ML20235Y726
| ML20235Y726 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/06/1987 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235Y729 | List: |
| References | |
| P-87355, TAC-64747, NUDOCS 8710200464 | |
| Download: ML20235Y726 (5) | |
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hPublic Service.
P."J.h P.O. Box 840 Denver, CO 80201- 0840
' October 6, 1987' R.O. WILLIAMS, JR.
. Fort St. Vrain VICE PRESIDENT Unit No. 1' NUCLEAR OPERATIONS P-87355 i
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555' Attention: Mr. Jose A. Calvo, Director Project Directorate IV Docket No. 50-267
SUBJECT:
Request for Additional Information for SSLO Training Program
REFERENCE:
NRC Letter Heitner to Williams, Dated July 30, 1987 (G-87257) i Dear Mr. Calvo.
1 This letter is in response to your request for additional information as identified 'in the referenced letter.
We have attached the information requested (Attachment 1) and also the documents which in addition to TP-SSLO, provide the basis for meeting the requirements l
of 10 CFR 55 (Attachments 2, 3, and 4). We feel the SSLO Training i
Program does meet the criteria of 10 CFR 55 and will be acceptable for INP0-accreditation.
l If, after your review of this additional information, you have questions or additional concerns, we feel it would be important to meet with you to discuss the SSLO program and assure the timely resolution of your concerns.
)
Please address any questions or concerns to Mr. M. H. Holmes at (303)
)
480-6900.
Sincerely,
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R. O. Williams p
Vice President, Nuclear Operations p
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P-87355-October 6,,1987
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t Attachments:
. Attach' ment 1 - Responsefto NRC Request'for Additional Information :- Training Management Procedures- ~-' Maintenance Administrative'. Procedure (MAP-4)
Maintenance Department Personnel. Experience, Qualification,,'and Training! Requirements
' Attachment'4. r Special Senior-Licensed : Training Record Book cc:. Mr. K.
L~. Heitner, Project Manager Project Directorate - IV Division of. Reactor Proje' cts.- III, IV, V and Special Projects Office of Nuclear Reactor Regulation Regional Administrator,.RegionLIV ATTN:. Mr. J. E.. Gagliardo, Chief Reactor Projects Branch Mr. R. E. Farrell-
' Senior Resident' Inspector Fort St--. Vrain l
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-ATTACHMENT 1 Response to NRC Request for Additional Information NRC Comment:
A.
With regard to the SSLO training, it is not clear how the SSLO program was developed to provide applicants the nece s sa ry knowledge, skills, and abilities to perform licensed duties.
In addition to the details contained in the course description in 4.1 and 4.2 of the program, it must explain how the current program was developed and to what extent the program incorporates the following elements the Commission considers essential for acceptable training programs:
1.
Systematic analysis of the jobs to be performed.
2.
Learning objectives that are derived from the analysis and that described desired performance.
3.
Training, design, and implementation based on the learning objectives.
4.
Evalw. ion of trainee mastery of the objectives during training.
5.
Evaluation and revision of the training based on the performance of trained personnel in the job setting.
These elements are contained in the " Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel" of March 20, 1985 and further discussed in NUREG-1220, July 1986
" Training Review Criteria and Proc (1ures."
How We Comply.:
The Special Senior Licensed Operator (Fuel Handler) Program was developed using a systematic approach to training as detailed in the Training Management Procedures (TMP).
The TMP are higher-level procedures than the Training Procedures (TP) and thus govern
.the activities of the TP.
TMP 3.1 outlines the methodology utilized for a systematic analysis of the SSLO jobs / tasks that are performed.
TMP 3.2 outlines methods of deriving learning objectives from the analysis that describes desired performance.
In addition, Section 4.5 of TMP 3.2 outlines that the job / task analysis is also used for the development of Job Performance Measures, lesson plan outlines, I
and to establish requirements for the SSLO Training Procedure.
1 (TP-SSLO).
In addition to the information provided in TP-SSLO, TMP 2.1 provides additional information on methods used for the implementation of the SSLO Training Program.
Section 4.3 of TMP 2.1 defines the method of evaluation of trainee mastery of objectives during classroom, in plant and laboratory training I
1 3'
1 2
c
- settings.
In' addition to the information provided,in TP-SSLO, TMP ?4.1.' outlines the methods used for. evaluation 'and revision of :
the..SSLO Training Program..
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NRC Comment:
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i B.
With Lregard. to/ education land experience for SSLO candidates,' we find the omission of these requirements unacceptable..In.Section i
7.Jofr the-Fort ;St'.-
Vrain. Technical Specifications, PSC.has committed to meet the minimum qualifications of ANSI' N18.1-1971
" Selection 'and Training'of Personnel for-Nuclear Power Plants."
'i
-As~a minimum an SSLO must have. a high school diploma or equivalent
'to ' meet. the education. -requirements.
Experience
. requirements'for SSLO should be-established based on ANSI N18.'l-
'l 1971 for licensed personnel, q
How We Comply, The education and experience requirements for SSLO candidates are specified in Section 3.1.2 of Maintenance-Administrative Procedure (MAP-4) - Maintenance Department Personnel Experience, 1
Qualification, and
' Training Requirements.
This section 1
demonstrates our commitment to ANSI N18.1-1971 as specified in
.Section 7 of the Fort St. Vrain Technical Specifications.
'NRC Comment:
C.
We ' reque st'.. that. you review the.information describing SSLO
')
training.in.the 1974-75 period to determine to what extent the program content' has changed.
Some'of the. responsibilities and.
knowledge developed in the 74-75 period may have been
. inadvertently omitted.
There is also the possibility that all responsibilities of the SSLO are not clearly defined.
PSC should also confirm that all the tasks identified for the SSLO are contained in the Senior Operator training program.
1 How We Comply:
'The knowledge, skills, and abilities derived frorr, the job / task analysis of the SSLO position were compared with the responsibilities.and knowledges developed during the 1974-75 period to ensure no inadvertent omissions.
This comparison unveiled that some of the responsibilities and knowledges i
identified during the 74-75 period no longer represent valid requirements' of the SSLO position and thus were deleted from the SSLO Training Program.
TP-SSLO provides an overview of overall I
program content.
Detailed academic and task lesson plan lists h
4 i
(
3
)
are identified in the SSLO Training Record Book.
The Senior Reactor Operator (SRO) position at Fort St.
Vrain does not function as an SSLO in that they do not perform the mechanical j
tasks of fuel handling.
The SR0 acts in a supervisory capacity only and the appropriate tasks are identified in the SR0 training setting. matrix and are incorporated in the SR0 Training Program, which has been accredited by INP0.
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