B12491, Forwards Addl Info Re Licensed Operator Continuing Training Program,Licensed Operator Requalification Training Program & Selected Portions of Nuclear Training Manual & Other Supporting Info,Per NRC 870224 Request

Forwards Addl Info Re Licensed Operator Continuing Training Program,Licensed Operator Requalification Training Program & Selected Portions of Nuclear Training Manual & Other Supporting Info,Per NRC 870224 Request

ML20206P779
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	04/15/1987
From:	Mroczka E, Romberg W CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206P782	List: B12491, Forwards Addl Info Re Licensed Operator Continuing Training Program,Licensed Operator Requalification Training Program & Selected Portions of Nuclear Training Manual & Other Supporting Info,Per NRC 870224 Request ML20206Q130 ML20206Q296 ML20206Q373
References
B12491, TAC-64137, TAC-64138, TAC-64620, NUDOCS 8704210264
Download: ML20206P779 (14)

Text

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.aos 'auoaeaco*= HARTFORD, CONNECTICUT 06141-0270 L L j Z', *],",[,',"", (203) 665 5000 April 15,1987 Docket Nos. 50-213 50-245 50-336 B12491 Re: 10CFR50.54 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Additional Information Concerning Licensed Operator Requalification Programs During December,1986, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) submitted revised licensed operator requalification Training Program implementing Procedures (TPIP) and program descriptions for the Haddam Neck Plant and Millstone Unit Nos. I and 2, respectively, to the NRC Staff for program review.(l) The NRC Staff completed its review and found that some portion of each of the programs could not be verified to meet the criteria of either 10CFR55, Appendix A or the H. R. Denton letter of March 28, 1980, which are in effect until 10CFR$5 is revised. In a letter dated February 24, 1987,(2) the Staff requested additional information for each of the requalification training programs to resolve this issue.

The purpose of this letter is to provide the additional information requested by the Staff. Attachments A, B and C to this letter provide responses for the Haddam Neck Plant and Millstone Unit Nos. I and 2, respectively. Additionally, Attachment D includes applicable portions of the Northeast Utilities Nuclear Training Manual and other supporting information for the already submitted TPIPs.

(1)E. 3. Mroczka letter to C. I. Grimes, " Revised Licensed Operator Requalification Training Program Procedures and Program Descriptions,"

dated December 8,1986.

(2)F. M. Akstulewicz letter to E. 3. Mroczka, " Request for Additional Information Concerning Licensed Operator Requalification Programs," dated lj February 24,1987.

l 8704210264 DR 870415 ADOCK 05000213 PDR J

U1 Nucirr Regulet:ry Ccmmissi:n B12491/Page 2 April 15,1987 ,

We believe that the responses presented in the attachments address the concerns of the Staff, and show that our licensed operator requalification programs are

• being implemented in full compliance with both 10CFR55, Appendix A and H. R. Denton's letter dated March 28,1980. Please feel free to contact us if any l further questions arise on these matters. I J

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLC,AR ENERGY COMPANY E. J. mnx an E. 3. Mroczka Senior, Vice President b0 h heA'y 1 By: W. D. Romberg V Vice President ,

i cc: Dr. T. E. Murley, Region I Administrator '

F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant

3. 3. Shea, NRC Project Manager, Millstone Unit No. I D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Resident Inspector, Haddam Neck Plant T. Rebelowski, Resident Inspector, Millstone Unit Nos. I and 2 ,

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Docket No. 50-213 B12491 a

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Attachment A Connecticut Yankee Atomic Power Company Haddam Neck Plant Licensed Operator Continuing Training Program Additional Information April,1987

Attr.chment A B12491/Page 1 April 15,1987 HADDAM NECK PLANT LICENSED OPERATOR CONTINUING TRAINING PROGRAM ADDITIONAL INFORMATION SECTION 6.7 - RECORDS STAFF REQUEST:

This portion of the licensee's submittal states that records shall be maintained in accordance with their Reference 3.1, " Nuclear Training Manual." Clarification must be provided with respect to the requirements of this reference so that the Staff can ensure that the requirements of 10CFR55, Appendix A, paragraph 5, are met.

RESPONSE

The Northeast Utilities Nuclear Training Manual (NTM) Procedure NTM-1.16, Nuclear Training Records, is provided for review in Attachment D. This procedure lists in its attachments those records retained by CYAPCO to document implementation of our instructional design model, including student participation. When considered . together with additional program specific documentation requirements contained in the Licensed Operator Continuing Training Program Implementing Procedure (NTM-3.04),(1) e.g., shift removal / reinstatement notification memos, etc., all items required by 10CFR55, Appendix A, paragraph 5 are included.

ATTACHMENT 3.1 - SECTION 5.0 - TRAINING SCHEDULE STAFF REQUEST:

Lecture topics do not include applicable portions of Title 10, Chapter I, Code of Federal Regulations, as required by Appendix A, paragraph 2.1 of 10CFR55.

RESPONSE

Licensed operator requalification program lectures at the Haddam Neck Plant do address applicable portions of Title 10, Chapter I, Code of Federal Regulations on a continuing basis in those areas where examinations, or other feedback mechanisms indicate that an emphasis in scope and depth of coverage is needed.

The statement, " Applicable Portions of Title 10, Chapter I, Code of Federal Regulations" was unintentionally omitted from Attachment 8.1, Section 5.0 of the Licensed Operator Continuing Training Implementing Procedure (NTM-3.04) 9 (1) Enclosure to E. 3. Mroczka's letter to C. I. Grimes, " Revised Licensed Operator Requalification Training Program Procedures and Program Descriptions," dated December 8,1986.

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Attrchmtnt A B12491/Page 2 April 15,1987 during procedure preparation. The omission was first identified during an internal program evaluation conducted in mid-December, 1986. This administrative oversight will be corrected by May 15, 1987, in the next revision to the Training Program Description of NTM-3.04.

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' Docket No. 50-245 B12491 Attachment B Northeast Nuclear Energy Company Millstone Unit No. I Licensed Operator Requalification Training Program Additional Information April,1987

Attachmtnt B.

B12491/Page 1

- April 15,1987 MILLSTONE UNIT NO. I LICENSED OPERATOR REQUALIFICATION TRAINING PROGRAM ADDITIONAL INFORMATION SECTION 6.4 - EXAMINATIONS AND LESSON PLANS STAFF REQUEST:

This section of the licensee's program outlines examination categories and indicates which members of the training staff have approval responsibility for each category.- However, the categories are not clearly defined except the Category V is designated as a final exa'mination for which the acceptable standard of performance is stated as " satisfactory." Enclosure ,1 of the March 28, 1980, Denton letter states that the criteria .for the annual requalification examination shall be 80% overall and 70% in each category. If the Category,V examination is the annual or final requalification examination, it must meet the standard as stated in the Denton letter. . )

RESPONSE

- The ' Category V examination referenced in Section 6.4 of the Millstone Unit No.1 Licensed Requalification Training Program -Implementing Procedure (TPIP)(OperatorIl-is not the rmnual written examination administered per 10CFR55, Appendix A requirements. _ It is an operational examination administered annually on the reference plant simulator and evaluated on -a

. satisfactory-unsatisfactory basis, and thus consistent with the NRC initial licensing practice. A written Category I examination is administered annually and evaluated using the March 28,1980 Denton letter criteria of 80% overall and 70% in each category per Section 6.4.2 of the TPIP. The requirement for the Category I examination is delineated in Sections 5.8 (1986) and 5.15 (1987) of the requalification TPIP Training Program Description (Attachment 8.1 to

' NTM 3.04).

Section 6.1 of the NU Nuclear Training Manual Procedure NTM 1.11, Examination Controls, defines the various examination categories used in the '

operator training programs. NTM 1.11 is provided in Attachment D.

STAFF REQUEST:

This portion of the licensee's submittal states that records will be maintained in accordance with licensee Reference 3.4, " Nuclear Training Manual."

Clarification must be provided with respect to the requirements of this reference so that the Staff can ensure that the requirements of 10CFR55, Appendix A, paragraph 5, are met.

(1) Enclosure to E. 3. Mroczka's letter to C. I. Grimes, " Revised Licensed Operator Requalification Training Program Procedures and Program Descriptions," dated December 8,1986.  !

1 Attachment B -

B12491/Page 2 April 15,' 1987 ~

RESPONSE

The Northeast Utilities (NU) Nuclear Training Manual' (NTM) Procedure NTM-1.16, Nuclear Training Records, is provided for review in Attachment D. . This procedure lists in its attachments those records retained by NNECO to document

- Implementation of our instructional design model, including student participation. . When considered together with additional program specific documentation requirements contained in the Millstone Station Administrative .

Control Procedure (ACP) 8.09, Millstone Licensed Operator Requalification Programs, all items required by 10CFR55, Appendix A, paragraph 5 are included.

TRAINING PROGRAM NO. MPI-LOR-86/87, SECTION 4.0 - TOPICAL OUTLINE STAFF REQUEST:

This part of 'the program description does not include " Applicable Portions of

- Title .10, Chtpter I, Code of Federal Regulations" under lecture topics.

Appendix A of 10CFR55, paragraph 2.1 requires this subject to be part of the licensee's lecture series.

The control manipulations required in this portion of -the licensee's program appear to exclude the following manipulations required by Enclosure 4 of the March 28,1980, Denton letter:

- Loss of normal feedwater or normal feedwater system failure

- Loss of all feedwater (normal and emergency)

- Main steam-line break (inside or outside containment)

Because the licensee has described. the control manipulations differently than Enclosure.4, it is possible that these manipulations are actually included in the program. In a telephone conversation with the NRC subject matter reviewer, the licensee's training department has agreed to indicate how the control manipulations in the licensee's program correspond to those in the Denton letter.

RESPONSE

Applicable topics from Title 10, Chapter I, Code of Federal Regulations are covered throughout the Millstone Unit No. I licensed operator requalification program. While no specific lesson plan with that title is included in the topical listing, appropriate items are' included with other related topics, such as,

' technical specification changes, reportable occurrences, shift duties, etc.

Additionally, topics related to 10CFR20, Standards fcr Protection Against Radiation, are covered annually as part of the Radiation Worker Requalification Training Program.

All control manipulations, as requested by the March 28,1980 Denton letter, are included in the requalification program and appropriate documentation substantiating each licensed operator's participation is maintained in Nuclear Training Department records. However, the topical outline included in the requalification training program implementing procedure lists only the broad simulator exercise titles. Therefore, there are often several control manipulations buried within an individual exercise. For example, Simulator

Att chmtnt B B12491/Page 3 April 15,1987 Lesson Plan R01-86-7(S), provided in Attachment D, shows that a main steam-line break evolution is included (page 5), although not specifically identifiable by the exercise title.

l ACCELERATED REQUALIFICATION STAFF REQUEST:

There is no provision in the licensee's submittal for an accelerated requalification program or removal from licensed duties when examination

standards are not met. Paragraph 4.e of 10CFR55, Appendix A states that the ,

! requalification program shall include: [

Provisions for each licensed and senior operator to participate in an )

accelerated requalification program where performance evaluations '

conducted pursuant to paragraph 4.a through 4.d clearly indicate the need.

RESPONSE

Specific provisions for unsatisfactory student performance in requalification, including accelerated requalification training, are presently contained in the Millstone Station Administrative Control Procedure (ACP) 8.09, Millstone Licensed Operator Requalification Programs. It is significant to note that these requirements will be incorporated into future revisions of the Millstone Unit No. I Licensed Operator Requalification . Training Program Implementing Procedure (NTM 3.04) and ACP 8.09 will be cancelled to consolidate the specific requirements of the requalification program.

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Docket No. 50-336 B12491 Attachment C Northeast Nuclear Energy Company Millstone Unit No. 2 Licensed Operator Requalification Training Program Additional Information April,1987

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Attachmsnt C B12491/Page 1 April 15,1987 MILLSTONE UNIT NO. 2 LICENSED OPERATOR REQUALIFICATION TRAINING PROGRAM ADDITIONAL INFORMATION SECTION 6.4 - EXAMINATIONS AND LESSON PLANS STAFF REQUEST:

This section of the licensee's program outlines examination categories and indicates which members of the training sta'f have approval responsibility for each category. However, the categories are not clearly defined except the Category V is designated as a final examination for which the acceptable standard of performance is stated as " satisfactory." Enclosure 1 of the March 28, 1980, Denton letter states that the criteria for the annual requalification examination shall be 80% overall and 70% in each category. If the Category V examination is the annual or final requalification exam! nation, it must meet the standard as stated in the Denton letter.

RESPONSE

The Category V examination referenced in Section 6.4 of the Millstone Unit No.2 Licensed O Requalification Training Program Implementing Procedure (TPIP)(1)peratoris not the annual written examination administered per 10CFR$5, Appendix A requirements. It is an operational examination administered annually on the reference plant simulator and evaluated on a I satisfactory-unsatisfactory basis, and thus consistent with the NRC initial '

licensing practice. A written Category I examination is administered annually and evaluated using the March 28,1980 Denton letter criteria of 80% overall and 70% in each category per Section 6.4.2 of the TPIP. The requirement for the Category I examination is delineated in Section 7.4.2.1 of the requalification TPIP Training Program Description (Attachment 8.1 to NTM 3.04).

Section 6.1 of the NU Nuclear Training Manual Procedure NTM 1.11, Examination Controls, defines the various examination categories used in the operator training programs. NTM 1.11 is provided in Attachment D.

SECTION 6.6 - RETRAINING REQUIREMENTS STAFF REQUEST:

This section states that the determination of the need for accelerated requalification training,its method and content will be determined in accordance with the Nuclear Training Manual. The licensee should clarify what the 1 requirements are with respect to accelerated requalification programs and l 1

(1) Enclosure to E. 3. Mroczka's letter to C. I. Grimes, " Revised Licensed Operator Requalification Training Program Procedures and Program Descriptions," dated December 8,1986.

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Attachm::nt C B12491/Page 2 April 15,1987

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removal from licensed duties when examination standards are not met.  ;

Appendix A of 10CFR55, Part 4.e requires that the provisions be made for each  ;

licensed operator and senior operator to participate in an accelerated requalification program where nerformance evaluations clearly indicate the need.

RESPONSE

Specific provisions for unsatisfactory student performance in requalification, including accelerated requalification training, are presently contained in the Millstone Station Administrative Control Procedure (ACP) 8.09, Millstone Licensed Operator Requalification Programs, which is included in Attachment D.

It is significant to note that these requirements will be incorporated into future revisions of the Millstone Unit 2 Licensed Operator Requalification Training Program Implementing Procedure (NTM 3.04) and ACP 8.09 will be cancelled to consolidate the specific requirements of the requalification program.

SECTION 6.7 - RECORDS STAFF REQUEST:

This portion of the licensee's submittal states that records shall be maintained in accordance with their Reference 3.1, " Nuclear Training Manual." Clarification must be provided with respect to the requirements of this reference so that the Staff can ensure that the requirements of 10CFR55, Appendix A, paragraph 5, are met.

RESPONSE

The Northeast Utilities Nuclear Training Manual (NTM) Procedure NTM-1.16, Nuclear Training Records, is provided for review in Attachment D. This procedure lists in its attachments those records retained by NNECO to document implementation of our instructional design model, including student participation. When considered together with additional program specific documentation requirements contained in the Millstone Station Administrative Control Procedure (ACP) 8.09, Millstone Licensed Operator Requalification Programs, all items required by 10CFR55, Appendix A, paragraph 5 are included.

SECTION II.A - CONTROL MANIPULATIONS STAFF REQUEST:

In its list of required control manipulations, the licensee states that the following three shall be done on a biennial basis:

Plant or reactor start-ups to include a range that reactivity feedback from nuclear heat addition is noticeable and heat-up rate is established, Manual control of steam generators and/or feedwater during start-up and

, shutdown,

' Attachm:nt C .

B12491/Page 3 April 15,1987 -

Any significant (10%) power changes in manual rod control'.

The March 28, 1980, Denton letter requires that these. manipulations be -

performed on an annual basis.

RESPONSEi In the Millstone Unit No. 2 License Operator TPIP Training Program Description, the annual and biennial control manipulation requirements are indicated using a single asterisk, or a double asterisk, respectively. - The three control -

manipulations listed incorrectly are the result of typographi_ cal errors that were not identified during the review and approval process. This administrative oversight wi!! be corrected by May 15, 1987 with the next revision to the Training Program Description.

'It is significant to note that all control manipulations have been performed by each Millstone Unit No. 2 license holder per the March 28, 1980, Denton letter requirements, and appropriate documentation exists in Nuclear Training Department records to substantiate that fact.

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Docket Nos. 50-213 50-245 50-336 B12491 Attachment D Connecticut Yankee Atomic Power Company Northeast Nuclear Energy Company Selected Portions of Nuclear Training Manual and Other Supporting Information April,1987