ML20028C681

Improvements in Training & Requalification Programs as Required by TMI Action Items I.A.2.1 & II.B.4 for Pilgrim Nuclear Power Station, Technical Evaluation Rept

ML20028C681
Person / Time
Site:	Pilgrim
Issue date:	08/17/1982
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20028C680	List: ML20028C681
References
CON-NRC-03-82-096, CON-NRC-3-82-96, RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-660, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM SAI-186-029-30, SAI-186-29-30, NUDOCS 8301130198
Download: ML20028C681 (15)

Text

-

s <

Enclosure 2 SAI-186-029-30 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 Pilgrim Nuclear Power Station (Docket'50-293) c August 17, 1982 l

l Prepared By:

Science Applications, Inc.

1710 Goodridge Drive McLean, Virginia 22102 Prepared for:

l U.S. Nuclear Regulatory Comission ,.

Washington, D.C. 20555 l

Contract NRC-03-82-096 l

l .

8301130198 821230 PDR ADOCK 05000293

? PDR _

Science AppflCations,lnC.

_-. a _

_ _ _ _ _ _ _ _ - - _ ~

TABLE OF CONTENTS Section Page I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . l' II. SCOPE AND CONTENT OF THE EVALUATION . . . . . . . . . 1 A. I.A.2.1: Immediate Upgrading of RO and SRO Training and Qualifications ..... 1 B. II.B.4: Training for Mitigating Core Damage. . 6 ,

III. LICENSEE SUBMITTALS . . . . . . . . . . . . . . . . . 7 IV. EVALUATION. . . . . . . . . . . . . . . . . . . . . . 9 A. I.A.2.1: Immediate Upgrading of RO and SR0 Training and Qualifications .... 9 B. II.B.4: Training for Mitigating Core Damage. . 11 V. CONCLUSIONS . . . . . . . . . . . . . . . ... . . . . 12 .

VI. REFERENCES. . . . . . . . . . . . . . . . . . . . . . 13 i

~

I. INTRODUCTION Science Applications, Inc. (SAI), as technical assistance 'contrac-tor to the U.S. Nuclear Regulatory Commission, has evaluated the response by the Boston Edison Company for the Pilgrim Nuclear Power Station (Docket 50-293) to certain requirements contained in post-TMI Action Items I.A.2.1, Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications, and II.B.4, Training for Mitigating Core Dama These

.re'quirements were set forth in NUREG-0660 (Reference 1) ge. and were subsequently clarified in NUREG-0737 (Reference 2).*

The purpose of the evaluation was to determine whether the the licensee's operator requirements. training pertains The evaluation and requalification programs satisfy to Technical Assignment Control (TAC)

System numbers 44187 (NUREG-0737, I.A.2.1.4) and 44537 (NUREG-0737 II.B.4.1). As delineated below, the evaluation covers only some aspects of item I.A.2.1.4.

l The detailed evaluation of the licensee's submittals is presented 1

in Section IV; the conclusions are in Section V.

II. SCOPE AND CONTENT OF THE EVALUATION A. I.A.2.1: Imediate Upgrading of RO and SRO Training and Qualifications The clarification of TMI Action Item I.A.2.1 in NUREG-0737 incor-parates a letter and four enclosures, dated March 28, 1980, from Harold R.

• Denton, Director, Office of Nuclear Reactor Regulation, USNRC, to all power reactor applicants and licensees, concerning qualifications of reactor operators (hereafter referred to as Denton's letter). This letter and enclosures imposes a number of training requirements on power reactor licensees. This evaluation specifically addressed a subset of the require-ments stated in Enclosure 1 of Denton's letter, namely: Item A.2.c, which relates to operator training requirements; item A.2.e, which concerns instructor requalification; and Section C, which addresses operator requali-i fication. Some of these requirements are elaborated in Enclosures 2, 3, and 4 of Denton's letter. The training requirements under evaluation are sum-marized in Figure 1. The elaborations of these requirements in Enclosures 2, 3 and 4 of Denton's letter are shown respectively in Figures 2, .3 and 4.

As noted in Figure 1, Enclosures 2 and 3 indicate minimum require-ments concerning course content in their respective areas. In addition, the Operator Licensing Branch in NRC has taken the position (Reference 3) that the training in mitigating core damage and related subjects should consist i

o_nclosure 1 of NUREG-0737 and NRC's Technical Assistance Control System ,

s iistinguish 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

'6 o t

t

- a _

Figure 1. Training Requirements from TMI Action Item I.A.2.1*

Program Element adtC Requirements" Enclosure 1.ItemA.2.c(1)

. Training programs shall be modified. as necessary. to provide training in heat transfer fluid flou and thermodynamics. (Enc'osure 2 provides guidelines for the minimum content of such training.)

OptRAT!0N5 Enclosure 1. Item A.2.c(2)

PERSONNEL Training programs shall be sedified. as necessary to provide training in the use of installed plant systems to control or mitigate an accident in which the TRA!h!NG core is severely damaged. (Enclosure 3 provides guidelines for the mintswm content of such training.)

Enclosure 1. Item A.2.c.(3)

Training programs shall be modified, as necessary to provide increased emphasis on reactor and plant transients.

Enclosure 1. Item A.2.e INSTAUCTOR Instructors shall be enrolled in sopropriate recualification programs to assure they are cognizant of current operating history. problems, and changes to pro-REQUAL!r! CAT!0N cedures and administrative limitations.

4:e Enclosure 1. Item C.1 Content of the licensed operator.requalificatien programs shall be modified to in*clude instruction in heat transfer, fluid flow themodynamics and mitiga-tion ef accidents involving a degraded core. (Enc 1csures 2 and 3 provide guide.

lines for the minimum content of such training.)

Enclosure 1. Item C.2 PERSONNR 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 70t each category.

Enclosure 1. Item C.3 Programs should be modified to require the control manipulations listed in Enclosure 4. hermal control manipulations, such as plant or reactor startups, sust be perfomed. Control manipulations during abnomal or emergency opera-tions sust be walked through with, and evaluated by, a member of the training staff at a minimum. An appropriate simulator may be used to satisfy the requirerents for control manipulations.

'The recuirements shown see a subset of these contained in Item 1.A.2.1.

" References to Enclosures are to Denton's letter of March 28. 1960, which is contained in the clarif t-cation of Item I. A.2.1 in NdREG-0737.

1 2

l

Figure 2. Enclosure 2 from Denton's Letter TRAlutna lu nLAT TRAM 5FER. FLUID FLOW AND THERM 00fmAMICS

1. Basic pr'eperties of Fluids end Matter.

This section should cover a basic introduction to matter and its properties. This section should include such concepts as temperature measurements and effects, density and its effects, specific weight, buoyancy, viscosity and other properties of fluids. A working knowledge of steam tables should also be included. Energy movement should be discussed including such fundamentals as heat eschenge, specific heat latent heat of vaporitation and sensible heat.

2. Fluid Statics.

Isample of these This section should cover the pressure, temperature and volume effects on fluids.

parametric changes should be illustrated by the instructorCauses and related calculations and effects should of pressure andbe performed temperature by the students and discussed in the training sessions.

changes in the various components and systems should be discussed in the training sessions. Causes and effects of pressure and temperature changes in the various components and systems should be discussed The as applicable to the f acility with particular emphasis on saf ety significaht features.

characteristics of f orce and pressure, pressure in lieutes at rest, principles of hydraulics, saturation pressure and tagerature and subcooling should also be included.

3. Fluid DyneM es.

This section should cover the flow of fluids and such concepts as Bernoulli's principle, energy in moving fluids, flow measure theory and devices and pressure fosses due to friction and orificing.

Othee concepts and terms to be discussed in this section are NP5M. carry over, carry under, kinetic energy, head loss relationships and two phase flow fundamentals. practical applications relating to the reactor coolant system and steam generators should also be included.

l 4. Meat Treasf er by Conduction. Convection and Radiation.

Tnis section should cover the fundamentals of heat transf er by conductions. This section should Heat include discussions on such concepts and terms as specific heat, heat flus and atomic action.

transfer characteristics of fuel rods and heat exchangers should be included in this section.

This section should cover the fundamentals of. heat transfer by convection. hatural and forced circula- a tion should be discussed as appitcable to the various systems at the f acility. 'The convection current Meat patterns created by espandtng fluids in a confined area should be included in this sectio j gas f ormation during normal and accident concitions.

This section should cover the fundamentals of heat transfer by theenal radiation in the form of radiant energy. The electromagnetic energy emitted by a bois as a result of itsComparisons temperature should should be be mace discussed and illustrated by the use of equations and sample calculations.

of a black body absorber and a white body esitter.

5. Chance of phase - toiline.

their inherent characteristics and This section should include descriptions of the state of matter, Calculations should be performed involving thermodynamic steam aus11ty and properties such as void f raction enthalpy and entropy.The types of boiling should pc discussed as applicable to properties.

the f acility during normal evolutions and accideat conditions.

6. Burnout and Flow Instability.

This section should cover descriptions and mechanisms for calculating such terms as critical flux, critical power. DnB ratio and hot channel f actors. This section should also include instructions for instabilities. Sample calculations should preventing and monitoring for clad or fuel damage and flow be tilustrated by the instructor and calculations should be performed by the students and discussed in the training sessions. Methods and procedures for using the plant computer to determine quantitative values of various f actors during plant operation and plant heat balance determinations should also be covered in this section.  ?

7. Reactor Meat Transfer timits.

This section smould include a discussion of heat transf er limits by examining fuel rod and reactor l

design and limitations. The basis for the limits should be covered in This this section along with section should cover recommended methods to ensure that Itaits are net approached or exceeded.

discussions of peakieg f actors, radial and axial power distributions and changes of these f actors due to the influence of other variables such as moderator tenqstrature, tenon and Control rod position.

1 l

\,'

l 3

• 9

e Figure 3. Enclosure 3 from Denton's Letter -

TRA!NING CRITERIA FOR MITIGAT1nG CORE DeMGE A. Incore instrumentation

1. Use of fised or novable incere detectors to determine entent of core desage and geometry changes.

2. Use of thermocouples in determining peak temperatures; sethods for extended range readings; methods for direct readings at teminal junctions.

3. Methods f or call'ing up (printing) incore data from the plant computer.

3. Escore nuclear instrumentation (N!$1 '

1. Use of 'i$ for determination of void formation; void location basis for NIS response as a function of core .'iceratures and density changes.

C. Vital Instruac cation

1. Instru mentation response in an accident environment; f ailure sequence (time to f atture, method of f ailure); indication reliacility (actual vs indicated level).

2. Alternative methods for measuring flows, pressures, levels, and tageratures.

a. Determination of pressu'riter level if all level transmitters fail,

b. Determination of letdown flow mith a clogged filter.(low flo=).

c. Determination of other Reactor Coolant System parameters if the primary method of messy ement l has failed. .tp D. primary Cne*1stry

1. Espected chemistry results eith severe core damage; consecuences of transf erring small ouantities of liquid outside contaiment; incertance of using less tight systems.

2. Espected isotopic breakdown for core damage; for clad damage.

3. Corrosion eff ects of extended immersion in primary mater; time to failure.

E. esciatica Monitoring

1. Response of Process and Area Monitors to severe desages; behavior of detectors when saturated; method for detecting radiation readings by direct measurement at detector output (overrenged detector); espected accuracy of detectors at diff erent locations; use of detectors to setermine entent of core damage.

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

F. Gas Generation

1. Methods of My generation during an accident; other sources of gas (18. Ke); techniques for venting or disocsal of non-condensibles.

2. M 2

flam ability and esplostre limit; sources of 02 in containment or Reactor Coolant System.

O 4

4

Figure 4. Control Manipulations Listed in Enclosure 4.

CollTROL MA4]PULAT10n3

• 1. Plant or reactor stae'tes to include a range that roectivity feedback free nuclear heat addition is noticeaie and heatu, rate is est=uin.d.

2. Plant shutdown.

• 3. Manuel control of steam generators and/or feedseter during startup and shutdown.

4 Soration and or dilution during p>er operation.

• 5. Any significant (greater than 105) poser changes in aanval red control or rectrculation flam.

I

6. Any reacto* Power change of 105 or greater where lead change is eerformed with lead limit control i

or where flua, temperature, or speed control is on senwel (fo- WTGA).

• 7. Loss of coolant including:

1. significant Past stese generat6r leaks

2. inside and outside primary contaivment

3. large and small including lask rate determination 4 saturated Reacte" 6eolent response (PeM).

8. Loss of instreent air (if simulated plant specific).

g. Loss of electrical power (and/or degraded power sources [.

• 13. Loss of core coolaet flow / natural circulatton.

11. Loss of condenser vacuum, to

12. Loss of service mater if required for safety, i

13. Loss of shutdown ' cooling.

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

15. Loss of normal feed ater or comal feedwater systee f ailure.

• 16. Loss of all feed ater (normal and emergency).

17. Loss of protective system channel.

f

18. Mispositioned control rod or rods (or e.J orops).

Ig. Innility to drive control rods.

20. Conditions requiring use'of emergency boration or standby lievid control systee.

21. Fuel cladding f ailure or high activity in reactor coolant or offges.

22. Turbine or generator trip.

23. Malfunction of automatic control system (s) whica effect reactivity.

24 Malfunction of reactor coolant pressure / volume control system. /

25. Reactor trip.

26. Main stese line break (inside or outside containment).

27. huclear insiementation f ailure(s).

• Starred itees to be performed annually, all others biennially.

N, 5

of at least 80 contact hours

• in both the initial training and the requali-fication programs. The NRC considers thermodynamics, fluid flow and heat transfer to be related subjects, so the 80-hour requirement applies to the combined subject areas of Enclosures 2 and 3. The 80 contact hour criterion is not intended to be applied rigidly; rather, its purpose is to provide greater assurance of adequate course content when the licensee's training courses are not described in detail.

Since the licensees generally have their own unique course out-lines, adequacy of response to these requirements necessarily depends only on whether it is at a level of detail comparable to that specified in the

! enclosures (and consistent with the 80 contact hour requirement) and whether i it can reasonably be concluded from the licensee's description of his train-ing material that the , items in the enclosures are covered.

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

These guidelines, given in References 4 and 5, were developed in response to the same requirements and are more than adequate, i.e., training programs

, based specifically on the complete INP0 documents are expected to satisfy all the requirements pertaining to training material .which are addressed in this evaluation.

I i The licensee's ressionse concerning increased emphasis on tran-l sients is considered by SAI to be acceptable if.it makes explicit reference i to increased emphasis on transients and gives some indication of the nature l

of the increase, or, if it addresses both normal _ and abnormal transients i (without necessarily indicating an increase in emphasis) and the requalifi-

• cation program satisfies the requirements for control manipulations, Enclo-sure 1, Item C.3. The latter requirement calls for all the manipulations listed in Enclosure 4 (Figure 4 in this report) to be performed, at the frequency indicated, unless they are specifically not applicable to the licensee's type of reactor (s). Some of these manipulations may be performed on a simulator. Personnel with senior licenses may be credited with these activities if they direct or evaluate control manipulations as.they are performed by others. Although these manipulations are acceptable for meet-ing the reactivity control manipulations required by Appendix A paragraph 3.a of 10 CFR 55, the requirements of Enclosure 4 are more demanding.

Enclosure 4 requires about 32 specific manipulations over a two-year cycle while 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.

B. II.B.4: Training for Mitigating Core Damage l Item II.B.4 in NUREG-0737 requires that " shift technical advisors and operating personnel from the plant manager through the operations chain to the licensed operators" receive training on the use of installed systems to control or mitigate accidents in which the core is severely damaged.

• A contact hour is a one-hour period in which the course instructor is present or available for instructing or assisting students; lectures, seminars, discussions, problem-solving sessions, and examinations are considered contact periods. This definition is taken from Reference 4.

6 i -_ - . . - - . . _ - - - . - -

Enclosure 3 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.2.1, in the operator requalification program.

However, II.B.4 applies also to operations personnel who are not licensed and are not candidates for licenses. This may include one or more of the highest levels of management at the plant. These non-licensed personnel are not explicitly required to have training in heat transfer, fluid flow and thermodynamics and are therefore not obligated for the full 80 contact hours of training in mitigating core damage and related subjects.

Some non-operating personnel, notably managers and technicians in instrumentation and control, health physics and chemistry departments, are

, supposed to receive those portions of the training which are commensurate with their responsibilities. Since this imposes no additional demands on the program itself, we do not addre'ss it in this evaluation. It would be 4

aporopriate for resident inspectors to verify that non-operating personnel i 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 i

might have been made for other reasons subsequent to the response to Denton's letter. .

e III. LICENSEE SUBMITTALS.

The licensee (the Boston Edison Company) has submitted to NRC a number of items (letters and various attachments) which explain their training and requalification programs. These submittals, made in response to Denton's letter, form the information base for this evaluation. For the

( Pilgrim Nuclear Power Station, there were four submittals with attachments. .

l for a total of sixteen items, which are listed below. Submittal Item 6 and l the attachments thereto were in response to the NRC request for additional l information dated April 27,.1982 (Reference 6).

1. Letter from C.J. Mathis, Deputy" Nuclear Operations Manager, Pilgrim Nuclear Power Station, to P.F. Collins, Chief of Operator Licensing Branch, NRC. September 12, 1980. (1 pg, -

with enclosure: item 2). NRC Acc No: 8009220250.

(re: Response to NRC letter dated March 28,1980).

2. Excerpt from the PNPS Training Manual titled

" Initial Operator Training", Section 3.1.1.

Untitled, undated. (16 pp, attached to item 1). -

NRC Acc. No: 8009220252.

3. Letter f rom R.D. Machon, Nuclear Operations Manager, Pilgrim Nuclear Power Station, to D.H.

7

e Beckham, Acting Chief of Operator Licensing Branch, NRC. January 21, 1982. (1 pg, with enclosure: item 4). BECo Ltr.: #82-15. (re: -

Transmittal, additional submittal concerning PNPS requalification program).

4. "NRC Licensed Operator Requalffication- Program",-

Pilgrim Nuclear Power Station, Revision 5.-

Approved by R.D. Machon, Nuclear Operations Manager, February 1,1982. (10 pp, attached to item 3).

5. Letter from A.V. Morisi, Manager of Nuclear Operations Support Dept., BOSTON Edision Co., to T.A. Ippolito, Chief of Operating Reactors Branch f3, Division of Operating Reactors, NRC.

December 10, 1981. (2 pp). NRC Acc. No: ,

8112220506. (re: Notifications & details of NUREG-0737, Item II.B.4 commitment changes).

6. Letter from A.V. Morisi, Manager of Nuclear Operations Support Dept., BOSTON Edison Co., to D.B. Vassallo, Chief of Operating Reactors Branch f 2, Division of Licensing, NRC. June 14, 1982.(5 pp, with enclosures: items 7,8,9,10,11,12,13,14,15,16). NRC Acc No:

8206210593. (re: Response to NRC's RAI dated April 27,1982). y

7. " Operations Group Training, General l Indoctrination", PNPS.. Undated. (1_ pg, attached to item 6).

8. " Qualification Requirements for Nuclear Plant Operator", PNPS. Undated. (8 pp, attached to item 6).

9. " Qualification Requirements for Nuclear Operating Supervisor", PNPS. Undated.(1 pg, attached to item 6). .

10. " Qualification Requirements for Nuclear Watch Engineer", PNPS. Undated. (1 pg, attached to item 6).

?

l 11. ," Qualification Requirements for Senior Reactor

Operator", PNPS. Undated.(3 pp, attached'to item l

6).

l 12. " Qualification . Requirements for Nuclear Auxiliary Operator", PNPS. Undated. (3 pp, attached to item 6).

8 1

. . )

13. " Qualification Requirements for Fuel Handlers, Limited SRO License Holders", PHPS. Undated. (3 pp, attached to item 6).

14. " Heat Transfer, Thermodynamics & Fluid Flow Course". Undated.(2 pp, attached .to item 6 ).

(re: Table of Contents).

15. " Recognizing & Mitigating the Consequences of Severe Reactor Core Damage". Undated.(11 pp, attched to item' 6). (re: Table of Contents, Course Outlines, & Organizational Chart).

16. " Pilgrim Abnormal Event Analysis Training Manual".

February 1932. NEDE-24862D, Class III. (4 pp, j attached to item 6). (re: Table of Contents).

t IV. EVALUATION SAI's evaluation of the training programs at the Boston Edison Company's Pilgrim Nuclear Power Station is presented below. Section A addresses TMI Action Item I.A.2.1 and presents the assessment organized in the manner of Figure 1. Section B addresses TMI Action Item II.B.4.

A. I.A.2.1: Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualification.

Enclosure 1, Item A.2.c(1)

• e

The basic requirements are that the training programs given to l

reactor operator and senior reactor operator candidates cover the subjects of heat transfer, fluid flow and thermodynamics at the level of detail specified in Enclosure 2 of Denton's letter.

Submittal item 14 " Heat Transfer Thermodynamics and Fluid Flow Course" table of contents indicates the course substantially addresses the l topical areas of Enclosure 2 of Denton's letter. In submittal item 6, in

response to the NRC request for additional information (Reference 6), the licensee states it believes the lecture course meets the detail spelled out in Enclosure 2 of Denton's letter. It is reasonable to conclude that the requirements of this Enclosure 1 item are met. .

Enclosure 1, 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 De'nton's letter (see Figure 3 of this report).

Submittal item 6, in response to the NRC request for additional J vinformation, indicates that their training programs covering accident /

mitigation and related subjects consists of a total of 116 contact training hours. Submittal item 6 also states that a book entitled " Recognizing and 9

$ a

Mitigating the Consequences of Severe Reactor Core Damage" by General Physics Corporation (submittal item 15), which is a generic BWR course, is presently in use, The licensee further states that a plant-specific book is in preparation by General Physics and that this book / course, when available, will be used for both initial and requalification training. Submittal item 15 presents the Table of Contents of the aforementioned book as well as the

' course outline. Examination of these constituents of submitt'al item 15 indicates the level of detail specified in Enclosure 3 of Denton's letter is attained. Therefore, the requirements of this Enclosure 1 item are met.

Enclosure 1, Item A.2.c(3)

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

Submittal item 6 states: "Our Reactor Operator and Senior Reactor Operator training on transient analysis has received increasea emphasis for both normal and abnormal transients. " General Electric, under contract to us, has rewritten'their abnormal event analysis book to be site-specific to Pilgrim Nuclear Power Station. This course is 40 contact hours." Examina-tion of submittal item 16, " Pilgrim Abnormal Event Analysis Training Manual" Table of Contents supports the statement made in submittal item 6 regarding

. increased emphasis in the training program on dealing with reactor transients. The requirement of this Enclosure 1 item is fully satisified.

~

Enclosure 1, Item A.2.e The requirement is that instructors for reactor operator training +

, programs be enrolled in appropriate requalification programs to assure they' l are cognizant of current operating history, problems and changes to i procedures and administrative limitations.

I Submittal item 4 states: "Those licensed staff members who are actively engaged in implementation (we presume this refers to instructors) of the Requalification Program will be required to complete those sections of this program for which they serve an active function". The submittal further states in the requalification program all operators and senior operators will,'among other . things, review design changes, procedure' changes and f acility license changes. Additionally, attendance at a series of lectures relating to these subjects is mandatory for all licensed operators and senior operators. Although clear statement is lacking regarding activities incumbent upon instructors we feel it is reasonable to conclude the requirement of this Enclosure 1 item is met.

Enclosure 1, Item C.1 e The primary requirement is that the requalific'ation programs have instruction in the areas of heat transfer, fluid flow, thermodynamics and l accident mitigation. The level of detail required in the requalification program is that of Enclosures 2 and 3 of Denton's letter. In addition, these instructions must involve an adequate number of contact hours. '

Submittal item 6 indicates that the course in heat transfer, fluid j flow, thermodynamics and accident mitigation are the same for both initial I and requalification programs and refer to submittal items 14 and 15, which 10

e' O were found to conform with Enclosures 2 and 3 of Denton's letter in the i preceding evaluation of Enclosure 1, Items A.2.c(1) and A.2.c(2). This being the case, the level of detail required by this Enclosure 1 item is met. Submittal item 6 also points out that the course in heat transfer, fluid flow and thermodynamics involves 80 contact hours and the course in accident mitigation provides 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of training. This satisfies the requirement for an adequate number of contact hours' . The requirements of this Enclosure 1 item are, met.

Enclosure 1. 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. ,

Submittal item 4,Section V states: "If a licensed operator or senior operator fails to achieve an overall grade of 80% or less than 70% on any section on his yearly requalification examination, he will be removed

, from licensed duties and will be required to complete an accelerated l training program". This policy satisifies the requirement of this Enclosure 1 item.

Enclosure 1 Item C.3 i

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 mar,ipulations required and their performance frequency are identified in Enc 1Jsure.4 of the Denton ,

letter (see Figure 4 of this report).

! Submittal item 4, Section IV includes a list.of control manipulations which conforms with those in Enclosure 4 of Denton's letter.

This submittal item states that all the listed manipulations will be performed by all licensed operators, annually and biennially as required, during the course of the two-year requalification program. The requirements of this Enclosure 1 item are therefore satisified.

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 operatino personnel from the plant manager to the licensed operators. This includes both licensed and non-licensed personnel.

Initialcandidatetrainingprogramsforreactoroperatoradd senior reactor operator and requalification programs for these positions provide training in accident mitigation and related subjects (submittal items 14 and 15). Submittal item 6 indicates' accident mitigation training

'I provided all operations personnel, including Shift Technical Supervisors, from the Plant Manager through the operations chain to the licensed /

Vperators. The submittal item states: "All qualified Shift Technical Advisors, Nuclear Plant Operators, Nuclear Operations Supervisors and Nuclear Watch Engineers have received Mitigation of Core Damage Training".

l 11

. .x _ _,

.---2..

"In addition, the Nuclear Operations Manager and two (2) Deputy Operations Managers have received Mitigation of Core Damage Training." An organization chart, included in submittal item 15, presents a graphic repetition of the foregoing. All evidence indicates i.he requirements of

_II.B.4 have been met.

V. CONCLUSIONS SAI evaluation of the TMI Action Items I.A.2.1 and II.B.4 in Part IV, Sections A and B leads to the conclusion that all requirements are met.

The only significant weakness, due to' a dearth of detail and clarity, is in connection with Enclosure 1, Item A.2e which deals with instructor requali-fication. ,

i l-l l - ,

l .

I I

12

V. REFERENCES

1. "NRC Action Plan Developed as a Result of the TMI-2 Accident." NUREG-0660, United States Nuclear Regulatory Commission. May 1980.

2. " Clarification of TMI Action Plan 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 Dama e," STG-01, The Institute of Nuclear Power Operations.

January 15 1981.

6. The NRC letter request for additional information regarding specific details of the training programs conducted by the Bos n Edison Company dated April 27, 1982.

e 1

\,'

13 O