View source for AECM-86-0272, Forwards Rev 5 to Vol 1 of Administrative Procedure 01-S-04-2, Licensed Operator Requalification Training, Safety-Related, in Response to NRC 851127 Request for Addl Info

{{Adams
| number = ML20214M094
| issue date = 09/04/1986
| title = Forwards Rev 5 to Vol 1 of Administrative Procedure 01-S-04-2, Licensed Operator Requalification Training, Safety-Related, in Response to NRC 851127 Request for Addl Info
| author name = Kingsley O
| author affiliation = MISSISSIPPI POWER &amp; LIGHT CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000416
| license number = 
| contact person = 
| document report number = AECM-86-0272, AECM-86-272, TAC-62717, NUDOCS 8609100537
| package number = ML20214M097
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
| project = TAC:62717
| stage = Request
}}

=Text=
{{#Wiki_filter:.     .
   .4 j            MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi Emil&lhididd5        P. O. B O X 164 0, J A C K S O N, MIS SIS SIP PI 39215-1640 September 4, 1986 O. D. KINGSLEY, JR.
VICE PRESIDENT NUCLE AR OPERATIONS U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.               20555 Attention: Mr. Harold R. Denton, Director

==Dear Mr. Denton:==

==SUBJECT:==
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Additional Information Related to the GGNS Licensed Operator Requalification Program AECM-86/0272 By letter (AECM-85/0296) dated September 11, 1985, Mississippi Power &
Light (MP&L) submitted for NRC review the Grand Gulf Nuclear Station (GGNS) procedure (01-S-04-2, Revision 4) describing the Licensed Operator Requalification Program in support of the NRC review associated with Generic Letter 84-14. NRC staff review of this program generated additional questions which were provided to MP&L by letter (MAEC-85/0403) dated November 27, 1985.
The MP&L response to these questions was scheduled to follow the INP0 review and accreditation. The INP0 review and accreditation is now complete.
Attachment 1 to this letter provides MP&L's item by item response to the NRC staff concerns regarding revision 4 to the GGNS Licensed Operator Requalification Program.
Attachment 2 provides the revised GGNS Procedure (01-S-04-2, Revision 5) describing the GGNS Licensed Operator Requalification Program.
If you require additional information, please advise.
Yours   , ly ,
s ODK:vog Attachments                                                             j cc:      (See Next Page) 00 9
8609100S37 860904 PDR ADOCK 05000416                                                                             \
V                             PDR                                                              jl J13AECM86082602 - 1                Member Middle South Utilities System

AECM-86/0272 Page 2
 ,                 cc: Mr. T. H. Cloninger (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. R. C. Butcher (w/a) 4 Mr. James M. Taylor, Director (w/a)
Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i
Dr. J. Nelson Grace, Regional Administrator (w/a)
U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W.,                           Suite 2900 Atlanta, Georgia 30323 J
O l
c l
1 i
1 J13AECM86082602 - 2

4~
Attachment 1 MP&L Response to NRC Concerns Regarding Revision 4.
to the GGNS Licensed Operator Requalifications Program i~
l l
I.
l I
i-c I                                                                 .
!               J13AECM86082602 - 4
!-~.,_...--.,_..._-._.._...-_,._.,,,-.-_._._--.....--,-,,,,,-,,_.   . . . - _ - - . _ , , , . . _ , , . . . , . - - - -

9
: 1.      Section 3.9 - Reference to Training Section Instruction 14-5-02-3 CONCERN This reference contains the implementing procedure for the Licensed Operator Requalification Program. MP&L should review the following comments and responses to' assure the implementing procedure continues to reflect the features contained in the program.

===RESPONSE===
The implementing procedure has been reviewed and found to be consistent with the program as described in GGNS procedure 01-S-04-2, Revision 5.
2 .-     Section 5.2 - Definitions CONCERN Since evaluations are conducted utilizing the GGNS simulator, we recommend that simulator evaluations be included in this section.

===RESPONSE===
The definition section reference to examinations was deleted when revision 5 of 01-S-04-2 was issued. Annual examinations are now explicitly covered in section 6.4, Annual Requalification Examinations.
Simulator performance evaluations are discussed in sections 6.4 and 6.5.
          - 3.      Section 6.2 - Requalification Program Participants A. CONCERN With regard to instructor's participation in the requalification program, we concur with the concept of an appropriate requalification program and the use of guest lecturers. Licensed instructors need additional participation. Our. comments are contained in section 6.5.
1

===RESPONSE===
See response to item 6.5.
B. CONCERN
!                   Personnel who are exempt from specific areas due to normal duties should be exempted by an administrative procedure which is approved by station management. For example, section 6.3.3, Station Design Feature
,                   Awareness, is normally issued by the Operations Manager and his immediate subordinate; therefore, they may be exempt from this requirement.
8 J13AECM86082602 - 5 t

===RESPONSE===
Any exemptions from requalification training were contained in revision 4 of 01-S-04-2, which is an administrative level procedure approved by station management.
Revision 5 of 01-S-04-2 in section 1.2.4 allows exemptions from attendance to requalification training as allowed by 10 CFR 55 Appendix A. These exemptions are now approved on a case by case basis by the Training Superintendent.
C. CONCERN With regard to licensed personnel who have recently received a license, they should have been participating _in the lecture series and On-the-Job partion of the program. In addition, recently licensed personnel may be exempt from the annual examination up to six (6) months from the effective date of the license.

===RESPONSE===
While candidates are awaiting results of the license examination, they are assigned to an on-shift position in the control room performing duties that do not require a licensed individual. They rotate with their assigned shift. When the shift reports to training for their requalification cycle, these license candidates attend the licensed requalification training with the shift and take any appropriate weekly examinations. Section 6.4.1.a of 01-S-04-2 revision 5 contains the provision that individuals who have held their license for less than 6 calendar months prior to the start of the annual examination cycle may be exempt from taking the annual examination.
: 4.      Section 6.3.1 - Lecture Series A. CONCERN Our interpretation is that the six lectures will be repeated for all shift personnel. Staff personnel will also be required to attend lectures unless exempted by provisions contained in 6.2 or 6.3.6.

===RESPONSE===
The lecture series is conducted for seven consecutive weeks. During this time the six operations shifts rotate into the lecture series for one week. The seventh week is to allow time for personnel who for one reason or another did not attend with their shift, ie: vacation. Exemptions from a',tendance are as stated in section 1.2.3 and 1.2.4 of revision 5 of 01-S-04-2.
e J13AECM86082602 - 6

B. CONCERN In section 18.1.12, Amendment 49, MP&L response to . item I.C.5 of NUREG 0737 included feedback from operating experience in the Required Reading Program. MP&L should evaluate if significant events from operating experience is a suitable topic to add to the lecture series.

===RESPONSE===
Section 6.2 of revision 5 of 01-S-04-2 contains two lecture series. In section 6.2.2.a, a lecture topic titled "Related Nuclear Industry and In-house Operating Experience", has been added.
: 5. Section 6.3.2 - Reactivity Control Manipulations A. CONCERN With regard to control manipulations, the program lacks evaluations as described in Item'I.A.2.1 of NUREG 0737 (reference item C.3, Enclosure 1 of the H. R. Denton letter of March 28,1980). These evaluations should also be included in section 6.7.8. MP&L should also consider a suitable practice period before conducting evaluations.
;               RESPONSE Section 6.3.1 of revision 5 of 01-S-04-2 delineates the control manipulations and how the operator gains credit for completio'n of these manipulations. Also, this section allows the operators to gain credit for manipulations performed in the control room if their performance is documented as satisfactory by the Operations Superintendent.
B. CONCERN Our review of other licensees' programs and actual events indicate a lack of practice for Senior Operators in the implementation of the Site Emergency Plan. MP&L should review simulator scenarios to insure that Senior Operators are given periodic practice in implementing the Site Emergency Plan and until they are relieved from duties by facility management.

===RESPONSE===
Section 6.3.2 of revision 5 of 01-S-04-2 provides direction on the development and use of simulator scenarios. A review of the approved scenarios indicates that there are situations provided to give the Senior Operators practice in the implementation of the Site Emergency Plan.
J13AECM86082602 - 7
: 6. Section 6.3.5 - Examinations CONCERN With regard to personnel who score less than 80% in a lecture series examination, our position is that retraining and reexamination be conducted in a timely manner. Therefore, remedial assignments and reexamination should be completed within a specified time period. If    the individual does not achieve the passing criteria, management must consider the individual for accelerated training in section 6.4.1.

===RESPONSE===
Section 6.2.5 of revision 5 of 01-S-04-2 contains the criteria for lecture series examinations and the course of action should an individual not attain the passing criteria. Remedial training and reexamination is required to be completed within 8 weeks.
: 7. Section 6.3.6 - Annual Requalification Examination CONCERN Ikritten examination - We recommend a separate paragraph contain criteria for those personnel who may be exempted.from attending lectures. In addition, since lectures in a particular subject may introduce new or revised material, instructors should evaluate if licensed personnel who are exempted would benefit from attendance at a lecture. Some licensees allow personnel to " test-out" in order to be exempted from' attendance of lectures where new material is presented.

===RESPONSE===
Exemptions from attendance to lecture series are approved by the Training Superintendent on a case by case basis as stated in section 1.2.4 of revision 5 of 01-S-04-2. He may elect to allow the individual to gain credit for the lecture series through credit by examination as stated in 14-S-01-4, Examinations.
: 8. Section 6.5 - Requalification for Instructors CONCERN MP&L should consider an appropriate period for licensed instructors to participate in shift activities, preferably on a monthly basis.
J13AECM86082602 - 8

L'    ,

===RESPONSE===
MP&L licensed instructors maintain active licenses by participating in
    \                      shift activities as required by 10 CFR 55. At this time 10 CFR 55 only l
requires participation on a once every four (4) month basis. Although instructors do participate in shif t activities more frequently than the once pe'r 4 month requirement, there is no statement to this fact in 01-S-04-2 due to training schedules and resource requirements.
: 9.             Section 6.6. - Requalification of Inactive Operators                                                                     i l
CONCERN                                                                                                                  I l
l                          The NRC's current position concerning this area is in the revision to Regulatory Guide 1.8, " Personnel Selection and Training". During the l
interim, MP&L should consider inactive operators; become current in the requalification 0JT; perform a period of licensed activities under
;                          supervision; and review of lecture series material before administration
!                          of a written and/or oral examination. Cerification by MP&L and NRC
(                          review is conducted in accordance with 10 CFR 55.31(e).

===RESPONSE===
Inactive status retraining is covered in section 6.10 of revision 5 of l
01-S-04-2.                                 Once this retraining has been completed and examination results are compiled, NRC approval of the retraining provided is obtained                                                I through formal notification to the NRC Regional Administrator. The individual is not allowed to resume licensed duties until notification from the NRC that the retraining is acceptable.
l J13AECM86082602 - 9

Attachment 2 GGNS Licensed Operator Requalification Program (Revision 5)
J13AECM86082602 - 10}}