ML13317A377
| ML13317A377 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/17/1982 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13317A376 | List: |
| References | |
| CON-NRC-03-82-096, CON-NRC-3-82-96, RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM SAI-186-029-17, SAI-186-29-17, TAC-44128, NUDOCS 8210290320 | |
| Download: ML13317A377 (15) | |
Text
ENCLOSURE 1
- g 0
SAl f86-029-17 TECHNICAL EVALUATION REPORT IMPROVEMENTS IN TRAINING AND REQUALIFICATION PROGRAMS AS REQUIRED BY TMI ACTION ITEMS I.A.2.1 AND II.B.4 for the San Onofre Nuclear Generating Station, Unit.1 (Docket 50-206)
August 17, 1982 Prepared By:
Science Applications, Inc.
1710 Goodridge Drive
- McLean, Virginia 22102 Prepared for:
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Contract NRC-03-82-096 8210290320 621026 PDR ADOCK 05000206 V
PDR science Applications, Inc.
TABLE OF CONTENTS Section Page I.
INTRODUCTION....
1 II.
SCOPE AND CONTENT OF THE EVALUATION A.
I.A.2.1: Immediate Upgrading of RO and SRO Training and Qualifications 1
B. II.B.4:
Training for Mitigating Core Damage.
6 III.
LICENSEE SUBMITTALS.
7 IV..
EVALUATION..................
9 A.
I.A.2.1:
Immediate Upgrading of. RO and SRO Training and Qualifications 9
B.
II.B.4:
Training for Mitigating Core Damage.
11 V.
CONCLUSIONS.
...12 VI.
REFERENCES................
13
I. INTRODUCTION Science Applications, Inc. (SAI),
as technical assistance contrac tor to the U.S.
Nuclear Regulatory Commission, has evaluated the response by Southern California Edison Company for the San Onofre Nuclear Generating Station, Unit 1 (Docket 50-206) to certain requirements contained in post TMI Action Items I.A.2.1, Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications, and II.B.4, Training for Mitigating Core Damage.
These requirements were set forth in NUREG-0660 (Reference 1) and were subsequently clarified in NUREG-0737 (Reference 2).*
The purpose of the evaluation was to determine whether the licensee's operator training and requalification programs satisfy the requirements. The evaluation pertains to Technical Assignment Control (TAC)
System numbers 44199 (NUREG-0737,- I.A.2.1.4) and 44549 (NUREG-0737, II.B.4.1).
As delineated below, the evaluation covers only some aspects of item I.A.2.1.4.
The detailed evaluation of the licensee's submittals is presented in Section IV; the conclusions are in Section V.
II. SCOPE AND CONTENT OF THE EVALUATION A. I.A.2.1:
Immediate Upgrading of RO and SRO Training and Qualifications The clarification of TMI Action Item I.A.2.1 in NUREG-0737 incor porates a letter and four enclosures, dated March 28, 1980, from Harold R.
Denton, Director, Office of Nuclear Reactor Regulation,-USNRC, to all power reactor applicants and licensees, concerning qualifications of reactor operators (hereafter referred to as Denton's letter).
This letter and enclosures imposes a number of training requirements on power reactor licensees. This evaluation specifically addressed a subset of the require ments stated in Enclosure 1 of Denton's letter, namely:
Item A.2.c, which relates to operator traini-ng requirements; item A.2.e, which concerns instructor requalification; and Section C, which addresses operator requali fication. Some of these requirements are elaborated in Enclosures 2, 3, and 4 of Denton's letter.
The training requirements under evaluation are sum marized in Figure 1. The elaborations of these requirements in Enclosures 2, 3 and 4 of Denton's letter are shown respectively in Figures 2, 3 and 4.
As noted in Figure 1, Enclosures 2 and 3 indicate minimum require ments concerning course content in their respective areas. In addition, the Operator Licensing Branch in NRC has taken the position (Reference 3) that the training in mitigating core damage and related subjects should consist
- Enclosure 1 of NUREG-0737 and NRC's.Technical Assistance Control System distinguish four sub-actions within I.A.2.1 and two sub-actions within II.B.4.
These subdivisions are not carried forward to the actual presentation of the requirements in Enclosure 3 of NUREG-0737.
If they had been, the items of concern here would be contained in I.A.2.1.4 and II.B.4.1.
Figure 1. Training Requirements from TMI Action Item I.A.2.1*
Program Element NRC Requirements*, Item A.2.c(1)
Training programs shall be modified, as necessary, to provide training in heat transfer, fluid flow and thermodynamics. (Enclosure 2 provides guidelines for the minimum content of such training.)
OPERATIONS, Item A.2.c(2)
PERSONNEL Training programs shall be modified, as necessary to provide training in the TRAINING use of installed plant systems to control or mitigate an accident in which the core is severely damaged.
(Enclosure 3 provides guidelines for the minimum content of such training.), Item A.2.c.(3)
Training programs shall be modified, as necessary to provide increased emphasis on reactor and plant transients.,
Item A.2.e INSTRUCTOR Instructors shall be enrolled in appropriate requalification programs to assure REQUALIFICATION they are cognizant of current operating history, problems, and changes to pro cedures and administrative limitations., Item C.1 Content of the licensed operator requalification programs shall be modified to irclude instruction in heat transfer, fluid flow, thermodynamics, and mitiga tion of accidents involving a degraded core. (Enclosures 2 and 3 provide guide lines for the minimum content of such training.)
PERSONNEL, Item C.2 CATION The criteria for requiring a licensed individual to participate in accelerated REQUALIFC requalification shall be modified to be consistent with the new passing grade for issuance of a license: 80 overall and 70', each category., Item C.3 Programs should be modified to require the control manipulations listed in. Normal control manipulations, such as plant or reactor startups, must be performed. Control manipulations during abnormal or emergency opera tions must be walked through with, and evaluated by, a member of the training staff at a minimum. An appropriate simulator may be used to satisfy the requirements for control manipulations.
'The requirements shown are a subset of those contained in Item I.A.2.1.
- References to Enclosures are to Denton's letter of March 28, 1980, which is contained in the clarifi cation of Item 1.A.2.1 in NUREG-0737.
Figure 2. from Denton's Letter TRAINING IN HEAT TRANSFER, FLUID FLOW AND THERMODYNAMICS
- 1. Basic Properties of Fluids and Matter.
This section should cover a basic introduction to matter and its properties.
This section should include such concepts as temperature measurements and effects, density and its effects, specific weight, buoyancy, viscosity and other properties of fluids. A working knowledge of steam tables should also be included.
Energy movement should be discussed including such fundamentals as heat exchange, specific heat, latent heat of vaporization and sensible heat.
- 2. Fluid Statics.
This section should cover the pressure, temperature and volume effects on fluids.
Example of these parametric changes should be illustrated by the instructor and related calculations should be performed by the students and discussed in the training sessions. Causes and effects of pressure and temperature changes in the various components and systems should be discussed in the training sessions.
Causes and effects of pressure and temperature changes in the various components and systems should be discussed as applicable to the facility with particular emphasis on safety significant features.
The characteristics of force and pressure, pressure in liquids at rest, principles of hydraulics, saturation pressure and temperature and subcooling should also be included.
- 3. Fluid Dynamics.
This section should cover the flow of fluids and such concepts as Bernoulli's principle, energy in moving fluids, flow measure theory and devices and pressure losses due to friction and orificing.
Other concepts and terms to be discussed in this section are NPSH, carry over, carry under, kinetic energy, head-loss relationships and two phase flow fundamentals.
Practical applications relating to the reactor coolant system and steam generators should also be included.
- 4. Heat Transfer by Conduction, Convection and Radiation.
This section should cover the fundamentals of heat transfer by conductions.
This section should include discussions on such concepts and terms as specific heat, heat flux and atomic action.
Heat transfer characteristics of fuel rods and heat exchangers should te included in this section.
This section should cover the fundamentals of heat transfer by convection. Natural and forced circula tion should be discussed as applicable to the various systems at the facility. The convection current patterns created by expanding fluids in a confined area should be included in this section.
Heat transport and fluid flow reductions or stoppage should be discussed due to steam and/or noncondensible gas formation during normal and accident conditions.
This section should cover the fundamentals of heat transfer by thermal radiation in the form of radiant energy. The electromagnetic energy emitted by a body as a result of its temperature should be discussed and illustrated by the use of equations and sample calculations.
Comparisons should be made of a black body absorber and a white body emitter.
- 5. Chanoe of Phase - Boiling.
This section should include descriptions of the state of matter, their inherent characteristics and thermodynamic properties such as enthalpy and entropy.
Calculations should be performed involving steam quality and void fraction properties.
The types of boiling should be discussed as applicable to the facility during normal evolutions and accident conditions.
- 6. Burnout and Flow Instability.
This section should cover descriptions and mechanisms for calculating such terms as critical flux, critical power, DNS ratio and hot channel factors.
This section should also include instructions for preventing and monitoring for clad or fuel damage and flow instabilities. Sample calculations should be illustrated by the instructor and calculations should be performed by the students and discussed in the training sessions. Methods and procedures for using the plant computer to determine quantitative values of various factors during plant operation and plant heat balance determinations should also be covered in this section.
- 7. Reactor Heat Transfer Limits.
This section should include a discussion of heat transfer limits by examining fuel rod and reactor design and limitations. The basis for the limits should be covered in this section along with recommended methods to ensure that limits are not approached or exceeded.
This section should cover discussions of peaking factors, radial and axial power distributions and changes of these factors due to the influence of other variables such as moderator temperature, xenon and control rod position.
3
Figure 3. Enclosure 3 from Denton's Letter TRAINING CRITERIA FOR MITIGATING CORE DAMAGE A. Incore Instrumentation
- 1. Use of fixed or movable incore detectors to determine extent of core damage and geometry changes.
- 2. Use of thermocouples in determining peak temperatures; methods for extended range readings; methods for direct readings at terminal junctions.
- 3. Methods for calling up (printing) incore data from the plant computer.
B. Excore Nuclear Instrumentation (NIS)
- 1.
Use of NIS for determination of void formation; void location basis for NIS response as a function of core temperatures and density changes.
C.
Vital Instrumentation
- 1. Instrumentation response in an accident environment; failure sequence (time to failure, method of failure); indication reliability (actual vs indicated level).
- 2. Alternative methods for measuring flows, pressures, levels, and temperatures.
- a. Determination of pressurizer level if all level transmitters fail.
- b. Determination of letdown flow with a clogged filter (low flow).
- c. Determination of other Reactor Coolant System parameters if the primary method of measurement has failed.
D. Primary Chemistry
- 1. Expected chemistry results with severe core damage; consequences of transferring small quantities of liquid outside containment; importance of using leak tight systems.
- 2. Expected isotopic breakdown for core damage; for clad damage.
- 3. Corrosion effects of extended imersion in primary water; time to failure.
E. Radiation Monitoring
- 1. Resoonse of Process and Area Monitors to severe damages; behavior of detectors when saturated; method for detecting radiation readings by direct measurement at detector output (overranged detector);
expected accuracy of detectors at different locations; use of detectors to determine extent of core damage.
- 2.
Methods of determining dose rate inside containment from measurements taken outside containment.
F..
Gas Generation
- 1.
Methods of H2 generation during an accident; other sources of gas (Xe, Ke); techniques for venting or disposal of non-condensibles.
- 2.
H2 flamability and explosive limit; sources of 02 in containment or Reactor Coolant System.
4
Figure 4. Control Manipulations Listedlin Enclosure 4.
CONTROL MANIPULATIONS
- 1.
Plant or reactor startups to include a range that reietivity feedback from nuclear heat addition is noticeable and heatup rate is established.
- 2.
Plant shutdown.
- 3.
Manual control of steam generators and/or feedwater diing startup and shutdown.
- 4.
Boration and or dilution during power operation.
- 5.
Any significant (greater than 10%) power changes in meiral rod control or recirculation flow.
- 6.
Any reactor power change of 10% or greater where load 'dange is performed with load limit control or where flux, temperature, or speed control is on madual (for HTGR).
- 7.
Loss of coolant including:
- 1. significant PWR steam generator leaks
- 2. inside and outside primary containment
- 3.
large and small, including leak-rate determination
- 4.
saturated Reactor Coolant response (PWR).
- 8.
Loss of instrument air (if simulated plant specific).
- 9.
Loss of electrical power (and/or degraded power sources).
- 10.
Loss of core coolant flow/natural circulation.
- 11.
- 12.
Loss of service water if required for safety.
- 13.
Loss of shjtdown cooling.
- 14.
Loss of component cooling system or cooling to an individual component.
- 15.
Loss of normal feedwater or normal feedwater system failure.
- 16, Loss of all feed.ater (normal and emergency).
- 17.
Loss of protective system channel.
- 18.
Mispositioned control rod or rods (or rod drops).
- 19.
Inability to drive control rods.
- 20.
Conditions requiring use of emergency boration or standby liquid control system.
- 21.
Fuel cladding failure or high activity in reactor coolant or offgas.
- 22.
Turbine or generator trip.
- 23.
Malfunction of automatic control system(s) which affect reactivity.
- 24.
Malfunction of reactor coolant pressure/volume control:system.
- 25.
- 26.
Main steam line break (inside or outside containment).
- 27.
Nuclear instrumentation failure(s).
Starred items to be performed annually, all others biennially.
5
of at least 80 contact hours* in both the initial training and the requali fication programs.
The NRC considers thermodynamics, fluid flow and heat transfer to be related subjects, so the 80-hour requirement applies to the combined subject areas of Enclosures 2 and 3. The 80 contact hour criterion is not intended to be applied rigidly; rather, its purpose is to provide greater assurance of adequate course content when the licensee's training courses are not described in detail.
Since the licensees generally have their own unique course out lines, adequacy of response to these requirements necessarily depends only on whether it is at a level of detail comparable to that specified in the enclosures (and consistent with the 80 contact hour requirement) and whether it can reasonably be concluded from the licensee's description of his train ing material that the items in the enclosures are covered.
The Institute of Nuclear Power Operations (INPO) has developed its.
own guidelines for training in the subject areas of Enclosures 2 and 3.
These guidelines, given in References 4 and 5, were developed in response to the same requirements and are more than adequate, i.e., training programs based specifically on the complete INPO documents are expected to satisfy all the-requirements pertaining to training material which are addressed in this evaluation.
The licensee's response concerning increased emphasis on tran sients is cQnsidered by SAI to be acceptable if it makes explicit reference to increased emphasis on transients and gives some indication of the nature of the increase, or, if it addresses both normal and abnormal transients (without necessarily indicating an increase in emphasis) and the requalifi cation program satisfies the requirements for control manipulations, Enclo sure 1, Item C.3.
The latter requirement calls for all the manipulations listed in Enclosure 4 (Figure 4 in this report) to be performed, at the frequency indicated, unless they are specifically not applicable to the licensee's type of reactor(s).
Some of these manipulations may be performed on a simulator.
Personnel with senior licenses may be credited with these activities if they direct or evaluate control manipulations as they are performed by others. Although these manipulations are acceptable for meet ing the reactivity control manipulations required by Appendix A paragraph 3.a of 10 CFR 55, the requirements of Enclosure 4 are more demanding. requires about 32 specific manipulations over a two-year cycle while 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.
B. II.B.4:
Training for Mitigating Core Damage Item II.B.4 in NUREG-0737 requires that "shift technical advisors and operating personnel from the plant manager through the operations chain to the licensed operators" receive training on the use of installed systems to control or mitigate accidents in which the core is severely damaged.
- A contact hour is a one-hour period in which the course instructor is present or available for instructing or assisting students; lectures, seminars, discussions, problem-solving sessions, and examinations are considered contact periods. This definition is taken from Reference 4.
6 of Denton's letter provides guidance on the content of this training.
"lant Manager" is here taken to mean the highest ranking manager at the plant site.
Fdr licensed personnel, this training would be redundant in that it is also required, by I.A.2.1, in the operator requalification program.
However, II.B.4 applies also to operations personnel who are not licensed and are not candidates for licenses. This may include one or more of the highest levels of management at the plant.
These non-licensed personnel are not explicitly required to have training in heat transfer, fluid flow and thermodynamics and are therefore not obligated for the full 80 contact hours of training in mitigating core damage and related subjects.
Some non-operating personnel, notably managers and technicians in instrumentation and control, health physics and chemistry departments, are supposed to receive those portions of the training which are commensurate with their 'responsibilities.
Since this imposes no additional demands on the progra itself, we do not address it in this evaluation.
It would be appropriate-for resident inspectors to verify that non-operating personnel receive the proper training.
The required implementation dates for all items have passed.
- Hence, this evaluation did not address the dates of implementation.
- Moreover, the evaluation does not cover training program modifications that mi.ght have been made for other reasons subsequent to the response to Denton's letter.
III.
LICENSEE SUBMITTALS The licensee (Southern California Edison Company) has submitted to NRC a number of items (letters and various attachments) which explain their training and requalification programs. These submittals, made in response to Denton's letter, form the information base for this evaluation.
For the San Onofre Nuclear Generating Station, Unit 1, there were 5 submittals with attachments, for a total of 11 items, which are listed below.
- 1.
Letter from' H.L.
- Ottoson, Manager of Nuclear Operations, San Onofre Nuclear Generating Station (SONGS) Unit 1, to P.F. Collins, Chief of Operator Licensing Branch, NRC.
July 31, 1980.
(2 pp, with enclosure: item 2).
(re: Response to NRC letter dated March 29, 1980).
- 2.
"Operator Requalification Program", SONGS Unit 1, Revision 2. July, 1980.
(15 pp, attached to item 1).
- 3.
Letter from W.C.
- Moody, Manager of Nuclear Licensing, Southern California Edison Co.,
to D.M.
Crutchfield, Chief of Operating Reactors Branch #5, 7
pg).
NRC Acc No: 8110080095.
(re: Clarification of TMI Action Plan Requirements).
- 4.
Letter from R.W. Krieger, Supervising Engineer, SONGS Unit 1 Licensing, to D.M. Crutchfield, Chief of Operating Reactors Branch #5, Division of Licensing, NRC. November 25, 1981.
(2 pp).
NRC Acc No: 8112210233.
(re: Clarification of TMI Action Plan Requirements).
- 5. Letter from K.P. Baskin, Manager of Nuclear Engineering, Safety & Licensing, Southern California Edison Co., to D.M. Crutchfield, Chief of Operating Reactors Branch- #5, Division of Licensing, NRC.
March 24, 1982.
(1 pg, with enclosures: items 6, 7, & 8).
NRC Acc No:
8203260146.
- 6.
Training memorandum 20-81, "Nuclear Operator Training & Requalification Program",
Nuclear Training Division, SONGS Unit 1 or Units 2 & 3.
Signed by W.G. Zintl, November 25, 1981.
(1 pg, attached to item 5).
I.D. No: 1859A.
- 7.
"Additional Training Files to be included in Licensed Operator Initial Training Program".
Undated. (1 pg, included in Enclosure 1, attached to item 5).
I.D. No: 2670A.
- 8. "Operator Requalification Program",
SONGS 1,
Revision 2.
July 1980.
(11 pp, attached to item 5).
NRC Acc No: 8203260147.
(Notes: a new Section 7 is attached to the July 1980 version).
- 9. Letter from K. P. Baskin, Manager of Nuclear Engineering, Safety & Licensing, Southern California Edison Co., to D.M. Crutchfield, Chief of Operating Reactors Branch #5, Division of Licensing, NRC.
June 29, 1982. (4 pp, with enclosures: items 10 & 11).
(re: Response to NRC's RAI).
- 10.
"Training Memorandum 8-80/Rev. 1 ",
Nuclear Training Division, SONGS.
February 23, 1981. (14 pp, attached to item 9).
(re: Training for Mitigating Core Damage, Course Outlines).
- 11.
"Facility Organization".
May 07, 1981.
(1 pg, attached to item 9).
(re: Organizational Chart).
8
IV. EVALUATION SAI's evaluation of the training programsat Southern Cal ifornia Edison Company's San Onofre Nuclear Generating Station, Unit 1, is presented below. Section A addresses TMI Action Item I.A.2.1 and presents the assessment organized in the manner of Figure 1..Section-B addresses TMI Action Item II.B.4.
A. I.A.2.1: Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualification., Item A.2.c(1)
The basic requirements are that the traihing programs given to reactor operator and senior reactor operator candidates cover the subjects of heat transfer, fluid flow and thermodynamics at the level of detail specified in Enclosure 2 of Denton's letter.
Southern California. Edison Company submitted an addendum (submittal item 6) which applies to their training program.
This addendum outlined additional criteria for their initial training program, as a commitment to Denton's letter. Part of the commitment calls for training in "Heat Transfer, Fluid Flow and Thermodynamics" to be incorporated into their training program. Later, the licensee in submittal item 9 stated that the initial training program for San Onofre Unit 1 has been upgraded to 'comply with Enclosure 2 of the Denton letter. The licensee further stated that the level of detail covered in the program meets or exceeds that which is required by Denton's letter.
Therefore, SAI would credit Southern California Edison Company for meeting this requirement.
At the same time, SAI recommends that the material contents of this training be subject to audit against Enclosure 2 during a future inspection., Item A.2.c(2)
The requirements are that the training programs for reactor and senior reactor operator candidates cover the subject of accident mitigation at the level of detail specified in Enclosure 3 of Denton's letter (see Figure 3 of this report).
The addendum discussed in item A.2.c.(1) also listed a training subject titled "Core Damage Mitigation" as part-of the commitment to Denton's letter. In addition, the licensee, later, submitted a course outline titled "Mitigating Core Damage Lecture Outline Unit 1" (appendix A in submittal item 10). This outline directly addresses all items in Enclo sure 3 except one. Although the missing item, "methods for calling up (printing) incore data from the plant computer",
is!
not explicitly identi fied in the outline, SAI believes that this item is.covered in the outline
.and the licensee stated in submittal item 9 that San Onofre expanded its training in this area and the detail of this training meets or exceeds the requirement. Therefore, SAI judges that this requirement is met at the San Onofre Nuclear Generating Station, Unit 1...
Another requirement relative to accident mitigation training is that about 80 contact hours be involved for training in the area of accident mitigation and related subjects (heat transfer, fluid flow and 9
thermodynamics). Submittal item 9 shows a 40 contact hour training involve ment in the area of accident mitigation with core damage.
In addition, the licensee stated in submittal item 9 that their training program in the area of heat transfer, fluid flow and thermodynamics involves 80 contact hours.
Therefore, this requirement is met at San Onofre Nuclear Generating Station, Unit 1., Item A.2.c(3)
The requirement is that there be an increased emphasis in the training program on dealing.with reactor transients.
The licensee stated in submittal item 9 that San Onofre has expanded its training in the area of accidentsand transients. The licensee further stated that the detail of this increased training meets or exceeds the requirement. Therefore, SAI would credit the licensee with meeting the NRC criterion., Item A.2.e The requirement is that instructors for reactor operator training programs be enrolled in appropriate requalification programs to assure they are cognizant of current operating history, problems and changes to procedures and administrative limitations.
Southern California Edison Company in submittal item 1 stated that their revised requalification program requires all licensed instructors to be participants in the requalification program. SAI has examined the requalification program and found that it does address Abnormal Occurrence Reports, Radiation Protection Manual, Facility Design Changes, Fire Preven tion Manual, Facility License Changes and Procedure Changes. This meets the NRC requirement., Item C.1 The primary requirement is that the requalification programs have instruction in the areas of heat transfer, fluid flow, thermodynamics and accident mitigation. The level of detail required in the requalification program is that of Enclosures 2 and 3 of Denton's letter.
In addition, these instructions must involve an adequate number of contact hours.
The licensee in submittal item 9 stated that their requalification program covers the topics in the initial training program but not to the detail of the initial training program.
The licensee further stated that "the requalification program does not involve a total of 80 contact hours, but the portion of time spent on these topics is proportional to the amount of time spent during the initial training program".
SAI asked the NRC Project Manager to inquire about the number of contact hours involvement relating to accident mitigation training in the requalification program.
The licensee, in responding to NRC Project Manager, stated that their requalification program totals 16 contact hours (8 contact hours in accident mitigation training and 8 contact hours in heat transfer, fluid flow and thermodynamics) of training for this subject area.
Since the licensee's requalification program, is not in compliance with the NRC's 80 contact hours 10
criterion, S I judges that this requirement is not met at San Onofre Nuclear Generating Station, Unit 1.,Item C.2 Tht requirement for licensed'operators to participate in the accelerated requalification program must be based on passing scores of 80%
overall, 70% in each category.
Antoverall grade of 80% with no one section less than 70% on the annual examfhation is considered acceptable at San Onofre Nuclear Generating Station, Unit 1. If a licensed operator or senior operator fails to meet this criterion, they will be removed from licensed duties and assigned to accelerated training. The individual will be assigned licensed duties after completing the course and satisfactorily passing an examination covering the required subjects. This is in compliance with the NRC requirement.., Item C.3 TqI Action Item I.A.2.1' calls for the T1'icenlsed dperator' re-uaiifi-.
cation progrim to include performance of control manipulations involving both normal land abnormal situations. The specific manipulations required and their performance frequency are identified in Enclosure 4 of the Denton letter (see Figure 4 of this report).
The submitted requalification program (submittal item 2) includes all the ites in Enclosure.4 except one, "loss of service water if required for safety". Later, the licensee in submittal item 9 stated that "the salt
-water coolfng system at San Onofre Unit 1 provides the safety related cooling fun'ction for component cooling that service water cooling might provide at a'plant that does not use salt water for its ultimate heat sink".
SAI judges from this that the licensee's requalification program meets the requirement.
B. II.B.4 Training.for Mitigating Core Damage Item II.B.4 requires that training for mitigating core damage, as indicated in Enclosure 3 of Denton's letter, be given to shift technical advisors and operating personnel from the plant manager to the licensed operators. This includes b6th licensed and non-licensed personnel.
The training of the licensed personnel does not meet the require ments of Action Item II.B.4 because the licensed personnel who receive this training through the requalification program do not meet the 80 contact hours criterion for this training area (the requalification program involves only 16 contlact hours training in this area).
Based on information, including an organization chart, supplied by Southern California Edison Company in their response (submittal items 9 and
- 11) to NRC's'request for additional information (Reference 6), it appears that this requirement for the non-licensed personnel is satisfied at SONGS
- 1. Specifically, this training is given to personnel holding the following positions: Station Manager, Assistant Manager Operations, Plant Superinten dent, Watch'Engineers, Operating Foreman, Plant Operators, Supervisor of Plant Coordi'nation, Operating Foremen and Shift Technical Advisors.
11
V. CONCLUSIONS Based on our evaluation as discussed above, SAI concludes that the.
licensee does not fully meet the requirements of NUREG-0737 item I.A.2.1.
The deficiency occurs in the requalification program, which has less than 80 contact hours involvement in the training for heat transfer, fluid flow, thermodynamics, and accident mitigation with core damage.
The licensee also fails to fully satisfy the requirements of NUREG-0737 item II.B.4 because licensed personnel receive less than 80 contact hours training which relates to mitigating core damage.
An upgrading of the requalification program to include 80 contact hours on these subjects would automatically satisfy the II.B.4 deficiency for licensed personnel.
12
V. REFERENCES
- 1.
"NRC Action Plan Developed as a Result of the TMI-2 Accident."
NUREG 0660, United States Nuclear Regulatory., CoMmission.
May 1980.
- 2.
"Clarification of TMI Action Plan Requilements," NUREG-0737, United States Nuclear Regulatory Commission.
NoVember 1980.
- 3.
The NRC requirement for 80 contact hoO-s is an Operator Licensing Branch technical position. It was iIcluded with the acceptance criteria provided by NRC to SAI for use in the present evaluation. See letter, Harley Silver, Technical AssistaACe Program Management Group, Division of Licensing, USNRC to Bryce Johhton, Program Manager, Science Applications, Inc.,
Subject:
Contract No. NRC-03-82-096, Final Work Assignment 2, December 23, 1981.
- 4.
"Guidelines for Heat Transfer, Fl'uid-Flow and 'Thermodynamics Instruction," STG-02, The Institute-of Nuclear,'Power. Operations.
December 12, 1980.
- 5. "Guidelines for Training to Recognize and Mitigate the Consequences of Core Damage," STG-01, The Institute of Nuclear Power Operations.
January 15, 1981.
- 6. Letter from Dennis M. Crutchfield, NRC-to R. Dietch, Nuclear Engineering and Operations, Southern California Edison Company, transmitting request' for additional information on Upgraded SRO and RO Training and Training for Mitigating Core Damage, dated 10 May 1982.
13