ML20137X199

Forwards Comments Identifying Changes & Addl Info Necessary to Complete Review of Util 850924 Licensed Operator Requalification Training Program.Response Requested within 30 Days of Ltr Date

ML20137X199
Person / Time
Site:	Hatch
Issue date:	11/14/1985
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Beckham J GEORGIA POWER CO.
References
TAC-59751, TAC-59752, NUDOCS 8512100436
Download: ML20137X199 (6)

Text

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DoSket'sNos.50-321 DISTRin"Tinn and'50-366 (Docket _h JPartlow imt,PDR ACRS-10 L PDR Ringram ORB #4 Rdg GRivenbark Mr.'J. T. Beckham, Jr.__ 'HThompson Gray File :

Vice President - Nuclear Generation OELD Georgia Power Company EJordan

~P. O. Box 4545 .

BGrimes

. Atlanta, Georgia. 30302

Dear Mr. Beckham:

.We have reviewed the Hatch License Requalification Program submitted by your letter of September 24, 1985.

The enclosure'to this letter provides comments resulting from our review of

-this program.- These comments. identify changes that must be addressed and additional information that must be provided by Georgia Power Company in

-order for us to complete our review. You are requested to provide a written response to these comments within 30 days of receipt of this letter.-

The reporting and/or recordkeeping requirements of this letter affect fewer-than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

. . . ~ ,

?

^

John F. Stolz, Chief Operating Reactors Branch #4-Division of Licensing

Enclosure:

Request for' Additional Information N cc w/ enclosure:

.See next page OR 4:)L lb ORB #4:DL GRivenbark;cf .1Stolz 11/$85 11/ /85 8512100436 851114 PDR ADOCK 05y3 1 1

Mr. J. T. Beckham, Jr. Edwin I. Hatch Nuclear Plant, Georgia Power Company Units Nos. I and 2 cc:

G. F. Trowbridge, Esq.

Shaw, P'ttman, Potts and Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Mr. L. T. Gucwa Engineering Department Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. H. C. Nix, Jr., General Manager Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 Baxley, Georgia 31513 Mr. Louis B. Long Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Resident inspector U.S. Nuclear Regulatory Comission Route 1 P. O. Box 279 Baxley, Georgia 31513 Regional Administrator, Region II U.S. Nuclear Regulatory Comission, 101 Marietta Street, Suite 3100 Atlanta, Georiga 30303 Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Comissioner Department of Natural Resources 270 Washington Street, N.W.

Atlanta, Georgia 30334 Chairman Appling County Comissioners County Courthouse Baxley, Georgia 31513

EDWIN 1. HATCH NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321/366 l LICENSED OPERATOR REQUALIFICATION TRAINING PROGRAM REQUEST FOR ADDITIONAL INFORMATION I. INTRODUCTION In a letter of September 24, 1985, Georgia Power Company (GPC) submitted the Licensed Operator Requalification Training Program for the Hatch Plant.

The program was submitted in response to the Region II Inspection Report 50-321/85-07, which war transmitted to GPC on April 1,1985. Region II requested that the program be submitted by October 15, 1985. The program was written in accordance with Regulatory Guide 1.70, " Standard Fonnat and Contents of Safety Analysis Reports for Nuclear Power Plants."

We hue reviewed the program using criteria contained in Section 13.2 of NUREG-0800, " Standard Review Plan." We have also reviewed the i requalification program description contained in the revised FSAR, Section 13.2, of July 1985. We consider that the September 24, 1985, submittal will be the program of record as described in Generic Letter 84-14.

i.

GPC should respond to the following General and Specific Coments.

II. General Comments o Upon completion of resolution of our coments, GPC should submit the program as the program of record as described in Generic Letter 84-14.

The program should be in accordance with the Plant Hatch Administrative and Quality Assurance Procedures, contain applicable references and be reviewed and approved by designated personnel.

I o Several Sections of the program contain significant requirements in one paragraph. These requirements could be more readily understood if each individual requirement were identified. For example, Section 3.2.1, Active Status, identifies the method to remain on active status.

Sections 3.2.2.2, 4.2, 4.3, and 4.4 could be -made more clear if they were rewritten using the style in Section 3.2.1.

III. Specific Comments 0.0 Applicability 0.1 Individuals who are exempt from participating in portions of the program should be clearly identified in the program or in a suitable j administrative procedure. For example:

o The number of instructors who prepare and administer examinations o Personnel who prepare notice of procedure, design and license changes as described in Section 3.3 of the program l

1 0.2 The staff recommends that license candidates become enrolled in  !

training described in Section 3.3, " Plant changes " at a suitable i period in the initial training program. They should continue to-participate in this portion of the program after administration of j license examinations.

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. 0.3 Senior Operator upgrade program candidates should continue to participate in training described in Section 3.3 4

We have not been able to identify the qualification and requalification requirements of instructors in this program.

GPC should refer to the H. R. Denton letter of March 28, 1980, contained in NUREG-0737 and include instructor criteria and i requalification requirements or reference an administrative

procedure in this section of the program.

i 2.0 : Lectures.

i o The September 24, 1985, letter and Section 4.2, Written Evaluctions, '

refer to a four segment lecture series. Therefore, the lecture series description should be contained in this section, o Since segment training, evaluation, and the exemption request in the

September 24, 1985, letter represents a new training and evaluation process, all personnel must attend the lecture series for the first 2 years of the program. Provisions to " test out" portions.of the program will be considered after completion of the 2 year period.

o GPC should evaluate the review of operating experience (Item I.C.5 or NUREG-0737) and Plant Changes (Item 3.3 of the program) as additional

- subjects in the lecture series, o The use of self-study, as stated in item 2 of Appendix A, should also be included in limitations of the program.

3.1 Reactivity Controls o if credit for manipulations may be granted for those who direct or evaluate licensed personnel, GPC should indicate how these personnel 4 are evaluated (Refer to item C.3, Enclosure 1, of the March 28, 1980,

H. R. Denton letter).

l o " Loss of feedwater (normal and emergency)" should be a " starred" item 4

in lieu of " loss of normal feedwater or nomal feedwater system failure" (refer to Enclosure 4 of the March 28, 1980 4. R. Denton letter).

o With regard to the Plant Hatch simulator, GPC should commit to implementation of Regulatory Guide 1.149, " Nuclear Power Plant Simulator for use in Operating Training."

1

-o. GPC should also consider introduction, review and evaluation of changes described in Section 3.3 as part of the reactivity control portion of the program.

- . . _ - _ . . - . - ___ _. , _ ...__ ,__.,. __ __ _ _ _ _ _ _ _ _ _. _ . . . _ _ . _ _ _ _ _ _ - - _ . . ~ _ . . . . -

3.2 Knowledge of Systems GPC should indicate' how this segment is evaluated and how the evaluation is documented.

I 3.2.2.2 Inactive Status o Refer to General Connents.

o .GPC should reference 10 CFR 55.31(e) ir. this section of the program.

o Before inactive licensees are evaluated by management, the program should require: review of license changes and any other required reading; review of the material presented in the segment lecture and e'xamination on that segment; performance of the reactivity control manipulations which were missed during the previous segment (s).

o Inactive licensees should also perform a period of licensed activities under supervision.

3.3 Plant Changes i -- GPC should evaluate whether or not a review of operating experience (Item I.C.5 of NUREG-0737) should be added to this segment of the program.

4.1 Annual Diagnostic Examinations o Diagnostic examinations may be administered at any time during the requalification cycle. Diagnostic examinations are a suitable device to determine strengths and weaknesses in retention and application of knowledge. However, diagnostic examinations, at this time, do not substitute for the Annual Examination required by Appendix A of 10 CFR 55.

4.2 Written Evaluations The segment examination does not include category or subject areas, and

therefore, does not appear to comply with criteria contained in Section C.2, Enclosure 1 of the March 28, 1980 H. R. Denton letter. GPC should explain how categor / subject areas are evaluated in the segmented program (Refer to Section 4.4 .

4.3 Observation and Evaluation o Annual examinations should include simulator and oral operating examinations. Exceptions may be granted if the simulator is not available, o rogram, GPC Since should simulator include evaluation exercises are included of each segment'sinexercises.

the segmented p(Refer to our comments in Section 3.1).

o Suspension from licensed duties due to unsatisfactory performance on actual events should be clearly identified in this section. (Referto general comments).

4.4 Accelerated Requalification Program o Clarify whether reexaminations are administered in sections or one comprehensive examination without sections.

o In lieu of the minimum number of questions for re-examinations, examination questions should be based on the objectives of the accelerated training program.

5.4 Individual Files o Individual files should also include waivers and justification for participation in the program.

o The records must include the training administered during an accelerated program. (Refer to Section 5, Appendix A 10 CFR Part 55).