ML20210S096
| ML20210S096 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/09/1987 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Berkow H NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20210S100 | List: |
| References | |
| P-87049, TAC-64747, NUDOCS 8702170559 | |
| Download: ML20210S096 (16) | |
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16805 WCR 19 1/2, Platteville, Colorado 80651 February 9, 1987 Fort St. Vrain Unit No. 1 P-87049 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C. 20555 Attention:
Mr. H. N. Berkow, Director Standardization and Special Projects Directorate Docket No. 50-267
SUBJECT:
Fort St. Vrain Licensed Operator and Special Senior Licensed Operator Requalification Program Additional Information
REFERENCES:
- 1) PSC Letter Gahm to Berkow, Dated April 28, 1986 (P-86336)
- 2) PSC Letter Gahm to Heitner, Dated August 4, 1986 (P-86506)
- 3) NRC Letter Hinson to Williams, Dated December 29, 1986 (G-86659)
- 4) NRC Letter Heitner to Walker, Dated June 20, 1986 (G-86335)
Dear Mr. Berkow:
The Fort St.
Vrain Licensed Operator Requalification Program was submitted to your office for review in the PSC letter Reference 1.
You responded with a request for additional information which was provided in Reference 2.
This included the description and procedure for the Special Senior Licensed Operator Requalification Program.
8702170559 870209 PDR ADOCK 05000267 V
PDR I
p P-87049 February 9,-1987 In Reference 3,
you again requested additional information en both the Licensed Operator and the SSLO Requalification Programs.
The additional information is included with this letter in the form of four enclosures. contains requested information for the Licensed Operater Requalification Program. is a copy of the revised and approved Licensed Operator Requalification Procedure (TP-LR). contains requested information for the Special Senior Licensed Operator Program. is a copy of the newly developed and approved training procedure for Special Senior Licensed Operator Program (TP-SSLO).
TP-LR and.TP-SSLO have been approved by the Plant Operations Review Committee (PORC) and implemented. They respond to the needs of the new accreditation program which is in effect, and they fill or exceed the requirements of the current NRC approved requalification programs.
Any comments or questions concerning this submittal should be made directly to Mr. M. H.~ Holmes at (303) 480-6960.
Sincerely, NY l
J. W. Gahm i
Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/SRW:sl i
Enclosures cc: Mr. K. L. Heitner, Project Manager Standardization and Special Projects Directorate Regional Administrator, Region IV Attention:
Mr. J. E. Gagliardo, Chief
}g Reactor Projects Branch 1
Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain
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r ADDITIONAL INFORMATION FOR THE LICENSED REQUALIFICATION PROGRAM 3.5 Waiver Requirements NRC CONCERN:
The staff accepts the waivers contained in sections 3.5.1 through 3.5.3 for license personnel and instructors providing an oral evaluation is conducted once every two years. With regard to Itcense instructors in section 3.5.4, written annual examinations may be waived for a period of up to two years and oral examinations must be conducted at least once every two years.
PSC RESPONSE:
Section 3.5 Vaiver Requirements will be reworded as follows:
3.5.1 Instructors will be excused from those lectures, quizzes, and examinations which they have prepared, reviewed, or presented.
3.5.2 Individuals who conduct operating / oral examinations shall be excused from taking said examinations.
3.5.3 Individuals who review the annual requalification written and oral examination shall be excused from taking said examinations provided an oral evaluation is conducted every two years.
3.5.4 Instructor involvement in preparation, review and/or conduct of the annual written and oral examinations shall be rotated so that each instructor will be required to take a written and an oral examination during each two year period. The written and oral examinations need not be taken during the same requalification year.
)
i Note:
Sections 3.5.1 and 3.5.2 apply to the implementation of the Licensed Requalification Program normal rotations.
Sections 3.5.3 and 3.5.4 apply only to the annual Licensed Requalification examinations.
It is our intent to have i
instructors, who fall under section 3.5.4, rotate the written l
and oral examinations in the two year period resulting in an l
annual evaluation of each instructor.
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4.1.5 & 6 Operations Seminars, On Shift Reviews NRC CONCERN:
The response does not answer the staff's concern for timely review of changes to facility design, procedures or license.
The review of Required Reading in Section 4.3.1.1 or the Station Manager Administrative Procedure, SMAP-8, should provide for review of changes and should be referenced in this program.
PSC RESPONSE:
Sections 4.1.5 and 4.1.5, reworded as follows, identify Training's respons!bilities for timely review of changes to facility design, procedures or license. A note will also be added to the procedure referencing the Shift Turnover Procedure, SOAP-4 (SMAP-8 has been replaced by SOAP-4).
4.1.5 Operations Seminars shall be utilized during the classroom / laboratory portion to review LER's, OIAG material, and any significant information s'
that each licensed operator and senior or.erator is cognizant of facility design changes, procedure changes, and facility license changes.
4.1.6 On shift Review In order to ensure that any procedural changes, Technical Specifications
- changes, plant modifications, and LER's which take place during those months when operations seminars are not held, on-shift review of the material may be held.
Note:
Timely review of changes to facility design, procedure or license shall be accomplished in accordance with SOAP-4, Plant Operations Shift Turnover Procedure.
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I Enclosura 1 9.2.1 Classroom Instruction NRC CONCERN:
The reference contained in the NRC concern for this section should have stated:
" Applicable Portions of Title 10, Chapter 1, Code of Federal Regulations." Please modify your program to adopt this change.
PSC RESPONSE:
Section 4.2.1., i and j will be added as follows:
4.2.1.1 Mitigating Core Damage 1)
Mitigation of Accidents 4.2.1.j Applicable portions of Title 10, Chapter 1, Code of Federal Regulations NRC CONCERN:
Describe any mitigating core damage procedure development that may have been done.
PSC RESPONSE:
A Mitigating Core Damage Program was initially developed prior to the accreditation process that met the requirements of NUREG 0737, Item II.B.4.
That program, which is no longer being used, has been attached for your review per your request.
The accreditation process performed by the Operations Training Unit, utilizing INP0's TSD principles, produced Mitigating Core Damage skills and knowledges that were more inclusive than the topics listed in the old procedure. The lesson plans that they generated were more job specific than the previous training
. program. Therefore, the accredited training program meets the intent of NUREG 0737, Item II.B.4.
The accreditation process in progress for the Technical Training Unit, utilizing INP0's TSD principles, also generated job specific lesson plans on Mitigation of Core Damage for the following programs:
Results Technical Advisors Health Physics Radiochemistry
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4.2.2 & 3 Laboratory / Task Training - Control Manipulations NRC CONCERNS:
The emergency procedures contained in Section 4.2.1 " Classroom" and the evaluation process in Section 4.2.2 are conducted over a two year period.
The previous Requalification Program, submitted on January 2,1981, contains provisions for annual review of Technical Specifications and Abnormal and Emergency Procedure review process. However, based on the rationale of PSC review of the change, procedure review may have been within the requirements of Section 3d of Appendix A and the provisions of 10 CFR Part 50.54 (1-1).
PSC RESPONSE:
PSC has decreased the frequency of review for Technical Specifications, Emergency and Abnormal Procedures from one year to two years.
10 CFR Part 55, Appendix A, Requalification Program Requirements, 3d states that review of the contents of all abnormal and emergency procedures be done on a regular basis. The accreditation process, based on INP0's TSD methods, indicates that the material necessary to be reviewed by licensed operators has significantly increased over the old requalification program.
The Task Analysis for Licensed and Senior Licensed Operators has generated a requalification program that is more performance based and increases the depth of knowledge required for all Job Performance Measures (JPM's) and Lesson Plans (LP's) including abnormal and emergency procedures.
Therefore, in order to provide an accredited Requalification Program based on INP0's TSD methods, it is necessary to expand the time period for review of Technical Specifications, Abnormal and Emergency Procedures from one year to two years. Although first indication is that abnormal and emergency procedure training may be decreasing, in reality the amount and depth of training received has increased and will produce individuals with more awareness and ability to deal with abnormal and emergency situations. The requalification program is structured such that Technical Specifications, Abnormal and Emergency Procedures will be covered in a two year cycle.
This is in accordance with 10 CFR 55, Appendix A, Requalification Program Requirements, Part I and Part 3d.
Submitting FSV's Licensed Requalification Training Procedure for your review and approval meets the requirements of 10 CFR Part 50.54(1-1).
'EnclosurQ 1 4.2.2 Laboratory / Task Training - Evaluation NRC CONCERN:
The Requalification. Review Panel needs to be alerted to the performance of the individual or crew during actual events.
PSC RESPONSE:
This is documented on Form 0-11 and the PSC response to 4.4.2.2 is also applicable.
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, Additional PSC Comments 4.2.2 Laboratory / Task Training - Evaluation The original response given in letter P-86506 dated August 4, 1986, has been reviewed and it was determined that the documentation was unwieldy and redundant.
It is the responsibility of the Supervisor of Operator Training to insure that remedial training is developed and completed satisfactorily utilizing the Training Development Request (TDR) procedures as stated in TMP 4.1.
Section 4.2.2 will be reworded as follows:
4.2.2.1 Over the two year requalification period, all licensed individuals shall be evaluated on the performance of manipulations listed in Step 4.2.3.
Tasks must be performed or simulated by walkthrough with a member of the Training Staff or qualified individuals as defined by TP-TI.
4.2.2.2 If an ir.dividual simulates a
task by walkthrough, performance of the task will be evaluated by use of the Job Performance Measure (JPM) for the specific task. Completion of the simulated tasks shall be documented on a Reactivity Manipulation Sheet (Form 0-11).
4.2.2.3 If an individual has actually performed or supervised the performance of a
task satisfactorily, the individual will be given credit for performing the task. Performance of the task is satisfactory if the actions of the operator during the task are within procedural requirements and will be documented on Form 0-11, page 1.
The actual event is summarized on Event Description, Form 0-11, Page 2,
and attached to the Reactivity Manipulation Sheet (Form 0-11), Page 1.
If additional training needs are identified as a result of the event or the performance of the task is unsatisfactory, Form 0-11 (both pages) shall be submitted with a Training Development Request (TDR) for evaluation by the Operator Training Unit.
_- 4.3.1.2 Performance on Unit Examination NRC CONCERN:
The staff disagrees with PSC's response. Unit examinations provide a continuing evaluation process of individual knowledge.
The subject matter contained in lectures or other settings may be misinterpreted by one or more individuals.
While total scores represent passing, individual question scores need to be further evaluated. The program :hould be revised to provide for examination evaluation and additional tutorial sessions as determined by the instructor and the training supervisors.
PSC RESPONSE:
Training has structured the Operator Requalification Program such that there are five opportunities for students to attend all lectures.
It is also a requirement that individuals attend at least 80% of the lectures and that they achieve at least 80%
or greater on their written examinations.
If an individual misses a lecture or fails an examination, he is required to l
make-up the missed lecture or retake the failed exam.
It would l
be impossible for the Training Department to provide classroom instruction by instructors on all missed lectures or failed I
examinations in the one week period designated for make-up.
Therefore, it is necessary to find an alternative method that provides the opportunity to meet the requirements of the Requalification Programs.
TP-LR and TP-NUT state that any missed lectures, examinations, or failed examinations must be made-up prior to the completion of the Requalification Program.
It was intended that this make-up be completed by the individual on a "self-study" basis due to the time constraints and physical impossibility of classroom instruction. This "self-study" does not leave the individual to his own methods to learn material.
It is a guided self-study as delineated below.
The Training Department will provide individuals who must complete make-up with the materials necessary to complete the missed lectures.
This will include the lesson plan and the necessary attachments. Since it is extremely important that each individual have the opportunity to be involved in the classroom discussions that occur during instruction, Training has committed to have each rotation of the Requalification Programs video taped so they may be used for make-up purposes.
Therefore, in most cases, it will also include a video tape of the lecture. The student will be responsible for preparing himself for the examination using these materials. As some classes do not lend themselves to video taping (classes that rely heavily on student interaction such as Teambuilding, Communications, etc.), it will be necessary for the student to make arrangements with the Training Department to make-up those classes by other means.
In all cases, an instructor will be available to assist the student in his preparation and to administer the examination, j
- c. When a student does not receive a passing grade. on an examination, he.is given an opportunity to review the _ material that was provided.
The examination is also. reviewed with an instructor and the student signs the cover sheet stating that he has reviewed the examination with the instructor and has been informed of and understands the correct answers to any questions he may have missed. He then has the responsibility of preparing himself for the reexamination using the materials and the test review.
The instructor will be available to assist the student in answering any questions regarding the make-up, administer the reexamination, and provide additional tutorial sessions as determined necessary by the instructor and the Training Supervisors. This exam review process provides an evaluation of examinations, and when coupled with the Training Development Request (TDR) System as described in TMP 4.1, allows for a continuing evaluation of individual knowledge.
It would be ideal to provide students with the. opportunity to
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attend classes' designed specifically for make-up of missed lectures or make-up of failed examinations. However, Training offers each lecture and class five times each year and each operator;. has the responsibility:.to meet the training requirements as stated in the Training Procedures.
Since time constraints and necessary manpower make it physically impossible to reteach each individual who missed a lecture or failed an examination, it is necessary to utilize other methods to insure that students meet the training requirements.
Therefore,
- Training will continue to implement the make-up system as stated
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74.4.2.2 LRequalification Review Panel NRC CONCERN:
PSC should verify that there are adequate records which reflect.
on-the-job performance.
PSC RESPONSE:
The following statement will be added to section 4.4.2.2:
"The following criteria shall be used for the evaluation'of an individual's eligibility to continue in the program:
a.
The individual's performance on the job as evaluated in accordance with'SMAP-20, Procedure for Supervisor Responsibilities, and actual manipulations as per Section 4.2.2.3 of this procedure.
b.
The individual's performance in previous-requalification training.
c.
The need.for the individual's license."
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<Use of Form 20, Trainino Needs Survey 4
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NRC CONCERN:
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Verify that FSV's Training Management Procedure (kMP.4.1)
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includes notification to individuals that they may request 1
additional training.
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PSC RESPONSE:
Training Management Procedure (TMP)4.1,Section4.1.4, states that any employee may -request., training development by' completing a Training, Development Request, Part 1, Attachment TMP 4.1f, and forwarding the request to the Training Support Supervisor for' informational analysis, per Section 4.2 of the TMP. Also, Form 20 will be reinstated into the TP's'to provide another mechanism for operator input into the training program.
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!?~ %- v ~ r Rh. <h'p / Attachment i u ~[ k TrP-25 t / MITIGATING CORE DAMAGE / z, f@a, 1.0 Purpose This program is a comprehensive list of all topics necessary to insure that all pertinent station personnel are adequately trained in' cheir areas of responsibility towards mitigating core j damage. 2.0 Aeolicability [
- l This training program is applicable to'Results, Health Physics, y
Radiochemistry, Operations, and plant management personnel as [ )(p' g noted under each topic. g /E>";f 3.0 General Descriotion sigd 3 b. Training is required annually in the topics listed below for the 5 (,,,. p 1-indicated personnel. This training need not be consecutive. W., / j jfJ 3.1 Licensed Personnel o, 3.1.1 Emergency Procedures \\r \\ J'/ 3.1.2 FSAR Accidents 3.1.3 Nuci m..atrumentation p 3.1.4 Area and Process Monitors r 3.2 Technical Advisors, Superintendent of Operations, and Station Manager 3.2.1 Emergency Frocedures i o 3.2.2 FSAR Accidents 3 3.2.3 Nuclear Instrumentation 3.2.4 Area and Process Monitors J)- ie I} 3.2.5 Computer Programs s) \\ p g 3.3 Health Physics Technicians and Health Physics Supervisor s' / 3.3.1 Area and Process Monitors e s i 3.3.2 Methods of Determining Reactor Building Dose Rates from Outside the Reactor Building 3.3.3 Applicable Portions of Primary Coolant Chemistry , N:, ur"^' o ') w -+ ,ww, y. y-r ,--,v -,v--- -~----w--vw- --,r w ,-- - - + - - - - -em
i Attachment . 5 3.4 R diochemistry Laboratory Technicians and Radiochemistry -Supervisor ~ > 3.4.1 Primary Coolant Chemistry Y 3.5 Results Instrument Technicians, Engineers and Supervisors i 3.5.1 Nuclear Instrumentation 3.5.2 Area and Process Monitors 4.0 Procedure e 4.1 Training Schedule 4.1.1 Licensed Personnel Licensed Personnel wi11 receive this training during each requalification year. The topics will be covered individually as each fits into the requalification year schedule. 4.1.2 Technical Advisors, Superintendent of Operations, and Plant Managers These
- personnel will normally receive this training-during the Technical Advisor Requalification Training.
-If conditions exist such that this is not convenients or feasible, the training can be scheduled!at an, earlier or later date not to exceed t 3 months from the final day of requalification. 4.1.3 Health Physics Technicians and Health Physics ,,A Supervisor a Training will be scheduled annually 2 3 months as determined by the Training Supervisor and Radiation Protection Manager. As Health Physics personnel work shifts, it is anticipated that it will take repetitive classes to achieve full i 1'\\* participation. f. t L 4.1.4 Radiochemistry Labora tory Technicians and Radiochemistry Supervisor s Training will'be scheduled as in 4.1.3 above. 4.1.5 Results Instrument Technicians, Engineers, and t Supervisors 1 Training will be scheduled annually i 3 months as determined by the Training Supervisor and the Q Superintendent of Nuclear Betterment Engineering. l< ..,_.-_.e-,- -.,m--._,___-e_. __-m,e~3 r.., Attachment 3., 4.2 Topic Details 4.2.1 Emergency Procedure Training Emergency Procedure "G" - Extended Loss of Forced Cooling will be covered in this training. As this procedure references the Safe Shutdown Cooling under Highly Degraded Conditions Document and Abnormal Procedures for Shutdown Cooling, they will be covered under this topic. Included is a means for extended range readings of region outlet thermocouples. 4.2.2 FSAR Accidents Training This training will cover DBA-1, DBA-2, and MCA in the FSAR. This training will emphasize prompt operable actions and consequences of failure to act within specified time frames. ~ 4.2.3 Nuclear Instrumentation This training will include the location, type, and limits of the Nuclear Instrumentation as well as expected response under accident conditions. This subject will also cover all operational aspects of the Nuclear Instrumentation such as trips, alarms, and overlap conditions. 4.2.4 Area and Process Monitors Training This training will cover the area and process monitors in detail such as operational requirements, failure modes, sources of expected activity, and expected response under highly degraded conditions. Health Physics and Results personnel will receive additional training in methods to read and calculate dose rates from the RIS modules as well as expected detector accuracy. r--
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Attachment 4.2.5 Computer Program Training This training will familiarize the appropriate personnel with the abilities of the various computer programs to aid in accident analysis. This should include calculations of expected maximum and average fuel temperatures after LOFC, the relationship between core outlet thermocouple readings and interior core conditions under no flow situations, expected fuel failure as 'a function of interior core temperatures, percentage of fuel failure as a function of circulating activity and assessment of liner and concrete conditions as a function of liner cooling water temperatures. 4.2.6 Methods of Determining Reactor Building Dose Rates from outside the Reactor Building This training will provide a means for the appropriate personnel to estimate dose rates inside the reactor building without requiring entry. 4.2.7 Primary Coolant Chemistry This training will provide the appropriate personnel with information on the expected analyses if fuel damage has occurred, including isotopic analyses results as well as means to monitor LTA performance during a rapid depressurization. Health Physics personnel will receive training in the expected hazards of transport of primary coolant samples after significant fuel degradation has occurred. 5.0 References NUREG 0737, Item II.B.4 Letters from R. M. Harrington date'd June 8, 1981, and September 14, 1981, on Fort St. Vrain Application of NUREG 0737, Item II.B.4. e O ,,,~._.-,-_,-__,,.,...-.,_.4 - -. _..,.. -}}