ML20042E733
| ML20042E733 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/27/1990 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20042E732 | List: |
| References | |
| NUDOCS 9005030016 | |
| Download: ML20042E733 (13) | |
Text
. DocketNumb$r50-346 .di License Number NPF-3 Serial. Number 1669 Enclosure
-. Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING' LICENSE NUMBER HPF-3 FOR
. DAVIS-BESSE NUCLEAR POWER STATION UNIT FUMBER L Attached are requested changes tc the Davis-Besse Nuclear Pover Station, Unit Number 1, Facility Operating License Number NPT-3. Also included.are.the Safety Evaluation and Significant Hazards Consideration,.
The proposed changes (submitted under cover letter Serial Number 1669)-
concern:
Deletion of the March 5,1980 Order from the Davis-Besse Nuclehr:Pover Statf or.
Facility Operating License Number NPF-3.
For: D. C. Shelton Vice Pres /fent Nuclear By:
T.
!h7 fers, Technical Services Director Sworn and subscribed Lefore me this 27th day of April, 1990.
boo $in) b 12A Notary fdblic, State ot Ohio EVELYM L DRESS NOTARf PUBUC, STATE OFOMO 15 90042 My Ort: 2,n6.pkr.sMy28.24 f,((0{DbCK0500g'7 6 P
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. Docket Number 50-346 License Number-NPF-3 Serial Number 1669 Enclosure
. Page 2 The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit Number 1, Facility Operating License Number NPF-3.
A. Time Required to Implement: This change vill be implemented within 45 days following NRC issuance of the License Amendment.~
B. Reason for Change (DCR Number 88-0123): Delete the March 5, 1980 Order from the Davis-Besse Facility Operating License.
C. Safety Evaluation: See attached Safety Evaluation (Attachment 1).
D. Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment 2). ;
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"?)N Fyjgggj.7 y.g
.' Docket Nu;ber 50-346
. Licens) Nu;b2r NPF-3
. Serial Number 1669 Attachment 1
- Page 1 SAFETY EVALUATION TITLE Delete the Mare.h 5, 1980 Order from the Davis-Besse Facility Operating License DESCRIPTION OF THE PROPOSED ACTIVITY The purpose of this Safety Evaluation is to review a proposed change to the 7 ~
Davis-Besse Nuclear Power Station, Unit Number 1, Operating License. The' i
proposed change involves the deletion cf the NRC's March 5, 1980 order from the License which added additional training and experience requirements to the Davis-Besse Nuclear Power Station, Unit Number 1, Facility Operating License Number NPF-3.
On March 5, 1980 (Log Number 530), the NRC issued an Order which modified the Davir:-Besse Nuclear Power Station, Unit Number 1, Facility Operating License Number NPF-3 (Attachment A). Toledo Edison responded on.Maren_28, 1980 (Serial Number 1-123) setting forth the intended method of complying with the Order, and proposed the following:
- 1. Meeting the December 6, 1979 draft version of. ANSI 3.1, Standard for Qualification and Training of Personnel for Nuclear Power Plants, including the revised pages as of December 21,-1979, which was exchanged L at a February 29, 1980 meeting between the NRC and Toledo Edison '
6 representatives.
- 2. Defining the complete complement for each operating. shift and the operating shift staffing levels as that identified in Technical-Specification Table 6.2-1, Minimum Shift Crew composition.
- 3. Meeting qualification and training levels identified in the following sections of the draft ANSI Standard 3.1 for those individuals identified in 2 above
- a. Senior Operating License - Section 4.1 and 4.3.1.2.a, b and c.
- b. Operating License - Section 4.1 and 4.5.1.2.a, b.and c.
- c. Non-Licensed - Section 4.1 and 4.5.1.1.a, b, e and d.
where Section 4.1, General Qualifications, outlines the education, experience, health and skill requirements for nuclear power plant .
personnel commensurate with their functional level of responsibility- '
to provide reasonable assurance that decisions and actions during normal and abnormal conditions would.be such that the plant would be operated in a safe and efficient manner.
Section 4.i.'.2.a, b and e outlines the education, experience and training requirements for Senior Operators. j
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. Docket'Nurbst 50-346
_ License Number NPF-3
.. Serial Number 1669 Attachment 1
.. Page 2 Section 4.5.1.2.a, b and c outlines the education, experience and training requirements for Licensed Operators.
Section 4.5.1.1.a. b, e and d outlines the education, experience, training and qualification requirements for Non-Licensed Operators.
On June 113 1980, the NRC (Leg Number 1-386) responded and said that the proposed method of compliance with the Order was acceptable, noting the following clarification:
In meeting Section 5.2.1.8 of ANSI 3.1, training in supervisory skills vill be provided to new Senior-Licensed Operators subsequent to the'.r obtaining a Senior Reactor Operator License, but within six months after they are ass!gned shift duties as a Senior _ Reactor Operator.
On March 25, 1987, the final rule to 10 CFR Part 55 was published in the Federal Register (52 FR 9453 - 9469), with an effective date of May 26, 1987.
The NRO amendui its regulations tot 1) clarify.the re:c stions-for_ issuing-licenses to Operators and Senior Operators; 2) revise the requirements and scope of written examinations and operating tests for Operators and Senior Operators, including a requirement for a simulation, facility;-3) codify procedures for administering requalification exar.inationsl and 4) ancr be the i
form and centent for operator license applications. From April ( :a April 12 0, a series of_public meetings were held to discuss implementation er tbc requirements of this final rule, associated Regulatory Guides, ano Lxaminer Standards. At each meeting, a formal presentation by the staff was followed by an open forum in which the staff responded to questions. Announcements were made at each meeting that the questions and ansvers from the meetings vould be consolidated into a NUREG and disseminated-to interested parties. On November 12, 1987, the NRC issued Generic Letter 87-16, Transmittal of NUREG-1262, " Answers to Questions at Public Meetings Regarding Implementation of Title 10, code of Federal Regulations, Part 55 on Operators' Licenses".
Regulatory Guide 1.8, Revision 2, Qualification of Personnel for Nuclear Power Plants, was part of the rulemaking package and was effective for all facilities on March 31, 1988. Regulatory Guide 1.8 endorses ANSI /ANS 3.1, 1981, Selection, Qualification and Training of Personnel for Nuclear Power Plants, for the positions of Shift Supervisor, Senior Operator, Licensed Operator, and Shift Technical Advisor. Generic Letter 87-16, announcing the issuance of NUREG-1262, further endorsed that Regulatory Guide 1.8 vent into effect for all facilities on March 31, 1988, and specifically discussed the acceptability of the training program if it is accredited by Institute of Nuclear Power Operations (INFO). In addition, NUREG-1262 concluded that "in review of INP0 accreditation criteria, the staff has concluded that they are-equivalent to the NRC's. If a utility implements an accredited training-program, the accreditation vill constitute the basis for NRC acceptance of that certification from a responsible utility officer, as' indicated in Generic Letter 87-07".
Generic Letter 87-07, dated March 19, 1987, discussed the option of substituting an accredited training program for the initial and' requalification training programs previously approved by the NRC, stating that
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.' ' Dock 3t Nu:ber 50-346 Lic:ns2 Nurber NPF-3 Serial Number 1669 Attachment 1
. Page 3 this option may be implemented upon written notification to the NRC and does not require staff-review. This is consistent with Generic Letter 87-16 announcing the issuance of NUREG-1262, 10 CFR 55.31 and 10 CFR 55.59.
On March 20, 1985,- the NRC issued the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147). This policy statement endorsed the training accreditation program managed by INPO-in that it encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the performance- requirements of their jobs. The accreditation process, as described in the INPO training guidelines, contains qualification criteria for entering into training as it related to each position. ;
On December 11, 1986, the Fational Academy for Nuclear Training granted ;
accreditation for the Davis-Besse Nuclear Power Station Operator Training i Programs. Consequently, on March 29, 1988,- Toledo Edison submitted a letter to the NRC (Serial Number 1502) certifying that the Davis-Desse Nuclear Power Station, Unit Number 1, Operator Training Programs were accredited by INPO and that Toledo Edison has substituted.the training programs, which are !
accredited, and-utilize a systems approach to training, for both the initial and requalification training programs previously approved by the NRC.
Therefore, Toledo Edison has opted to use the INP0 accredited Operator Training Programs that use a systems approach to training acceptable to the
'IRC, and the staff has concluded that the INPO accreditation criteria for both training and experience are equivalent to the NRC's. This-is consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07. The Toledo Edison Operator Training Programs meet the requirements of 10 CFR 55.
REFERENCES z .
Log Number 530, dated March 5, 1980, NRC Order modifying License (Attachment A).
i Serial Number 1-123, dated March 28, 1980, discussing Toledo Edison's method '
of compliance with the Order.
Log Number 1-352, dated April 16, 1980, discussing NRC receipt of Serial 1-123 j and the need for more NRC review time. !
Log Number 1-386, dated June 11, 1980, discussing NRC acceptance of Toledo Edison's method of compliance, noting one clarification.
Serial Number 1399, dated October 16, 1967, License Amendment Application to i revise Appendix A Technical Specification requirements for Control Room Staffing.
Serial Number 1447, dated November 20, 1987, Editorial change to License Amendment Application on Control Room Staffing, i Serial Number 1502, dated March 29, 1988, discussing the accreditation of the Davis-Bessa Operator Training Programs.
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Docket Number 50-346 Licensa Number NPF-3
. Serial Number 1669 Attachment 1
. Page 4 Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, dated March 20, 1985, (50 FR 11147).
Technical Specification Tatle 6.2-1, Minimum Shift Crew Composition.
Inspection Report Number 50-346/80-09, dated April 21, 1980, (Log Number 1-347).
Inspection Report Number 50-346/81-87, dated June 5, 1981, (Log Number 1-515).
SYSTEMS AND COMPONENTS AFFECTED None SAFETY FUNCTIONS AFFECTED None EFFECTS ON SAFETY On March 5, 1980, the NRC issued to the Toledo Edison Company an Order modifying the Davis-Besse Nuclear Power Station, Unit Number 1, Facility Operating License Number NPF-3 (Attachment'A). This Order was the result of a series of management meetings initiated by Region III to address the licensee's enforcement history, number of personnel errors, breakdown in management control, equipment problems and lack of management's effectiveness in dealing with identified problems. The NRC reviewed and verified. Toledo Edison's compliance with the Order in Inspection Report Numbers 50-346/80-09, dated April 21, 1980 (Log Number 1-347) and 50-346/81-87, dated June 5, 1981 (Log Number 1-515). Since that time, Toledo Edison has made a number of changes and has achieved accreditation of the Operator Training Programs.
Therefore, because the Toledo Edison Operator Training Programs are accredited, use a systems approach to training acceptable to-the NRC, and meet 10 CFR Part 55, Toledo Edison proposes the deletion of the March 5, 1980 Order from the License. This is consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07.
Each item of the order is discussed below:
Item 1 a) of the March 5, 1980 Order required Toledo Edison to return six experienced and fully qualified Equipment Operators (who had been involved in operator license training) to regular shift work to provide two fully qualified Equipment Operators for each operating shift. The additional qualified individuals were required to remain on shift duty until such time as they were relieved from duty by other fully qualified individuals who were appropriately trained and certified by the training department; Technical Specifice ;on T - , . .s , F um Shift Crew Composition, requires i two Non-Licensed Operator- a a sh;? in Modes 1 through 4 and one Non-Licensed Operato. to + F' ! -Todes 5 and 6. Administrative Procedure DB-0P-00000, Cou.uet m. .+w.s. cions, Section 6.4.1, requires that two <
qualified EO-III's (fully qualified Equipment Operators) or higher (or
m Docket Number 50-346 Licenas Nusbar NPF-3 Serial Number 1669 Attachment 1
.Page 5 certified as qualified on safety systems) be on shift in Modes 1 through 4.
In addition, the Operator Training Programs are accredited by INPO and use a systems approach to training. This ensures that personnel are sufficiently trained and fully qualified before placing them on shift. Therefore, because Technical Specification requirements and procedural requirements ensure that two fully qualified Equipment Operators are assigned to esch shift in Modes 1 through 4, and that one fully qualified Equipment Operator is assigned to each shift in Modes 5 and 6, Toledo Edison prcposes deleting item 1 a) of the March 5, 1980 Order.
Item 1 b)-of the March 5, 1980 Order requires Toledo Edison to provide one additional person for each day shift to relieve the Shift Foreman (Shift' !
. Supervisor) of non-licensed administrative responsibilities.
Administrative Procedure DB-0P-00000, Conduct of Operations, Section 6.4.6, l requires that a Shift Supervisor Administrative Assistant (SSAA) be assigned, on day shift, seven days a week, to assist the Shift Supervisor in handling certain administrative duties and paper work. DB-0P-00000 also requires that an additional Senior Reactor Operator (the Assistant Shift Supervisor) be on ,
shift in Modes 1 through 4 thereby minimizing the administrative duties of'the '
Shift Supervisor. Toledo Edison submitted a License Amendment Application Serial Number 1399, dated October 16, 1987, and Serial Number 1447, dated November 20, 1987, to the NRC requesting that Technical Specification Table 6.2-1 be revised to reflect 10 CFR 50.54(m) and to be consistent with DC-0P-00000, requiring that two Senior Reactor Operators be on shift in Modes 1 through 4. Therefore, because procedural requirements ensure a SSAA is assigned to each day shift, seven days a week, to relieve the Shift Supervisor of non-licensed administrative responsibilities, and two Senior Reactor Operators are on shift in Modes 1 through 4, Toledo Edison proposes deleting item i b) of the March 5, 1980 Order.
Item 1 c) of the March 5, 1980 Order requires Toledo Edison to expedite the on-the-job training schedule for existing Equipment Operators who are not yet .;
fully qualified. '
Technical Specification Table 6.2-1 and DB-0P-00000 ensure a qualified minimum shift crew composition. In addition, the Operator Training Programs are 1 accredited by INP0 and use a systems approach to training acceptable to the NRC, further ensuring that personnel vill be sufficiently trained and fully i
qualified before placing them on shift. Therefore, Toledo Edison proposes deleting Item 1 c) of the March 5, 1980 Order.
Item 2 of the March 5, 1980 Order requires Toledo Edison te man each operating shift with a complete complement of fully qualified personnel in accordance with the affing and qualification levels set furth in draft ANSI 3.1, prior to retuu. ig the station to operation from the scheduled April 1980 refueling outage.
The Toledo Edison Operator Training Programs meet the requirements of 10 CFR i Part 55, and Toledo Edison has an INP0 accredited Operator Training Program that uses a systems approach to training acceptable to the NRC, and the NRC ]
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. Dockst Nu2btr 50-346 ;
Lic:ns2 Nurbar NPF-3 ,
. Serial Number 1669 ,
Attachment 1
& Page 6 has concluded that INPO accreditation criteria are equivalent to the NRC's criteria. This is consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07. Therefore, Toledo Edison proposes deleting Item 2 of the March 5, 1980 Order.
DISCUSSION OF UNREVIEVED SAFETY OUESTION The proposed change involves the deletion of the March 5, 1980 Order from the License because the Davis-Besse Operator Training Programs meet the requirements of 10 CFR Part 55, are accredited by INPO, and use a systems approach to training acceptable to the NRC.- Therefore, the implementation of these changes would:
Not increase the probability of occurrence of an accident previously evaluated in.the USAR because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55. Additionally, Toledo Edison received INP0 i accreditation for the Davis-Besse Operator Training Programs on December 11, 1986. The NRC staff has concluded that INPO accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endorses the INP0-managed Training Accreditation Program ?n that it encompacses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-3262, and Generic Lotter 87-07.
Not increase the consequences of an accident previously evaluated in the USAR because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55. Additionally, Toledo Edison received INPO accreditation for the Davis-Besse Operator Training Programs on December 11, 1986. The NRC Staff has concluded that INP0 accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement -on Training and Qualificatio.7 of Nuclear Power Plant Personnel, the NRC endorses the INP0-managed Training Accreditation Program in that is encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs.'
This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07.
Not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the USAR because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55.
Additionally, Toledo Edisom received INPC accreditation for the Davis-Besse Operator Training Programs on December 11,.1986. The NRC Staff has concluded that INP0 accreditation criteria are equivalent.to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power-Plant Personnel, the NRC endorses the INP0-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the bases to ensure that personnel have qualificatiens commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 annciuncing the issuance of NUREG-1262, and Generic Letter 87-07.
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Docket Number 50-346 Licensa Nuabar NPP-3 J Serial Number 1669 Attachment 1
, Page 7 Not increase the consequences-of a malfunction of equipment important to safety previously evaluated in the USAR'because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55.. Additionally, Toledo Edison received INPO accreditation for the Davis-Besse Operator Training Programs on' December 11, 1986. The NRC Staff has concluded that INPO accreditation criteria are equivalent to the .RC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endurses the INPD-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs. This is also consistent with 10 CPR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07.
Not create the possibility for~an accide/t of a different type than any evaluated previously in the USAR because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55. Additionally, Toledo Edison received INP0 accreditation for the Davis-Besse-Operator Training Programs on Dpcember 11, 1986. The NRC Staff has concluded that INPO accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endorses the INPO-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07.
Not create the possibility for a malfunctior. of a different type than any evaluated in the USAR because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55. Additionally, Toledo Edison received INPO accreditation for the Davis-Besse Operator Training Programs on December 11, 1986. ' The NRC Staff has concluded that INP0 accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endorses the INPO-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with=the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, nnd Generic Letter 87-07.
Not reduce the margin of safety as defined in the basis for any Technical Specification because the Toledo Edison Operator Training Programs meet the requirements of 10 CFR Part 55 for ensuring adequate training. Additionally, Toledo Edison received INPO accreditation for the Davis-Besse Operator Training Programs on December 11, 1986. The NRC Staff has concluded.that INPO accreditation criteria are equivalent to the NRC's. In the Commission. Policy Statement on Training and Qualification'of Nuclear Power Plant Personnel, the NRC endorses the INP0-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the basis to ensure that personnel have qualifications commensurate with the
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Docket Number 50-346 4 License Number.NPF-3
. Serial Number 1669 Attachment 1 4 Page 8 perforu nce requirements of thej ' jobs. This is also consistent with 10 CFR 55.31, b5.59, Generic Letter _87-16 announcing the_ issuance of NUREG-1262, and Generic Letter 87-07.
CONCLUSION Based on the above, it ic concluded that the proposed Operating License-change does not constitute an unreviewed-safety question.
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. Docket Number 50 346 Licenza Number NPF-3 Serial Number 1669 Attachment 2
. Page 1 SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF THE PROPOSED ACTIVITY The purpose of this Significant Hazards Consideration is to review a proposed change to the Davis-Besse Nuclear Power Station, Unit Number 1,. Operating License. The proposed change involves the deletion of the NRC's March 5, 1980 Order from the License which added additional training and experience requirements to the Davis-Besse Nuclear Power Station, Unit Number 1, Facility _
Operating License Number NPF-3.
The discussion below-provides the Significant Hazards Consideration for the change as proposed in the Safety Evaluation (Attachment 1).
SIGNIFICANT HAZARDS CONSIDERATION The Nuclear Regulatory Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazard exists. . A proposed amendment to an Operating License for a facility involves no significant hazards if'operaticn of the facility in accordance with the proposed amendment vouldt 1) Not involve a significant increase in the probability or consequentes of an accident previously evaluated; 2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) Not involve a s.'gnificant reduction in a margin of safety.
Toledo Edison has reviewed the proposed changes as discussed in the Safety Evaluation and determined that a significant hazard does not exist because operation of the Davis-Besse Nuclear Power Station, Unit Number 1 in accordance with this change vould:
Not significantly increase the probability or corsequences of e:. ac ' '
previously evaluated in the USAR because the Toledo Edison Operator ,
ing Progo as meet the requirements of 10 CFR Part 55. Additionally, Tole 6e ;dison received INPO accreditation for the Davis-Besse Operator Training Programs on December 11, 1986. The NRC staff has concluded-that-INP0 accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endorses the INP0-managed Training Accreditation Program in that it encompasses the elements of performance-based training and vill provide the. basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREC.1262, and Generic Letter 87-07.
Not create the possibility of a new or different kind of accident from any previously evaluated because the Toledo Edison Operator Training Programs meet
, the requirements of 10 CFR Part 55. Additionally, Toledo Edison received INP0 accreditation for the Davis-Berre Operator Training Programs on December 11, 1986. The NRC Staff han concluded that INPO accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the NRC endorses the 1 -- .
o Docket Nuzber 50-346
. License Numbar NPF-3
. Serial Number 1669 :
Attachment 2
. Page 2 4
INPO-managed Training Accreditation Program in that is encompasses the eierents of performance-based training and vill provide the basis to ensure that persor.nel have qualifications commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic Letter 87-07.
Not significantly reduce the margin of safety as defined in the basis for any Technical Specitication because the Toledo Edison Operator Training Programs meet the requirsments of 10 CFR Part 55 for ensuring adequate training.
' Additionally, Toledo Edison received INPO accreditation for the Davis-Besse Operator Training-Programs on December 11,-1986. The NRC Staff has concluded that INPO accreditation criteria are equivalent to the NRC's. In the Commission Policy Statement on Training and Qualification of Nuclear Power Plants Personnel, the NRC endorses the INPD-managed Training Accreditation Program Ja that it encompasses the elements of performance-based training and will proside r the basis to ensure that personnel have qualifications
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commensurate with the performance requirements of their jobs. This is also consistent with 10 CFR 55.31, 55.59, Generic Letter 87-16 announcing the issuance of NUREG-1262, and Generic-Letter 87-07, t CONCLUSION Based on the above, Toledo Edison has determined that the proposed Operating License change does not involve a significant hazard.
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m Dockst Nu b:r 50-346-
, License Number NPF-3 Serial Number 1669
.. Attachment A MARCH 5, 1980 ORDER DAVIS-BESSE FACILITY OPERATING LICENSE TRAINING AND E'XPERIENCE REQUIREMENTS
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- UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION
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/ MAR 0 51930 Docket No. 50-346 Toledo Edison Company ATTN: Mr. W. A. Johnson President Edison Plaza 300 Madison Avenue Toledo, OH '43652 Gentlemen:
Enclosed is an order modifying your license effective immediately.
Sincerely, f (,
4 ctor tello Jr Director-Office of Inspection and-Enforcement CERTIFIED MA!'.
RETURN RECEIPf REQUtSTED r
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. q_.e 4 7 n G S35 i UNITED STATES OF~ AMERICA '
- NUCLEAR REGULATORY COMMISSION 1
In the Matter of ) =.
) I Docket No. 50-346 :
THE TOLEDO EDIS0N COMPANY AND )
THE CLEVELAND ELECTRIC ILLUMINATING - )
COMPANY )
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l Davis-Besse Nuclear Power Station, ) .
Unit No. 1. ) ,
4 ORDER MODIFYING LICENSE
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EFFECTIVE _IMMEDIATELY I ,
1 The Toledo Edison Company and the Cleveland Electric Illuminating Company are holders of Facility Operating License No. ' NPF-3 which authorizes the operation of the Davis-Besse Nuclear Power Station, Unit'No.1 (the facility <
' or Davis-Besse 1), at steady state. power levels not- in excess of 2772 megawatts thermal (rated power). The Toledo Edison Company is the lead licensee, (the licor.see). The facility is a Babcock & Wilcox (8&W) designed pressurized water -
reactor (PWR) located at the licensee's site in Ottawa County, Ohio.
II I
Davis-Besse Unit No. I was the first nuclear power reactor built and operated by the licensee. The facility, which began commercial operation November 21, 1977, experienced a higher than normal number of operating events during early operation and testing. Many of these events were caused by personnel errors and procedural deficiencies. A meeting with h '
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2-6 licensee t 'rporate management was held during August 1978 in which the operating staff weasacsses were noted along with the related problem of untimely evaluation and resolution of_ facility change requests.
III The facility, being of B&W design, has undergone a significant number of pro-cedural, equipment and operational changes as a result of lessons learned from the investigation af the Three Mile Island accident which occurred on Marchf 28, 1979. An order issued to the licensee on May 16, 1979 and several NRC Bulletins have required majcr additional effort on the licensee's corporate and plant staffs.
IV A series of management meetings was initiated by Region III to address the licensee's enforcement history, number of personnel errors, breakdown in management controls, equipment problems and lack of management's effectiveness in dealing with identified problems. The primary thrust of_ the first meeting ,
in this series held on April 14, 1979, was to address the need for immediate action by the licensee to improve management con'trols and plant operations. In the second meeting held on May 31, 1979, the licensee presented a program, based upon its assessment of problem areas, to improve the level of management control, staffing, training, the correction of equipment problems and plant operations. ,
During meetings held on July 17 and September 19, 1979, the_ licensee presented i
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s schedules and progress renorts on their program for corrective ection. At the September 19, 1979, meeting, it appeared that licensee management had made progress in its control of licensed activities. Personnel errors-were declining and organizational changes were underway.
V A recent evaluation of the licensee's operation shows that the staffing, while improved, is not yet at the desired level. Timely resolution of problems is M still a matter of concern. The changes required by the TMI investigations and
!ated studies and bulletins continue to place an additional burden on the coprating st.cff causing extended use of overtime.
During the week. of February 18, 1980, the Resident Inspector, upon direct questioning of plant oporators, was told by one operator that staffing problems were so significant that the plant was unsafe to operate. On February 25, 1980, the Director, Region III, and the Director, Division of Reactor Operations Inspection, IE, interviewed several plant. workers including senior licensed operators, licensed operators and nonlicensed personnel. Perceived problems of excessive work hours and inadequate training were identified during these inter-views. Some of those interviewed, including two senior licensed operators stated their view that some shifts did not have adequately qualified people to _
sur.cessfully handle an emergency. None of these interviewed rated the plant as being any better than marginally safe. Additional investigation was conducted
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onsite on February 26 and 27, 1980. These investigations showed that while the licensee meets the staf fing requirements of its license, concerns remain regarding the adequacy of training of nonlicensed personnel, the ability to respond to emergency conditi9as, and the overall depth of the staff.
Specifically:
- 1) Six of the more experienced equipment operators have been. effectively removed from regular shif t work to train to become licensed operators;
- 2) Some of the remaining eouipment operators have been trained on the-equipment only in certain zones. While,this is adequate for routine-shif t operations, these equipment operators are not trained en all safety related equipment such that they could be relied upon if needed in other work zones during an emergency.
- 3) There is little flexibility to accommodate the loss of staff because -
of sickness or other work leave. Such problems result in ' additional overtime work requirements.
A meeting was held with licensee management-in the Region III office on February 2!) . 1980, to discuss the above concerns and to consider corrective actions.
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VI The past experience of plant operations, the observation by plant operators as to the adequacy of the operating staff,'and the above NRC findings, demonstrate that changes in the plant operating staff are required to provide reasonable-assurance that the facility can be safely' operated under emergency condition:.
Therefore, in view of the above, I have determined that the public health, safety and interest require License No. NFF-3 be modified as. stated. in Part VII below, effective immediately, r.
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VII Accordingly, pursuant to the Atomic Energy-Act of 1954,'as amended, and the Commission regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED THAT:
- 1. The licensee shall:
a) Return six experienced and fully qualified equipment operators, who have been involved in operator license training, to regular shift work to provide two fully qualified equipment operators for each operating shift. The additional qualified. individuals will remain on shift duty until such time as they are relieved.
from duty by other fu', qualified individuals who are appropriately trained and certified by the licensee's training department.
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w b) Provide one additional person for each day shif t to relieve the shift foreman of nonlicensed administi tive responsibilities.
c) Expedite the on-the-job training schedule for existing equipment operators who are not yet fully qualified. This program sh ll-be accomplished by personnel from Toledo Edison Company _ or an outside contract organization and shall continue at least until the refueling outage.
Or in the alternative to items a), b) and c) above, place and maintain the facility in a cold shutdown or refueling mode of operation.
- 2. Prior to Wturn of the station to operations from- the scheduled April 1980 refueling outage, each operating shift shall1 have-a complete complement of fully trained personnel .in accordance with the staffing and qualification levels set forth in draf t ANSI Standard 3.1.
VIII Th'e licensee, or any other person who has an interest affected by this Order,
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may, within twenty-five days of the date of this Order, request a hearing. Any request for a hearing shall be addressed to-the Director, Office of-Inspection and Enforcemer.t, U. S.H. R.C. , Washington, D.C. 20555. If.a hearing is requested, J
the Commission will issue an order designating the time and place of hearing.
Such a request for hearing SHALL NOT' STAY THE IMMEDIATE EFFECTIVENESS OF THIS CRDER.-
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- p, IX In tha event the licensee or any other person requests a hearing as _provided above, the issues to be considered at such a hearing shall be:
c (1) whether the- facts set forth in Section II, III, IV-and V are true; and (2) whether this- Order should be sustained.
FOR THE NUCLEAR REGULATORY COMMISSION 4
Victor Stelin', Jr.'
' Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this E day of March 1980.
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