980) and was 9"
AcaNcn Nuclear Regulatory later mandated by plant-specific Interested persons, applicants and licensees were invited to submit written Commission
* Confirmatory Orders.
ACTION: Policy Statement on Engineering Concurrently. the NRC and industry comments to the Secretary of the Expertise on Shift.
embarked on a longer. term effort aimed. Commission. Following consideration of at upgrading staffing levels and the..
the comments, the Commission.
amended the Draft Policy Statement as sussasant This Policy Statement training and qualifications of the presents the policy of the Nuclear operating staffs. improving the man.
discussed in the following sections.
Regulatory Commission (NRC) with machine interface, and increasing Comments on the Draft Policy Statement
~
respect to ensuring that adequate capabilities for responding to engineering and accident assessme'n emergencies. At the time the STA A totalof 34 responses were received expertise is possessed by the operating requirement was imposed. it was and evaluated.The pubtle comments staff at a nuclear power plant.This Intended that use of the dedicated STA related primarily to the combined SRO/
Policy Statement offers licensees two would be an interim measure only until STA position. The following discus sion options for providing engineering these longer term goals were achievid, highlights the major points raised in the expertise on shift and meetir.g licensed Thne long term initiatives comments and the resolution of those operator staffing requirements.
ccllectively result in an improvement in comments. A detailed analysis of all Option 1 provides for elimination of the capabilities and qualifications of the public comments and their resolution the separate Shift Technical Advisor shift crew and their abihty to diagnose was also prepared. (Copies of those (STA) position by allowing licensees to and respond to accidents. These letters and the detailed analysis of all combine one of the required Senior initiatives include shift staffing the public comments are available for Reactor Operator (SRO) positions with increases. training and qualiiira tion public inspection and copying for a fee the STA position into a dual role (SRO/
program improvements. hardware at the NRC Public Document Room at STA) position. Option 2 provides that a ' modifications. emphasis on human
'1717 61 Street NW, Washington. DCI l
licensee may continue to use an NRC, factors c nsiderations. procedural Of the 34 letters received. ta included approved STA program, with certain upgrades, and development of extensive support for the flexibihty provided by modsIications. while meeting licensed emergency response organizations to the Policy Statement. lhe major points operator staffing requirements.
augment on shift capabihiles during made in the public comments were us sFracTsve c. ATE: October 28.1985.
abnormal conditions.
follows:
FCR FU8 THEn leerOAedAhoes CONT ACT:
Draft Policy Statement
: 1. Support for the Policy Statement; Clara Goodman. Office of Nuclear On luly 25.1983, the Commission
: 2. Opposition to combining the Reactor Regulation. U.S. Nuclear published in the Federal Register (48 FR functi ns of the SRO and the STA:
l Regulatory Comrnission. Washington.
: 3. Opposition lo a bachelor's degree DC 20555. Telephone: 301/492-4694.
*Nupr.c seri,e,,perte end.ihe, doc.
ae.
requirement for the SHO/STA position:
suppuasamTAny swronas ATion:
**r'.''prias m a r 6a th. 'Na c rw''*'*.c p.c.**a' ac*d 'a 'h'
* aa"< * * ' * *
* 8' r** 'a 's *< "*a
: 4. Recommendation that equivaleni y
., c r
Back ground Pam. 8FU 88 5'rnt hw. wnhu 'an Dc. T he to a bachelor's degree be further a
tcporte mey t,e perchased ream she O S d'I8"'d*-
Fo!!owing the accident at ihree Mile c..eraaieat roni.as Ortu tuol t,y c.iiias 2021
: 5. Concern that a bachelor's degree Island in htarch 1979. a number of zwaum e, t,y =nhas she cru P O en 37042.
requirement for the SRO/STA position studiea were conducted to determine
* * 'Z'j$8 j,2[,3,"*,'M,*,','',,,
would result in a higher turnover rate why the accident occurred, what factora s.,.
. u a n.p.nm m er te==m.. sm e,,
and potentially bloded career palha fur might have contributed to its severity.
sept sud. spnaa.,td VA arm operators; and r
 
i 4'l623 Feder:I Regirl r / Vol. 50, No. Pon / hfoniiny. Orlober ?n. Ion'i / Notices
: c. Reference to a proposed beschclor's allow the individual to meet one of four was that rareer paths to the senior degree requirement for the Shift educational alternatives.
operating positions would be blocked Supervisor, believed to be currently under NRC consideration.
: 4. Recommendation that Equirolency to for those indisiduals without degrees. In A general description of the major a Bachelor's Degree Be fuither response. the Commission notes that public comments and responses to these Defm.ed-individuals may move to other pmitions within the utihty. Ilowever this can be sre as follows:
hfan commenters stated that the slewed as desirabic since it wouhl L Supporf for the /b!/cy Statement _
@a ency Ph na ""e t a restrictive increase the number of employees with or required clarificatiott. In response, th" valuntile operating en perience in other Eighteen commenters fasored ihe Commission notes that a bachelor's positions at the utility.
option offered in the Draft Policy degree in engineering is no longer e The only positions which may not 1,e Statement of combining the SRO and basic requirement but is one of four available for individuals without a STA functions into one dua!-role educational alternatives. The term degree would be the STA or the SRO/
position. They endorsed the flexibility
" equivalent" has been deleted?
STA position. The career path to other provided by the Policy Statemectahey Changes related to educational supported the view that it is beneficial alternatives are summarized below:
senior operating positions remains available' to cornbine engineering expertise with
* Most states require a bachelor's operating e mperiences degree in engineering and several yenra a Reference to a ProposedBache/or's
: 2. Opposition to the Dual-Role SRO/
of engineering exprrtence for an Degree Requirement for the Shift, STA Position-.
individual to sit for the Professional Supernsor-Engineer (PE) examination, A few states
-A few c mmenters n the rederal
--~~
Fourindividualcommenters stated still allow an individual without fortnal that there is a possibility that the person education but many years of practical Reg ster notice t k the opportunity to.,
comment n whether a bache!ur s
,A..
in the dual-rule position would function ' engineering experience and training to cs an additional operator in the event of sit for the examination. llowever, this.
degree should be required for specific an abnormal occurrence instead of being option is becoming available less often.
p sm ns in the opnaung staff of available to provide the engineering and ' llence, this alternative allows nucle 8r Power plants, and in partientar.,
eccident assessment expertise individuals who do not have a degree f r the Shift Supervisor,e position.
3,,
necessary in these circumstances. In but have successfully completed the PE The Final Policy Statement on response, the Commission notes it is the examination to meet one of the Engineering Expertise on Shift does t ut,,
intent of the Policy Statement that the educational alternatives of Option 1.
address the issue of requiring a degree person in the dual-role position have
. Other bechelor's degrees.
f r the Shift Supervisor. Early In 1938 specific training in accident assessment determined to be acceptable the staff considered a " Proposed. 4.o..c.
cnd provide that expertise during an '
alternatives are a bachelor's degree in Rulemalung Concerning Requirements i.
cbnormaloccurrence.The staffing levels - engineering technology from an for Senior Managers" in SECY-44-104,a This proposed rulemaking would have,. -
require'd by to CFR 50.54(m)(2). which accredited institution or a bachelor's became effective January 1.1984 degree in a physical science from an,
, required that an additional degreed..
SRO-licensed individual be assigned to.
increased the number of operatoes eml accredited institution. These degree -
Senior Operators on shift after the initial programs are acceptable provided that :.. each shift of a nudear power plant who would be responsible for mar.aaerint v STA position was required. This. ~/ 2 theyinclude course work in the increase in shift persennel would allow physical mathematicat or engineering '* '' direction of allplant fu,nctionsincludina.
the SRO/STA to provide both a ccident -
sciences. These requirements are chemistry, health phy sics. rnafntenanca....
assessment expertise and to analyse ' i intended to ensure that the individual-opera tions, security. and technical i.,.
cnd respond to off. normal occurrences'
* han substantial knowlddge and..
services.Following severalmeetings e >
-when needed. E.xperience has shown understanding of the physical and..
with the staff and industry v that an STA.whois also an SRO. is mothematical sciences and the" represcatatives the Ccmmission.
O concluded that this proposed rulemakins -
better accepted by the shift crew.
principles of engineering. i.
~
Derefore. the assessment and direction '
+ The Commission has deleted the was not warranted: therefore. lt was not t by an SRO/STA in an off-normal event educational alternatives thst allow for approved. One of the prirnary bases for might be better accepted by the crew successfulcompletion of the technical the proposed senior manager rule was
' than assessment and adFiCe by!a portion of an engineering deFre, -
' the need to provide engineering.,
program and the soccessful cumpletion expertise to the shift cisw.which is also separat e STA..
10pposition to a Boc'helor's begrre for. cf the Engineer-in-Training (ETT) the prima y objective of this pobey.
the SRO/STA lbsition-examination. ne Commission's Statement.
objective is to enhance engineering Deselopment of Final Policy Statmnent '3 Several commenters felt that the expertite on shift through mme stringent t person who filled the SRO/STA position educat;onal requirements for the As a rmfNf the analyMIpuW.,,
..in should not be required to hasa a individual fil!ing the dual. role positinn'.
c mments, the Commission clarified the
. educational afternatives of the dual role.
bachelor's degree.De Comrnission notes that since NUREG-0737. Irem '
* 1 C#"C'f' thef C U"Chelor'8 UFSfre -
(SRO/STAJ position. He revisinns to.,
~
I.A.1.1. specified that the STA should.
Requirement Would flesuls m o fligher the Draft Policy Statement resultrd in' '
have a bachelor's degree or the,,:
t TurnoverRafa and a lbtentiolly SECY-84-355, s' draft ihra! Itlley ' #,'
' (quivalent in a odentific or engineertng Blocked CareerIbf,hforShifi
.,.., Statement on Engineering Expestiston.as I
discipline the degree requirement is not ''' f*P #T"P#--
Shift.,,,in differenc, e, b, tween the, y.
De ma e
new. This corrtinues to be the ; e:8C Several commenters expressed "
e
.,,y sducational regoirement for a dedicated.i concern that degreed individuals would Draft Poffey Statement and SECY 84,,
7 STA. flowever, the educational..' '
leave for other posilions in the plant i. 2 355 concerned the educations!
e The DraIt it! Icy Statement required pd.
requirements for the dual.rofe (SRO/ i -. contributing to a high tarnover rate on qualifications for the' dual role positi STA) position have been changed to s 9 shift. Another ccmcerrr of commenters of
 
~
Federal Register / Vol.:50. No.208.hMonday October 28. 1965 :/ Notices.
..- 43823 person lilling the dual role position x individual have both an SRO licana and a
,a.Ucensed as a senior operatoren the o baccalaureate degree in engineering or BS degru in engineering or related science or nuclear power unit (s) to which assigned, lelaled sciences or one of three -
have passed the PE examinadan prior to.
and equivalents to the degree. SECY-84-355, g'l, 3,8 fd nYt
: b. Mate the'STA Mning criterie of ?
o nr ce in cad m c..
required a bachelor's degree in
,a credentials.Strinkinety absent from the,.-
NUREG-0737 Item I.A.1.1.and one of s Engmeering from an accredited -
a the following educational alternatives: 1 policy are the spoofic skdle or abit hes.
institution or one of five acceptable needed to perfonn hee duties.Thus, the. r (1) Bachelor's degree la engineeritig citernatives to the engmeenng degre,el.
~*
Commission has postponed the question of from an accredited institution; -
The staff met with the Commissioners what those skala should be and how they 4)Prdfessidal Engineer *a license.
on November 5,1984, to discuss SECY-should or could be achiev' d and
- obtained by the succe,ssfu1 campIetion of e
84-355. As a result of that meeting the~
demonstrated.1his leaves me no choice but Commissioners directed the staff to to vote against the modifications proposed to the PE examinatwn;;
the policy Statement on Engineering -
(3) Bachelor's degree in engineering coordinate the Policy Statement on 1.
Engineering Expertise on Shift with the 5 Expertise on Shift.By'elirainatir. attematives technology from an accredited -.. !
i to a bachelor's degree for individuals who institution, including course work in the; Nuclear Utilities Management and
~
**"'d *'h''"l8e occupy the dual role. the physical mathematical,or engineering.
Ifuman Resources Committee (NUMARC). Another draft Final Policy, Commimon would be igenna h '
sciences; or -
c..,,...
,'j"[.,,lr", p,po
[,*,
(4) Bachelor's degree in a physical
[
Statement. SECY-85-150, was the result.
..s cf the Commissioners' direction, staff science from an accredited institution.
flexibit ty. We would be trnposing our...,.
cnalysis. resolution to public comments.
solution without addressing the benefits ht including course work in the physical.
cnd staff coordination with NUMARC. -
will be eliminated by not allowing fleubihty.
mathematical, or engineering sciences.
The majority of the Commission !
This leaves the utihties with little mcentive to cpproved a version of the Policy.
change from W current position which is Optio.n 2: Contin.ued Use o/STA ~ ".
Statement in SECY-85-150 with changes allowed by Option 2. Since e maienty of h Position in the educational alternatives....
Comminion hu alrudy determined that
%Is option is satisflAd by ple'cing on l$pmmnent from the curnat pmgram would Furthermore, the Commission has a
deleted an item from SECY-85-150,.
be desirable, the Commission should provide each shift a dedicated Shift Technical Advisor (STA) who meets the STA -
' which allowed for college-level training - ",* ",'j,'f'$'*,"y,*,'d ment, eg.
criteria of NUREG-W37. Item I.A.1.b.,"
~'
p instead of formal college education for '
modified. does not provide that mechanism.
The STA should auume an active role.:
the dual-role position. ne objective of ;
and we pmvide no lustifiestion for overriding in shift activities. For example, the STA,
the Commission is to enhance..
J h stafra evaluation of h benefits et h should review plant logs, participate in sngineering expertise on shift through flexibihty would bnns.
shift turnover activities, and maintain an more stringent educational requirements awareness of plant configuration and for the individualidling the SRO/STA., Pgcy Sta,e nent position. The educational alternatives in The Commission continues to stress 1.icensee proposals different then the this Fir q Policy Statement require a the importance of providing engineering two options described above will be bachehe s degree in engmeenna.
and accident assessment expertise on considered by the staff on a case-by. '
engineesing technology, or physical shift. In this Policy Statement.
* accident case basis. To eliminate the STA science from an accredited institution, assessment " means immediate actions position, a licensee of an operating or a PE bcense ootained through needed to be taken while an event is in reactor should apply for a modificadon successful completion of the PE progress.This policy Statement does not to its license and an applicant for an,
require any changes in the formal Y
operating license should modify its Final 1 a thou8h this Final Polic i
Statement includes an option whig -
education and training of operators and. Safety Analysis Report to reflect.
Senior Operators not expected to fill the elimination of the STA position and a
" " ' f the STA
,, 'id dual-role SRO/STA position.
commitment to provide a required SRO p
Dra Policy Statement, the former encourages The intent of this pohcy guidance may on shift with the quahfications licensees to work towards havmg the be satisfied by either of the options described in Option s above.
STA assume an active role in shift described below.The Commission,
NRC will accept a utdity's cctivities.
prefers a combmed SRO/STA position modifications ifit finds that the proposal While it is the Commission's (Opuon 1). In addition. in the long term, meets the intent of this Policy.
~
preference that licensees move toward the Commission would prefer that the Statement. NRC will review, on a case-the dual. role ISRO/STA) position.
STA be combbed with the Shift brease basis. multi <anit sites with dual.
l continuation of an approved STA Supervisor in the dual role position.
licensed SROs to ensure that an program remains an acceptable option.
Either Option 1 or Option 2 may be adequate number cflicensed staff are The Commission acknowledges that used on each shift. A utility may use available an.d that engineenng expertise some licensees may prefer the dedicated Option 1 on some shifts and Option 2 on can be provided when needed. It is the STA position for a number of reasons.
other shifts, or may use the same option intent of this Policy Statement to ensure The Commission also recognizes the on every shift. If Option 1 is used for a J that engineering and accident cdvantages of integrating the shift then the separate STA position assessment expertise is possessed by qualificaliunis and training of the STA may be ehrnineted for that shift.
the i ant og'erating staff.
d luto the licensed operating stall.
Option I: Comb /nedSRO/STA Position Dated et washinston. DC. on this 22 day of
.he separate views of Commissioner october. teess Thomas M Roberts on this Policy This option is satisfaed by assigning yo, gg
%g, Statement follow; an individual with the followmg i em in agreement with the malvrity's qual:Gcadone Io eads operating shift Samuel l. Chills, ineent that operators should be well tremed crew as one of the SROs (preferably the Secretary o/Commissen.
end quhfied to perfonn their duties.
Shift Supervisor) required by 10 CFR lF R Doc.85-25649 Fded 10-25-45,8.45 aml t lowever. shes puhcy, by requinds that an 50 54(mj(2)(i):
se.u o coos resems L
-}}

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