ML20138Q352

Responds to 851028 Request for Addl Info Re Operator Requalification Program.Items Discussed Will Be Incorporated as Future Rev to FSAR

ML20138Q352
Person / Time
Site:	Seabrook
Issue date:	12/16/1985
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Noonan V Office of Nuclear Reactor Regulation
References
SBN-908, NUDOCS 8512270154
Download: ML20138Q352 (8)

Text

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George S. Thomas

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I vice President Nuclear Production J \

P25c Service of New Hampshire December 16, 1985 SBN-908 T. F. B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director PWR Project Directorate #5

References:

(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos.

50-443 and 50-444.

(b) USNRC Letter, dated October 28, 1985, " Request for Additional Information for Seabrook Station Units 1 and 2, Operator Requalification Program," G. W. Knighton to R. J. Harrison Subj ect: Response to RAI for Seabrook Station Regarding Operator Requalification Program

Dear Sir:

In answer to the referenced request for additional information, attached please find our response to items 1 through 8. Discussions in our response require changes to the Scabrook FSAR. These changes to the FSAR will be made and submitted in a future revision to that document.

Should you or your staff have any questions regarding our responses, please contact Mr. Peter Richardson, Training Center Manager, at (603) 474-9574, extension 2605.

Very truly yours, w

G e S. Thomas GST/cj b Attachment cc: ASLB Service List ljC 851216 hY'AD-J. Knight (ltr only) \

V 050 3 EB (BALLARD) i EICSB (HOSA) I l PSB V (GAiJ4ILL) l

. RSB (BERLINGER)

FOB (BENAROYA)

P.O. Box 300 + SeabM,NHO3874 . Telephone (603)474-9521

p RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SEABROOK STATION UNITS 1 AND 2 DOCKET NOS. 50-443 AND 50-444 LICENSED OPERATOR REQUALIFICATION PROGRAM

1. A. sentence has been added to the third paragraph of FSAR Section 13.2.1.3, stating that the Vice President-Nuclear Production will certify the eligibility of individuals for renewal of license.

2. As discussed in a telephone conversation between Peter M. Richardson and Ms. Mary Louise Roe on November 1, 1985, FSAR Section 13.2.1.3 has been revised to include the following statement:

Fundamentals and Systems Review lectures will cover topics in which the standard source material is relatively constant; for example, reactor theory, plant design, radiation control, etc. These lectures -

will include instruction in heat transfer, fluid flow, the rmodyna-mics, and mitigation of accidents involving a degraded core.

3. In the telephone conversation cited above, Mr. Richardson and Ms. Roe agreed that the requested change in the program description in the FSAR is not necessary. The following information about the Seabrook Training Center's academic and performance review process for licensed operators is already in FSAR Section 13.2.1.3.

Requalification training at Seabrook ' Station is conducted on a modular basis with at least ten one-week modules being presented every two years. Each module of training includes both written and demonstrative examinations. At least once a year, each licensed operator will be observed and evaluated while responding to either real or simulated abnormal or emergency conditions.

Exam failure or unsatisfactory performance will require that the deficient licensee meet with the appropriate academic review board. The academic review process is a three-tiered program of progressive corrective actions designed to upgradt knowledge and skills identified as deficient. The three levels in the academic review process are:

1. Staff Counselor Interviews

2. Alert Status Review Board

3. Performance Review Board Any academic review board that is convened will make recommendations as it deems necessary to upgrade deficient areas. The recommendations of the Performance Review Board may include immediate removal from licensed duties.

RAI RESPONSE-PAGE 2 A performance review will be conducted whenever any of the following situations occur:

o A licensed operator receives a modular exam score of less than 70 percent more than once during the annual cycle, or an annual overall grade average of less than 80 percent.

o A licensed operator receives a poor performance evaluation.

o Prior to resuming or assuming active license responsibilities after absence of four months or longer from actively performing the functions of an operator or senior operator.

The purpose of the review will be to determine a course of action necessary to upgrade an individual's performance to an acceptable level.

A supplemental training program will be established to upgrade areas where deficiencies are shown. A decision to suspend an operator from licensed duties will not be based on examination scores alone, but on all aspects of the operator's performance.

4. As explained in the telephone conversation cited previously, oral examina-tions may be used as an evaluative tool in requalification training. Both written and demonstrative examinations will be given in each requalifica-tion training module. If an oral examinations is the best way to test for the information or skills covered in a particular module, then that is the means that will be used.

5. In order to maintain an acceptable level of operating proficiency, all licensed operators at Seabrook Station are required to participate in the on-the-job training component of the requalification training program, as described in FSAR Section 13.2.1.3.b. The on-the-job training includes practice on a Seabrook site-specific simulator. Simulator training provides the license holder with the opportunity to actually perform or supervise control manipulations.

We do not believe that it is necessary to provide additional proficiency activities for licensed operators. Having licensees' perform watch-standing duties in the control room as observers would provide less effective training than that already conducted at the simulator during requalification training. If regulations are changed in the future to require licensees to spend additional time in the control room, we will revise the requalification training program and the FSAR to comply with the change.

A revision to our Performance Evaluation and Review section of the FSAR has been made to reflect the action to be completed if a licensee has not

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been actively performing the functions of an operator or senior operator for a period of four months or longer, as specified in 10CFR55.31(e).

RAI RESPONSE--PAGE 3

6. The subjects specifically listed in the FSAR as items to be covered by written examinations are those specified by 10 CFR Part 55, Appendix A.

We are aware that other guidelines apply, but we do not believe that it is neces ary to address all of them in the FSAR. The Seabrook Training Center is committed to a performance-based training program, and examina-tions are designed to test knowledge and skills required for safe and ef ficient job performance.

'7. The plant evolutions and abnormal / emergency procedures listed on pages 13.2-10 and 13.2-10a of our submittal are not covered all at once in an annual or biennial block of training. They are reviewed in classroom and simulator training presented throughout the year during the week-long requalification training modules.

8. FSAR Section 13.2.1.3 has been revised by the addition of the following paragraph, which is now Section 13.2.1.3.g.

Requalification training program records will be maintained for a minimum of two years f rom the date of the recorded event to document the participation of each licensed operator and senior licensed operator in the program. The records will include copies of written examinations administered, the answers given by the licensee, results of evaluations, and documentation of any additional training in areas in which the licensee had exhibited deficiencies.

l I

FSAR REVISION 1 The following revision is to be inserted in place of the third paragraph in Section 13.2.1.3 on page 13.2-7.

A minimum of ten weeks per two-year cycle will be dedicated to the requalification training program. All licenced Seabrook Station instructors will participate in the program ia order to remain cognizant of current operating history, procedural changes, dasign changes, and administrative policies, except to the extent that their normal duties preclude the need for specific retraining in particular areas. Each application for renewal of an operator or senior operator license will be accompanied by a statement, signed by the Vice President-Nuclear Production, certifying that the applicant has satisfactorily completed the requalification program during the effective term of his or her current license and that he or she has discharged license responsibilities competently and safely.

The requalification training program consists of four interrelated elements:

o Requalification Examinations o On-the-Job Training o Pre-Planned Lecture Seric.s o Special Retraining Programs

FSAR REVISION 2 The following revision is to be inserted near the top of page 13.2-10d in place of an existing paragraph beginning, " Fundamentals and Systems Review lectures...."

Fundamentals and Systems Review lectures will cover topics in which the standard source material is relatively constant; for example, reactor theory, plant design, radiation control, etc. These lectures will include instruction in heat transfer, fluid flow, thermodynanics, and mitigation of accidents involving a degraded core.

t

FSAR' REVISION 3'

' The following revision is to be added to the very end of FSAR Section 13.2.1.3.

g. Requalification Training Program Records Requalification training program records will be maintained for a minimum of,two-years from the date of the recorded event to document the participation of each licensed operator and senior licensed operator in'the program. The records will' include copies of written examinations administered, the answers given by the licensee, results of evaluations, and documentation of any additional training in areas in which the licensee had exhibited deficiencies.

FSAR REVISION 4 The following revision is to be inserted in place of 13.2.1.2(f).

f. Performance Evaluation and Review Requalification training program effectiveness shall be monitored as described in Subsection 13.2.1.1.

At least once per year, each licensed operator will be observed and evaluated while responding to either real or simulated abnormal or emergency conditions. The evaluation will be performed by the individual's immediate supervisor or a member of the Training Center Staff.

A performance review will be conducted when any of the following situations occur:

o A licensed operator receives a modular exam score of less than 70 percent more than once during the annual cycle, or an annual overall grade average of less than 80 percent.

o A licensed operator receives a poor performance evaluation.

o Prior to resuming or assuming active license responsibilities af ter absence of four months or longer f rom actively performing the functions of an operator or senior operator.

The purpose of the review will be to determine a course of action necessary to upgrade an individual's performance to an acceptable level. A supplemental training program will be established to upgrade areas where deficiencies are shown.

The review will be conducted as scan as practical af ter one of the above conditions occur. The action taken will be dependent on such.

factors as examination performance, watch-standing performance, observed operational performance and judges overall competence.

A performance review will be conducted to determine the necessary actions to be performed by a licensee, prior to assuming respon-sibilities at any operational shift level; RO, SRO, Unit Shift Supervisor, Shift Superintendent. Typically this perfo mance review would address actions to be performed by an inactive licensee prior to being placed in an operating position requiring a license. The results of this review will be used to certify to the commission that the licensee's knowlddge and understanding of facility operation and administration are satisfactory, as required by 10CFR55.31(e).