ML20202D874

Clarifies Licensed Retraining Programs,In Response to NRC 860428 Request,Including Info Re NUREG-0737 Items Concerning Licensed Operator Retraining & Refueling License Retraining. Supporting Documentation Encl

ML20202D874
Person / Time
Site:	Beaver Valley
Issue date:	06/30/1986
From:	Carey J DUQUESNE LIGHT CO.
To:	Tam P Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-1.C.5, TASK-TM NUDOCS 8607140238
Download: ML20202D874 (12)

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'Af Telephone (412) 393-6000 Nuclear Group P.O. Box 4 Shippingport, PA 15077 0004 June 30, 1986 Director of Nuclear Reactor Regulation U.S. thiclear Regulatory emuni== ion ATIN: Mr. Peter S Tam, Project Manager Project Directorate No. 2 Division of PWR Licensing - A Washington, DC 20555 Mail Stop 340 Rt.n.Ku1CE:

Beaver Valley Power Station Unit 1 Docket No. 50-334, License DPR-66 Clarification of Operations Training and Simulator Training Pr@ tam

Dear Mr. Tam:

This letter is in response to your reg. inst dated April 28, 1986, for addition clarificaticn of our subnitted Licensed Retraining Pr@taas.

I.

LICENSED OPERATOR RETRADTDiG 1.

Foral Classroom Trainirn The formal classroom training does not include topics relating to:

mitigation of core damage; technical specifications and applicable portions of Title 10CFR. Include these topics or state how the topics are incorporated in classrocm training.

Reference:

Item I.A.2.1 of NUREG-0737, Appendix A of 10CFR Part 55.

Response: The topics of question have been included in the re-training pt w am although not listed specifically in the r

topic descriptions. Mitigating core Enmage training is included within Abnormal and Emergency Procedure review.

Ibchnical Specificationi, and applicable portions of Title 10CFR are included within the appropriate topic being presented. The NGTAM will be revised to indicate this.

0) 8607140238 860630 0

PDR ADOCK 05000334 f

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4 Mr. Peter J. Tam June 30, 1986 Page Please clarify the subject matter contained in Topic VIII

" Plant Status Updates" Response: Plant status updates includes:

1.

Plant Design Chuge Training 2.

Plant Administrative Changes 3.

Incident Reports 4.

I.E. Information Notices 5.

I.E. Circulars 6.

I.E. Bulletins 7.

Power Reactor Events 8.

INFO Significant Operating Events Reports 9.

Operations Supervisor Discussions 2.

Plant Manipulations Trainirn

'Ihe list of manipulations, Item 8, should include exercises with degraded power sources.

Reference:

I.A.2.1 of NUREG-0737 Response: 'Ihe Simulator Training program (plant manipulations) includes exercise with degraded sources. 'Ihe NGTAM will be revised to indicate this.

We concur with the overall goals of the Licensed (Simulator) Re-training Prwiam contained in Section 12.5.

However, the pr@ ram should also be haasd on the needs of individuals and crews as well as faarihack fran the site Operations section when any weaknesses are identified. In addition, simulator training may be a more suitable setting to deircr-Late operating experience.

Ecference:

Section 2.2.4.2 - Formal Classroom Training Section 2.2.4.5 - Performance Evaluation, Item I.C.5 of NUREG-0737.

Response: 'Ibe Operations Training Section has and does utilize faadhack from operating individuals and crews. 'Ihe simalator is used as a major input to performance evaluaticn and will continue to be used. 'Ihe NGrAM will be revised to reflect this.

Mr. Peter J. Tam June 30, 1906 Page 3.

Individual Study

'Ihe subjects contained in the monthly rnading assignments do not include provisions for review and self-study of significant operating experience and incident reports. Is this information contained in other ph==== of the s,om?

Reference:

Ihase 4, Section 2.2.3 - Scope of Training, Item I.C.5 of NUREG-0737.

Response: 'Ihe subjects of question may be covered by Monthly Study Guides or during Plant States Updates. 'Ihe NGTAM will be revised to reflect this.

4.

Performan Evaluation Evaluaticms of the performance and oca:petency of licensed personnel are conducted annually and appear to be conducted on the job as well as during exercises utilizing the Beaver Valley simulator.

'Ihese evaluations do not include provisions for evaluation of actual abnormal and emergency conditions nor are provisions in-cluded for accelerated training. In addition, performance evaulation criteria should be imindM in Section 2.2.5.3 of the pr 4 am.

Reference:

Section 4 of Appendix A - 10CFR55.

Response: Performance Eviduations, as described in Section 2.2.4.5 of the NGIAM, includes an annual evaluation of the Licensed operations personnel thre.igh the operations Supervisory chain, also included is the Annual Simulator Evaluation. In accition, personnel performance is reviewed by Supervision through the use of off-Normal Event EspusLis and Incident Reports. 'Ihe NGTAM will be revised to include the requirement for accelerated retraining haem cn an unsatisfactory performance on the evaluation. 'Ihis has always been the requirement at Beaver Valley.

Please see attached Performance Objectives for the Simulator Performance Evaluation.

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Mr. Peter J. Tam June 30, 1986 Page 5.

Frwicun Documentation With regard to rwdis, the gwicou should include written exam-ination answer logs, records of accelerated training for indivirtmla, reexaminations for written examinations and performance evaluaticos.

Reference:

Section 5, Appendix A, 10G R55 Fesponse: 'Ihe indicated records of question have been and are records that are maintained within the Frwtmu. 'Ihe NGIAM will be revised to indicate this.

6.

Instructor Oualifications Please identify the pronartwe(s) which establish the qualification of instructors and require instructors to be enrolled in an appropriate requalification prwicuu.

Reference:

Item I.A.2.1 of NUREG-0737 Please see attachment frcal Volume I of the NGIAM which defines instructor qualifications.

7.

Prwuuu Administration We have not been able to identify provision for waivers of licensed instructors and operations personnel who develop, administer and grade annual written examinations. Frwicuu which contain such provisions limit the number of waivers to two or three licensed individuals who are rotated every year. You should consider adding the feature to the requalification prwtanni.

Response: At present time, the annual written examination is prepared by an independent contractor under the super-vision of the Director-Cperations Training. 'Ihe examin-ations are reviewed and approved by the Director-Operations Training and one other designated Senior Reactor Operator within the Training Section. The examinations are administered and graded by the independent contractor and grading reviewed by the Training Section. Administration of the examination is conducted in accordance with Volume I of the NGIAM.

(see attached)

'Ihe NGIAM will be revised to included the developnent and approval authority.

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Mr. Peter J. Tam June 30, 1986 Page '

II. REFUEIJNG LICENSE RETRAINING 1.

Scoos of Trainim

'Ihis swsma lacks the Ihase V features ocmtained in the Licensed Operator Retraining P&wsm-.

Is Ihase V unique to licensed operators or do the refueling Ihase III oral examinations provide for periodic evaluations?

Reference:

Section 4, Appendix A of 10GR55.

Response: Within the Refueling License Retraining swimn, the phase III Oral Examination is utilized as the means for periodic evaluation. In addition, the individuals are rated on an annual basis against goals and objectives set for the u c.=ining their performance during a refueling outage.

(for those years that a refueling takes place).

2.

Formal Cls-tush Trainim Please refer to ocncerns in the licensed operator psupmu regarding Technical Specifications and applicable portions of Title 10GR.

Response: 'Ihese individuals, who are also Shift Technical Advisors i

also attend License Retraining as described in Section l

2.2.

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3.

Oral Examinations

'Ihere are no provisicos or criteria for accelerated training.

Reference:

Secticn 4, Appendix A of 10GR55.

I Response: 'Ihe requi&===d. has existed within the prwimu even though it was not prescribed within the NGTAM. 'Ihe NGTAM will be revised to incorporate this requirement.

4.

Ptwsmu Documentation Please refer to cr-rits contained in the license c.perator retraining program.

Response: 'Iha ICIAM will be revised to irmr@ rate oczuments.

Mr. Peter J. Tam June 30, 1986 Page 5.

Procram Referen_qs We ra'r==wwxt including the following references:

Prmarbre(s) which define the authority and responsibility of the Refueling Senior Operators, Applicable portims 10GR.

Reference to applicable systems and analyses contained in

FSAR, Reference to a Job and Task Analysis for Refueling Senior Cparatuso, i

'Ihe requested references will be aMad, except the job and task analysis. 'Ihe job and task analysis for Refueling Senior Operators is currently being conducted. Upon ocupletion, it will be used as an irput to the Retraining Program.

6.

Conditions of License With regard to actively performing duties under their license, the Refueling Senior Operatv&= probably exceed the limits of lOGR55

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31(e). 'Ihis conditim will ocntinue in the st-f r-i final rule-making of 10GR55. 'Iherefore, you should consider exceptions or a unique intasswi.ation for omditions of licenses for Refueling Senior Operators to participate in pre-refueling activities which include review of pm bres, testing fuel handlirq equipnent, 1

training and evaluatico of fuel handling pWLMAusl performing re-fueling activities.

Response: A hiption of what is considered active in accordance with 10GR55.31(e) will be revised into the NGIAM. 'Ihe description included is what has been done in the past.

DescriDtion:

Active Licenses - any licensee that is current and satisfactory within the scope of the Refueling License Retraining Prw tam and participates in pre-refueling activities, including testing of the fuel handling aT r-ant, review of suc.=dures and super-i vision of purwuel performing refueling activities shall be considered as having an active license in accordance with 10GR55.31(e). Any licensee that does not meet this requirau=it will be considered inactive and will require satisfactory empletion of an oral examination administered by an individual with an active Refueling Senior Reactor Operator.

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Mr. Peter J. Tam Ubne 30, 1986 Page 7.

Instruction Oualifications Please refer to the e,rmunants contained in the Licensed Operator Retraining Prwtam.

Please refer to I6.

Upon ocupleting the revision to the Nuclear Group Training Mministrative Manual, a copy will be forwarded for your review. If any further clarification is required, Mr. T. Burns of the Training Department will be available, at (412) 393-5751, for di= = ion.

Very truly yours, G. w ]Jos W

President ear Group cc: Mr. W. M. Troskoski, Resident In--+m-U.S. Nuclear Regulatory h 4 = ion Beaver Valley Power Station Shippingport, PA 15077 U.S. Nuclear Regulatory hiaion c/o Wnnant Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Capany P.O. Box 26666 One James River Plaza Richmand, VA 23261

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EVOLUTION / SCENARIO TITLE:

Operation at Power with Malfunctions License Operator Training, (V - 4) e I

SHIFT ASSIGNMENT NAMES RO(P)

RO(S)

SS STA 1:

2:

l 3:

4:

PERFORMANCE OBJECUVES:

EVALUADON (S. M U) 1.

Utilize the appropriate procedures and administrative 1

2 3

4 controls to iperate the plant at power.

2.

Utilize appropriate controls and indications to oper-1) ate the plant and plant equipment within specified limits.

2) 3.

Utilize appropriate alarms and indications to correct-ly assess plant conditions and recognize and diagnose 3) problems as they occur.

4.

Correctly prioritize required actions under multiple 4) casualty conditions or the loss / degradation of one or more critical safety functions.

5 ) '-

5.

Perform, from memory and in correct order (when re-quired), all immediate action steps required by appli-6) cable Emergency Procedures..

6.

Reference and follow all applicable Abnormal, Emer-7) gency and Alarm Respons'e Procedures.

7.

Recognize plant conditions requiring entry into Tech-8) nical Specification Action Statements.

8.

Utilizing the Technical Specifications, reference ap-9) propriate LCOs and determine the proper course of action.

10) l 9.

Properly supervise / monitor the activities of control room watchstanders, 11)

10. Communicate correctly and ef fectively.

11. Implement the EPP as required.

12)

12. Effectively manage / utilize other plant watchstanders and personnel.

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13. Observe good watchstanding practices.

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14. Perform all calculations required by the evolution 14)

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<n pengence I

INSTRUCTOR:

DATE:

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DUQUESNE LIGHT COMPANY Vol. 1 Nuclear Group Ch. 2 Training Administrative Manual Sect. 2.4 i

2.4 PERSONNEL QUALIFICATIONS I

2.4.1 Manager - Nuclear Training The Manager - Nuclear Training will possess a Bachelor of Science degree or the equivalent and will:

1.

Possess and maintain a USNRC Senior Operator License.

2.

Have 4 years of power plant experience, 2 years of which are nu-clear power plant experience.

3.

Demonstrate a working knowledge of nuclear facility operations and maintenance, instructional design principles, and regulatory codes I

and standards.

6 For the purposes of thdp manual, degree equivalency is defined as 4 Note:

years of formal academic trainjng or 4 years of professional level experi-ence, or a combination of the 60 totaling 4 years.

2.4.2 Training Directors and I;1structors Training Directors and Instructors will have a high school education and will have special training, education and experience consistent with as-l signed programs or t@ics.

The Manager - Nuclear Training may appoint or concur with tihe appoEntment of Duquesne Light Company staff personnel or consultants, to conduit instruction in their particular areas of expertise.

In addition to the foregoir.g general qualifications:

1.

Engineering Instructors will have a Bachelor of Science degree or the equivalent, as defined above.

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Revision 0 Page 2.13

DUQUESNE LIGHT COMPANY Vol. 1 Nuclear Group Ch. 2 Training Administrative Manual Sect. 2.4 i

2.

Nuclear Operations and Maintenance Instructors will possess and maintain a USNRC Senior Operator License or USNRC instructor certification for the Beaver Valley Power Station.

3.

Instructors who conduct simulator training programs will be appro-priately certified on the Beaver Va'lley control room simulator.

4.

Instructors who provide Qualification Standard Checkoffs (QSCs) will be qualified by successfully completing individual QSCs before administering them to others, except that personnel licensed or certified for the Beaver Valley Power Station need not complete QSCs for nuclear steam supply or emergency safety feature systems (NSSS/ESF).

5.

Systems training for the following training programs will be con-ducted by a qualified Nuclear Operations and Maintenance Instruc-tor or by other personnel who have completed training and QSCs for the systems being taught:

a.

Licensed operator training and retraining b.

Fuel handler training and retraining c.

Non-licensed operator training and retraining d.

Shift Technical Advisor training and retraining 6.

Training in t'ransient and accident analysis and integrated plant responses for licensed operators and Shift Technical Advisors will be conducted by qualified Nuclear Operations and Maintenance In-structors.

Equivalent qualifications may be achieved by having passed a USNRC licensing or certification examination at the senior operator level, combined with demonstration of adequate knowledge

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of the subjects being taught.

Revision 0 Page 2.14

DUQUESNE LIGHT COMPANY Vol. 1 Nuclear Group Ch. 5 Training Administrative Manual Sect. 5.2 i

sessions may be initiated by Nuclear Training Department personnel or by trainees themselves. A Report of Counseling may also be used to commend a

trainee for outstanding academic or general performance.

i 2.

Whenever it is desired to document such counseling sessions, a Re-port of Counseling (Figure 5.13) will b.e initiated by the involved member of the Nuclear Training Department.

3.

The original copy of the Report of Counseling will be placed in,the trainee's Individual Training File. Copies will be provided to the Training Director and the Director Personnel Administration.

Further distribution will be made at the option of tne counselor.

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5.2.3 Administration of Examinations 5.2.3.1 General Each person who proctors or administers an examination will assure that it is conducted in a formal and noncompromising manner.

Proctors will be knowledgeable permanent or temporary members of the Nuclear Training Department staff.

5.2.3.2 Conduct of Written Examinations The following guidelines will be observed by personnel who proctor written examinations.

Proctors will initiate any additional actions necessary to assure written examinations are administered in the correct manner.

1.

All material not required to complete an examination will be cTeared from desks or tables.

Revision 0 Page 5.11

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DUQUESNE LIGHT COMPANY Vol. 1 Nuclear Group Ch. 5 Training Administrative Manual Sect. 5.2 i

2.

Examinations will be proctored continuously.

If required, arrange-ments for a relief should be made before the start of examinations.

3.

Trainees' requests for clarification will be addressed to the proc-tor. Clarifying information will be provided to all trainees.

4.

Only one trainee at a time will be permitted to leave the examina-tion setting while the examination is in progress, except as speci-fied in 5, below.

1 5.

As trainees complete examinations, they will turn them in to the proctor and leave the general vicinity of the examinati.on setting, as defined by the proc' tor, until all trainees are finished or until the examination is terminated.

6.

If a trainee is observed cheating on an examination, the examina-1 4

tion will be collected by the proctor and marked with the date, time, a short description of ' circumstances, and the proctor's ini-tials.

The trainee will be assigned a grade of zero.

The incident will be brought to the attention of the supervising Training Director as soon as practicable.

5.2.3.3 Conduct of Practical Examinations 1.

Practical examinations will be administered in accordance with associated 0JT Qualification Checkout Sheets.

2.

The examiner will normally provide the trainee with required tools, equipment and procedures.

In some cases, the trainee may be re-quired to assemble these items'as part of the examination.

Revision 0 Page 5.12 u