ML19256A999

Responds to NRC 781116 Ltr Re Violations Noted in Insp Rept 50-267/78-19.Does Not Believe There Is a Violation or Approved Requalification Program

ML19256A999
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/27/1978
From:	Millen C PUBLIC SERVICE CO. OF COLORADO
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19256A997	List: ML19256A999
References
P-78209, NUDOCS 7901170377
Download: ML19256A999 (2)

Text

-

l t

PUBLIC SERVICE COMPANY OF COLORADO P. O. DOx e40 DENVER, COLORADO 80201 G. K. 31ILIEN D ENiOR viCE PRESaDEN T December 27, 1978 Fort St. Vrain Uni t No . 1 P-78209 Mr. Karl V. Seyf rit, Director Nuclear Regulatory Commission Region IV Office of Inspection and Enforcement 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76012 REF: Facility Operating License No. DPR-34 Docket No. 50-267

Dear Mr. Seyfrit:

With respect to your Notice of Violation resulting from IE Inspection 78-19 for the period of November 11, 1978, through November 16, 1978, we have the following response:

Your enclosure states that four reac tor operators scored less than 80% on Category E of the requalification examination. Two o f the four reactor opera-tors were not licensed, and therefore, were not subject to the requirements of the approved requalification plan in effect at that time. Of the five licensed reactor operators participating in the annual examination, two had scores below 80%, and all scored above 70% in Category E. The average score achieved by all licensed reactor operators examined in Category E was 81.6%.

We know of no requirement, either in 10CFR55 or in the approved Requalifi-cation Training Frogram in effect at the time, which mandates group or in-dividual review for scores below 80% in a particular category.

Your Notice of Violation also contends that the subject of Safety and Emer-gency Systems was not discussed in subsequent training lectures. The approved Requalification Program in effect at the time did not require lectures and other training activities under the heading of " Safety and Emergency Systems."

Rather the program is geared to lecture and study activities in accordance 7901170377

Mr. Karl V. Seyfrit December 27, 1978 with the system designations used for Fort St. Vrain. For the training period of 19 77-78, each licensed operator participated in the following review classes which are directly related to Safety and Emergency Systems:

All Technical Specifications, including Basis Abnormal Operating Procedures for each System Operating Procedure All approved Emergency Procedures For each participant in the Requalification Program, these reviews amounted to at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of classroom time. We regard this as an adequate re-view for the five reactor operators examined in Category E, even though their scores on the average, were above 80%.

For this notice, we fail to recognize that we are in violation of either 10CFR55, Appendix A, or our approved Requalification Program in effect at th e time . We believe we were, and continue to be, in compliance with re-spect to conduct of our Requalification Training Program.

If you have any further questions, please contact this office.

Very truly yours ,

.:/ -9lo.s'~ .D&rlgy C. K. Millen CKM/alk

,