ML18018A755

Forwards Response to Request for Addl Info Re FSAR Section 13.2 & Open Item 322 Concerning Shift Technical Advisor Training

ML18018A755
Person / Time
Site:	Harris
Issue date:	09/16/1983
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
LAP-83-411, NUDOCS 8309230417
Download: ML18018A755 (42)

Text

b REGULATORY FORMATION DISTRIBUTION SY M (RIDS)

ACCESSION NBR:8309230417 DOC ~ DATE! 83/09/16 NOTARIZED NO DOCKET ¹ P'ACIL:50 400 Shearon Harrjs Nuclear Power Planti Unjt ii ~

Caroljna 05000400 50-401 Shearon Harris Nuclear Power Planti Unit 2i Carolina 05000401 AUTH NAME AUTHOR AFF ILI'ATION MCDUFFIE>M,A. Carol ina Power 8 Light Co.

REC IP t NAME RECIPIENT AFFILIATION

'DENTONiH ~ R, Office of Nuclear Reactor Regulationi 'Diit ector

SUBJECT:

Forwards response to request for addi info re FSAR Section 13.2 8 Open Item 322 concerning shift"technical advisor training ~

DISTRIBUTION CODE: B001S COPIES RECEIVED:LTR 'NCL'-'SIZE: " -.

'TITLE! Licensing Submittal: PSAR/FSAR Amdts 8 Related Cor respondence NOTES!

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL IO CODE/NAME LTTR ENCL NRR/DL/ADL 1 0 NRR LB3 BC j, 0 NRR LB3 LA 1 *0 BUCKI KYr B 01 1 1 INTERNAL: ELD/HDS1 1 0 IE FILE IE/DEPER/KPB 3 IE/DEPER/IRB 35 21 36'E/DEQA/QAB 1 1 NRR/DK/AEAB NRR/DE/CEB 11 1 1 NRR/DK/EHEB NRR/DE/EQB 13 2 2 NRR/DE/GB 28 NRR/DE/MEB 18 1 1 NRR/DE/MTEB 17 NRR/DE/SAB 24 1 1 NRR/DE/SGEB 25 NRR/DHFS/HFKB40 1 1 NRR/DHFS/LQB 32 NRR/DHFS/PSRB 1 1 NRR/OL/SSPB NRR/DSI/AEB 26 1 1 NRR/DSI/ASB NRR/DSI/CPB 10 1 NRR/DSI/CSB 09 NRR/DSI/ICSB 16 1 '1 NRR/DS I/METB 12 NRR/DS I/PSB 19 1 1 B 22 NRR/DS I/RSB 23 1 1 04 RGN? 3 RM/DDAMI/MIB EXTERNAL'CRS 41 6 6 BNL(AMDTS ONLY) 1- 1 OMB/DSS (AMDTS) 1 1 FEMA REP DI'V 39 1 1 LPDR 03 1 1 NRC PDR 02 1 NSIC 05 1 NTIS 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 53 ENCL 46

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@ME, Carolina Power & Light Company SERIAL: LAP-83-411 SEP 16 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-400 AND 50-401 ADDITIONAL INFORMATION REGARDING TRAINING

Dear Mr. Denton:

Carolina Power & Light Company hereby transmits one original and forty copies of additional information requested by the NRC Staff as a part of the safety review of the Shearon Harris Nuclear Power Plant (SHNPP).

The information supplied includes as Attachment I a marked-up SHNPP Final Safety Analysis Report Section 13.2 describing the current SHNPP training program, and as Attachment II additional information on Open Item 322 concerning Shift Technical Advisor Training (STA).

Yours very truly, M. A. McDuffie Senior Vice President Nuclear Generation NEC/ccc (7809NEC)

Attachments CC: Mr. B. C. Buckley (NRC) Mr. Wells Eddleman Mr. G. F. Maxwell (NRC-SHNPP) Dr. Phyllis Lotchin Mr. J. P. O'Reilly (NRC-RII) Mr. John D. Runkle Mr. Travis Payne (KUDZU) Dr. Richard D. Wilson Mr. Daniel F. Read (CHANGE/ELP) Mr. G. 0. Bright (ASLB)

Chapel Hill Public Library Dr. J. H. Carpenter (ASLB)

Wake County Public Library Mr. J. L. Kelley (ASLB) g3092304 830916 050pp400 PDR ADOCK PDR A

411 Fayettevilie Street o P. O. 8ox 1551 o Raleigh, N. C. 27602

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ATTACHMENT I QUESTION: FSAR SECTION 13 ' DIFFERS FROM MANAGEMENT CAPABILITY REPORT.

I RESPONSE: By letter dated August 4, 1983, Carolina Power 6 Light Company submitted a revised Management Capability Report for the Shearon Harris Nuclear Power Plant (SHNPP). A marked-up Final Safety Analysis Report Section 13.2 is attached describing the curient SHNPP training program including that information previously supplied in Section 2.1.3 of the Management Capability Report.

This revised Section 13.2 supersedes Section 2.1.3 of the Management Capability Report and will be included in a future amendment to the SHNPP Final Safety Analysis Report.

S1BlPP F SAR

13. 2 TRAIN iNG*

13. 2. 1 PLANT STAFF TRAINING PROGRAM The ob)ective of the SHNPP training program is to develop and maintain an operating organization capable of and responsible for the safe a.id eff,. <<.

operation and,maintenance of the plant. This training program ia designed to comply with the requirements of Regulatory Guide 1.8, "Personne> S<<lecticn ai~".

Training," with exceptions as stated in Section 1.8. The program is designed to provide training based on individual employee experience and intended position in order to fulfillNRC licensing and personnel qualification requirements for the initial plant staff, replacement personnel, and maintenance and upgrading of plant personnel. Fire brigade training is described in Section 13.2.3. 4// p/m+ Pc-i"~/)el ct~+ ~~<~> <<~~~+~~i f~'8~

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This section describes the formal training program for all initial plant management and supervisory personnel, licensed Senior Reactor Operator (SRO),

and licensed Reactor Operator (RO) candidates, technicians, and general employees. An overview of the program schedule is presented in Figure 13.2.1-1.

13. 2. 1. 1. 1 Plant iManagement and Supervisory Personnel Training The formal training program for the plant management and supervisory personnel provides these personnel with the qualifications necessary to assure thai t.h.

plant will be operated in a safe and efficient manner. As personnel are designated to fill individual positions, their qualifications are reviewed and training 's prescribed such that qualifications required by Section 13.1.3 are met at the time of Operating License issuance or appointment to the position, whichever is later.

Plant supervisory personnel not possessing technical training sufficient for their areas of responsibility will attend specialized training courses as described below. Diesel generator training will be given to operators, operator supervisory personnel, and maintenance supervisors and personne's discussed in Section 8.3.1.1.1.5.

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%training course%aught by(the Westinghouse Nuclear Services Divisionor>

This pr'essurized water reactor (PWR) chemist course provides PWR systems

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training and details of routine chemistry surveillance, and updates and extends knowledge in specific areas of chemistry. Topics covered in the program are listed below:

1) The PWR

2) Mathematics review

3) Reactor chemistry

4) Radiochemistry theory

~ Further information is contained in TMI appendix.

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Radiochemistry - laboratory procedurr.s

6) Operating plant training laboratory procedures b) Instrumentation and Control -, ansg~~~~.

training course~<taught by'he Westinghouse Nuclear V fhr- Services Division This instrumentation and control engineer course provides

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Shift Foremen (SRO Candidates) recourse Senior Control Operators (SRO Candidates)

Control Operators (]RO Candidates)

Each section of the training program and its duration is detai'ed below:

a) Basic Auxiliary Operator Training Program - This consists

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~ning. w structured on-the-go ~Pe gourse is designed to provide

<<I'neo theoretical training in an in-plant~r inforcement of the basic science and technology of power plant operations.

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Examinations are given regularly throughout this phase of training to monitor the trainees'rogress. Each trainee must achieve no less than a~percent QYfg grade in this course prior to entering the next phase of the training program.

ea b) Nuclear Auxiliary Operator Training Program>> This program is designed to provide those persons with little or no nuclea aue

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- " i "arC wigh r-a the necessary theoretical knowledge to ecome The program consists of approximately .

weeks of formal classroom training interspersed with on-the-job, training

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SHNPP PSAR The topics covered are listed below:

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2) Nuclear <<Aeory

3) Keat transfer

4) Radiation protection Instrumentation and control I

(y ) Reactor protection Al+o included I'n th classroom portion of this co se are tvo we s of appli nuclear theory, r iation prote~ion, and rea r operations the North Carolina State iversity PULSTAR reactor, d one week of . troduction o po~er plant ntrol board operation on t .SHNPP simulat lhlsaic."7 Examina ons are giv regularly t ughout this c se to monit the train s'rogress In order to uccessfully co lete this co se a trainee Pa.) mus achieve a nimum course eraga grade o 0 percent in uding mprehensive xaminations.

~ZHNPP gol License iactur -gargas ='his dorsal 15-seek. traini program will be conducted by CP with the assistance of one,or'more nsite personnel fro Vestinghouse Nu ear Services Div'ision. Approximate hal) of each day vil be spent in the lassroom with tQ remaining/half dayjspent/ in the plant i ntifying the eq pment associatediwith the topic covered in/the classroom ssion. The pla systems and procedures to he coverec( are Jlisted below:

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Nuclear stea supply systems and procedure

2) Engineered safety systems and/ procedures~'

Had, 3) Turbine- nerator systems and procedures/

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and procedures and procedures

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8) Emergency procedures I  !

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9) Radiation ppf ection procedur

10) Chemistry/pxbcedures

11) Plan compute

12) chnical specif ications Reviews and examinations wil be given regularly throughout the iprogram to evaluat the effectiveness of this phase of trkininf.

d) Pl nt System On-The-Jab'raining Durin this 9-week portion of the CoPd Lice se Training Program tea students will gain additional knowledge of actual pla t systems configurati n and operation through in-plant hands-on raining. is training,>will be tructured, controlled, and monit red by the plant train g staff through the e of a qualification card syste Knowledge of plant systems will al o be augmented b ,participation n procedures de elopme'nt, system acce tance testing,, d later, in ho functional te ting./ I I

e) Cold Lic nse Simulator Trainin Thi&9~eek portion of the Co1.d License Traini'n Progxam will be subd vided into three)segments. All segments, will be conducte by CP&L personnel at the SHNPP, simul tor. The first segment will consist of a proximately 3 weeks evoted to contro board familia isation and review, analy is and practice in the areas of normal and emergency operations. The s cond segment will~cohsist of approxim ~tely two weeks instruct n in the areaszof inhegrated plant response under no 1 of'lassroom and emergency condi ious with emphasis og control room inqtruments e respond and/the operator's nitoring,,diagnosis,(and control functions. The th hard s ment will consist of approximately foud, weeks of simula ed plant opera ion on a continuing shift rotation schedule. +is segment will provide exper$ nce and further training 1 the areas of total )plant operation nd control un hr normal and emergency c nMtions in a realistic control room pnvironment including shift relief d rotation. The tqaining staff wil( monitor prog ess and performance in this'egment and instruct as required through periodic off-shift critiques./

I f) Pre-License~Review Series and Audit - +is portion of t e Cold Licen e Training Programfwill be onducted by MestingAouse personnel at(the SHNPP s te during the perio'd between he completion of hot functional testing and the administeringzof NRC licen ng examinations. The pre-license review series consists of 'pproximately ~eeks of i.nstructidn including 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />'s per day of classroom rk with the rema nder of the. day be n g used for speci'al 1v instructi n, plant tours, an individual study. The topics covered in this lecture series include: /

1) Reactor .physics an kinetics l I

2) Reactor contxol an protection systems

3) Health physics and plant chemistry 1-6 Amendment No. 2

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SHNPP Co~License Theory Training - Th~is a formal, approxim%5Ly ll"week,,training program~Reviews and examinations will be given regularly to evaluate the effectiveness oE the training. To successfully complete this training requires a minimum average grade of at Least 80 percent. The sub)ect aroas covered by this training are Listed beLow:

l. Math Review 2 ~ Nuclear and'eactor Theory 3~ Heat Transfer, Fluid FLow, and Thermodynamics 4~ Health Physics, Radiation Protection, and Chemistry 5~ Pulstar Reactor Training at N. C. State Cold License Systems Training and Systems On-The-Job-Training-During this 18-week portion of the Cold License Training Program the students will gain knowledge of actual plant systems configuration and operation. This course consists of nine weeks of systems classroom training alternating with nine weeks of systems research and systems tracing (where possible).

Effectiveness oE this training will be monitored through written examinations and systems checkouts. A record" systems checkout s will be kept on a Harris Plant Systems Qualification Card which will be completed over the duration oE the course. To mainta(n standardization, Systems Qualification Guidelines outlining specific knowledge require'd for each system have been provided to all students and training personnel. To successfully complete system training requires a minimum average grade of 80 percent Eor written examinations. All system checkouts must have a grade of "satisfactory." Plant systems to be covered are Listed below:

l. Coolant System 2 ~ Reactor Vessel and Internals 3.

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'eactor Steam Generator Pressurizer

5. Reactor Coolant Pumps

6. Chemical and Volume Control System

7. Safety Injection System

8. Residual Heat Removal System

9. Containment Spray System

10. Containment Coolant System

11. Auxiliary Feedwater System

12. Containment Isolation System

13. Component Cooling System 14 Normal and Emergency Service Water System

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Hydrogen Recombiners 16 Post Accident Hydrogen Purge System

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17. Post A ident Hydrogen tfonitoring Sys

18. Cold Leg Accumulators

19. Control Room Ventilation System

20. Fuel Handling Building Ventilation System

21. Auxiliary Building Ventilation System

22. Boron Thermal Regeneration System

23. Fuel Pool Cooling System

24. Instrument and Service Air Systems

25. Fuel Handling and Storage

26. Demineralized Water System tern

27. Primary ifakeup System 28, Boron Recycle System

29. Fire Protection System

30. Communication System

31. Sampling Sys

32. Trace Heating

33. Main Steam System 34 Auxiliary Steam System

35. Condensate and Feedwater Systems

36. Condensate Polishers and Demin

37. Main Turbine and Generator

38. TW Lube Oil

39. Main Turbine Sealing Steam and Exhaust

40. Generator Gas System

41. Hydrogen Seal Oil System

42. Electro Hydraulic System

43. Turbine Supervisory Control System

44. Main Condenser Evacuation System 45 Steam Dump System

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ffoisture Separator Reheaters and Feedwater lfeaters

47. Cooling Tower 48 Ultimate fleat;Sink

49. Essential Services Chilled Water System

50. Nonessential Services Chilled Water Sys tern

51. Waste Process Building Cooling Water System

52. Circulating 1/ater System

53. Nuclear Ins trumen td t ion System

54. Reactor Protection System

55. Steam Generator Water Level Control System

56. Pressurizer Pressure Control System

57. Pressurizer Level Control System 58 Incore Instruments

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Steam Dump Control System

60. Sequencer 61 Metal Impact tfonitoring System

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Seismic Monitoring System

.63. Rod Control System 64 Offsite Power System

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6.9 Kv Auxiliary System 66 480 Volt Auxiliary System

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208/120 Volt AC System

68. 120 Volt Uninterruptable AC System

69. Standby AC Power Supply (Diesel)

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71. Control Room Area Ventilation tern System

72. Fuel Handling Ventilation Sys

73. Auxiliary and Radwaste Area Ventilation System

74. Turbine Building Area Ventilatioa System

75. Engineered Safety Feature Ventilation System

76. Containment Ventilation System 77 Control Rod Drive Mechanism Ventilation System

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Containment Atmosphere Purge Exhaust System

79. Diesel Generator Fuel Oil System

80. Diesel Generator Cooling Water System 81 Diesel Generator Air Starting System

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~ Diesel Generator Lubrication System

83. Diesel Generator Combustion Air intake and Exhaust

84. Diesel Engine

85. Liquid Waste Systems

86. Solid Waste Systems

87. Waste Gas System

88. Radiation Monitoring System

89. Subcooled Monitoring System'nowledge of plant systems will be augmented by participating in procedures development, system acceptance testing, and hot functional testing.

Cold License Procedure, Theory Review, and Simulator Preparatory Training This approximately five-week course is adminstered prior to going to the simulator. Review and examinations will be conducted regularly to evaluate training effectiveness.

Topics covered in this course include: 1) Procedures; 2) Theory Review; 3) Mitigation of Core Damage; 4) Transient'and Safety Analysis; 5) Safety and Control Systems Review; and 6) Review of 1'ndustry Events. ~) &X~ 4@A~~~

Cold License Simulator Training - The Cold License Simulator Training Program will be"-approximately nine weeks in length (eight weeks minimum) ~ The training will include, but not be limited to: 1) control board familiarization; 2) control functions; 3) procedure usage (including Plant Emergency Procedure implementation); 4) transient and accident analysis; and 5) control manipulations during normal, abnormal, and emergency conditions (including multiple failures) . Emphasis will be placed on integrated system response under normal and emergency conditions icluding control room instrument response, diagnostics, and mitigation of core damage. During the training, shift relief will be included in order to provide experience (n the areas of total plant operation and control under normal and emergency conditions in a realistic control room environment.

The training staff will monitor progress and performance during the training and instruct as required through periodic critiques. Written and operating examinations patterned after HRC licensing examinations will be administered after completion

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of simulator training co certify cold license candidates Reactor Operator and/or Senior Reactor Operator level.

1 Cold License Review Series and Audie - This portion of the Cold at ehe License Training Program wi11 be conducted at the SHNPP sl.te during the period between the completion of hoe Eunceinnal tescing and the administering of NRC licensing examinations. The review series consists of approximately 2 weeks oE instruction including 5 hours per day of classroom work with the remainder of the day being used for special instruction, plant tours, and individual study. The topics covered in this lecture series include:

I. Reactor physics and kinetics

2. Reactor control and procection systems 3~ Health Physics and plant chemistry

4. Technical SpeciEications

5. Transient, instruIIIent Eailure, and accident analysis (PTS)

6. Normal and emergency operating procedures

7. Heat transfer, fluid flow and thermodynamics

8. ~ Nova~ Wk~p,t zgoar .

The audit phase of chis portion of ehe Cold License Training Program will consist of written and oral examinations. The purpose oE this audit will be to identify any areas requiring additional training effort. Individual or group weak areas identified by this audit will be corrected by intensive training efforts for those involved and training program modifications to minimize recurrence in future classes.

Cold License Pre-Licenses Revt,ew " This approximately four-week phase of training is designed to improve ehe weak areas brought out Crom audits and to bring the License Candidaees eo a peak knowledge 1evel for the NRC examinations. Plant procedures and subjects are listed belowI.

l. Procedures 2~ Theory Review 3~ Mitigating core damage

4. Transient and safety analysis 5~ Safeey and control systems review

6. Review of industry events 7 ~ Review of plant and procedure changes since initial training 8 Simulator review Other Cold License Training Required - Cold License Candidates will receive training in the followt.ng areas:

1 ~ Fire Brigade Training Emergency Plan Training 2

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he dit phase of his p+ort on o the Cold Lice e T/aining Pro am will I o si t of written a d or reas examin tions administ red and graded estin house personn . The purpos of this audft quiring addi nal training ffort. Tndivigual or group w k areas will'e dentif ed by this udge will be corr ted y intensive training ef orts for hose in olved a training pragram mo ications to inimize rec r nce in to iden ify any uture cl sse I'

) Management sining for License Supervisors - Personnel recuirtna nfor Reactor Opera or licenses will r eive inst'ruction in the ifo llowing r ervisory skills:

1),Eeade r sh i p Enterpersonnel ommunication

3) Command responsib ities and limi s

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5) Pr blem anad.ysis

6) Deci <<ial analysis

7) Ad inis ation requirement the particular s erv ory ositions.

l()/Pt<< Training on Special Low Power Tescing Each licensed reactor operator (RO) ot senior reactor operator. (SRO) who performs RO or SRO duties shall participate in the initiation, maintenance and recovery from natural circulation. All RO's and SRO's who perform license duties shall be scheduled for. this event. However,, if participation is prevented by unforeseen events, the affected RO or SRO shall par'ticipate in natural circulation on the simulator, complete a walk-thru, and review the test in its entirety with an SRO who participated in the test; these actions shall be completed before licensed duties are assumed.

13. 2. 1.3 Shift Engineer (Shift Technical Advisor) Training Shift Engineers will be provided with training in the following areas, as a minimum:

1) Duties and responsibilities of the Shift Engineer

2) Plant design and layout

3) Accidents analyzed, in this FSAR and their consequences Amendment No. 8 13.2.1-7

SHNPP FSAR 0

4) Thermodynamics and fluid flow

5) Integrated plant response

6) Capabilicies and limicacions of plane instruments and controls Additionally, Shift Engineers will receive a minimum of cwo weeks of training on the SHNPP simulator to include asterisked [*) icems in Section 13 ~ 2. 2. I ~ 2a.

13. 2.1 ~ I e4 Technical Personnel Training Technical personnel who require specfalized training co properly oerform in their areas of responsibility will attend formal training courses in their particular specialities as well as receive on-the-job training ae the plane site prior to start-up. This training is described below:

Radiaeion Control and Tes (RC&T) Technician Training -'C&T 1

a Techni ians not having the qualifi ations shown in Section 13.4 .3.1 will he requi;e to complete the applicable training programs describecl below prior eo appointm nt to their respective posi ions. ~

I) Basic RC&T Course Series -~RC&T Technician III Basic Chemistry 2 weeks Basic Health Physi s 2 weeks Basic Counting Roo - I week Basic Environmental I week f

2) In rmediate RC&T Course Seri s - RC&T Technician II Intermediate Chemistr I week Intermediate Health Ph. sics I week Intermediate Counting R om I week Intermediate Fnvironmen 1 I week These coures are pr sented by CP&L personnel. At and above ehe RC&T Technician I level, pecialized training will provided as necessary ',

by CP&L or by vendors RC&T personnel will als receive on-ebe-job training

~

I y", by participaeing in s stems checkouc and scare-u, preparing ehe laboratories I for service, pareicipa ing in initial radiation rveys, and participating in

the writing, review ana study of radiologica3. and chemical procedure manuals.

e i

" b) Inscrumentation a d Control (I&C) Technicia Training I & C Technicians not having th qualifications shown in ection 13.1.3.l I will be required co compl e the applicable trainin -programs described below prior. to appointment to eheir respective posi'c ons.

I) Basic I&C Course series - I&C Technic"an II i

Basic Elect onic I week Basic Pneumepic Instrumentation 2 ~eeks Basic Electr(ca3. I week 13-2.1-8 emend~mene .Tn.

Sflt<PP 1 SAli 1

Intermed'into >4(; ':o. rs-'erius L&C Technic!. an II intermediate l'ec tl.v<lics Intermudips te pneumat Lcs Inte'rmed.(ati. ELectr Leal i t This series inc4u des approximately 4 instructional weeks.

All 'of these courses ar presented by CY6'L personn 1. At and above the IGC 'Cechnician I level, specialized training will e provided as necessary by 1

(;YhL!or by vendors. Add Iitionally, Instrumentation and Control Te hnicians will receive on-the-job training prior'o start-up by participati in c hecgut and testing of dontroL circuits, annuncia or responses, computer inputs, calibration of controls and instruments, an4 troubleshooti g various equipment problems.

c) lechanic and Electr cian Training t'iechanic and Electricia s not having he qualifications hown in Section 13.1.3.1 will be r e qui.re to complete 4~eek basic and/o 4-week intermediate co rses in their re pective crafts. These courses will be presented by CPRL pe sonnel. A ditiona 11 y, klechm(ic and Electricians 11 receive on-the-job t aining pri r to s tart-up through f miliarization and ~ssociation wi(;h the equ pment on th plan site and throug performing maint nance on equipment and ystems as th y a e released t operations. >lech nics and Electricians m y receive ad n ed or spec ial.ize training for theiq individual functions a necessary thr h attendance t CYhL or vendor c'nurses.

d) Radwaste Operator Training - kadwaste Operations personnel not having the qualifications shown in Section 13.1.3.1 will be required to complete a training program in radwaste operations. This program will be conducted by CY6L personnel with assistance from vendors as necessary. The program will consist of the Basic A portions of the Basic

j. ary Operator Training Program and applicable

'raining Program described above, augmented by classroom and structured on-the-job training in the areas of radwaste systems and procedures and related technical specifications. Additionally, radwaste operations personnel will receive on-the-job training in their area of responsibility through participating in system checkout and start-up. A ~hkcrellnpu Cco cf ~&~ cuLl be, u.filgzcd. Q uLL Radcua~ Cpera&rs.

13.'L. l. l. 5 Auxiliary (Non-Licensed) Operator Training Auxiliary Operators will partici.pate in the Basic Auxiliary Operator Training Program and the Nuclear Auxiliary Operator Training Program as described in Section 13.Z.1.1.Z. This training, along with a qualification card system, will provide sufficient training and evaluation for these individuals to become qualified Auxiliary Operators.

13.2. 1-9

Radiation rmncroi and Test (RC) and Environmental & chemistry (E&c) Technician

~Trainkn RC and E&C Technicians will be equired to complete the applic hie training programs described belou. (~ (3.1 9. l lP. Basic G>ursa Series - RC and E&C Technician III Basic Chemistry 2 weeks Basic Health Physics 2 weeks Basic Counting Room - 1 week Basic Environmental 1 week Intermediate Course Series - RC and E&C Technician II Intermediate Chemistry 1 week Intermediate: Health Physics 1 week Intermediate Counting Room 1 week Intermediate Environmental - 1 week At and above. the RC and E&C Technician I leve1; specialized training will be provided as necessary by the Company or by vendors. Radiation Conerol and Environmental & Chemistry personnel will also receive on-the-job training by participating in systems checkout and start-up, preparing the laboratories for service, participating in initial radiation surveys, and participating in the writing, reviev, and study of radiological and chemical procedure manuals ~

Instrumentation and Control (T&C) Technician TrafninP. - I&C Technicians not havt.ng the appropriate qualifications 11 be required to complete the applicable training programs described below prior to appointmene to their respective positions. -a pl i) g'. Basic I&C Course Series - I&C Technician III Basic El ec tronic Ins trumen t a t ion - 1 week Basic Pneumatic Instrumentation - 2 weeks Basic Eleceromechani.cal Devices - 1 week l

z) P. Intermediate I&C Course Series ' I&C Technician II Intermedi.ate Electronic Instrumentation

• Intermediate Pneumatic Instrumentat inn -

• Intermediate Eleceronmechanical Devices - *

~This series includes approximately four instruceional weeks.

At and above the I&C Technician I level, specialized training will be providerl as necessary by Carolina Power & Light Company or by vendors. Additionally, Instrumentation and Conerol Technicians will receive on-the-job training prior to startup by participating in checkout and testing of control circuits, annunciator responses, computer inpues, calibration of controls anrl instruments, and troubleshooting various equipmeae problems.

Electrician Traininr. Mechanics and Electricianspwill be ~++~~irs.r 3 g) Mechanic and ~

required to complete 4~eek basic and/or 4~eek inte'rmediate courses in their respective crafts. Additionally; lfechanics and,Electricians vill receive on-the-job training vi h the equipment on the lant site.- Me ha ic c,'M~ and ~C'~s

~

SNNPP FSAR

13. 2. 1. 1. 6 General Employee Trainin dc,ice

~ A11 lant personn (those assigned the plant on a day-to-fry W part ipate in the eneral Employee Tr ning Program. This prog m consists basis) w111 5 of, but is not limit to, a Radiological ealth arid Safety program hat hns been deve oped under t guidance of Regula y Guides 8.13, 8.27, an 8.29, as well as dustrial Sa y, ?lant Security, rgency Preparedness, and other plant b ~

1,3. 2. 1. l. 7 Previous Nuclear Training Plant operating and supervisory personnel who must qualify for license examinations are categorized by experience into the following groups.

n) Individuals with no previous nuclear experience b) Individuals with nuclear experie<<ce at facilities not subject to licensing.

c) "

Individuals holding or who have held licenses for comparable facilities.

Persons in category A) above will participate in all portions of the Licensed Operator Training Program described in Section 13.2. 1. 1. 2.

Persons in category B) above will .receive training as required based upon their experience on a case-by-case basis.

Persons in the third category will receive on-site training to prepare them for the NRC license examination.

13.2.1.2 Coordination with Prep erational Tests and Fuel Loadin ~

Figure 13.2.1-1 presents the various training programs in relation to preoperational testing and fuel loading. In the event that fuel loading is delayed after the completion of the formal training program, a continuing review and update program, similar to the requalification program described in Section 13.2.2.1, will be conducted for, as a minimum, those individuals scheduled for cold license examinations.

13. 2. 1-10 Amendment,No. 5..

I I"cui~inqr All permanently employedd lant p an ersonnel {those assigneil on a da y -to-day per basis) wi11 part icipatee in a General Employee T ra L n Lng n Proi ram consisting of, but not limited to, Radi olo g ical f t Health an d S a e y, Ouality Assurance, industrial Safety, Plant Secur

<<ppropriate plant plans ns curit y, and p rocedures.

1, Emergency Plan, Five General1 empem lo re Prc tee t Lon, anil other r

ee traLning oyee will be provided to Company p ersonnel at the time o f emp loyment oym at the plant or as i in is designed to qualify p ntry into various parts of the operating plant and to be able to function sa fe ly an d 1 bl h need to be reported within these areas. There w training and testing to ensure that all plant personne ill bee annual requaLLficatinn ersonnel remain current Ln the areas nf plant plans and procedures.

The Nuclear Operationsn De paartment has an orientation p ro g ram for all new empLoyees that is desi es g ned to acquaint. the h new emp loyee oye with the policies, procedures, practicess of the Company andd the h De artment.

Departmen included in this ew li of the "Corporate Oua ty Assurance s Program PolLcy Statement," I

~

Corporate Nuclear lear Safety S li l

y Policy, Policy. Th ese po licy statements are contained Lnn an or

" an

" o orientation lh en a program manual that is provided to each new employee.

13.2.2 REPLACEHENT AND RETRAINZNV A training program will be utilized to maintain the proficiency of the plant operating organization after the initial plant start-up. This training program will include, as described below, requalification training for licensed personnel, and replacement training for replacement personnel.

13.2.2.1 Licensed 0 erator Re ualification Trainin Following the initial licensing of cold license candidates, a requalification training program will be initiated to maintain and demonstrate the continued competence of all licensed personnel. This requalification training program will be conducted on an annual basis and will include pre-planned lectures, on-the-job training, and regular and continuing operator evaluation. The SHNPP simulator will be used to fulfillappropriate portions of this retraining program.

13. 2. 2. 1. 1 Lec tures A minimum of six pre-planned lectures will be presented during each requalification cycle. These lectures will be scheduled throughout the year taking, into account heavy vacation periods and infrequent operations such as refueling periods and forced outages. Lectures may be deferred due to unanticipated shutdowns. However, these lectures shall be conducted as soon as practicable thereafter. Content of the lectures shall take into consideration the categories as listed in 10CFR Part 55, Appendix A, heat transfer, fluid flow, thermodynamics, mitigation of accidents involving a degraded core, operating experiences from similar plants and the results of the annual examination. Training aids such as films, video tapes, and slides may be used and some self-study may be required in conjunction with the lectures. An instructor will present or attend as an auditor at least 50 percent of the lecture series.

All licensed individuals will be required to attend every pre-planned lecture except those specifically exempted. Exemptions will be allowed only for individuals scoring greater than 80 percent in the corresponding area on the previous examination.

13.?. 2. 1. 2 On-the-job Training The on-the-job training portion of the requalification program will consist of the following:

a) Control >1anipulation -Licensed reactor operators shall manipulate and senior reactor operators shall manipulate or direct or evaluate the activities of those manipulating the station controls through a minimum of ten reactivity changes during each annual cycle. These manipulations may consist of any of the following, providing that asterisked items are performed annually and all other items are performed on a tm year cycle:

• 1) Start~p to the point of adding heat

2) Orderly shutdown 13.2.2-1

SHNPP FSAR

• 3) ilanual steam generator control during start-up and shutdown

4) Boration and/or dilution during power operation

~5) Any, significant ()l.O percent) power changes in manual rod control

6) Turbine start-up.and shutdown

+7) Loss of coolant (a) including significant steam generator leaks (b) Large and small including leak rate determination (c) Resulting in saturated RCS

8) Loss of ins trumen t air

')

Loss of electrical power and/or degraded power sources

• 10) Loss of forced coolant flow/natural circulation ll) Loss of circulating water/condenser vacuum

12) Loss of service water

13) Loss of shutdown cooling l,4) Loss of component cooling system or CCM to an individual component

15) Loss of normal feedwater or normal feedwater system failure

• 1b) Loss of all feedwater (normal and emergency)

17) Loss of protective system channel

18) Control rod misalignment or drop

19) ZhabQ.ity to drive control rods

?U) Conditions requiring emergency boration

21) High activity in reactor coolant

22) Turbine or generator trip

23) ifalfunction of automatic control system(s) which affect reac tivity

24) i'1alfunction of CVCS system

25) Reac tor trip

13. 2. 2-2

SHNPP FSAR

26) Hain steam line break (inside or outside containment)

27) Nuclear instrumention failure(s)

These control manipulations may be performed on the SHNPP simulator.

8gsrE&s b) Knowledge of Plant ~~Wees lndividuaxs licensed as reactor operators and senior reactor operators shall demonstrate an understanding of the operation of controls and equipment and shall be familiar with the operating procedures in each area for which they are licensed.

Demonstration methods may include any of the following:

1) i@nipulation of the systems and their associated equipment.

2) A walk-through of the procedural steps required to start, stop or change conditions of the system.

3) Vse of the SHNPP simulator c) Knowledge of Facility Design, Procedure, and Facility License

(;hanges: Licensed reactor operators and senior reactor operators shall be made aware of safety-related facility design changes that affect station operation, operating'rocedure changes and facility license changes.

Demonstration methods include any of the following:

1) Brief lectures conducted by the Operating Supervisor or other appropriate personnel.

2) Staff meetings

3) Written communications to each licensed individual from facility management

4) Explanation of major changes as part of the pre-planned lecture series d) Knowledge of Emergency Operating Procedures: Licensed reactor operators and senior reactor operators shall review the contents of emergency operating procedures periodically such that knowledge of these procedures is maintained.

Uemonstration methods may include any of the following:

1) Actual performance under emergency conditions

2) Drills using the SHNPP simulator

3) A walk-through of the procedural steps necessary to cope with the situation 13 ~ 2. 2-3

0 S11NP P F SAR

4) Brief lectures conducted by the Operating Supervisor or other appropriate personnel S) Self-study combined with items 1) through 4) above.

13.2. 2. 1. 3 Evalua tion The evaluation program for licensed personnel will include the following:

a) Annual Mritten Examination: Annual examinations comparable in scope and degree of difficulty to an NRC examination shall be given to each licensed reactor operator and senior reactor operator. The examination will contain categories of examination questions as follows:

1) Theory and principLes of operation

2) Heat transfer, fluid flow and thermodynamics

3) General and specific operating characteristics

4) Plant instrumentation and control systems S) Plant protection systems

6) Engineered safety systems

7) Normal and emergency operating procedures

8) Radiation control and safety

9) Technical specifications

10) Applicable portions of Title 10, Chapter 1, Code of Federal Regula tions

11) Operating experience from similar plants A grade of less than 70 percent in any category shall require accelerated requalification in that category. A grade of less than 80 percent overall requires accelerated requalification in all categories graded less than 80 percent.

b) Annual Observation and Written Evaluation: Observation and evaluation of the performance of 1icensed reactor operators and senior reactor operators by supervisors or training staff members will include evaluation of performance during actual or simuLated emergency conditions. Observation and evaluation of the performance of Licensed personnel during simulated emergency conditions may be conducted by simulator training staff personnel ~

Discussions of actions taken or to be taken during emergency situations may be used as evaluation tools in Lieu of or in addition to the above methods. Any licensed reactor operator or senior reactor operator given an unsatisfactory overall evaluation shall require acceLerated requalification.

L3. 2. 2-4

SHNPP FSAR 13.Z.Z. L.4 Accelerated Requalification Persons requiring accelerated requalification as a result of annual evaluation shall not perform Licensed duties until sucessfully completing the program.

Accelerated requalification shall be given in the categories required or areas identified fn the annual observation and written evaluation. The Training Supervisor will tailor the scope and duration of the accelerated program to che individuals'emonstrated deficiencies. Successful completion of the program shall be measured by a reexamination of individual categories, repeating an entire written annual examination or reevaluation by observation or oral examirracion. Successful completion of an accelerated requalification program shall be by the grade criteria in Section 13.2.2.1.3.

L3.Z.Z.L.S Training Personnel Training personnel who are licensed are exempt from the provisions of Section 13.2.2-1, for which they have primary responsibility for administering. For example, individuals responsible for preparing, administering, and grading the annual wricten examination will be credited with successfully completing the examination.

13.2.2.2 Nonlicensed Personnel Retraining Nonlicensed personnel shall receive retraining on the topics listed in Section L3.2.1.1.4 on a regularly scheduled basis. Ln addition, retraining shalL include fame.iarization with plant operating experience, modifications and design changes, revision to procedures and indoctrination in new procedures applicable to the personnel involved.

13.2.2.3 Re lacement Trainin Replacement training is conducted to fill vacancies and prepare individuals for increased responsibility in the supervisory, technicaL, operating, and maintenance staffs. Replacement personnel will receive training in areas in which they are noc already qualified by reason of experience, technical training, and/or on-the-job training.

Radiological Control and Test Technicians, Instrumentation and Control Technicians, Electricians, Mechanics, and Radwaste Operators will receive general training in their job areas as pare of the Company craft development program. This program provides sufficient training, as described in Section 13.2.1.1.3 to enabLe newly hired personnel to advance to become competent and proficient craftsmen-Auxiliary operators may eventually qualify to enter a "hot" license training program designed to prepare them to become licensed Control Operators.

Kn the overall program, replacement personnel will receive training comparable to that received by the initial staff. This will ensure that the required level of proficiency is maintained in all positions.

13. 2. 2-5

SHNPP FSAR 13.2.3 FIRE BRIGADE TRAINING 13.2.3.1 Fire Brigade Hembers 13.2.3.F 1 Instruction Instructions in the topics listed below will be administered to each individual prior to assignment as a fire brigade member. The instructions will include:

a) Identification of the location and types of fire hazards that could produce fires within the plant, including identification of the areas where breathing air will be required.

b) Identification of the location of installed and portable Eire fighting equipment in each area, and familiarization with the layout of the plant, including access and regress routes to each area.

c) Proper use of available equipment, and the correct methods of fighting the following types of fire: electrical, cable and cable trays, hydrogen, flammable liquids, waste/debris, and record file.

d) Indoctrination to the plant fire fighting plan, with coverage of each individual's responsibilities and their changes.

e) 'roper use of breathing, communication, lighting, and portable ventilation equipment.

f) A detailed review of procedures, with particular emphasis on what equipment must be used in particular areas.

g) A review of the latest modifications to the facility, procedures, fire fighting equipment, and Eire fighting plan.

h) The proper method of fighting fires inside buildings and tunnels.

Refresher instructions will be provided to all fire brigade members on a regularly scheduled basis of not less than four sessions a year with sessions to be repeated at a frequency of not more than 2 years. Instructions will be provided by qualified individuals knowledgeable and experienced in fighting the fires that could occur in the plant with the equipment available at the plant. Special instructions will be provided for fire brigade leaders in directing and coordinating fire fighting activities.

13 ' F 1.2 Practice Sessions Practice sessions will be held for fire brigade members to teach them the proper method of fighting various types of fires and to provide them with practice in extinguishing actual fires. These sessions will be conducted at facilities sufficiently remote from the nuclear plant so as not to endanger safety-related equipment, with the sessions provided at regular intervals not exceeding 1 year. These practice sessions will be conducted requiring Eire 2 13.2.3-1 Amendment No. 2

C SHNPP FSAR brigade members to don protective quipment, including emergency breathing apparatus.

13 2.3 ' ~ 3 Drills Drills will be performed in the plant so that the fire brigade will remain proficient in fire fighting techniques. These drills will include:

a) The simulated use of equipment for the various situations and types of fires which could reasonably occur in each safety-related area.

b) Conformance, where possible, to the established plant Eire fighting plans.

c) Operation of fire fighting equipment, where practical, including self-contained breathing apparatus, communication equipment, and portable and installed ventilation equipment, Drills will be performed at regular intervals, not to exceed three months, for each fire brigade to allow members of the brigade to tra'n as a team. At least one drill per year for each fire brigade will be unannounced to determine the fire readiness of the plan't fire brigade and plant fire protection systems and equipment. Drills will be planned to establish training obgectives and will be critiqued to determine how well the training objectives were met. This critique will, as a minimum, assess: fire alarm effectiveness; response time; selection, placement and use of equipment; the fire brigade chief's direction of the fire fighting effort; and each fire brigade member's response to the emergency.

A drill will be held annually at which offsite Eire department participation will be requested.

13 2.3 2 Other Station Employees 13.2.3.2.1 instruction for All Non-Fire Brigade Members Once a year all employees will be instructed on the fire protection plan, evacuation routes, and procedures for reporting a Eire. Security personnel will be instructed in entry procedures for offsite Eire departments, crowd control for people exiting the stations, and procedures for reporting potential fire hazards observed when touring the facility. Instruction will also be given to all shift personnel who will assist the fire brigade in the event of a fire. Temporary employees will be given instructions to familiarize them with the plant's evacuation signals, evacuation routes, and procedures for reporting fires.

13.2.3.2 ' Drills A plant evacuation drill will be performed annually.

l3. 2. 3-2 Amendment No. 2

SHNPP FSAR 13.2.3.3 Fire Protection Staff Fire prote'ction staff members will be introduced to a program of specialized training. Instructions for the staff will include:

a) . Analysis of building layout and system design with respect to fire protection requirements, including consideration of potential hazards associated with postulated design basis fires..

b) Design and maintenance of fire detection suppression and extinguishing systems.

c) Fire protection techniques and procedures.

d) Training in manual firefighting techniques and procedures for plant personnel and the fire brigade.

13.2.3.4 Offsite Fire Departments In accordance with commitments for the use of offsite fire departments, the training offered these offsite fire fighting personnel w1.11 include courses in basic radiation principles and practices'. Additional training will be offered to familiarize them with typical radiation hazards that may be encountered vhen fighting fires at a nuclear power plant.

13.2.3.5 Construction Personnel Training for construction personnel will include instructions in reporting fires, responding to alarms, and locating evacuation routes.

13.2.3.6 Initial Training The initial fire protection training program vill be completed prior to receipt of fuel at the site. The Emergency Plan implementing procedures for fire protection will be completed at least three months prior to receipt of fuel. Sufficient fire protection drills will be performed immediately prior to fuel receipt to provide assurance that the plant staff is adequately trained to cope vith fire-related emergencies.

13.2.3-3 Amendment No. 2

SHNPP FSAR 13.2.4 APPf ICABLE NRC DOCUMENTS The applicable portions of the NRC regulations, RG's, and reports listed below vill be used in providing guidance in the training of plant pe rsonne1.

a) 10CFR50, "Licensing of Production and Utilization Facilities" b) 10CFR55, "Operators'icenses" c) 10CFR19, "Notices, Instructions, and Reports to Workers; Inspections" d) RG 1.8, "Personnel Selection and Training" e) RG 1.101, "Emergency Planning for Nuclear Power Plants" f) RG 1.120, "Fire Protection Guidelines for Nuclear Power Plants" g) RG 8.2, "Guide for Administrative Practices in Radiation Moni to r ing" h) RG 8.8, "Information Relevant to Maintaining Occupational Radiation Exposure As Low As Is Reasonably Achievable (Nuclear Power Reactors)"

i) RG 8.10, "Operating Philosophy for ifaintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable" j) RG 8.13, "Instruction Concerning Prenatal Radiation Exposure" k) Utility Staffing and Training for Nuclear Power, "WASH-1130",

revised June 1973.

1) NRC Operator Licensing Guide, NUREG-0094, July 1976.

H. R. Denton's NRC Letter of March 28, 1980, Subject alifications of Reactor Operators n) NUREG 0737 "Clarification of 'Pill Action Plan Requirements."

o) NVREG 0694 "TMI Related Requirements for New Operating Licenses."

p) NRC Generic Letter 81-04 "Emergency Procedures and Training for Station Blackout Events."

q) RG 8.27, Radiation Protection Training for Personnel at LightWater-Cooled Nuclear Power Plants."

RG 8.29, "Instruction Concerning Risks from Occupational Radiation Exposure" 13.2.4-1 Amendment Nn.. 5

I APFFIOX TITLE OR tJIC NO K 1979 tg80 198 I l982 COLD ORGAtazATIOHAL FUNCTION UCENSE LSXttgE JFMA CAI8tlOATES J JASONO JFMAM J JASO D JFM M J JA SOHO JF MA M J JASOND JFMAM J JASONQ GENERAL MANAGER E D MANAGER-POWER f%miCTION SRO I E 0 PLANT MANAGER SROI E D SUPERNTEtlXHT OPERATIONS SRO E 0 OPERATING SUPERVtsOR SRO E D SHIFT FOREMAN SRO E D SENIOR CONTROL OPERATORS SRO E D CONTROL OPERATORS 12 E D AUXILIARY OPERATORS PERF & TEST SUPERVISOR E D SEtSCR EIIGIHEER REACTOR SROI E D SENCR ENGltKER PERF. SROI E D ENGINEERING SUPERVISOR E D SUPERINTEtlDENT MAINT. E D CFKLL & ENVIROH. SUPERVIOR ELEC. MANT. SUPERVISOR MECH. LIANT SUPERVISOR RC & T TECHNICIANS I & C TECHHICIAtts MECHANICS RADansTE OPERATORS L II TRAINItlG PROGRAM DESIGNATORS GENERAL NOTES:

A. BASC AUXILIARY OPERATOR TRAINING 0 BASIC MECHANIC COURSE SERIES l SELECTED STAFF PERSOtlNEL WILL f4RTICIPATE IN

& NUCLEAR AUXILIARY OPERATOR TRAltllNG P. INTERMEDIATE MECHANIC COURSE SERIES SPECIALIZED VENDOR AIID/GR CP&L TRAlt&tlG.

C COLD UCENSE LECTURE SERIES SYSTEM ON-THE-JOB TRAINING

2. OPERATIONS TRAINING SCHEDULES ARE TYPICAL.

0 PLANT COURSE PARTIClf%TION WILL BE ROTATED To REDUCE CLASS E. COLO LICENSE SIMULATOR TRAINING SI2E AHD MAIHTAIH CONTIIASTY OF OPERATIONS PERSONHE F. PRE- LICENSE REVIEW SERIES & AUDIT AT PLANT SITE.

G. PWR CHEMIST COURSE LICENSE NOTES: 3. INDICATED TRAINING FOR TECHNICIANS MECHANICS AM) tf. I & C ENGINEERS COURSE RADWASTE OPERATORS IS TYPICAL. AESE COUR WILL-I. tlXLEAR ENGINEERS CCaIRSE I. BACKGROUND FOR LICENSE, DESIRABLE. BE OFFERED SEVERAL TIMES AtJIUALLY BEGINNIN I980.

J. MAitfTENAtlCE MAHAGEMENT PROGRAM rL OPERATIONS PERSONNEL WILL l%RTICIPATE IN PROCEDURE ";

K, BASIC RC & T COURSE SERIES PREPARATION AtlD STARTUP ACTIVITIES.

I IHTERMEDIATE RC&T COURSE SERES M. BASIC I &C COURSE SERIES N. IIFFERMEDIATE I &C COURSE SERIES SHEARON HAIIRIS taUCLEAII POWER PLAN Carolina Power 5 Light Company FINAI. SAFETY ANALYSIS IISPOIIT TRAltllNGSCHEDULE FIGURE 13.2.1 1

ATTACHMENT II OPEN ITEM 322 QUESTION: REVIEWER REOUESTED ADDITIONAL INFORMATION CONCERNING TRAINING/RETRAINING OF SHNPP SHIFT TECHNICAL ADVISORS (STAs)

RESPONSE: The Shearon Harris Shift Technical Advisors (STAs) are an integral part of the Operations organization of the plant. They report to the Principal Engineer-Operations, who in turn reports to the Manager-Operations along with the Operations Supervisor and the Radwaste Supervisor. During plant operations, the STAs routinely serve on a rotating shift for several weeks. This is followed by a period of day shift .work only for training or review activities before the STAs return to rotating shift work. While the STAs are on shift, they typically review control room activities, conduct plant tours to assess equipment status, and work on operationally related projects such as procedure changes or reviews of plant events. Periodically, they work in a non-rotating shift capacity in the Operations office, which involves working on projects such as development of input to responses on licensing concerns of an operational nature, reviews of new procedures, procedure changes and plant modifications for operational impact and review of plant operating data to ensure plant safety is being maintained. In addition, retraining will be conducted for one week every six weeks for the STAs in a shift rotation and for those in the off-shift capacity. Depending on the number of individuals in the organization, an individual STA could be in a non-rotating shift capacity for a few weeks. However, CP&L would not consider this individual as being unqualified at the end of this period due to the nature of his activities, which are intimately related to the safety of plant operations.

When the unit is in a cold shutdown condition (assuming single unit operation), the STAs are not required to be on shift. During these periods, they would typically work on outage-related projects in the Operations Unit or in other plant units. Since outages such as refueling outages can extend well beyond a one-month time period, and perhaps beyond a four-month time period, CPSL believes that the work that an STA would be assigned would be of such a nature as to keep the individual informed of plant conditions to a degree where requalification is unnecessary and unduly restrictive.

While it is possible that individuals qualified as STAs may be involved in special assignments that remove them from a position described above for a period of time, we do not believe that a requirement for requalification after one month of not performing the STA function or related work is necessary. The SHNPP retraining program for operators and STAs will still require these individuals to receive the necessary training to remain qualified. The training for STAs meets and in many cases exceeds

the education and training recommendations of the INPO guidelines (Rev. 1). For example, it is the goal of SHNPP that every qualified STA also obtain and hold a current SRO license on the SHNPP plant.

Carolina Power 6 Light Company believes that the STA organization, their work activitie's and the training they receive make them highly qualified individuals to perform the functions required of them, and thus they would not require requalification training until they were away from their area of responsibility for longer than four months, consistent with the position of'Revision 1 to the INPO guidelines.

I l