SNRC-1062, Forwards Response to NRC Comments on Licensed Operator Requalification Program
| ML20094B254 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/31/1984 |
| From: | Leonard J LONG ISLAND LIGHTING CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SNRC-1062, NUDOCS 8408060323 | |
| Download: ML20094B254 (4) | |
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LONG ISLAND LIGHTING COMPANY Ca w w m u m m m dj SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY ROAD e WADING RIVER, N.Y.11792 JOHN O. LEON ARD, JR.
VICE P..EstDENT. NUCLEAR OPERATIONS July 31, 1984 SNRC-1062 Mr. Harold R.
Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Licensed Operator Requalification Program Shoreham' Nuclear Power Station - Unit 1 Docket No. 50-322
References:
1.
Letter from LILCO to NRC (SNRC-942) dated August 12, 1983 2.
LE'.ter from NRC (A. Schwencer) to LILCO (M. Pollock) dated March 14, 1984
Dear Mr. Denton:
Enclosed please find our response to the NRC connents regarding Shoreham's Licensed Operator Requalification Program.
If you have any questions or require additional information, please do not hesitate to call this office.
Very truly yo s,
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Jo n D. Leonar r.
Vic President - Nucl af Operations RL:ck Enclosure cc:
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LILC0'S-RESPONSE TO NRC COMMENTS REGARDING SH0REHAM'S LICENSED OPERATOR REQUALIFICATION PROGRAM Responses'to Specific Comments Comment 1:
Section 8.1.4 - Waiver of s ecific classroom J
lectures may be granted if tee individual receives a passing grade of 80% in the annual examination.
(Section 2, Appendix A of 10 CFR Part 55, Section 5.2.1.7 of ANS 3.10-1981)
Response
Procedure will be modified to reflect the fact that waivers will only be granted for areas in which an individual received a grade of greater or equal to 80%
on his annual exam.
Comment 2:
Section 8.2.1 - Lectures must include all subjects contained in Section 2 of Appendix A of 10 CFR Part 55.
Lectures in heat transfer, fluid flow, thermo-dynamics and mitigating of accidents involving a degraded core must also be included in your program.
(H. R. Denton letter of March 28, 1980)
Response
Procedure will be modified to align with 10 CFR Part 55 Appendix A terminology.
The addition of heat transfer, fluid flow, thermodynamics and mitigation of core damage training had been added prior to the receipt of the NRC comments.
It should further be noted that lectures on heat transfer and selected portions of the mitigation of core damage training were administered during the course of our 1983 requalification program.
Comment 3:
Section 8.3.1 - Control manipulation should reference Appendix 12.2.
In addition, control manipulations
.must be evaluated (Item C3, Enclosure 1 of the H.
R. Denton letter of March 28, 1980).
Response
Section 8.3.1 will be modified-to reference Appendix 12.2.
In addition control manipulation evaluations for all Appendix 12.2 items will be completed on a biennial basis.
Comment 4:
Section 8.3.2.1 - We believe that this should read "All licensed personnel shall be kept engnizant of SNPS design, procedural and facility license changes using one or more of the following methods.
Response
Procedure will be modified to incorporate this word change.
2 Comment 5:
Section 8.3.2.3 - We recognize that plant drills can provide valuable training.
We recommend that drill scenarios also include objectives.
We also request that " evaluators" periodically participate in the drill program.
Response
Drill scenarios will be modified to include the drill objective (s) prior to their use in the requalification program.
In addition, all SNPS licensed evaluators also are evaluated via drills as part of the requal-
'ification program.
Comment 6:
Section 8.3.2.4 - The staff is preparing a regu-latory guide which will address backup operators.
Therefore, backup operators are subject to future changes in your program.
Response
The regulatory guide will be reviewed for its impact on our backup license operators when it is issued.
Comment 7:
Section 8.4 - Please refer to Generic Letter 83-17 issued on April 18, 1983.
It provides additional information on the conduct of requalification examinations.
' Response:
Guidelines for the conduct of requalification exams are addressed in SP 12.014.07 Appendix 12.4, "Adminis-tration of Requalification Exams".
Comment 8:
Section 8.4.1 - We recommend a separate section pro-vide information on evaluations of actual performance and one-on-one walk-through examinations.
In add-ition, provisions for accelerated training must be provided if evaluations clearly indicate the need.
(Section 4, Appendix A of 10 CFR Part 55.)
Response
Actual performance is evaluated on an annual basis, as a minimum, for all on shift licensed personnel.
These performance evaluations are reviewed by the Operations Section and training needs are identified.
In general these needs will be used to identify topics to be pre-
-sented in the requalification program.
- However, accelerated retraining for an individual license holder can also be identified.
Back-up licensed holders will be evaluated during their reactivity manipulations by a member of the training section.
' Comment'9:
Section 8.4.5 - The program should contain limits on the number of exemptions.
Partial exemptions should also be considered.
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Response
Licensed individuals who are directly involved with the preparation and grading of examinations are required to take one full written and one full oral examination in a 2 year period.
This may be accomp-lished by a waiver of a full exam for one year or, by partial waivers in each year for identified sections.
Waivers should not be allowed for any one exam section in consecutive years.
Comment 10:
Section 11 - We recommend you add the following additional references:
Title 10 CFR Part 50 - Section 30.54, Conditions of Licenses.
Appendix A of 10 CFR Part 55 NUREG-1021, Operator Licensing Examiner Standards Regulatory Guide-l.8 - Personnel Selection and Training Regulatory Guide 1.149 - Nuclear Power Plant Simu-lators for use in Operator Training.
Response
Additional references will be added.
Responses to General Comments Comment 1:
Does this program apply to instructors?
If so, please include the degree of participation in the program?
(H. R. Denton letter of March 28, 1980.)
Response
Instructors licensed _on the Shoreham facility fully participate in all areas of the requalification pro-gram.
Comment 2:
Does the Limerick simulator meet the guidelines con-tained in Regulatory Guide 1.149 - Nuclear Power Plant Simulators?
Response
The Limerick Simulator meets the guidelines of Regu-latory Guide 1.149.
Comment 3:
We recommend you resubmit the program with modifi-cations developed as a result of our comments.
You may omit the Requalification Training Program and Schedule when the program is submitted.
Response
LILCO will resubmit the program with modifications developed as a result of your comments by mid-August.