ML20236K845
| ML20236K845 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/30/1987 |
| From: | Heitner K Office of Nuclear Reactor Regulation |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| Shared Package | |
| ML20235X238 | List: |
| References | |
| TAC-64747, NUDOCS 8708100019 | |
| Download: ML20236K845 (6) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
0 WASHINGTON, D. C. 20555 1
/
July 30, 1987
%..... /
Docket No. 50-267 Mr. R. O. Williams, Jr.
Vice President, Nuclear Operations Public Service Co. of Colorado P. O. Box 840 Denver, Colorado 80201-0840 4
Dear Mr. Williams,
I
SUBJECT:
FORT ST VRAIN - INITIAL AND REQUALIFICATION TRAINING PROGRAM FOR SPECIAL SENIOR LICENSED OPERATORS (TAC N0. 64747)
In letters dated August 4, 1986 (P-8650E) and February 9, 1987 (P-87049), the Public Service Company of Colorado (PSC) provided information and revisions to the Fort St. Vrain (FSV) Special Senior Licensed Operator - Fuel handler (SSLO) requalification program.
The February 9,1987 letter contained the initial training program for SSLO.
The submittals were in response to NRC letters of June 20, 1986 and December 19, 1986 which were specifically addressed to the SSLO requalification program.
At the same time, revisions to 10 CFR 55 became effective on May 26, 1987 there-by changing our review criteria from the subject matter contained in training programs and course duration to the methodology of developing training programs.
In revisions to 10 CFR 55, the NRC has endorsed INP0 accreditation methodology which is similar to the NRC approach to using a systems approach to training.
l Additional information concerning revision to 10 CFR 55 will be published in NUREG-1262 " Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 Operator Licenses." Our current position for programs which are not accredited is to use the review criteria contained in NUREG-1220 of July 1986, " Training Review Criteria and Procedures."
Our review of the SSLO initial program, which is scheduled for INP0 Accredita-tion Team review in the fall of 1987, indicates the program is based on the subject matter.
Such a program woG d be potentially unacceptable for INP0 accreditation, as well as no lorger meeting revised 10 CFR 55 criteria. We are also concerned that the program does not include criteria for SSLO education and experience, which PSC has committed to in Section 7 of the FSV Technical Specifications.
In addition, it appears that a number of systems have been deleted from the original training programs without acceptable justification.
We have enclosed a request for additional information that address our concerns as outlined above.
Please provide a response to this request within 75 days of the date of this letter.
The staff is available to meet with you to discuss i
the SSLO program and assure the resolution of our concerns in a timely fashion, h81O0019870730 y
ADOCK 05000267 PDR
.g.
The infortnation requested in this letter affects fewer than 10 respondents; therefore OMB clearance is not required under P.L.96-511.
Sincerely,
/r/
Kenneth L. Heitner, Project Manager Project Directorate - IV Division of Reactor Projects - III, j
IV, V and Special Projects
{
j Office of Nuclear Reactor Regulation
Enclosures:
As stated i
cc: w/ enclosures See next page
/k DISTRIB K O- } b Jodet File
( NRC PDR l
Local PDR PD4 Reading F. Schroeder P. Noonan j
i Project Manager i
OGC-Bethesda E. Jordan 1
J. Partlow ACRS (10)
PD4 Plant File J. Calvo l
PD-4 PD-41 PD-4[h PNoonan KHeitner JCalvo 07/w/87 07/ p/87 07/)c/87
l Mr. R. O. Williams Public Service Company of Colorado Fort St. Vrain cc:
Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorade 80220 Denver, Colorado 80201 Mr. David Alberstein, 14/159A Mr. R. O. Williams, Acting Manager GA Technologies, Inc.
Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Public Service Company of Colorado Denver, Colorado 80201 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 1
Senior Resident Inspector
)
U.S. Nuclear Regulatory Commission Mr. R. F. Walker P. 0. Box 840 Public Service Company of Colorado i
Platteville, Colorado 80651 Post Office Box 840 Denver, Colorado 80201-0840 Kelley, Stansfield & 0'Donnell Public Service Company Building Commitment Control Program Room 900 Coordinator i
550 15th Street Public Service Company of Colorado i
Denver, Colorado 80202 2420 W. 26th Ave. Suite 100-0 Denver, Colorado 80211 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 3
Arlington, Texas 76011 j
q Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 l
Regional Representative Radiation Programs Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver, Colorado 80202-2413 l
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Resolution of Fort St. Vrain Special Senior Licensed Operator [ Fuel Handler]
Training Program l
I.
Background
In letters dated August 4, 1986 and February 9, 1987, the Public Service Company of Colorado (PSC) provided information and revisions to the Fort St. Vrain (FSV) Special Senior Licensed Operator-fuel handler (SSLO) requalification program. The February 9, 1987 letter also included the initial training for SSLO. The submittals were in response to NRC letters of June 20, 1986 and December 19. 1986. During this period the staff was aware that the FSV licensed operator programs were in the INP0
(
accreditation review process and were coincidently accredited in November 1986. The staff has been informed that the FSV maintenance Training Program which, includes SSLO training, is currently scheduled for an INP0 I
team visit in the fall of 1987.
SSLO initial training and requalification programs have not been clearly _
defined in past or current regulations, regulatory guides, industry standards, or Commission NUREGs. The staff has reviewed past correspondence regarding SSLO which included summaries of meetings 'and PSC submittals in the 1974-75 period to better understand SSLO job responsibilities at the time the SSLO program was developed. The enclosures contain this information. (Enclosures 2 and 3.)
Revisions to 10 CFR 55 became effective on M6y ?6, 1986. Generic Letter 87-07 provided guidance to licensees to the requirements of $55.31(a) and 055.59(c) regarding initial and requalification training and the option of substituting an accredited training program for initial and requalifica-tion training programs approved by the Conmission. Additional
. guidance to licensees is also contained in NUREG-1262 " Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operator Licenses."
II.
Request for Additional Information o
A.
With regard to the SSLO training, it is not clear how the SSLO program was developed to provide applicants the necessary 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.
l 2.
Learning objectives that are derived from the analysis and that j
described desired performance.
3.
Training, design, and implementation based on the learning objectives.
4.
Evaluation 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 Procedures."
B.
With regard to education and experience for SSLO candidates, we find the omission of these requirements unacceptable.
In Section 7 of the Fort St. Vrain Technical Specifications, PSC has committed to i
l l
I
3 meet the minimum qualifications of ANSI N18.1-1971 " Selection and Training of Personnel for Nuclear Power Plants". 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 N18.1-1971 for licensed personnel.
C.
We request 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 for 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 SSLO are contained in the Senior Operator training program.
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