ML20215C329
| ML20215C329 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/02/1986 |
| From: | Boger B Office of Nuclear Reactor Regulation |
| To: | Berkow H Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM TAC-61470, NUDOCS 8610100238 | |
| Download: ML20215C329 (10) | |
Text
,
n nero UNITED STATES E's 4
NUCLEAR REGULATORY COMMISSION a
y WASHINGTON, D. C. 20555
/
acu en MEMORANDUM FOR: Herbert N. Berkow, Project Director Standardization and Special Projects Directorate Division of PWR Licensing-B FROM:
Bruce A. Boger, Deputy Director Division of Human Factors Technology
SUBJECT:
FORT ST. VRAIN - LICENSED OPERATOR REQUALIFICATION PROGRAM (TAC N0. 61470)
The Public Service Corrpany of Colorado (PSC), in a letter of August 4,1986, provided additional information to our request transmitted to PSC on June 20, 1986, concerning the Fort St. Vrain Licensed Operator Requalification Program. The reason for our initial review of the program was based, in part, on a request from Region IV concerning provisions for accelerated training. This request.was transmitted to PSC in a letter of April 28, 1986.
We have reviewed PSC responses and find, with some exceptions, that the Licensed Operator Requalification Program meets the requirements of Appendix A of 10 CFR Part 55 and the provisions contained in Item I.A.2.1 of NUREG-0737. With regard to Item II.B.4 of NUREG-0737, we are preparing a summary of our review and will be forwarding it to your office within 7 days. contains an interim evaluation.
In response to the June 20, 1986, letter, PSC has also provided the Fuel Handler (Special Senior Licensed Operator (SSLO)) Requalification Program for review. We have reviewed the SSLO program and determined that we need additional information to complete our review. The request is contained in.
DHFT is aware of Region IV's requalification examination of licensed personnel at Fort St. Vrain which resulted in an unsatisfactory evaluation of the program. The results of the examination and subsequent meeting with PCS to implement corrective actions is contained in the RIY report, 50-267/0L 87-01 of August 4,1986. Region IV will administer an additional round of requalification examinations on September 15, 1986.
We have reviewed PSC proposed corrective actions to Region IV and PSC response to the RAI of June 20, 1986, and determine that there m_ay have been some contributing factors in the program which led to poor performance during requalification examinations. The areas include: Operations Seminars, On Shift Reviews, Laboratory / Task Training - Control Manipulations and Performance on Unit Examinations. PSC should delay modifications to the current program until the September 1986 requalification examination is evaluated by Region IV and the results transmitted to PSC.
fQ w
, Since PSC will submit a revised requalification program for licensed operators and will respond to the RAI for fuel handlers - SSLO, we will provide a SALP on the conclusion of our review.
This review was conducted by Joseph J. Buzy, HFMT.
Bruce A. Boger, Deputy Director Division of Human Factors Technology i
Enclosures:
As stated i
i si i
5 l
f 4
i l
INTERIM EVALUATION OF THE FORT ST. VRAIN LICENSED OPERATOR REQUALIFICATION PROGRAM The Public Service Company of Colorado (PSC), in a letter of August 4,1986, provided a response to a request for additional information (RAI) concerning the Fort St. Vrain Licensed Operator Requalification Program and provided the Fuel. Handler (Special Senior Licensed Operator (SSLO)) Requalification Program. The RAI was in an NRC letter of June 20, 1986.
PSC also advised the Comission that changes to the licensed operator program would be made within 30 days after Commission approval. Our coments are contained under
. pecific and General Comments.
With regard to Specific and General Coments to the licensed operator program, PSC should delay modifications to the current program until the September 1986 requalification examination is evaluated by Region IV and the results transmitted to PSC. PSC should then provide resolution of our coments and a revised program.
With regard to the SSLO program, we have included a requast for additional information at Enclosure 2.
PSC should respond to this RAI within 30 days of receipt of this request.
I.
Specific Commen$
3.5 Waiver Requirements We accept the waivers contained in Section 3.5.1-3.5.3 for licensed personnel and instructors providing an oral evaluation is conducted once every 2 years.
With regard to licensed instructors in Section 3.5.4, written annual examinations may be waived for a period of up to 2 years and oral 1
examinations must be conducted at least once every 2 years.
1.
, 4.1.5 & 6 Operations Seminars, On Shift Reviews The response does not answer our 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 be referenced in this program.
4.2.1 Classroom Instruction
~
The reference should have stated " applicable portions of Title 10, Chapter 1, Code of Federal Regulations." Please modify your program to reference this change.
With regard to mitigation of core damage procedures referenced ti the March 24, 1982, letter from R. A. Clark to D. Warenbourg, we have further researched this concern and determined that Item II.B.4 of NUREG-0737 was found satisfactory in the Order confirming PSC comitments on post-TMI' issues which was transmitted to PSC on April 27, 1983. We will request. additional assistance in this issue by separate correspondence.
Please refer to our comments in 4.2.2 & 3 regarding review of abnormal and emergency procedures.
4.2.2 & 3 Laboratory / Task Training - Control Manipulations We have reviewed ti.ose events listed in the current Fort St. Vrain emergency procedures and determined that the loss of off-site power and rod withdrawal accidents are addressed in Section 4.2.3 of the program. This satisfies our Concern.
A further review of your program indicates that the emergency procedures contained in Section 4.2.1 " Classroom" and tiie evaluation process in 4.2.2 are conducted over a 2 year period. The previous requalification program
i
, I submitted on January 2,1981, contain provisions for annual review of Technical Specifications, Abnormal and Emergency Procedures.
It appears that the current program has ejtended the Abnormal and Emergency Procedure review process. However,basedlntherationaleofPSCreviewofthechange, procedure review may have been within requirements'of Section 3d of Appendix A and the provisions of 10 CFR 50.54 (1-li. PSCsibuldrespondto this additional concern.
4.2.2 Laboratory / Task Training - Evaluation PSC's response should include provisions to alert the Requalification Review Panel of individual or crew performance during actual events. See PSC response to NRC concerns in 4.4.2.2.
l 4.3.1.2 Performance on Unit Examinations l
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 have been misinterpreted by one or more individuals. While total scores represent passing, individual question scores need to be further evaluated.
The program should provide for examination evaluation and additional tutorial sessions as determined by the instructor and the training supervisors.
4.4.2.2 Requalification Review Panel l
PSC response is acceptable. However, PSC should ensure that there are i
adequate records which reflect on the job performance.
l
e 4 II. General Comments 1.
Use of Form 20, Training Needs Survey Does the Training Management Procedure (TMP 4.1) include notification to individuals that they may request additional training?
2.
Licenses Limited to Fuel Handling Our comments are contained in Enclosure 2.
3.
Maintenance of Records PSC response is acceptable.
I
r
~
The Fuel Handler (Special Senior Licensed Operator (SSLO)) Requalification Program is appropriate for planned activities and contains the necessary elements in Appendix A of 10 CFR Part 55 as well as those considered in future rulemaking. However, the program lacks specific requirements in the following elements:
A.
Lectures Procedures should include those normal, abnormal and emergency procedures related to fuel handling.
There are no lectures which include technical specifications applicable for fuel handling.
There are no lectures for applicable portions of Title 10, Chapter 1, Code of Federal Regulations.
B.
On-the-Job / Additional Training There are no provisions for review of abnormal and emergency procedures on a regularly scheduled basis.
(Please refer to General Comments)
Fuel handling manipulations appear to be limited to practice before actual in-core fuel handling. There are no provisions for simulated exercises or other forms of practice.
C.
Evaluations There is no methodology or passing criteria for performance evaluations.
There is no accelerated training criteria for unsatisfactory performance evaluations.
There appears to be no records for performance evaluations.
There appears to be no formal retraining or reexamination if licensed personnel do not achieve passing criteria on written examinations.
Reexamination appears to be limited to an oral examinatfon.
General Comments The requalification program does not appear to provide for continuing training or practice to maintain proficiency at any time after the scheduled refueling or the annual requalification training. Therefore, SSLO may not perform duties or obtain practice for periods up to 1 year, thereby would be subject to provisions contained in 55.31(e) or similar conditions contained in future rulemaking.
If not included in other procedures, you should consider an additional provision in this program to allow retraining and practice before appointing SSLO to licensed duties as prescribed by 50.54(1).
Return to duty programs should include:
1.
Review of LERs and significant industry events related to fuel handling.
2.
Review of refueling and related abnormal and emergency procedures including any specific refueling procedure changes.
3.
Review of changes to equipment and facility license related to fuel handling.
4.
Participate in preparation of fuel handling equipment and related systems and be cognizant of activities performed during this period.
p s...
- 5.
Practice manipulations of fuel handling equipment or related activities.
6.
Any evaluations deemed necessary before appointing the SSLO to licensed duties.
With regard to retraining if individual does not achieve quiz scores of greater than 80%, the program requires review of lesson plan material as the method of remedial assignments. The program should also include examination evaluation and tutorial sessions as determined by the instructor and the training supervisor.
r 4
Ooc'nch No, so-167 Doke ',
\\2Ilf86
. S+i
+ o ',
Po cke t Fi ler on M.c %sowL.'iR Arec P-1st Eom Fo 3+6V M acn en P co st Ve a, r, S u\\od :
PrhcLtd Ab Ocea A
The ahcued am%
docm
+
bwr locem provsded b
tW c Fu W1'E S - vtch com pa ry ov Cclomd o,
~1m a cu d o nce.
w%
N R yt.
OSEce.Lebc
%. n we
< e y e r+ %A-aro v18 e cop e r-40 y om fue 4(EC onc1 Locui Fy9 R's av e
nt i ~
/Ab,
/J w Ow g
C. Hnso m
-