ML20197J087

Forwards SER & SALP Input Re Licensed Operator Requalification Training Program.Program Does Not Conform to Requirements Specified in App a to 10CFR55

ML20197J087
Person / Time
Site:	Columbia
Issue date:	09/26/1984
From:	Russell W Office of Nuclear Reactor Regulation
To:	Novak T Office of Nuclear Reactor Regulation
References
CON-WNP-0773, CON-WNP-773 NUDOCS 8410100044
Download: ML20197J087 (10)

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SEP 2 61984 3' DHFS Reading - 2 H. Bacher J. Persensky lie!!ORNiDuil FOR: Thonas li. Ilovak, Assistant Director D. Shum for Licensing Division of Licensing FROM: Willian T. Russell, Deputy Director Division of Hunan Factors Safety

SUBJECT:

SAFETY EVALUATI0tl FOR IIASHIflGT0il i!UCLEAR PLAliT, VilIT 2, LICEllSED OPERATOR REQUALIFICATI0tl TRAI!1IflG PROGRN1 By letter dated !!ay 15, 1984, the licensee of Washington Huclear Plant, Unit 2, subnitted a requalification training progran for licensed reactor operators and senior reactor operators for !!RC review. The enclosed SER and SALP were prepared by the Personnel Qualifications Section of the Licensee Qualifications Branch af ter having reviewed the above cited progran.

Based on our review, we find (as noted in the SER Sections A, B and E) that the licensee's requalification training progran for licensed reactor cpera-tors and senior reactor operators does not fully conforn to the requirenents as specified in the Appendix A to 10 CFR Part 55 and in the letter frcn H. R. Denton to all power reactor applicants and licensees dated flarch 28, 1980. Therefore, we have not been able to conclude that the licensee's requalification training progran is acceptable.

This review was conducted by D. Shun (X24906).

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Willian T. Russell, Deputy Director

& Division of Hunan Factors Safety

Enclosure:

As stated cc: A. Schwencer R. Auluck R. Pata, RV I

p 10100044 840926 h 9, <M ADOCK 05000397

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SAFETY EVALUATION REPORT FOR WASHINGTON NUCLEAR PLANT, UNIT 2 (WNP-2)

LICENSED OPERATOR REQUALIFICATION TRAINING PROGRAM By letter dated May 15, 1984, the licensee of Washington Nuclear Plant, Unit 2, submitted a requalification training program for licensed reactor operators and senior reactor operators for NRC review. This program'will consist of the following:

i A. Preplanned Lectures The licensee has indicated that six preplanned requalification training lectures will be scheduled throughout each two year operator license perioc. Lecture subjects and content will be based on the results of the annual examination admin stered to licensed reactor operators and d

senior reactor operators. However, we find that the content of the lectures described in the program by the licensee does not cover all the subjects as listed in Appendix A of 10 CFR Part 55. We will require the lectures to be modified to include the folicwing subjects as listed in Appendix A of 10 CFR Part 55 as well as in Enclosure 1 of H. R. Denton's March 28, 1980, letter:

Theory and principles of operation General and specific plant operating characteristics Plant instrumentation and control systems Plant protection systems Engineered safety systems Normal, abnormal, and emergency operating procedures Radiation control and safety l

Technical 5pecifications Applicable portions of Title 10, Chapter 1, Code of Federal Regulations use of installed plant systems to control or mitigate an accident in j which the core is severely damaged Reactor and plant transients and accidents With respect to the instructions in topics of fluid flow, thermodynamics I and heat transfer, we require the licensee to provide a program in accordance with the guidance as outlined in Enclosure 2 of H. R. Denton's March 28, 1980, letter.

Withrespecttotheinstruck;ionsinmitigatingcoredamage,werequire the licensee to provide a program in accordance with the guidance as outlined in Enclosure 3 of H. R. Denton's March 28, 1980, letter.

8. Control Manipulations The licensee has not made a commitment to the control manipulations required for licensed operators to comply with the requirements as specified in Enclosure 4 of H. R. Denton's letter of March 28, 1980, which requires that, during each two year license period, each licensed reactor operator shall perform all of the following listed control manipulations and each licensed senior reactor operator shall perform, direct or evaluate all of the following control manipulations:

• • Plant or reactor start-ups to include a range that reactivity feedback from nuclear heat addition is noticeable and heat-up rate is established

t Plant shutdcwn Manual control of feedwater during start-up and shutdown Any significant (740%) power changes in manual rod control or recirculation flow Loss of coolant including:

a. inside and outside primary containment

b. large and small, including leak-rate determination Loss of instrument air (if simulated plant-specific)

Loss of electrical power (and/or degraded power sources)

• • Loss of core coolant flow / natural circulation Loss of condenser vacuum

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Loss of service water if required for safety Loss of shutdown cooling 4

Loss of component cooling system or cooling to an individual component Loss of normal feedwater or normal feedwater system failure Loss of protective system channel

• Mispositioned control rod or rods (or rod drops)

Inability to drive control rods 1

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• Conditions requiring use of standby liquid control system

• Fuel cladding failure or with activity in reactor coolant or offgas 1

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• Turbine or generator trip

• Malfunction of automatic control system (s) which affect reactivity i

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• Malfunction of reactor coolant pressure / volume control system j

• Reactor trip

• Main steam line break (inside or outside containment) 1 Nuclear instrumentation failure (s)

The starred items shall be performed on an annual basis; all other items

! shall be performed on a two year cycle. An appropriate simulator, which reproduces the general operating characteristics of and has similar instrument and control arrangement to WNP-2, may be used to perform

! these control manipulations.  ;

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C. Simulator Training i

The licensee's requalification program will provide simulator training

} for all of the licensed reactor operators and senior reactor operators during the term of their licenses. We find that the licensee has committed to the requirement as specified in Enclosure 1 of H. R. Denton's letter of March 28, 1980, which requires all licensed operators to participate in a simulator training program as part of the requalification program.

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6 D. Update Lectures These lectures will ensure that each licensed reactor operator and senior reactor operator will be aware of the following:

(1) Modifications to WNP-2 plant, system, or equipment design, procedures including the Emergency Plan Implementing Procedures, I and Technical Specifications.

(2) Operating experience review of events at WNP-2 or other plants l which could change WNP-2 safety, effectiveness, or efficiency with special emphasis on preventing and coping with emergencies and severe abnormalities. These reviews include coverage of pertinent Licensee Event Reports and Monthly Operational Bulletin.

I E. Abnormal and Emergency Procedure Review The licensee has not addressed the abnormal and emergency procedure review in the requalification training program. As described in Appen-dix A to the 10 CFR Part 55, we required that each licensed reactor i operator and senior reactor operator shall review the contents of all abnormal and emergency procedures on a regularly scheduled basis.

F. In-plant Training The licensees requalification training program includes an in-plant retraining program to maintain operator skills for coping with normal, abnormal, and emergency situations in a realistic environment. In-plant training may include, among others, such activities as plant calcula-I tions (e.g. , reactivity, water inventory); system line-ups, restorations, 3

and operability demonstrations; operator performed surveillance tests; refueling operations; fire drills; radioactive spills; and others which cannot be performed on the simulator.

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.4 l G. Inactive Status Rctraining Program This program ensures that licensed reactor operators who have not been actively performing the functions of a reactor operator or senior reactor operator for a period of four months or longer shall be refamil-

_farized with plant systems, procedures and operating events before resuming normal activities. The completion of the refamiliarization program will include written and oral examinations to ensure that the licensee is Op-to-date and familiar with the plant.

H. Evaluation As required in Appendix A to 10 CFR Part 55, the evaluation progran for licensed personnel will include the following:

(a) Annual Written Examination A written annual examination, comparable in scope and degree of difficulty to an NRC examination, will be given to each licensed reactor operator and senior reactor operator. An individual who receives an overall grade of less than 80% on the annual examination, or receives a grade of less than 70% on any category l of the annual examination will be immediately relieved of all licensed duties and placed in an accelerated requalification program.

(b) Observation and Oral Examinations Observation and evaluation of performance and competency of licensed reactor operators and senior reactor operators by supervisors or training staff members will include oral examinations and evaluation of actions taken during actual or j simulated normal, abnormal and emergency conditions.

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I. Annual Overall Evaluation of Recualification Program The licensee has indicated that the requalification program will be evaluated by persons knowledgeable in training but excluding those directly responsible for the requalification program. This program will provide an independent assessment of the content, quality and appropri-ateness of WNP-2 licensed operator requalification program.

J. Accelerated Requalification Program The licensee has indicated that any licensed operator whose score is less than the established requirements in any section of the comprehen-siveannualexa$inationshallberequiredtoattendlecturesinthose sections of the examination. Should an individual fail to attain the established overall average or the established minimum in an individual section of the annual examination, that operator shall be removed from shift duties and shall be placed in an accelerated requalification program. The operator will be returned to shift duties after retesting and achieving the established requirements for overall average of each section.

As indicated in the above Sections A, B and E, Twe find that the licensee's requalification training program for licensed reactor operators and senior reactor operators does not fully conform to the requirements as specified in Appendix A to 10 CFR Part 55 and in the l

letter from H. R. Denton to all power reactor applicants ano licensees dated fiarch 28, 1980. Therefore, we have not been able to conclude that the licensee's requalification training program is acceptable.

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SALP EVALUATION FOR WASHINGTON NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-397 LICENSED OPERATOR REOUALIFICATION PROGRAM A. FUNCTIONAL AREAS: Licensed Operator Requalification Program

1. Management involvement in assuring quality We have not had a site visit to meet any of the corporate representatives, therefore, we have no basis to evaluate this licensing activity.

Rating: N/A

2. Approach to resolution of technical issues from a safety standpoint.

We have not had any contact with the licensee, therefore, we have no basis to evaluate this licensing activity.

Rating: N/A

3. Responsive to NRC initiatives We have no basis to evaluate this ite'm.

Rating: N/A

4. Staffing We have no basis to evaluate this item.

Rating: N/A

5. Reporting and analysis of reportable events.

We have no basis to evaluate this item.

Rating: N/A

6. Training and qualification effectiveness Based on our review of the licensee's requalification training program and providing that the licensee will resolve our concern (open items as described in the SER), the licensee's requalification training program will effectively maintain fully qualified plant personnel to operate the plant and maintain the plant safety.

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2 Rating: Category 2

7. Overall Rating for Plant Personnel Training: Category 2 B. Other Functional Areas N/A i

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