ML20052G191
| ML20052G191 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/10/1982 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM NUDOCS 8205140390 | |
| Download: ML20052G191 (14) | |
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Cp&L Carolina Power & Light Company g"
MAY 101982 N
9-f, ED, 13 /94A R
T Office of Nuclear Reactor Regulation y
ATTN:
Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 (2
g United States Nuclear Regulatory Commission Washington, D.C.
20555 N
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENTAL INFORMATION -
TMI ITEMS I.A.2.1 & II.B.4
Dear Mr. Vassallo:
=
Background===
By your letter dated April 2,1982, NRC requested Carolina Power &
Light Company (CP&L) to provide additional information regarding our July 28, 1980 submittal on Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications (NUREG-0737, Item I.A.2.1) and Training for Mitigating Core Damage (NUREG-0737, Item II.B.4).
The enclosure to this letter is in response to your April 2, request.
Discussion During the review of the NRC Request for Additional Information, my staff noted the requirement for a " minimum of 80 contact hours of training for mitigating core damage" (un-numbered question, page 3 and question 3, page 2).
Further review of NUREGs-0660 and 0737 and H. R. Denton's guidance letter of March 28, 1980, indicated no guidance for a minimum of 80 contact hours in mitigation of core damage.
CP&L contacted the NRC regarding the aforementioned guidance. NRC advised CP&L that NRC's technical consultant misinterpreted NRC's intent of the " minimum requirement". NRC's intent was that a licensee's training program would very likely be acceptable if a minimum of 80 contact hours were provided that related to mitigating core damage (i.e. including training on related systems, heat transfer, fluid flow and thermodynamics).
Enclosed please find a discussion of the Brunswick Steam Electric Plant Unit Nos. 1 and 2 (BSEP) training program for reactor operators and senior reactor operators. The BSEP training program meets or exceeds that required by NRC as referenced in H. R. Denton's letter of March 28, 1980.
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.g Mr. Vassallo Please contact our staff should you have any questions regarding the enclosed information.
Yours very'truly, U-P. W. Howe Vice President Technical ~ Services MSG /lr (n-38)
Enclosure oc:
Mr. R. T. Liner (Science Applications, Inc.)
Mr. J..P. O'Reilly (NRC-RII)
Mr. J. Van Vliet (NRC)
ENCLOSURE CAROLINA POWER & LIGHT COMPANY'S (CP&L) RESPONSE TO UPGRADED SRO AND RO TRAINING AND TRAINING FOR MITIGATING CORE DAMAGE - NRC REQUEST FOR ADDITIONAL INFORMATION (APRIL 2, 1982)
NRC Question 1 Does the training program have an increased emphasis on reactor and plant transients as called for in enclosure 1 of Denton's March 28, 1980 letter?
Does this training deal with both normal transients and abnormal (accident) transients?
CP&L Response Yes. The Lesson Plan for Plant Transients has been updated and our classroom lecture teaches all FSAR analyzed transients. These transients deal with both normal and abnormal transients including Design Basis Accidents. The program is updated after each core reload, based on supplemental reload licensing l
information supplied by the vendor. This training includes four days at the Limerick Simulator and transients are covered in detail.
NRC Question 2 Are the lectures and quizzes on the subject of accident mitigation given to shift technical advisors and operating personnel from plant manager through the operations chain to the licensed operators? If they are, would you please provide the titles of the people who are trained and an organization chart which illustrates their position in the operations chain?
CP&L's Response Lectures and tests reSarding Accident Mitigation have been given to the following:
- a)
- b)
Shift Operating Supervisors
' c)
Shift Foremen
- d)
Senior Control Operators
- e)
Reactor Operators i
' f)
All licensed non-operations personnel
- g)
Manager - Operations
t**
h)
Manager - Plant Operations t 1)
Manager - Maintenance t' j)
Manager - Environmental & Radiation Control t##- k)
, General Manager
- Tests were included in the final retraining exam.
- Missed one lecture (to be completed by June 15, 1982).
t Test not given.
Figure 1 indicates management positions in the operating chain that received the training.
NRC Question 3 Do the training and requalification program elements which involve heat transfer, fluid flow, thermodynamics and accident mitigation involve 80 contact hours?- (A contact hour of instruction 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 under this definition.)
CP&L Response Previous Training All licensed operators at the Brunswick Plant have received the following training which contained a minimum of 80 contact hours in the areas of Heat Transfer, Fluid' Flow, Thermodynamics and Accident Mitigation. The training was broken down as follows:
a)
Accident Mitigation with Core Damage
= 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> b)
Emergency Plan Training
= 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> c)
Simulator total retrair.ing course of
- 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, of which 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> are dedicated to Transients and Accident Mitigation 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />
=
d)
Heat Transfer, Fluid Flow and Thermodynamics
= 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 88 hours TOTAL
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J Current Training a)
Beginning in January, 1982, the initial classroom training (for subjects related to Accident Mitigation with Core Damage) for RO. candidates and SRO candidates is as follows:
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of Heat Transfer, Fluid Flow and Thermodynamics 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of ECCS Training 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of Emergency Plan Training 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of Transients, both abnormal and " normal" 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of DBA instruction 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of Accident Mitigation with Core Damage ( AMWCD)*
b)
Beginning in January, 1982, the annual operator retraining program (for subjects related to AMWCD) is as follows. A shorter period of time is allotted to Heat Transfer, Fluid Flow and Thermodynamics as well as transient responses and AMWCD. An approximate time breakdown is as follows:
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Heat Transfer, Fluid Flow and Thermodynamics 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> - Transients and DBA 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> - Emergency Plan Training 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> - AMWCD i
In addition, CP&L presently sends all licensed operators to the simulator for 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of training of which approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> is s~ lotted to AMWCD and its meth is of prevention. Of the total 120 classroom hours allotted to annual retraining (TI-200), 53% of these hours (those listed above) address Heat Transfer, Thermodynamics, Fluid Flow, ECCS, Emergency.
Plan Training, Transients and AMWCD.
c)
In reference toithe RO candidates' simulator time (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />), most of this time is spent in preparation for simulator certification ~from both the vendor and the NRC examiners. However, during this period of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> classroom, and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> simulator) a review of Heat Transfer, Fluid Flow, Thermodynamics, AMWCD, Transients and plant responses takes place.
d)
The SRO candidates receive 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> of simulator time prior to NRC simulator examinations. During this period, they are under constant training to evaluate plant responses during Transients, Accidents and other " abnormal" conditions including AMWCD.
'The core mitigation is a continuous topic during the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of ECCS instruction. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allotted to AMWCD is a " summary class" to allow the 4
student to incorporate the previous training concerning ECCS, Transients and DBA instruction with AMWCD.
NRC Question 4 Do your instructors enroll in appropriate requalification programs to assure they are cognizant of current operating history, problems, and changes to procedures and administrative limitatioas?
CP&L Respoilse All Brunswick licensed operator instructors participate fully in the retraining program (TI-200, page A-4, paragraph 1).
The instructors are taught by an instructor who has received General Electric (GE) training.
NRC Question (unnumbered question from page 3)
For item II.B.4 provide an outline of the training program for mitigating core damage, including the number of training hours involved.
Your outline can include any training program which relates to the training for mitigating core damage. Follow the guidelines given in enclosure 3 of H. R. Denton's letter dated March 28, 1980 and INPO Guidelines for Training to Recognize and Mitigate the Consequences of Core Damage (Document Number STG-01, Rev.
1, January 15, 1981).
NRC requires a minimum of 80 contact hours of training for mitigating core damage.
CP&L Response Following is an OUTLINE and a PRESENTATION for our " Mitigating Core Damage" training. This information shows 25 training hours while Item (a) under Previous Training in the response to NRC Question 3, shows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for AMWCD. This small discrepancy is because minor portions of the Mitigating Core Damage training were already a part of existing training and therefore, there is a slight overlap of some subjects (for example:
introductory information on instrumentation).
The training described below is not conducted as an independent module or modules. Rather, it is incorporated into all of the Current Training described in the response to NRC Question 3 l
1
MITIGATING CORE DAMAGE OUTLINE Response to Item II.B.4 I.
Introduction A.
Denton Letter (March 28, 1980) 1.
Brief Discussion B.
Three Mile Island 1.
Review Sequence of-Events - up to page 326 C.
ECCS 1.
Review Logic 2.
Capacity 3.
Break Size 4.
Decay Heat II.
Mitigating Core Damage A.
Sources of Water B.
Pump Curves 1.
Curves Developed by Vendor - Not. Valid Under All Conditions 2.
Human Engineering Factors C.
RTD's 1.
Theory 2.
Use 3
Extended Range D.
Thermocouples 1.
Theory 2.
Use 3
Extended Range E.
Pressure Instruments 1.
Theory 2.
Use F.
Level Instruments 1.
Type 2.
Range 3
Compensated Reference Leg 4.
" Cold Reference Leg"
- 5.. Effect of High Drywell Temperature on Level-Instruments G.
SRM Detectors 1.
Use of Detectors to Determine Water Level H.
S/RV Tailpipe Temperature 1.
Use to Determine Water Level 2.
Reliability I.
Blowdown Period 1.
Shrink and Swell J.
Refill Period 1.
Discussion l
K.
Natural Circulation 1.
Operator Control 2.
Normal and Internal Natural Circulation
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Hydrogen / Gas Generation
- 1. - Material in FSAR 2.
Data from Owners' Group 3
New Material from GE M.
Post Accident Sampling 1.
Review Sources of Radioactivity in a BWR 2.
Present Sampling Capability 3
New Sample Sink 4.
RC&T Sample Procedure l
N.
Radiation
- 1.. Review of Possible Radiation Sources 2.
Exposure Areas 3
FSAR Material 4.
Radiation Instrumentation O.
Degraded Core Corrosion Effects 1.
Chemistry 2.
Discuss Material from GE i
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MITIGATING CORE DAMAGE PRESENTATION I.
Introduction A.
Denton Letter (March 28, 1980) - 30 minutes 1.
Brief discussion of letter 2.
Use Enclosure 3 as reference to discuss topics addressed.
a.
Students receive a copy of Enclosure 3.
B.
Three Mile Island - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1.
Review student handout (Reference of Events up to Page 326 of NRC Report Volume I).
Relate Denton letter to sequence of events. Generate class discussion.
2.
Using B&W Plant Preliminary System's Manual, relate the NRC TMI sequence of events to B&W systems. Point out similarities between BWR and PWR systems.
3 Stress operator action toward alarms and temperature indications (that appeared to have been ignored). Stress trends.
a.
Superheat not recognized by operator. Review superheat and discuss recognition in BWR vessel.
4.
Discuss why nuclear instruments (SRMs) increased and decreased at various times during the accident.
5.
Discuss use of expanded readings using RTDs C.
ECCS - 1 1/2 hours 1.
Review Logic a.
Student handout - Review logic of ECCS from normal plant conditions to a LOCA condition with and without off-site power (diesels available). Also review logic with high drywell pressure.
2.
Capacity a.
Review capacity of water storage tanks (reference BSEP tank curves; these show tank level vs. gallons).
3 Break Size a.
Review pipe break size in relation to ECCS capacity (reference FSAR Volume II and Technical Specifications for Unit I and II).
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Decay Heat a.
Review amount of heat generated as decay heat (and length of time it will be generated).
II.
Mitigating Core Damage (Student handout - reference various owners' group letters)
A.
Sources of Water (partly from handout) - 45 minutes 1.
Capacity of storage tanks. Which tanks are preferred for water injection into vessel.
2.
Capacity of torus 3
Alternate sources of water 4.
Sea water (river) injection B.
Pump Curves (in handout) - 45 minutes 1.
Review pump curves for HPCI, RCIC, LPCI Mode of RHR, Core Spray, Condensate and Condensate Rooster pumps.
2.
Review data presented on curves and how curves are developed.
3 Note to students that curves are not for the pump installed in system but are developed in vendor's test facility.
4.
Discuss operator response to these curves. Discuss possibility of reading error due to lack of familiarity.
C.
RTD's (in handout) - 45 minutes 1.
Theory of operation (Reference Nuclear Power Instrumentation Systems Handbook and GEK Volume X) 2.
RTD use and advantages of use.
3 Extending the range of RTD's.
D.
Thermocouples (in handout) - 45 minutes 1.
Theory of thermocouple operation 2.
Thermocouple use and advantages of use.
3 Extending thermocouple range (basic concepts).
E.
Pressure Instruments (in handout) - 30 minutes 1.
Theory of operation (Volume X GEK).
2.
Temperature / Pressure relationship in a saturated system.
F.
Level Instruments (in handout - additional handout given on all level instruments).- 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 1.
Types of level instruments that operator has available in control room, and types that will initiate ECCS.
2.
Range of each instrument. Also,_where variable and reference leg vessel taps are located.
3 Compensated Reference Leg - Discuss which level instruments have this design, the temperature of the legs under normal conditions.
4.
Cold Leg Instruments - The level instruments having this design, and temperature under normal conditions.
5.
Effect of High Drywell Temperature on all Level Instruments a.
advantage of " cold leg" b.
possibility of level error c.
work problem showing water level response for a reference 0
leg temperature rise from 135 F to 300 F.
G.
SRM Detectors - 30 minutes 1.
Possible use of SRM for determining water level (reference Owners' Group letter).
2.
Reliability of indication.
H.
S/RV Tailpipe Temperature - 30 minutes 1.
Review type of thermocouple used.
2.
Use of Tailpipe Temperature to indicate reactor vessel full of water (reference Owners' Group letter).
I.
Blowdown Period - 30 minutes 1.
Discuss shrink and swell of water during this phase (reference to Volume II FSAR).
J.
Refill Period - 30 minutes 1.
Discuss core cooling (steam cooling) during refill period -
(reference Volume II FSAR).
K.
Natural Circulation - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1.
Inherent characteristics of a BWR (reference NED0-24708).
2.
Natural circulation as it relates to water level - Normal and Internal.
L.
Hydrogen / Gas Generation - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1.
Present material in FSAR (Volume II).
2.
Present data generated by Owners' Group letter 3
Present data from GE (information was not available until June, 1981).
M.
Post Accident Sampling - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1.
Review sources of radioactivity in a BWR (reference NED0-24810).
2.
Present sampling capability a.
RC&T procedure 1500 3
Review new sample sink a.
Reference - TMI group and NEDO-24889 4.
RC&T Sample Procedure a.
How exposure to RC&T is minimized N.
Radiation - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1.
Sources of radiation in the event of an accident 2.
Amount of exposure in key areas (Reference NFDO-24810) 3 Discuss applicable portions of FSAR Volume II 4.
Radiation instrumentation planned for BSEP (post-TMI).
O.
Degraded Core Corrosion Effects - 30 minutes 1.
Review LSEP chemistry handout.
2.
Review available information from GE.
SUMMARY
The BSEP training program complies with or exceeds the criteria as set forth in 10CFR55 and NUREG-0737 (Item Nos. I.A.2.1 and II.B.4).
As previously discussed in the transmittal letter to this enclosure, 80 contact hours is not a minimum requirement of training for mitigating core damage. But rather, the total training curriculum should be acceptable if at least 80 contact hours are provided that relate to mitigation of core damage.
NRC Inspection Report Nos. 50-324/82-05 and 50-325/82-05 (January 15 - February 15, 1982) states, "The inspector verified that the licensee had modified the reactor operator (and SRO) training programs to include training in heat transfer, thermodynamics, accident mitigation and the use of plant systems if core damage occurs, and has increased the emphasis on transients.
Certain individual operator training records were reviewed to verify completion of the above training; no discrepancies were identified.
This item and item II.B.4, Training for Mitigating Core Damage, are closed."
t General Manager -
Brunswick Plant Manager -
Plant Operations
""""E*# - ""
Manager - Maintenance Manager - Operations Shift Operating Supervisor SRO Shift Foreman SRO Shift Foreman SRO Senior Control Senior Control Operator SRO Operator SRO 1
.i Control Operator R0 Control Operator R0 Figure 1
-