ML20148S499

Requests Clarification of 10CFR55.53 C & F.2 Re Maint of Active Status for Senior Reactor Operation Fuel Handlers. Approval of Previously Approved Refueling Licensing Training Program for Maint of Active Status Requested

ML20148S499
Person / Time
Site:	Beaver Valley
Issue date:	12/21/1987
From:	Sieber J DUQUESNE LIGHT CO.
To:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
ND3VPN:5263, NUDOCS 8802030063
Download: ML20148S499 (8)

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'Af Telephone 1412) 393 4000 Nuclear Group P.O Box 4 Shippirv) port. PA 15077M December 21, 1987 ND3VPN:5263 Mr Robert M. Callo, Chief ,

Operations Branch l Division of Reactor Safety U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Reference:

Beaver Valley Power Station, Unit 1 Docket 50-334, License DPR-66 10CFR 55.53 C and f.2, SRO Fuel Handler; Active Status

Dear Mr. Gallo:

This is a request for clarification of the rule (10 CRF 55.53 C and f.2) concerning maintenance of active status for SRO Fuel Handlers. The rule states that for senior operators limited to fuel handling, one shift j must have been completed. Previous interpretations of this rule as stated at the Regional meeting associated with the new rule was that since these individuals only utilize their license during refuelings they must stand their first shift with an active Senior Reactor Operator.

Our Refueling License Retraining Program (enclosure 1) approved by I the NRC December 2, 1986 (enclosure 2) states that any licensee that is current and satisfactory within the scope of the Refueling License ,

Retraining Program and participates in the pre-refueling activities, I including testing of fuel handling equimpment, review of procedures and l supervision of personnel performing refueling activities, shall be considered active. We request that this program remain acceptable for maintenance of an active status. The individuals holding these licenses at our facility have been the responsible Fuel Handling Senior Operators for several refueling outages and are very experienced. Therefore we do not I see the need for these licenses to stand one shift with another Senior Reactor Operator.

I We would appreciate your response to this request in a timely manner, j since we are presently in a refueling outage and expect to commence fuct i handling in the near future. ,

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8802030063 871221 '

PDR ADOCK 05000334 /Yd)to P pm M i )

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ND3VPN:5263 l December 21, 1987 '

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This request was previously discussed between Mr. T. Burns of our Training Section and Mr. R. Keller of your staff.

Very truly yours, ,

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3. D. Sieber Vice President Nuclear JDS:TWB/ cal Enclosure

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T. W. Burns 1 R. J. Druga 4

W. S. Lacey R. M. Keller (NRC)

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DUQUESNE LIGHT COMPANY Voluna 2 Nuclear Group Chapter 2 Training Administrative Manual Section 2.7 2.7 REFUELING LICENSE RETRAINING PROGRAM 2.7.1 Procram Obiective ,

The objective of refueling license retraining is to assure the I continued competency of personnel assigned as Refueling Shift Supervisors during refueling and core alterations.

2.7.2 Program Applications l 3 Personnel who possess a Senior Reactor Operator's license limited to '

] fuel handling will be continuously enrolled in the Refueling License j Retraining Program.

The Refueling License Retraining Program will be conducted contin-uously for 24 months and upon completion will be followed by successive 24-month programs, each of which will begin promptly at the conclusion of the prcceding program. Each 24-month retraining program is comprised of two (2) retraining cycles 1 year in length.

2.7.3 Scoce of Trainina Refueling license retraining is conducted in four (4) phasce of instruction or practice, as follows..

1. Phase 1 -

Annual Written Examinations. Licensees are administered a comprehensive written examination limited in scope to the duties and responsibilities of Fuel !

Handling SRos. ,

2. Phase 2 - Formal Classroom Training. Structured classroom training based in part on the results of annual written examinations.

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3. Phase 3 - Oral Examinations. Walk-through of procedures,

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controls and indications related to Fuel Handling SRO  ;

duties. )

4. Phase 4 - Individual Study. Review and self-study of significant operating experienco reports, procedure reviews, Incident Reports, design changes and procedure changes.

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DUQUESNE LIGHT COMPANY Volumo 2 Nuclear Group Chapter 2 Training Administrative Manual Section 2.7 2.7.4 Trainina Outline 2.7.4.1 Annual Written Examinations once each year, licensees will complete a comprehensive written exam-  :

ination similar in scope and style to licensing examinations admin-istered for Fuel Handling SRos by the USNRC. The purposes of theso examinations will be to evaluate effectiveness of the prior year's retraining, and to identify areas where training may be required to upgrade knowledge. An overall grade of 80% combined with a grade of ac least 70% in each category will be considerad passing. The Director, operations Training, is responsible for development and approval of the annual written examination. The Director, Operations Training, will designate another Senior Reactor Operator to review and approve the examination in conjunction with the Director. ,

1. Licensees who fail the annual written examination will be relieved of duties requiring a license and will partici-pate in an acceleratGd retraining program. Refer to Subsection 2.7.5.2.

2. Licensees will be required to complete formal classroom training in any category for which a score of loss than 80% is earned.

3. The Director, Operations Training, the Director, Site Operations, and the Plant Manager will review the results of written examinations to datormine whero emphasis in retraining is needed. Where appropriate, results of this review will be incorporated into Phase 2.

2.7.4.2 Formal Classroom Training The scopo, duration, and preciso contont of formal classroom training will vary according to noods identified for individual cycles of the Refueling License Rotraining Program. Instructional cephasis will bo placed where annual written examinations indicato that weaknessen may be developing. Puol Handling SRos will attend Modules I through IV of the Licensed Operator Rotraining Program cach cycle. (Refer to Section 2.2.) Modules V and VI will be developed specifically for Fuol Handling SRos. Modulo V will consist of formal classroom train-ing and the Phase 3 oral examinations. Modulo VI will consist of Revision 1 Page 2.39

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DUQUESNE LIGHT COMPANY Volumo 2 Nuclear Group Chapter 2  ;

. Training Administrative Manual Section 2.7 formal classroom training and the annual written exsminations of Phase 1.

1. Topic IX - Reactor and Fuel Characteristics.

2. Topic X - Equipment, Instrumentation, and Design r Descriptions.

3. Topic XI - Procedures and Limitations.

4. Topic XII - Emergency Systems and Safety Devices.

5. Health Physics and Radiation Protection.

NOTE: Technical Specifications and applicable portions of Title 10 CFR are covered with the appropriate Topic.

2.7.4.3 Oral Examinations Proficiency with normal, abnormal and emergency procedures will be maintained by requiring licensees to demonstrate their familiarity with controls, indications, actions to be taken and expected plant responses. As a minimum, this will be achieved by walk-through exercises and will be considered as a periodic performance evalua-tion.

2.7.4.4 Individual Study Licensees will complete periodic reading assignments. The subjects covqrad in reading assignments may include, but not be limited to, the following as they relate to the duties and responsibilities of Fue, Handling SRoss

1. Facility Design Changes

2. Facility Procedure Changes.

3. Technical Specification Changes.

4. Emergency Preparedness Plan.

5. Radiological Control Procedures.

6. Temporary Station Procedures.

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DUQUESNE LIGHT COMPANY Volum3 2 Nuclear Group Chapter 2 Training Administrative Manual Section 2.7

7. Station Industrial Security Procedures. ,

8. Abnormal and Emergency Proccdures.

9. Incident Reports.

10. Significant operating Experience Reports 2.7.5 Procran Administration 2.7.5.1 Responsibility Responsibility for coordination and supervision of the Refueling License Training Program is delegated to the Director, operations Training.

2.7.5.2 Accelerated Retraining Any licensee who scores less than 80% overall on the annual written examination, or scores less than 70% in any category, or fails to receive a satisfactory score on the annual oral examination, will be relieved of duties requiring a license and will be placed in accel-erated retraining under the direction of the Director, operations Training, or his alternate. The licensee will be reinstated to licensed duties after completing the prescribed retraining and scoring at least 30% overall on re-examination and at least 70% in each category, or receiving a satisfactory on the defined weak areas of the annual oral examination.

2.7.5.3 Periodic Examinations Periodic writton examinations or quizzes will be administered to assess licensoos' knowledge of topics covered in Phaso 2 formal classroom instruction. Remedial training will bo performed for licensees who score less than 80% on periodic examinations. l 2.7.5.4 Active Licensos Any Licensoo that is current and satisfactory within the scopo of the Refueling License Retraining Program and participates in pre-refuel-ing activition, including testing of fuel handling equipment, review

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l DUQUESNE LIGHT COMPANY Volumo 2 '

Huclear Group Chapter 2 Training Administrative Manual Section 2.7 of procedures, and supervision of personnel performing refueling activities shall be considered as having an active license in accordance with 10 CFR 55.31(e). Any Licensee that does not meet -

this requirenent will be considered inactive and will require ,

satisfactory completion of an oral examination administered by an individual with an active refueling Senior operator License.  !

2.7.6 Procram Documentation l

Each df the documents specified in this Subsection will be maintained j with the program records for each cycle of the Refueling License Retraining Program.

1. A record of each licensee's participation in the Licensed operator Retraining Program will be maintained on the i Refueling License Retraining Summary (Figure 2.7.1). l

2. Attendance during Phase 2 formal classroom training will be reported on the Retraining Attendance Record (Volume 1, i Figure 5.8).

3. Phase 4 individual study will be programmed on a monthly basis. The Director operations Training will prepara the Individual Study Guide (Figure 2.2.2) and distribute a copy to each licensee. ,

4. Completion of Phase 3 oral examinations will be documented on the Fuel Handling SRO Walk-Through Training Checklist

< (Figure 2.7.2).

5. A copy of each annual examination, periodic examination, or quiz, answer keys and the answers provided by licensees  !

will be maintained with the individual's examination file  !

and in the Refueling License Retraining Examination file. i

6. The Summary of Recommendations (Figure 2.2.5) will be used l to document the recommendations for training emphasia l arising from the reviews of annual written examination l i results.

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DUQUESNE LIGHT COMPANY Volumo 2 Nuclear Group Chapter 2

, Training Administrative Manual Section 2.7

7. All records associated with required accelerated retraining will be maintained in the individual's RLRT file. The records will include a description of the accelerated retraining program, original and retake exam scores, and all pertinent information.

2.7.7 Procram References

1. U.S. Nuclear Regulatory Commission Memorandum; Limited ,

License November 21, 1967.

2. 10 CFR 50.54 2(iv). ,

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3. Beaver Valley Refueling Procedures.

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4. BVPS-1 -

Updated FSAR Section 14.2.1, Fuel Handling Accident. l 2.7.8 Summarv of Fiaures

1. Refueling License Retraining Summary - Figure 2.7.1

2. Fuel Handling SRO Walk-through Training Checklist - Figure 2.7.2

3. Retraining Attendance Record - Volume 1, Figure 5.8

4. Individual Study Guide - Volume 2, Figure 2.2.2 l l 5. Summary of Recommendations - Volume 2, Figure 2.2.5 4

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• [ y o, UNITED STATES NUCLEAR REGULATORY COMMISSION 7

WASHINGTON, D. C. 20646 f l December 2,1986 Docket No. 50-334 ,

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Mr. J. D. Sieber, Vice President l Duquesne Light Company Nuclear Operations Post Office Box 4 ,

Shippingport, PA 15077 i

Subject:

Beaver Valley Unit 1 - Revised Operation Training and Simulator Training Programs (TAC 601721 Ry letter dated October 30, 1985, you submitted the subject revised programs as a result of our Generic Letter 84-14. "Replacement and Requalification Training Program." Subsequent to that, as a result of our request for additional l information dated April 28, 1986, you submitted supplemental infonnation dated

• June 30 and September 30, 1986.

We have reviewed the documents and have held discussions with your training staff on November 5,1986. Based on this infomation, we have detennined. -,

with the following clarifications, that the requalification programs for Beaver Valley, Unit 1 meet the conditions contained in Appendix A of 10 CFR 55 and the criteria contained in NUREG-0737 and are, therefore, ,

acceptable. The issues clarified on November 5, 1986 are:

al For Section 2.2.4.3, "Plant Mantoulations Training," and Section 12.5.3, "Scope of Training (Simulator 1," that the need for additional simulator training is developed from infonnation obtained in Section 2.2.4.5, "Perfomance Evaluations." l b) That provision for continuing performance evaluations which may require accelerated training are contained in the "Beaver Valley Power 1 Station Adninistrative Procedure No.15 -- Evaluation of Job Performance," described in Section 2.2.4.5 of the requalification program.  ;

This completes our efforts on your submittals. The review was perfomed by  !

J. Buzy of the NRR staff.  !

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Peter S. Tam, Proiect Manager JWR Pro,iect Directorate #2 '

Division of PWR Licensing-A Office of Nuclear Reactor Regulation cc: See next page '

Mr. J. D. Sieber Reaver Valley 1 Power Station Duquesne Light Company cc:

Mr. W. S. Lacey Pennsylvania Power Company Station Superintendent James R. Edgerly Duquesne Light Comoany post Office 9ox 891 Beaver Valley Power Station New Castle, Pennsylvania 16103 Post Office Box a Shippingport, Pennsylvania 15007 Mr. Jess T. Shumate, comissioner State of West Virginia Department Mr. S. Sovick, Acting Supervisor of Labor of Licensing 1800 Washington Street, East Duquesne Light Company Charleston, West Virginia 25305 Post Office Box 4 Shippingport, Pennsylvania 15077 David K. Heydinger, M.D.

State Director of Health Mr. John A. Levin State Department of Health Public Utility Comission 1800 Washington Street East Post Office Box 3265 Charleston, West Virginia 25305 Harrisburg, Pennsylvania 17120 Regional Administrator, Region I Gerald Charnoff, Esquire U.S. Nuclear Regulatory Comission-Jay E. Silberg, Esquire 631 Park Avenue Shaw, Pittman, Potts and Trowbridge King of Prussia, Pennsylvania 19406 2300 N Street, N.W.

Washington, DC 20037 Mr. R. Janati Rureau of Radiation Protection Charles E. Thomas, Esquire Pennys1vania Department of Thomas and Thomas Environmental Resources 212 Locust Strett P.O. Box 2063 Box 999 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17108 John D. Rurrows, P.E.

Marvin Fein Director of Utilities Utility Counsel State of Ohio City of Pittsburgh Public Utilities Comissic,n 313 City-County Building 180 East Broad Street Pittsburg, Pennsylvania 15219 Columbus, Ohio 43266-0573 Resident Inspector U.S. Nuclear Regulatory Comission

• Post Office Pox 298 Shippingport, Pennsylvania 15077

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