ML15292A013

Pilgrim Nuclear Power Station - ERO Staffing and Training Teleconference with NRC Staff

ML15292A013
Person / Time
Site:	Pilgrim
Issue date:	10/20/2015
From:	Entergy Nuclear Generation Co
To:	Office of Nuclear Reactor Regulation
Venkataraman B
References
Download: ML15292A013 (11)

Text

Pilgrim Nuclear Power StationERO Staffing and TrainingTeleconference with NRC Staff October 20, 201510/15/15 1400 AgendaIntroduction of ParticipantsBackground and HistoryProblem StatementProposed ResolutionBasis for ChangeIntended ActionsNRC Staff Questions and PerspectiveConclusions 2

Introduction of ParticipantsNRC StaffEntergy -Pilgrim 3

Background and HistoryJuly 14, 2006 letter from Entergy to NRC Staff oERO substitution: ChemTech for RP Tech oTraining for ChemTechs describedFeb 5, 2007 letter from NRC Staff to Entergy oChange does not decrease effectiveness of plan oNo NRC approval necessary2015: Entergy determined ChemTech trainingnot consistent with July 14, 2006 letterImmediate actions; RP Tech added back to shifts; 4

Problem StatementLevel of training for ChemTechs acting for RPTechs described in July 14, 2006 letter exceedsactual requirements of the ERO function.

5 July 14, 2006 Letter: ChemTech Training 6

Proposed ResolutionEntergy proposal:

oReturn to onshiftChemTechs fulfilling the RP TechERO function for first 30 minutes of ERO initiation oReduce the scope of ChemTech training oSubmittal to NRC for review and approval prior toimplementationEntergy has concluded this change is acceptable 7

Basis for ChangeReduced level of training -consistent with limitedspecific actions of the ChemTechs within 30 minutesSpecific on-shift staffing study supports limited scopeof responsibilities of ChemTech for RP TechsOE review identified similar implementationsFebruary 5, 2007 NRC Staff letter concluded:

oPrevious Entergy proposal met requirements of:10CFR50.47(b)(2) -adequate staffing provided10CFR50, App E, IV.A -organization for coping oChemTech training considered an enhancement oNo decrease in effectiveness / no NRC approval required 8

Intended ActionsConference call with NRC StaffPreparation and submittal of request for priorNRC Staff review and approvalRevise trainingRevise ERO staffing 9

NRC Staff Questions and Perspective 10 Conclusions 11Proposed change in Chemistry Technician isappropriate based on ERO assignmentsProposed change is justified by staffing studyEntergy intends on submitting the proposedchange for prior NRC review and approval Pilgrim Nuclear Power StationERO Staffing and TrainingTeleconference with NRC Staff October 20, 201510/15/15 1400 AgendaIntroduction of ParticipantsBackground and HistoryProblem StatementProposed ResolutionBasis for ChangeIntended ActionsNRC Staff Questions and PerspectiveConclusions 2

Introduction of ParticipantsNRC StaffEntergy -Pilgrim 3

Background and HistoryJuly 14, 2006 letter from Entergy to NRC Staff oERO substitution: ChemTech for RP Tech oTraining for ChemTechs describedFeb 5, 2007 letter from NRC Staff to Entergy oChange does not decrease effectiveness of plan oNo NRC approval necessary2015: Entergy determined ChemTech trainingnot consistent with July 14, 2006 letterImmediate actions; RP Tech added back to shifts; 4

Problem StatementLevel of training for ChemTechs acting for RPTechs described in July 14, 2006 letter exceedsactual requirements of the ERO function.

5 July 14, 2006 Letter: ChemTech Training 6

Proposed ResolutionEntergy proposal:

oReturn to onshiftChemTechs fulfilling the RP TechERO function for first 30 minutes of ERO initiation oReduce the scope of ChemTech training oSubmittal to NRC for review and approval prior toimplementationEntergy has concluded this change is acceptable 7

Basis for ChangeReduced level of training -consistent with limitedspecific actions of the ChemTechs within 30 minutesSpecific on-shift staffing study supports limited scopeof responsibilities of ChemTech for RP TechsOE review identified similar implementationsFebruary 5, 2007 NRC Staff letter concluded:

oPrevious Entergy proposal met requirements of:10CFR50.47(b)(2) -adequate staffing provided10CFR50, App E, IV.A -organization for coping oChemTech training considered an enhancement oNo decrease in effectiveness / no NRC approval required 8

Intended ActionsConference call with NRC StaffPreparation and submittal of request for priorNRC Staff review and approvalRevise trainingRevise ERO staffing 9

NRC Staff Questions and Perspective 10 Conclusions 11Proposed change in Chemistry Technician isappropriate based on ERO assignmentsProposed change is justified by staffing studyEntergy intends on submitting the proposedchange for prior NRC review and approval