ML20027A906

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Improvements in Training & Requalification Programs as Required by TMI Action Items I.A.2.1 & II.B.4 for Oyster Creek Nuclear Generating Station, Technical Evaluation Rept
ML20027A906
Person / Time
Site: Oyster Creek
Issue date: 08/31/1982
From:
SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:
NRC
Shared Package
ML20027A907 List:
References
CON-NRC-03-82-096, RTR-NUREG-0737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM SAI-186-029-46, NUDOCS 8209030344
Download: ML20027A906 (15)


Text

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l SAI-186-029-46 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 Oyster Creek Nuclear Generating Station (Docket 50-219) l August 31, 1982 Prepared By:

Sci.ence Applications, Inc.

1710 Goodridge Drive McLean, Virginia 22102 Prepared for:

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

(

Contract NRC-03-82-096

%QPc369 g

Science Applications,inc.

TABLE OF CONTENTS Section M

I.

INTRODUCTION.....................

1 II.

SCOPE AND CONTENT OF THE EVALUATION.'........

1 A.

I.A.2.1:

Immediate Upgrading of R0 and SRO Training and Qualifications 1

B.

II.B.4:

Training for Mitigating Core Damage..

6 III.

LICENSEE SUBMITTALS.................

7 IV.

EVALUATION......................

8 A.

I.A.2.1:

Immediate Upgrading of R0 and SR0 Training and Qualifications

.8 B.

II.B.4:

Training for Mitigating Core Damage..

11 V.

CONCLUSIONS.....................

11 VI.

REFERENCES......................

12 l

'e w

v

I.

INTRODUCTION Science Applications, Inc. (SAI), as technical assistance contrac-tor to the U.S. Nuclear Regulatory Commissien, has evaluated the response by Jersey Central Power and Light Company for the Oyster Creek Nuclear Genera-ting Station (Docket 50-219) to certain requirements contained in post-TMI Action Items I.A.2.1, Immediate Upgrading of Reactor Oparator 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 (TAC) the requirements.

The evaluation pertains to Technical Assignment Control System numbers 44183 (NUREG-0737, I.A.2.1.4) and 44533 (NUREG-0737, I I.B.4.1).

As delineateo 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 R0 and SR0 Training and Qualifications l

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 t

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 l

relates to operator training requirements; item A.2.e, which concerns l

instructor requalification; and Section C, which addresses operator requali-l 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) th.at 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 I I.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.

1

Figure 1.

Training Requirements from TMI Action Item I.A.2.1*

Program Clement NRC Requirements **. Item A.2.c(1)

Training programs shall be sodified as necessary. to provide training in heat transfer. fluid flow and themodynamics. (Enclosure 2 provides guidelines for the minimum content of such training.)

OPERATIONS. Item A.2.c(2)

PER50uEL Training programs shall be modified, as necessary to provide training in the Wse of installed plant systems to control or mitigate an accident in which tht TUIN!%

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 recualification programs to assure they are cognizant of current operating history, problems, and changes to pro-REQuALIFICATION cedures and administrative limitations.. Item C.1 Content of the Itcensed operator recualification programs shall be modified to ificlude 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.). Item C.2 PER50mEL The criteria for requiring a licensed individual to participate in accelerated REQUALIFICATION recualification 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.

Nomal Control manipulations, such as plant or reactor startups, must be performed. Control manipulations during abnormal or emergency opera-tions must be walked througn 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.

  • ine reautrements shown are a subset of those contained in Item I.A.2.1.
    • References to Enclosures are to Denton's letter of March 23, 1980, which is contained in the clarifi-cation of Item I.A.2.1 in NUREG-0737.

2

Figure 2. from Denton's Letter L

TRAIN!nG la MEAT TRANSFER. FLUID FLOW AND THERM 00VMAMICS 1.

Beste properties of Fluids and Matter.

This section should cover a basic introduction to metter and its properties. This section should include such concents as temperature measurements and effects, density and its effects, specific wetent, buoyancy, viscosity and other properties of fluids. A working knowledge of steen tables should also be included. Energy movement should be discussed including such fundamentals as heat enchange, specific heat latent heat of vaporitetton and sensible heat.

2.

Fluid Staties.

This section should cover the pressure, temperature and volume eff ects on fluids. Esemple 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 Changen in the various Components and systems should be discussed as applicable to the f acility with particular emphasis on saf ety 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 Bernoullt'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 NP5M. carry over, carry under, kinette 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.

Meat 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 flun and atomic action. Meat transfer characteristics of fuel rods and heat enchangers should be included in this section.

This section should cover the fundamentals of heat transf er by convection. Natural and forced circula-tion should be discussed as applicable to the various systems at the f acility. 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 noncondensinle gas formation during normal and accident conditions.

This section should cover the fundamentals of heat transfee by thermal radiarion in the form of radiant i

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 saae of a black body absorber and a white body emitter.

5.

Chance of phase. Boiline.

This section should include descriptions of the state of matter. their inherent characteristics and trermodynamic 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 flun, critical power. DNB ratio and hot channel f actors. This section should also include instructions for preventing and monitoring for clad or fuel damage and flow instabilities. Sample calculations should be tilustrated by the instructor and calculations should be performed by the students and discussed in Methods and procedures for using the plant computer to determine cuantitative the training sessions.

values of various f actors during plant operation and plant heat balance determinations should also be covered in this section.

7.

Reactor Meat Transfer Limits.

This section should include a discussion of heat transfer limits by esamining fuel red and reactor design and 11mitations. The basis for the limits should be covered in this section along with 7

recommended methods to ensure that 11stts are not approached or exceeded. This section should Cover i

j discussions of peating f actors, radial and asial power distributions and changes of these f actors due to the influence of other variables such as moderator tegerature, senon and control rod position.

{

Figure 3. from Denton's Letter TRAIN! E CRITERIA FOR MITIGAT!nG CORE D W GE A.

Incore Instrweentation 1.

Use of fined or movable incore detectors to determine entent of, core damage and geometry changes.

2.

Use of thermoCouples in determining peak temperatures; methods for estended range readings; methods for direct readings at terminal junctions.

3.

Metnods for calling up (printing) incore data from the plant computer.

B.

Escore huelete Instrumentation (h!$)

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.

Vitai Instrumentation 1.

Instrumentation response in an accident environment; f ailure sequence (time to failure, method of failure);indicationreliability(actualvsindicatedlevel).

2.

Alternative methods for measuring flows, pressures, levels, and tegeratures, Determination of pressuriger level if all level transmitters fail.

s.

b.

Determination of letdown flow with a clogged filter (Iow flow).

Determination of other Reactor Coolant $ystem parameters if the primary method of measurement c.

has f ailed.

D.

Primacy Chemistry 1.

Espected chemistry results with severe core damage; consequences of transferring small quantities of liquid outside containment; importance of using less tight systers.

2.

Espected isotopic breakdown for core damage; for clad damage.

3.

Corrosion effects of entended toersion in primary water; time to f ailure.

E.

Radiation monitoring Response of Process and Area Monitors to severe damages; behavior of detectors when saturated; 1.

method f or detecting radiation readings by direct measurement at detector output (overranged detector); espected accuracy of detectors at different locations; use of Oetectors to determine j

entent of core damage.

2.

Methods of determining dose rate inside containment from measurements taken outside containment.

F.

Gas Generation venting 2 generation during an accident; other sources of gas (Xe, te); techniques for 1.

Methods of H or disposal of non-condentibles.

in containment or Reactor Coolant System.

2.

Hg flamability and esplosive limit; sources of 02 s

s 4

Figure 4.

Control Manipulations Listed in Enclosure 4.

CONTROL MAN!PutATIONS

  • 1.

Plant or reactor startuos to include a range that reactivity feedback from nuclear heat addition is noticeable and heatup rate is estabitshed.

2.

Plant shutdown.

'3.

Manual control of steam generators and/or feedseter during startup and shutdown.

4 80 ration and or dilution d. ring power operation.

's.

Any significant (creater than 105) poser chsiges in manual rod control or recirculation flow.

Any reactor power change of ids or g*uster where load change is perfo=med with load limit control 6.

or where flua, temperature, o speed control is on manual (for NTGR).

'7.

Loss of coolant including:

1.

significant PhR stees generator leaks 2.

inside and outside primary containment 3.

large and small, including leak-rate determination 4.

saturated Reactor Coolant response (pug).

8.

Loss of instreent air (if simulated plant specific).

g.

Loss of electrical power (and/or degraded power sources).

  • 10.

Loss of core coolant flow /natu al circulation.

r 11.

Loss of condenser vacuum.

12.

Loss of service mater if reautred for safety.

13.

Loss of shutdown cooling.

14 Loss of comoonent cooling systee or cooling to an individual comoonent.

15.

Loss of normal feed =ater or normal feed.ater system f ailure.

  • 16.

Less of all feed ater (normal and emergency).

17.

Loss of protective system channel.

18.

M16 positioned control rod or rods (or rod drops).

Ig.

Instility to drive control rods.

20.

Conditions requiring use of emergency boration or standby liquid control system.

21.

Fuel cladding f ailure or high activity in reactor coolant or offgas.

22.

Turbtne or generator trip.

23.

Malfunction of automatic control systee(s) which effect reactivity.

24.

Malfunction of reactor coolant pressure / volume control system.

25.

Reactor trip.

26.

Main steWe line break (inside or outside containment).

27.

Nuclear instrument 6 tion failure (s).

  • 5 tarred items to be performed annually, all others biennially.

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e of at least 80 contact hours

  • in both the initial training and the requali-fication programs.

The NRC considers thermodynamics, fluid flow and heat trensfer 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.

J 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 60 contact hour, requirement) and whether i

it can reasonably'be concluded from the licensee's descrfption of his train-ing material that the11tems in the enclosures are covered.-

The Institute of Nuclear Power Operations (INPO) has developeid its own guidelines for training in the subject areas of Enclosures 2 and~ 3.

i 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 INP0 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 considered 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 satisffes the requirements for control man 491ations, Enclo-sure 1, : tem 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 whil'e 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.,,

B.

1 II.8.4(

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 coatact 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.

" Plant Manager" is here taken to mean the highest ranking manager at the plant site.

For licensed personnel, this training would be redundant in that it is also required, by I.A.2.?, 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 it 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 program itself, we do not address it in this evaluation. It would be appropriate for resicent 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 might have been made for other reasons subsequent to the response to Denton's letter.

III. LICENSEE SUBMITTALS l

The licensee (Jersey Central Power and Light 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 evalua-tion.

For the Oyster Creek Nuclear Generating Station, there were two submit'tals with attachments, for a total of seven items, which are listed below.

l 1.

Letter from J.T. Carroll, Jr., Station Manager,

/

Jersey Central Power & Light Co., to P.F. Collins, l

Chief of Operator Licensing Branch,

NRC.

July l

28, 1980.

(1 pg, with enclosures: items 2, 3, &

l 4). NRC Acc No: 8008060281. (re: Response to NRC letter dated March 28, 1980; Transmittal).

2.

"0yster Creek NRC Reactor Operator Licensing Program", an excerpt from Section III - NRC Licensed Operator Training - of the Training Administration Manual.

Approved by the Station Manager, July 25, 1980. (19 pp, attached to item 1). NRC Acc No: 8008060287.

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3.

"0yster Creek NRC Senior Reactor Operator Upgrade Program", an excerpt from Section III - NRC Licensed Operator Training - of the Training Admin-istration Manual. Approved by the Station Manager, July 25, 1980.

(7 pp, attached to item 1).

NRC Acc No: 8008060287.

4.

"0yster Creek NRC Licensed Operator Requalification Program", an excerpt from Section III - NRC Licensed Operator Training - of the Training Admin-istration Manual. Approved by the Station Manager, July 25, 1980.

(20 pp,- attached to. item 1). NRC Acc No: 8008060287.

5.

Letter from P. B. Fiedler, Vice President and Director of Oyster Creek Plant, GPU Nuclear, to D.M.

Crutchfield, Chief of Operating Reactors Branch #5, Division of Licensing, NRC.

July 07, 1982.

(1 pg with enclosures: items 6 & 7).

(re:

~

Transmittal, response to NRC's RAI dated March 29, 1982).

Untitled & undated. (4p

6..

Response to NRC's RAIf., attached to item 5). (re:

7..

Untitled & undated. (2 pp, attached to item 5).

(re: Lesson Plan titles and the required contact hours).

Items 5-7 are responses to a request for additional information I

(Reference 6) made in the course of this evaluation.

In addition, further l

clarification was obtained through an informal connunication as follows:

8.

Telephone call between Paul Liang, SAI and Mike Laggard, Jersey Centra! Power. and Light Company,19 August 1982.

IV. EVALUATION l

SAI's evaluation of the training programs at. Jersey Central Power l

and Light Company's Oyster Creek Nuclear Generating Station is presented below.

Section A addresses TMI Action Item I.A.2.1 and presents the assess-l ment organized in the manner of Figure 1.

Section B addresses TMI Acti,on Item II.B.4.

A.

I.A.2.1:

Immediate Upgrading of Reactor Operator and Senior l

Reactor Operator Training and Qualification., Item A.2.c(1)

The basic requirements are that the training programs given to l

reactor operator and senior reactor operator candidates cover the subjects l

of heat transfer, fluid flow and thermodynamics at the level of detail specified in Enclosure 2 of Denton's letter.

8

Jersey Central Power and Light Company submitted a description of the training program (submittal item 2) used at Oyster Creek Nuclear Gener-ating Station. This description provided a list of lectures which appear to adequately address all but one item in Enclosure 2. In addition, the licensee in submittal item 6 stated that the lectures covered heat transfer, fluid flow and thermodynamics to the level of detail specified in Enclosure 2 with the exception that it is not possible to completely satisfy item 6 of.

The licensee further stated that Oyster Creek does not have a plant computer and therefore training in the use of plant computer is not possible.

SAI judges that this explanation is acceptable.

Therefore, SAI concludes that this criterion is met at Oyster Creek Nuclear Generating Station.

,, 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 l

Figure 3 of this report).

The licensee's submitted list of lecture series (submittal item 7) l appeared to address this training requirement well.

In addition, the licensee in submittal item 6 stated that this lecture series, in f act, covered the material at the level of detail specified in Enclosure 3 of the Denton's letter.

Moreover, the training for the accident mitigation with core damage and related subjects (heat transfer, fluid flow, thermodynamics) l in the licensee's training program contains about 100 contact hours of instruction.

Therefore, SAI concludes that this requirement is met at the Oyster Creek Nuclear Generating Station.

l, Item A.2.c(3)

The requirement is that there be an increased emphasis in the training program on dealing with reactor transients.

The Oyster Creek NRC Reactor Operator Licensing Program includes 40 contact hours of training in operating characteristics. This training area is composed of (1) Plant Transients, (2) Design Basis Accidents -

1 FDSAR, (3) Operator Response in Emergencies (4) Short Period Scrams, and (5) l the Oyster Creek 5/2/79 Event (the water level in the reactor core was too I

low).

In addition, the licensee's training program requires senior reactor I

operator and reactor operator candidates to participate in the shif t.

training which involvas significant reactivity manipulations.

One of the manipulations titled ' Plant and reactor operations that involve emergency or trar,ient procedures where reactivity is changing including reactor scrams and ' subsequent activities", also addresses this subject area. Therefore, the licensee's training program meets the requirement., 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.

9

The licensee stated in submittal item 6 that all of the Oyster Creek operator training staff are enrolled in appropriate requalification programs to assure that they are cognizant of current operating history, problems, and changes to procedures and administrative limitations.

Therefore, SAI would credit the licensee with meeting this 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'si letter.

In addition, these instructions must involve an adequate number of contact hours.

The licensee submitted a list of specifically designed Mitigating Core Damage lectures (submittal item 7).

This list involves 41.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of instruction and appears to address the required training specified in.

Furthermore, within submittal item 7, the licensee listed additional training lectures that relate to the training for mitigating core damage and these lectures total 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> of instruction. All these lec-tures give a total of 181.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of training for mitigating accidents with core damage and related subjects that are available in their requalification This was further verified during an informal phone conversation program.

between the licensee and SAI (submittal item 8).

Although it should be noted that the required level of material coverage and time of involvement for this training area in the requalification program are based on the result of individual annual examination scores, SAI also notes that allow-ance of such flexibility falls within normal NRC practice.

In addition, for 1981 the licensee did require 100% attendance and completion in the mitiga-tion of core damage program.

Therefore, SAI judges that the licensee's requalification program meets this requirement., Item C.2 The requirement for licensed operators to participate in the accelerated requalification program must be based on passing scores of 80%

overall, 70% in each category.

The material supplied describing the licensee's requalification program (submittal item 3) showed the inclusion of such an accelerated requalification program for reactor and senior reactor operators. Therefore, it is clear that this requirement is met at Oyster Creek Nuclear Generating Station., Item C.3 TMI Action Item I.A.2.1 calls for the licensed operator requalifi-cation program to include performance of control manipulations involving both normal and abnormal situations. The specific manipulations required and their p(erformance frequency are identified in Enclosure 4 of the Denton letter see Figure 4 of this report).

The licensee's requalification program (submittal item 3) explicitly identified all but two of the 27 manipulations specified in.

Items 4 and 6 are omitted because they do not apply to boiling 10

..c.

water reactors, the type used at Oyster Creek Nuclear Generating Station.

The stated frequency of performance is also in compliance with the require-ment. Therefore, this requirement is met at Oyster Creek Nuclear Generating Station.

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 shif t technical advisors and operating personnel from the plant manager to the licensed operators. This includes both licensed and non-licensed personnel.

The training of licensed personnel meets the requirements of Action Item II.B.4 because the licensed personnel receive this training through either the training or the requalification programs and the training and requalification programs meet the 80 contact hours criterion for this training area.

Based on information, including an organization chart, supplied by Jersey Central Power and Light Company in their response (submittal item 7) to NRC's request for additional information (Reference 6), this training is given to personnel holding the following positions:

Plant Operations Director, Manager Plant Operations, Group Shif t Supervisor, Group Operating Supervisor, Shift Control Room Operators, and Shift Technical Advisor.

l l

However, at Oyster Creek, the highest ranking manager (Vice President),

f ailed to receive this training.

Therefore, the NRC requirement is not satisfied for non-licensed personnel at Oyster Creek.

f V.

CONCLUSIONS Based on our evaluation as discussed above, SAI concludes that the licensee meets the requirements of NUREG-0737 item I.A.2.1.

However, the licensee fails to fully satisfy the requirements of NUREG-0737 item II.B.4 because the plant manager at Oyster Creek f ailed to receive this training.

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VI.

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 Requirements," NUREG-0737, United States Nuclear Regulatory Commission. November 1980.

3.

The NRC requirement for 80 contact hours is an Operator Licensing Branch technical position.

It was included with the acceptance criteria provided by NRC to SAI for use in the present evaluation.

See letter, Harley Silver, Technical Assistance Program Management Group, Division of Licensing, USNRC to Bryce Johnson, Program Manager, Science Applications, Inc.,

Subject:

Contract No. NRC-03-82-096, Final Work Assignment 2, December 23, 1981.

4.

" Guidelines for Heat Transfer, Fluid 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 P. B. Fielder, Vice President and Director, Jersey Central Power and Light Company, Oyster Creek, transmitting request for additional information on Upgraded Senior Reactor Operator and Reactor Operator Training and Training for Mitiga-ting Core Damage, dated 29 March 1982.

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