ML20035D486
| ML20035D486 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/08/1993 |
| From: | Cross J, Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9304130259 | |
| Download: ML20035D486 (7) | |
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g(n Portland General Electric Company j-
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hiiid James E. CROSS April 8, 1993 Vice President and Chief Nuclear Officer Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555 1
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Dear Sir:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGJMM By a letter dated March 27, 1993, the Nuclear Regulatory Commission i
requested additional information on the Certified Fuel Handler Training and Retraining Programs (Topical Report PGE-1057). Attached is the additional information that was requested.
j Sincerely, i
l T. D. Walt for J. E. Cross Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission l
Mr. David Stewart-Smith State of Oregon Department of Energy Mr. Kenneth Johnston NRC Resident Inspector Trojan Nuclear Plant 1
133054 9304130259 930408 PDR ADOCK 05000344
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121 SW Salmon Street, Portland, OR 97204
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503/464-8897
. Trojan Nuclear Plant Docum2nt Control Desk Docket 50-344 April 8, 1993 License NPF-1 Attachment Page 1 of 6 i
J Response to Request for Additional Information Regarding PGE 1057 3
1, 1.
QUESTION:
The Abstract states, "The criteria upon which the program becomes effective are specified."
Where are the criteria specified?
What are the criteria?
ANSWER:
The criteria upon which the program becomes effective are identified on page 1.0-1, Section 1.0,
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" Introduction".
The criteria upon which the program becomes effective are:
1 (1)
Approval of the Certified Fuel Handler Training and Retraining Programs by the Nuclear Regulatory i
Commission, and i
(2)
Issuance of a Possession Only License for the I
Trojan facility (or other regulatory action which prohibits transfer of fuel into the Containment Building), and (3)
Amendment of the facility license for the Trojan Nuclear Plant to eliminate the requirements for l
Nuclear Regulatory Commission (NRC) licensed l
Senior Reactor Operators and Reactor Operators, and the requirement for the associated 10 CFR 55 Training Program.
(Trojan Technical specifications 6.2.2, 6.3, and 6.4.)
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i 2.
QUESTION: On page 1.0-1,
" Introduction," PGE states that "The training of current holders of NRC Senior Reactor Operator and Reactor Operator licenses may be evaluated to determine if they satisfy the requirements of this program."
Why is the training of the SRO's being evaluated?
SRO's should already be qualified to supervise fuel
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handling / movement evolutions.
The RO licenses must be evaluated to determine what, if any, additional training j
will be required before certification.
Will the qualifications of individual license holders be evaluated?
Will any other PGE personnel be evaluated?
ANSWER: The wording was intended, as an administrative convenience, to allow use of the evaluation process to document that an SRO was a certified fuel handler.
PGE recognizes that an SRO is qualified to be a certified fuel handler.
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'T.rojan Nuclear Plant Document Control Desk Docket 50-344 April 8, 1993 License NPF-1 Attachment l
Page 2 of 6 l
The qualifications of individual license holders, other than current active SRO licenses, are required to be individually l
evaluated.
Evaluation of current active RO licenses will
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concentrate on differences between the requirements for a Certified Fuel Handler and a RO to identify if any additional training is required to become a Certified Fuel Handler [e.g.,
did the RO receive the same level of training and examination on technical specifications, fuel handling, l
administrative controls, etc. as required for a Certified Fuel Handler).
The Certified Fuel Handler Training Program allows the evaluation of other PGE personnel to determine if portions of the required training have already been completed and may be waived.
Evaluation will concentrate on if the level of training and examination in the subject area were the same as that required for a certified Fuel Handler.
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l 3.
QUESTION:
On page 1.0-2, reference is made to " Appropriate i
PGE management..."
Who is this management?
Can this management be delegated to other individuals?
l ANSWER:
The phrase " appropriate PGE management" means the l
senior site manager responsible for the unit.
[In the current organization this is the General Manager, Trojan Plant.] This senior level manager reports to the person with overall responsibility for the site.
This management
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approval can be delegated to an individual who is designated to act for this senior manager when he is absent.
i 4.
QUESTION: On page 2.1-1 and 3.1-1, reference is made to
" individual lecture".
What is individual lecture?
l ANSWER:
The reference to " individual lecture and/or self-study of topics" is intended to convey that the training of l
individual topics may be accomplished by either a classroom presentation or a self-study process.
PGE-1057 will be revised to clarify this.
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5.
QUESTION: How much of the training described on pages 2.1-1 and 3.1-1 will be lecture and how much will be self-study?
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ANSWER: The training identified in 2.1-1 will normally be self-study and On-The-Job since the position is expected to have personnel trained one at a time as hired.
If several trainees entered the program, lectures may be used to accomplish the same training.
The identified training in 3.1-1 will be primarily self-study with some lectures.
Trojan Nuclear Plant Document Control Dask D'ocket 50-344 April 8, 1993 License NPF-1 Attachment l
Page 3 of 6 6.
QUESTION: If the fundamentals listed on page 2.1-1 are those
" typically" in the fundamentals training program and given that using a SAT-based training program will allow adjustments to the program as appropriate for the current status, will any of the topics listed be considered part of a core program that all certified fuel handlers will receive?
ANSWER: Of the topics listed in section 2.1,
" Fundamentals Training", heat transfer, radiological safety principles and monitoring, facility / system design and function, and facility administrative and safety procedures are currently considered core topics.
Based on a review of the current license training program as it applies to a defueled condition, these core topics were identified as meeting current needs.
Changes to the core topics will be based on a logical assessment of changes in needs, using a Systems Approach to Training methodology.
The Systems Approach to Training Process used for the Certified Fuel Handler Program contains the following five key elements and is intended to provide a training system that will ensure successful performance on the job by trained individuals.
The elements are:
1.
Analysis of job performance requirements and training needs.
2.
Derivation of learning objectives based upon the preceding analysis.
3.
Design and implementation of the training program based upon the learning objectives.
4.
Trainee evaluation.
5.
Program evaluation and revision.
The key elements listed above will be achieved by adhering a
to the objectives established in NUREG-1220, Revision 1,
" Training Review Criteria and Procedures".
f 7.
QUESTION: On page 2.2-1, reference is made to a period of on-shift watches under instruction.
What is the minimum number of on-shift watches required for qualification?
ANSWER:
A minimum of 32-hours of under instruction watches is required prior to qualification as a certified Fuel Handler.
Trojan Nuclear Plant Document Control Desk Docket 50-344 April 8, 1993 License NPF-1 Attachment Page 4 of 6 i
8.
QUESTION:
On page 2.3-1,
" appropriate PGE management" is defined as the " General Manager, Trojan Plant."
Can this i
authority be delegated?
If so, to whom?
l Answer: The designation of " appropriate PGE management" has l
been changed from the " General Manager, Trojan Plant" to'the
" Senior Site Manager responsible for the Unit".
[In the current organization this is the General Manager, Trojan Plant.]
This senior manager reports to the person with overall responsibility for the site.
PGE-1057 will be revised to reflect this change.
This management approval can be delegated to an individual who is designated to act for this senior manager when the senior manager is absent.
9.
QUESTION: On page 3.1-1, PGE states that the actual content of the retraining program shall be determined by appropriate PGE management.
Is the content of the retraining program determined and presented over a 24-month basis or is the content determined and presented on a continuing basis?
What is the basis for the actual content of the retraining program?
I ANSWER:
The content of the retraining program includes a combination of predetermined topics and continuing training.
The predetermined topics include those that have been identified as requiring periodic retraining (e.g. retraining tasks) and are specified in a training document that requires that they be completed over a 24 month period.
The i
retraining program includes continuing training to cover plant and applicable industry events, plant changes, procedure changes and identified problem areas.
The actual content of each cycle's training will be determined using a i
Systems Approach to Training methodology, as described in the answer to Question 6.
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l 10.
QUESTION: Section 3.2.2,
" Missed Training," states that any missed training will be made up.
How long does an individual have to make up the missed training?
ANSWER: The Certified Fuel Handler Retraining program allows 60 days to make up missed training.
Those not completing the missed training within this time period will be suspended from standing watch until the missed training is completed.
I 11.
QUESTION: Section 3.2.2,
" Missed Training," states that if missed training is not completed, the individual is suspended until completion of retraining.
Does this s
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' Trojan Nuclear Plant Documsnt Control Desk l
Docket 50-344 April 8, 1993 License NPF-1 Attachment Page 5 of 6 remedial training require any additional qualification or l
watchstanding?
ANSWER:
No additional qualification or watchstanding is required, just completion of the missed training.
12.
QUESTION: The retraining program requires a comprehensive final examination.
Will any examinations be administered during the retraining cycle to determine training deficiencies?
ANSWER:
Examinations will be administered during the retraining cycle to provide assurance that effective training has occurred.
13.
QUESTION: Section 3.4.2,
" Waiver of Maintenance of Qualificction Requirements," states that an individual will not be exempted from the written examinations based on the fact the individual helped in exam preparation.
Does this mean that exemptions can be granted for other reasons?
If so, what are the reasons?
ANSWER:
Exemptions may be granted for reasons other than preparing examinations.
Exemptions will be approved by senior manager responsible for the unit [see answer to Question 3 Re: senior manager] and include a written basis for granting the exemption.
Exemptions from program requirements can be granted based on the following criteria:
a.
Completion of similar training (e.g., recent completion of the initial training program).
b.
Completion of similar evaluations (e.g.,
completion of graded emergency plan drill which tested similar skills, abilities or knowledge).
c.
Active participation in development, delivery, or evaluation of training (e.g., preparation of the annual examination).
14.
QUESTION: Section 4.0, Program Evaluation," requires
" routine assessments" of the effectiveness and accuracy of training.
How often will an assessment of the program be made?
ANSWER:
Assessments of the program will be completed annually.
- T,rojah Nuclear Plant Documnnt Control Desk Docket 50-344 April 8, 1993 License NPF-1 Attachment Page 6 of 6 15.
QUESTION: Will the written examination be open reference or i
closed reference?
Will certified fuel handlers be evaluated in the area of integrated operations?
ANSWER:
Written exams will be open reference except where the specific knowledge, skill or ability being tested is expected or required to be used without use of a reference (e.g., immediate response to an alarm or how to manually operate a motor operated valve].
Integrated operations will be evaluated in the operating exam.
16.
QUESTION: What will the operating exam described in Appendix B evaluate?
As Appendix B is currently written, it is not clear what the exam will do.
ANSWER:
The operating examination in Appendix B will provide an evaluation of skills and abilities that can not usually be evaluated in a written examination. The operating examination will be a walk-through type examination of control room systems and systems outside the control room.
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