ML20009F853

Motion for ASLB to Take Official Notice of NRC 810601 Ltr to All B&W Licensees & 810401 Ltr to All Licensees Re Training Programs of Licensed Operators.Related Correspondence

ML20009F853
Person / Time
Site:	Three Mile Island
Issue date:	07/20/1981
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20009F855	List: ML20009F853
References
NUDOCS 8108030104
Download: ML20009F853 (1)

Text

' fyLiTED .C.ORRESPONDENCF AAM - /20/81 gne n u

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• e LU g Nuclear Regulatory Commission (( JUL 3 J}ggy ,,

Before the Atomic Safety and Licensing B @y du,3, m acemog &

In the Matter of Metropolitan Edison Company, Three e Island Nuclear Generating Station, Unit No. 1, Docket 50- /

To Administrative Judges Ivan W. Smith, Linda W. Little, Walter H. Jordan 1981, Motion to the Board to Take Official Notice of NRC Letter, June 1, to all B&W Licensees and NRC Letter, July 1, 1981, to all Licensees Regarding Deficiencies in the Training Programs of Licensed Operators

Dear Chairman Smith,

and Drs. Little and Jordan:

This is motion to the Board to take of ficial notice of two recent docunents of the NRC regarding deficiencies in the training programs of licensed operators.

The first document to be noticed is a letter of the NRC, dated June 1, 1981, to all B&W Licensees, in which 8 deficiencies in the design of the ATOG program and its procedures are listed. Since the ATOG program was to have been ready for use with the training department at TMI this month, and since commitments of the Licensee in Exhibit 56 were made,specifically on the time for completion of the ATOG training, this moti'on is timely and appropriate.

The second document to be noticed is a letter of the NRC, dated July 1, 1982, to all Licensees. The deficiencies'in overall training per the March 28, 1980 letter of H. Denton have been detected Since the by the TMI Licensing Branch in administering NRC examinations.

operators were admin ~1stered licensing examinations in April, these e observations may very well apply to the operators at TMI.

The Board is also requested to consider the testimony of Mr. Kelly which was stated with certainty and not challenged in the hearing.

Mr. Kelly was asked, "Do we know all the things that we need to know to. operate a nuclear _ power plant?"

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Mr. Kelly, Licensee's expert w i t n'e s s , president of PQS auditors of nuclear training programs, answered, "No is the answer I really want -

, to give." Tr. 12624 - 5.

, Ry pectfully submitted, y *> / _ q e p jf4Aq W #% a h%<

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k C3.a d.3 smetan E d d es & SCTYiC#9 TO ALL B&W LICENSEES (Except Arkansas Nuclear One, Unit One) 9 Eitd

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SUBJECT:

NUREG-0737, ITEM I.C.1, ABNORMAL TRANSIENT OPERATOR GUIDELINES

. (AT0G) (Generic Letter No. 81-16 )

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The . staff ha's completed a preliniinary review of the ATOG prepared for  ?- ~

I Arkansas Nuclear One Unit One and submitted as generic guidelines in

• l response to NUREG-0737, Clarification of TMI Action Plan Requirements, i Item I.C.l. We have identified the followino deficiencies in areas j that were identified in NUREG-0737. but are nu. addressed by the ATOG s ubmittal: .

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h. The bases for the consideration of multipl.e and consequential ..g t,i failures is not provided. The sequence-of-event diagrams are not

, j complete 'i.e., ATWS following an initiating event).

2. Supporting analyses for multiple fa'ilures are not presented for a l

all cases. The description of the computer programs used to

., analyze the events is not provided.-

3. Operat'or errors of omission or commission are not addressed. ,

i 4. The following multiple failure events are not addressed: ,

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. (a) SG tube rupture in more than)one steam generator; (b) Failure of thd high-pressure 'reactoi coolant makeup system; (c) ATHS following an initiating event (with or without a turbine trip); and . c-(d) Failure of main and auxiliary.feddwater with partial or l

, complete loss of HPI.

5. The transition from emergency procedures into an adequate core cooling '

(ICC) procedure is not developed or included. (We ' understand that l B&W is incorporating ICC into the AT0G program for some future sub-mittal.)

Since you have referenced this report as applicable to your facility, please advise us within 30 days of your receint nf thic 1ptfor nf unter s[dhedule for response to these items and the imnart thic will hau/ nn j

your schedule for implementing a proqram of emeroency caeratino orocedures that comply with the requirements of NURFG-0737, Item I.C.l.

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All B&W Licensees Except -

ANO-1 Since the responses required by this letter affect fewer than 10 licensees and are required to obtain a benefit, they are not subject to Office of Management and Budget clearance as required by P.L.96-511.

Sincerely, ,

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Thomas M. Novak, Assistant Dire tor

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