ML20210N840
| ML20210N840 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 05/01/1986 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-1.A.2.3, TASK-TM 0C0486-0076-NL0, C486-76-NL, NUDOCS 8605050272 | |
| Download: ML20210N840 (3) | |
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@rewaums Consumers Pavver AIKNEAFS MISEftE55 oeneral offkes: 1945 West Parnell Road. Jackson MI 49201.(517) 788 0550 May 1, 1986
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INSTRUCTOR TRAINING AND QUALIFICATION The Palisades Operations Training Programs have recently been accredited. The Big Rock Point Operations Training Program accreditation is expected this summer. Discussions with members of your staff have prompted this letter to clarify our position with respect to instructor training qualifications.
In your letter of March 28, 1980, on Qualifications of Reactor Operators, training criteria for instructors was provided which required operations instructors to have a senior operator license and be enrolled in a requalifi-cation program. On October 31, 1980, NUREG-0737 was issued.
Item 1.A.2.3, Administration of Training Programs, reiterated the criteria in your previous letter and provided clarification for this short-term position. The NUREG-0737 position further stated, however, that accreditation of training institutions would include review of the necessity for completing a SR0 examination for the training instructors. The SRO license was intended to provide a level of technical competence.
Consumers Power Company letters of December 19, 1980, provided our position in response to Item I.A.2.3, that the permanent operations training instructors at Palisades and training coordinator at Big Rock Point would have SRO quali-fications and be enrolled in appropriate requalification programs.
The NRC safety evaluation reports of November 8, 1982 (BRP) and December 2, 1982 (PAL) and their attached Technical Evaluation Reports concluded the requirements of TMI Items (NUREG-0737) 1.A.2.1 and I.A.2.3 were resolved by virtue of the appropriateness of our training and requalification programs.
Those programs required instructors of the RO/SR0/SE hot license and requali-fication programs to meet the following conditions prior to and during their assignment as operations instructors.
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To hold or have held a SRO License on the facility where instructing, or 2.
To hold or have held a NRC Instructor Certificate on facil14y where instructing, and 3.
To meet Conaumers Power Company's qualification for instructional capabilities as set forth in Consumers Power Company's instructor certification programs, and 4.
To be enrolled in a requalification program to ensure he stays cognizant of current operating history, problems and changes to procedures and administrative controls.
Consumers Power Company's commitments to the above items were two-fold:
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To ensure qualified instructors conduct training, and 2.
To ensure qualifications for RO/SRO instructors meet or exceed those as established in Enclosure 1 Sections 2d and 2e of your March 28, 1980, letter.
On December 18, 1985, the Institute of Nuclear Power Operations (INPO) accred-ited the Palisades Operations Training Programs, including Initial Hot License RO/SRO/SE, Initial AO, and Requalification (continuing training) programs.
These programs include the recommendations established for instructor certiff-cations as set forth in INPO Guideline 82-026. Technical Instructor Training and Qualification. Consumers Power Company's Palisades and Big Rock Point instructor technical qualifications meet or exceed the requirements in Table 1 of the INPO Cuideline for the training of R0s/SR0s/SEs/ engineers or technical managers. Maintaining accredited programs at Palisades and attaining accredi-tation later this surmer at Big Rock Point will require that, with respect to instructor qualifications, objectives 2 and criteria 2.1 through 2.8 in Appendix A of The Accreditation of Traiaing in the Nuclear Power Industry (INPO 85-002, January 1985) are met.
Objective 2 states:
training staff (utility and contracted, if used) possess the technical knowledge, the experi-ence, and the developmental and instructional skille required to fulfill their i
assigned duties. Consumers Power is committed to meetir.g this objective by fulfilling the eight criteria established by INPO.
Ccmpliance with the accreditation criteria will no longer require that opera-tions instructors have a SRO license or NRC Instructor Certification. This position, we believe, is fully compatible with NUREG-0737 Item I.A.2.3 and the position the NRC has taken in statements concerning Final Rulemaking revisions to 10CFR55. The NRC recognizes the accreditation of training programs which includes instructor training, qualification and evaluation meets the intent of the Policy Statement on Training Qualifications, March 20, 1985, and super-sedes the need for training instructors to maintain a SRO license.
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Although'not required following accreditation, Consumers Power Company be-lieves it prudent to utilize NRC licensed training instructors, and will, therefore, continue to maintain and apply for licenses for certain instructors meeting the training requirements. We request the NRC to support our efforts j
to maintain this level of qualification in our training staff.
Those individuals with NRC Instructor Certificates will no longer renew their certification.
Instead, Consumers Power Company will administer equivalent instructor certification which, like an NRC issued certificate, will require successful completion of written, oral and simulator examinations.
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James L Kuemin Staff Licensing Engineer l
CC Administrator, Region III, USNRC NRC Resident Inspectors - Big Rock Point & Palisades l
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