ML20069D076

Improvements in Training & Requalification Programs as Required by TMI Action Items I.A.2.1 & II.B.4, Final Technical Evaluation Rept

ML20069D076
Person / Time
Site:	Cook
Issue date:	08/17/1982
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML17320A390	List: ML20069D076
References
CON-NRC-03-82-096, CON-NRC-3-82-96, TASK-1.A.2.1, TASK-2.B.4, TASK-TM SAI-186-029-09, SAI-186-29-9, NUDOCS 8208260154
Download: ML20069D076 (15)

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SAI-186-029-09 i

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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 Donald C. Cook Nuclear' Power Plant

< Units 1 and 2', -

(Docket 50-315 and 50-316)

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August 17, 1982 Prepared By:

Science Applications, Inc.

l '.1710 Goodridge Drive t

• McLean, Virginia 22102 l

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Prepared for: ,.

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t U.S. Nuclear Regulatory Commission

- Washington, D.C. 20555 Contract NRC-03-82-096 XA Copy Has Beer 1 Sent'to PDR .

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TABLE OF CONTENTS P_aage Section -

I. INTRODUCTION . . . . . ...". . . . . . . . . . . . .' 1 SCOPE AND CONTENT OF THE EVALUATION . . . . . . . . . 1 II.

A. I.A.2.1: Immediate Upgrading of RO and SRO

- Training and Qualifications . . . . . 1 B. II.B.4: Trainin.g for Mitigating Core Damage. . 7 LICENSEE SUBMITTALS . . . , .,. . . . . . . . . . . . 7 III,. -

IV. EVALUATION. . . . . . . . . .'r. . . . - . . . . . . .

9 A. I.A.2.1: Immediate Upgrading of RO and SRO Training and Qualifications . . . . .9 .

B. II .,B.4 : Training foi Mitigating Core Dam. age. . 12 CONCLUSIONS . . . . . . . . . . .,. . . . . . . . . . 12 V.

VI., REFERENCES. . . . . . . . . . . . . . . . . . . . . . 13 I

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. I. INTRODUCTION ,

t Science Applications, Inc. (SAI), as technical assistance contractor to the U.S. Nuclear Regulatory Commission, has evaluated the

- response by Indiana and Michigan Electric Company for the Donald C. Cook Nuclear Power Plant Units 1 and 2 (Dockets 50-315 and 50-316) to certain requirements contained in post-TMI Action Items I.A.2.1, Immediate Upgrading 1 of Reactor Operator and Senior Reactor Operator Training and Qualification, j

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 the -

requirements. The evaluation pertains to the following Technical Assignment Control (TAC) System numbers:

I.A.2.1 11.8.4 Unit i not available 44503 Unit 2 44154 . 44504 As delineated below, the evaluation cove'rs 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 Reactor Operator and Senior Reactor Operator Training and Qualifications The clarification of TMI Action Iterii 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 reactor applicants and licensees, concerning qualifications of reactor operators (hereafter referred to as Denton's letter). This letter an.d enclosures imposes a number of training requirements on power reactor licensees. This e' valuation specifically addressed a subset of the require-

'ments stated in Enclosure 1 of Denton's letter, namely: Item A.2.c,'which relates to opert, tor training requirements; item A.2.e, which concerns instructor requalification; and.Section C, which addresses operator requali-fication. Some of these requirements are elaborated in Enclosures 2, 3, and 4 of Denton's letter. The The training requirements under evaluation are sum- -

marized in Figure 1. elaborations of these requirements in Enclosuies

. 2, 3 and 4 of Denton's letter are shown respectively in Figures 2, 3 and 4.

• Enclosure 1 of NUREG-0737 and NRC's Technical Assistance Control System distingui;h four sub-actions w.i. thin I.A.2.1 and two .sub-actions within II .B .4. Thesa subdivisions are not carried forward to the actual

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presentation of the requir'ements 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. 4.

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

program Element aftC Aseutrements" Enclosure 1. Item A.2.c(1)

Training progrees shall te modified, as necessary, to provide training in heat transfer, fluid flew and thermodynamics. (Enclosure 2 provides guiselines for the minimum content of such training.) .

OPERATIONS taclosure 1. Item A.I.c(2)

- FIRL"O Training e a.ereat 1911 i= mfifkd, es accessery to provide training in the ese of installed plant systems Le contre) er mitigate en accieent in unich the TRAINING core is severely seanged. (Eno3osure 3 provides guidelines for the minimum content of such training.) ,

d Enclosure 1. Item A.I.c.(3) 'r Training progress shell be modified, as necessary to provide increased enehesis en rweser and plant transients.

Enclosure 1. Item A.2.e Ic5TRUCTOR Instructars shall to enrolled in appropriate requalification programs to assure they are cognitent of current e9erating history proelems, and jthenges to pre-RIWALIFICATION cedures and administrative limitations. ,

Enclosure 1. Ites C.1 Centent of the Ilconsed operator requalificatten progrees shall te modified to isiclude instruction in heat transfer. fluid flow. thermodynamics, and mitica-

• tien of accidents involving a degroced core. (tactosures 2 and 3 provide guise-lines for the sintem content of such training.)

gg Enclosure 1. Item C.2 The criteria for reeutring a licensed individual to participate in eccelerated at W FICATION reevalification shall he modified to be consistent with the new passing grade for issvence of 3 license: 80', overal) and 70t each category.

Enc'lesere 1. Item C.3 p.3ereas should be modified to reevire the centret manipulattens lis+rs in ErcIssure d. mornal centrol annipulettens, such as plant er reacter startups.

aust te performed. Centrol mentpulations during ebnersel er emergency toera-tiens mst be welked through with, and evaluated by, a acaber of the training -

staff at a minionsa. en appropriate sienlater any be used to satisfy the requirements for control annipulations. _

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• 'The reesirements themn are a subset of these contained in Item I.A.2.1.

"Aeferences to Enclosures are to Denton's letter of March 28. 1980 unich is contained in the clar'ft- ,

catien of item 1.A.2.1 in auRE6 0737. ,

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. Figure 2. Enclosure 2 from Denton's Letter IRAlatus la NEAT TRANSFtt. FLUID Fuhl AND TugancevaMICS

1. Basic prosecties of Fluids and nettee. ~

This section should cover a basfC f atroduction to matter and its properties. This seCtten shecid include such concepts es temperature measurements and effects, density and its effects. specif tC weignt, bueyency, viscostty and other properties of fluids. A serking kneeledge of steen tables should also be incibded. Energy movement should be discussed tecluding such fundamentals as heet eschenge, specific heet, latent heat of vapertaatten and sensible heat.

2. Fluid Statics. .

. Emaaple of these This section should cover the pressure, teaserature and volume effects on fluies.

parteetric changes should be illustrated by the instructor endand Causes related effectscalculattens of pressure andshould be perfereed temperature by the students and discussed in the training sessions. Causes and thenges in the verteus components and systees should be discussedThein the training ses ,

as applicable to the f act11ty with particular emphasis en safety significant features.

characteristics of force end pressues, pressure in lieules at rest principles of hydraulics, saturatten pressure and temperature and subcooling shoule also be included.

3. Fluid Dynamics.

This section should cover the flow of fluids and such concepts as Bernoulli's principle, energy in

• eoving fluids, fiss =titure thee*y end devices and pressure lesses due to friction and ortfictng. kinetic Other concepts and teres to be discussed in this section are NP5M. Carry ever, carry enderpractical applications relating to ene*gy. head-less relatio nships and too phase flee fundamentsis, the reacter coolant system and steen geneestors should else be facTuded,

4. Meat teaasfer Ir Conduction. Convection and sediction. ,

i This section should Ynis settien should cover the fundamentals of heet transfer by conductions.

include etscussions en such concepts and terms 48 specific heat, heat flua and atomic action. Meat

. transfer characteristics of fuel rods and heat enchangers should be included in this settien.

This section should cover the fundamentals of heet transfer by' convection.The Natural SPd forced convection current circula*

tien should be discussed as esplicable to the verfeus systems at the facility. Meat patterns created by esponding flufds in a confined area should be included in this settien.

transport and fluid f16e reducttens er stepsege s%16 be discussed due to steen

• ehd/or noncensensiste gas formatten during nereal and accident candittens.

This section should cover the fundamentals of heat transfer by thereal radiatten in the fare of radiant energy. The electresagnetic energy eettted by a body as a result of its temperature should be I discussed and illustrated by the use of equations and temple calculattens. Ceeparisons should be. made j

of a black body absorber and a ehtte body esitter.

5. Chaase of phase - Boiline. ,

their inherent characteristics and This section should include descriptfens of the state of matter. Calculations should be eerfereed invetring thermodynaest prope* ties such as enthalpy and entropy.The types of telling should be discussed as applicable to steam egality and void fraction preserties.

th? f acility euring neraal evolutions and accident conditions,

g. Bueneut and Flow Instability. ~

This section should coverletcriptions and mechanisms for calculating such teres as critical flus.

critical pe er. Dus rette end het channel facters. This section should aise include Seaple instructions calculattens for should preventing and menttoring for clad or fuel desage and flow instabilities.

• be illustrated by the instructor and calculations should be perfereed by the students and discussed in the training sesstens. methods and precedures for using the plant computer to determine cuantitative values of verteus facters during plant operation and plant heat balance determinations should else be covered in this section.

7. Reactee Meat Trentfer tietts.

• This section should include a discussten of heat tr,ansfer Itajts by esamining fuel tod and design and iteitations. This section should cover rectemended methods to ensure that lietts are not ap5 reached er esteeded, discussions of peaking facters, radfel and asial pende distributions and changes of these f acters due to the influence of other variables such as moderator temperaters senen and control red posttten.

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Figure 3. Enclosure 3 from Denton's Letter

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TRAINING CRITERIA FOR MIT184 TING CORE 04MsGE A. Incore Instroentation - l

1. Use of fiaed or novable incore detectors to determine entent of core damage and geometry changes.

2. Use of thermocouples in deteretning peak temperatures; methods for eatended range readings; methods for direct readings at terminal junctions.

3. Methods for ca11tng up (printing) intore data free the plant causuter.

B. Escore nuclear lastrwnentation (Nf5) '

1. Use of N15 for detereinstion of void formation; void location basis for NIS response as a function of core temperatares and density changes.

C. Vital Instruneetation

1. Instra-entation response in an accioent en ironseet: fa11ere sequeece (time to failure, metnos of f attuge); indication reltatility (actual vs indicatoo level).

2. Alternative methods for seasuring flows, pressures, levels, and temperatures.

a. Getermination of pressuriser level if all level transmitters f ail.

D. Determination of letdown flew with a clogged filter (Tom'flom).

c. Determination of other Reactor Coolant Systes parameters if the primary metnod of seasurement has failed. .

D. primaev Che-tstry

1. Espected chemistry results eith severe core damage; consequences of transferring small e.antities of lieute outside contairement; taportance of using less t1get systees. L.

2. Espected isotopic treakdown for core damage; for clad desage.

3. Corrosion effects of entendes imersion in primary mater; time to failure.

E. andtition aso nitorine f

1. Response of process and Area Monitors to severe damages; behavior of detectors ehen satuested; setnod for detecting radiation readings by direct seasurement at detector output (overranged detector); espected accuracy of detectors at different locations; ese of detectors to determine entent of core damage. ,

2. Methods of determining dose rate inside containment free seasurements taken outside containment.

F. Gas Generation

1. Methods of Np generation during an accident; other searces of ga,s (Ie, Le); technieues for venting or disposal df non-condensibles.

2. H2 fleemability and esplosite liett; sources of 02 ni containment er Reactor Coolant System.

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Figure 4. Control Manipulations Listed in Enclosure 4. ,

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CDdTRE NhmIptATIGIS ,f

• 1. nont er renner start.s to in.i.de a ren,e t at reani.it, fee en -ieer .eet additim is noticeable and heetup rate is established,

2. . plant shutdown.

• 3. Manuel contre) of steen generators and/or feedseter during starte and samtdemn.

4- geretten and er diletten during peser operation.

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• $. Any significant (greater then 105) peer thenges te eenwel red sentest er recirts1stien fim. ,

6. Any reacter peser thenge of 105 er greater where food thence is seefereed with lead liett tenteel er enere flua, temperature, er speed centrel is en manuel (for NTER).

Less of coolant taglading: 1,

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. 1. sienificant ps steen generator leeks - .

2. inside and outside prisery containment ,

2. is,se ne mu. inaud,,, ies.. rete e.ter.inett n ,

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4. saturated teacter Cootert ressense (pWR). .

8. Less of instrument air (if stavleted plant specific).

3. Less of electrical peser (and/or degraded power sewetes). , . ,

• 13. Less of core coolant flem/netv'el circelotten.

11. Less of tendenser vacusa. I 17 Less of service ester if reasired for safety.

13. Less of snetdeen seeling. .

1.. Less of cenpenent seeling system er seeling to en individual eenpenent. .

16. Less of normal feed =eter er nesual feedseter system fattere.

• 16. Less of $11 feedseter (normal and emergency).

17. Less of protective system channel.

18. Misposittened control red or rods (or red drops).

19. Instility to drtoe contre) reds.

20. Conditions reeutring use'ed emergency beratisa er standey lievid twtrol system.

21. Fuel cleading fe11ere er high activity in reatter Seelant er effges.

22. Turbine er ge eretor trip. .

23, Melfunction of estametic centrol systee(s) ehitt effect reettivity,

24. Malfunction of renter 8e01641 pressere/volsme tantre) systen, i Seatter trip. .

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26. Main steen line treek (inside er outside centeinuent).

27. butlear instrumentatten faf fere(s). t

• Sterred itees te be perfereed annually, all sthers tiennielly.

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As noted in Figure 1, Enclosures 2 and 3 indicate minimum require-ments concerning course content in their respective areas. In addition, the

- Operator Lie:ensing Branch in NRC has taken the position (Reference 3) that the training in mitigating core damage and related subjects should consist of at least 80 contact hours

• in both the initial training and the requali-fication programs. The NRC considers thermodynamics, fluid flow and Seat 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 hiive their own unique course out-lines, adequacy of response to these requiremeats r.acessarily 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 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

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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 .ame requirements and are more than adequate, i.e., training programs based specifically' on the complete INPO doc'uments are expected to satisfy 4

- all .the requirements pertaining to training material which are addressed in this evaluation.

The licensee's response concerning in" creased emphasis on tran-sients is considered by SAI to be acceptable if it makes expli. cit reference to increased emphasis on transients and gives some indication of the nature' c of the increase, or, if it addresses both normal and abnormal transients (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 l 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 twp-year f

cycle.

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

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l l 8. 11.8.4: Training for Mitigating Core Damage Item 11.8.4 in NLREG-0737 requires that " shift technical advisors .

and operating personnel from the plant manager through the operations chain l

to the licensed operators" receive training on the use of installed systems to control or mitigate accidents in which the core is severely damaged.

Enclosure 3 of Denton's letter provides guidance on the' content of this l

training. " Plant Manager" is here taken to sear; 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 op'erator 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 I

These non-licensed personnel are -

highest levels of management at the plant. -

l not explicitly required to have training in heat transfer, fluid flow and /

thermodynamics and are therefore not obligated for the full 30 contact hours l of training in mitigating core damage and related subjects. ,

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

supposed to receive those portions of the training which are commensurate l with their responsibilities. Since this ingposes no additional demands It would be on  ;

the program itself, we.do not address it in this evaluation. '

appropriate for resident inspectors to verify that non-operating personnel receive the proper training. ,

The required implementation dates for all itenis have passed.

.Hence, this evaluation did not address the dates of implementation.

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Moreover, the evaluation does not cover training program modifications that might have been n.cde for other reasons subsequent to the response- to ^

Denton's letter. ,

III. LICENSEE SUBMITTALS The licensee (Indiana and Michigan Electric Co.) has submitted to -

NRC a number of items (letters and various Theseattachments) submittals, made which in respease explain their training 'and requalification For the to Denton s letter, form theprograms. information base for this evaluation.

Donald C. Cook Nuclear Power Plant Units 1 and 2 the and attachments thereto were in response to the NRC request for additional -

information(Reference 6).

1. Letter from D.V. Sha11er, Plant Manager, NuclearIndiana Plant, to &

Michigan P.F. Collins, Electric Co., D.C.

Chief of < CookOperator Licensing

! Jul 25, 1980. (1 pg, with Branch, NRC. tem 2)y(re: Response to NRC letter enclosure: i dated March 28,1980).

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2. " Licensed Operator Requalification Program".

Indiana & Michigan Electric Co., D.C. Cook- Nuclear Plant. July,1980. (11 pp, attached to item 1). ,

3. Letter from R.S. Hunter, Vice President, Indiana &

Michigan Electric Co., Bowling Green Station, to  ;

H.R. Denton, Director of Office of Nuclear l Regulatory Commission, NRC. April 26,1982. (2 .

pp, with enclosure: item 4). NRC Acc No:

- 8205040593. (re: Submittal of a review. copy of ~

the Replacement TrainingProgram). .

" Operator Replacement Training Program" D.C. Cook

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Plant. Approved by D.V. Shaller, Plant Manager, March 27,1980. - (12 pp, attacted to item 3). NRC Acc. No: 8205040789 Letter from R.S. Hunter, Vice President, Indiana &  :

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Michigan Electric Co., to H.R. Denton, Director of, l

' Office of Nuclear Reactor Regulation, NRC. June

- 09, 1982. (1 pg, with enclosures: items i 6,7,8,9,10,11). (re: Response to NRC's ~ RAI dated Maf 03,1982). ,' , *

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6. Attachment 1, "Licensi'ng Action Request for Additional Information". - Undated (3 pp, attached '

to item 5). AEP:NRC:0694. (re: Response to l

' individual questions addressed in the NRC's RAI).

7. . Attacnment No. 2. Untitled. March 9,1982. (1 pg, l attached to item 5). AEP:NRC:0694. (re:

Organizational Chart). i

8. " Core Damage Mitigation ~ Course Outline".

Attachment 3. Undated. -(1 pg, attached to item 5.') (re: Table of Contents). <

"Non-Licensed Operator Training", Attachment 4.

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Approved by the Plant Manager August 07, 1981.

(49 pp, attiiched to item 5).

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10. " Operator Replacement Training", Attachment 5.

Approved by the Plant Manager on March' 27, 1980. .

(20 pp, attached to item 5).

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11. " Licensed Operator Requalification Program",

Attachment 6. July,1980. (62pp, attached to item 5). I

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IV. EVALUATION  !

SAI's evaluation of the training programs at Indiana and Michigan Electric Company's Donald C. Cook Nuclear Power Plant is presented below.

Section A addresses TMI Action' Item I.A.2.1 and presents the assessment organized in the manner of Figura 1. Section B addresses TMI Action Item II.8.4.

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

- Reactor Operator Trainir.g and Qualificatien. .

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

The basic requirements are that the training programs given to . .-

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.

' In Submittal item 6, in response to the NRC request for additional information (Reference 6), the licensee. indicates their initial training program for Reactor Operators and Senior Reactor Operators covers the subjects of heat' transfer, fluid flow andith'ermodynamics. The licensee sut:sequently states: "We do not meet the level of coverage spelled out in the enclosure ~of the Denton letter. Our review, with Dr. Jim Hayes of Purdue University, determined that some of the references were obsolete as well as being used for doctorate level courses.' We do not feel this level' of knowledge is required of Reactor Operators or Senior Reactor Operators."

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This statement indicates the requirements of this Enclosure 1 item

,z are not being satisfied. .

Enclosure 1. Item A.2.cf2) \

l The requirements are that the training programs for reactor and l

-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).

Submittal items.9 and 10 which are course outlines for Non-Licensed Operator Training and Operator Replacement Training, respectively,

- . do no.t show much related to accident mitigation. Accom1anying explanatory text, however, indicates that plant operating characteristics and response to transients will be taught and that accident diagnosis and corrective-actions will be emphasized. Submittal Item 8. " Core Damage Mitigation .

Course Outline," while very shy on detail, appears to substantially address the topical areas of Enclosure 3 to Denton's letter. Submittal item 6, in response to the NRC request for additional information (Reference 6), states that the training regarding the subject of using installed plant systems to control an accident in which the core is severely damagcd is covered to the level of detail spelled out in Enclosure 3 to Denton's letter. Submittal item 6 states: "No, we do not specify We 80 contact hours; however, generally

) train to meet learning objectives more than 80 contact not to minimum hour requirements." hours are given. It would appear, therefore, that the requirements of this Enclosure 1 item are met.

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

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

Submittal Item 6 states, "We have always emphasized reactor and plant transients. We do not It feel that increased emphasis on reactor and is and has been our polic t plant transients is required.

train in the areas of both normal and abnormal (accident)y transients prior and pract to' Mr. Denton's March 28, 1980 l etter." Submittal Items 9 and 10 confirm this policy statement. The requireinent of this Enclosure 1. item is fulfilled. .

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 are cognizant of current operating history, problems and changes (to procedures and administrative limitatSons. '

Submittal Item 6 states that Jicense training instructors attend the same requalification training program _as do any other licensed opera-tors. A review Of Submittal Item 2, " Licensed Operator Requalification

• Program," indicates the requirvent of this Enclosure 1 item is satisfied.

. Enclosure 1. Item C.1 ,

The primary requirement is that the requalificatio'n programs have fluid flow, thermodynamics and instruction in the areas accident mitigation. The of heat leveltransfer,l of detai mquired in the requalification In addition, program is that of Enclosures 2 and 3 of Denton's letter.

these instructions must involve an adequate number of contact hours.

Submittal Item 2 lists the following topics as subjects for formal classroom lectures during one requalification year:

1. Theory and . Principles of Operation (includes Thermodynamics,; Heat TransferandFluidFlow)

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l 2. General and Specific Plant Operating Characteristics .

3. Plant In.trumentation and Control Systems

4. Plant Protection Systems .

5. Engineered Safety Systems

6. Normal, Abnormal and Emergency Oper; ting Procedures

7. Radiation' Control and Safety .

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8. Technic.a1 Specificatioris

9. Applicable portions of Title 10 Chap'ter 1. Code of Federal Regulations 10

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This submittal item also states that the If entire lecturelecture the entire series will consume about 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and not less than 30.

series is composed of 30-40 hours it is clear that the specified (about 80) number of contact hours to be devoted to heat transfer, fluid flow, thermodynamics and accident mitigation cannot be provided.

Submitta'1 Item 6 states the following: " Heat transfer, fluid flow, and thermodynamics are subjects covered in the Licensed Operator Requalification Training Program; however, not necessarily to. the depth outlined in the Denton letter. The actual material that is covered and the details of the lectures are determined from the results of the previous Course outlines / lesson plans -

year's requalification examination results.

are prepared annually." " Item 6 of the lecture series is a given category The subject covering normal, abnormal, and emergency operating procedures.

of Core Damage Mitigation is covered in appropriate portions within various areas or lectures of the Requalification Training program.- The entire Core .

Damage Mitigation Training program is not covered annually,in the training."

It is concluded from the foregoing that (1) the requisite number of contact hours are not provided in the areas of heat transfer, fluid flow, thermodynamics and accident mitigation and (2) the requisite level of detail in the areas cf heat transfer, fluid flow and thermodynamics is not j ,

provided. . ,,

Enclosure 1. Item C.2 -

The requirement for licensed operators to participate in the accelerated requalificat. ion program must be based on passing :scores of 80%

overall, 70% in each category.

Submittal Item 2 makes the following statement: "An overall grade average of less than 80% or any category grade of less than 70% shall require the individual to be placed on an accelerated The scope and training duration program of the prepared to correct the identified weakness. accelerated training program sh each instance it is required. During participation in this accelerated training program, the operator shall not be placed in a position where he is performing licensed duties. Following completion of the accelerated train-ing program, the. operator shall be required to take and pass a second .

written examination in thos'e. areas in which he was deficient." This policy -

satisfies the requirement of Enclosure 1. Item C.2.

Enclosure 1. Item C.3 ,

TMI Action Item I.A.2.1 calls for the licensed operator requalifi- .

cation program to include performance of control manipulations involvin~g both normal and abnormal situations. The specific manipulations required and their letter see p(erformance Figure 4 of this frequency report). , are identified in Enclosure 4 of Submittal Item 11 lists control manipulations, sufficiently

~

similar to those 1.isted in Enclosure 4 of Denton's letter, to be performed annually and biennially in c6nnection with the The Reactor' submittal Operator furtherand saysSenior each Reactor Operator requalification program.

licensed operator will perform a minimum of plant control manipulations to,

6. -

11 '

, . - - . - , , . . - - _ _ _ . _ _ _ _ , . _ _ . . . , _ _ . _ _ _ _ _ . _ _ . , . _ _ - . , _ _ _ _ . - - - . . . _ _ - _ _~

.. _. ~_ ._

ith plant control systems. It has been demonstrate verified via phone conversation his skill / familiarity w(Reference 7) that " minimum" means all listed manipulations. 'It is therefore concluded that the requirements of this Er. closure 1 item have been met.

B. II.B.4 Training for Mitigating Core Damage ,

- Item IIJ.4 requires that training for mitigating core damage, as  !

indicated in Enclosure 3 of Denton's letter, be given to shift technical 2

advisors and operating personnel from the plant manager to the licensed '

operators. This includes both licensed and non-licensed personnel.

A training course on mitigation of core damage was presented to all operations personnel from the plant manager to the licensed operators. 1

- This fulfilled the requirement of II.B.4 for non-11 censed operations ,

personnel.

The Core Damage Mitigation Course Outline, Submittal Item 8, does not address heat transfer, fluid flow or thermodynamics and the requalification program does not provide'th,e requisite number of contact hours (80) to supplement the Core Damage sitigation Course in these topical

- areas as required by II.B.4. Therefore, the requirements of II.B.4 are not met by licensed operations personnel. -

VI. CONCLUSIONS ,

The SAI evaluation of the Indiana and Michigan Electric Power Company's training program at the Cook plant leads to the conclusion that the requirements of TMI Action Items I.A.2.1 and II.B.4 are not fully met for the following reasons:

1. Enclosure 1, Item A.2.c(1): The depth of training required by Enclosure 2 of Denton's letter is not provided.

2. Enclosure Item 1, C.1: It does not appear that the requirements of this Enclosure 1 item are met as the requisite number of con-tact training hours and the depth / detail are not in conformance with Enclosures 2 and 3 of Denton's letter.

3. II .B.4 : The requirements of this item do not appear to be met, for licensed operations personnel, because.the Accident M1tigation Course Outline does not include the related subjects; heat transfer, fluid flow and ther. odynamics, m and the requalification program does not provide the requisite number of contact hours to adequately supplement the Accident Mitigation Course in these topical areas-as required by II.B.4.

12 l

. , , _ _ . - , . _ ~ _ . _ _ , . _ _ _ , . . _ _ , . _ _ . . _ . . . - . _ , _ _ , _ _ . _ _ _ . _ _ _ _ _ _ _ . _ _ , . _ _ . _ , , _ _ _ _ _ _ . _ - _ _ _ _ . _ _ _ _ _ , _ _ . _ , , _ _ _ _ _ . . _ . _ _ _ , _ . . . _

4 7,. .

V. REFERENCES "NRC Action Plan Developed as a Result of the TMI-2May Accident."

1980.

lIUREG-1.

0660, United States Nuclear Regulatory Commission.

2. '" clarification of TMI Action Plan Kequirements," NUREG-0737. United -

States Nuclear Regulatory Commission. November 1980.

3.-

The NRC requirement for 80 Itcontact hours is with was. included an Operator Licensing the acceptance Branch technical position. See-criteria provided by NRC to SAI for use in the present evaluation.

letter, Harley Silver, Technical Assistance Program Man .

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,d STG-01, The Institute of Nuclear Power Operations. -

January 15, 1981.

6. NRC request for additional information sent. the Indiana and Michigan .

Electic Company dated May 3,1982.

7. Phone conversation betwe,en Mr. D. D. Nelson, Director 'of Trhining, Indiana and Michigan Electric Power Company, 19, 1982. Donald.-C. Cook Nuclear ..

Power Plant and R. M. Roland of SAI on July m.

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