ML20071L380

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

ML20071L380
Person / Time
Site:	Peach Bottom
Issue date:	08/26/1982
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20071L383	List: ML20071L380
References
CON-NRC-03-82-096, CON-NRC-3-82-96, RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM SAI-186-029-48, SAI-186-29-48, NUDOCS 8208310332
Download: ML20071L380 (14)

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SAI-lS6-029-48 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 hach Bottom Atomic Power Station, Units 2 and 3 (Dockets 50-277 and 50 278)

August 26, 1982 Prepared By:

Science Applications, Inc.

1710 Goodridge Drive McLean, Virginia 22102 Prepared for:

U.S. Nuclear Regulatory Commission Washington,.D.C. 20555 Contract NRC-03-82-096 XA Copy Has Been Sent to PDR M

i Science Applications,Inc.

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TABLE OF CONTENTS Section

't Page s

I.

INTR 00UCTI3N.....................

1 II.

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

1 A.

I.A.2.1:

Immediate Upgrading of R0 and SR0 Training and Qualifications 1

.B.

II.B.4:.

Training for Mitigating Core Damage..

7 III.

LICENSEE SUBNITTALS.................

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..

10 V.

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

11 VI.

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

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e e

1 1

I.

INTRODUCTION Science Applications, Inc. (SAI), as technical assistance contrac-tor to the U.S. Nuclear Regulatory Commission, has evaluated the response by Philadelphia Electric Company for the Peach Bottom Atomic Power Station (Dockets 50-277 and 50-278) 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 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:

I.A.2.1 II.B.4 Unit 2 44185 44535 Unit 3 44186 44536 As delineated 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.lt Imediate Upgrading of R0 and SR0 Training and Qualifications 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 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-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.

• 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 pensentation 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.

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Figure 1.

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

Program Element NRC Requirements". Item A.2.c(1)

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

OPERATIONS. Item A.2.c(2) pet $0kNEL Training programs shall be modified. as necessary to provide training in the use of installed plant systems to control or mitigate an accident in which the TRAINING core is severely damaged. (Enclosure 3 provides guidelines for the minimum content of such training.). Itse A.2.c.(3)

Training programs shall be modified. as necessary to provide increased emchasis on reactor and plant transients.. Item A.2.e INSTRUCT 04 Instructors shall be enrolled in sosropriate requalification programs to assure they are cognizant of current ocerating history, problems, and changes to pro-agg,g gg.uTION cedures and acministrative limitations.. Item C.1 Content of the licensed operator requalification programs shall be modified to in'clude instruction in heat transfer, fluid flow. thermodynamics, and mitiga-tion of accidents involving a degraded core. (Enclosures 2 and 3 provide guide-Itnes for the sinimum content of such training.). Item C.2 PERS M The criteria for requiring a licensed individual to partici:ste in accelerated RE M IF1 3T!0N requalification shall be modified to be centistent with the a.ew passing grade for issuance of a license: 80% overall and 70% each category.. !.em C.3 Programs should be modified to require the control manipulations listed in.

Normal control manipulations, suci as plant or reactor startsos, must be performed. Control manipulations during annormal or emergency opera-tions must be welked through with, and evaluated by, a member of the trainirg staff at a minimum. An appropriate simulator may be used to satisfy the requirements for control mentpulations.

'The requirements shewn are a subset of those contained in Iten !.A.2.1.

" References to Enclosures are to Denton's letter af March 28, 1980 unich is contained in the clarift.

cation of item 1. A.2.1 in NUREG-0737.

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Figure 2. from Denton's Letter l

TRA!ninr, In MEAT TRAmSFER, Ft UID FLOW Amo THERH00mAMIC$

1.

Basic Proserties of Fluids and Matter.

This section should cover a basic introduction to matter and its properties. This section should include such concepts as temperaturu measvrements and effects, density and its effects, specific weignt, buayancy, viscosity and other properties of fluids. A working knowledge of steam taales should also be included. Ene?gy movement should be discussed including such fundamentals as heat exchange, specif te heat, latent heat of vasoritation and sensible heat.

2.

Fluid Statics.

This section should cover the pressure, temperature and volume effects on fluids. Czample of these parametric changes snould 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 changes in the various components and systems should be discussed as app 1tcable to the factitty sith particular emphasis on safety significant features. The characteristics of force and pressure, pressure in liquids at rest, principles of hydraulics, saturation pressure and tagerature and subcooling should also be included.

3.

Fluid Dynamics.

This section should cover the flow of fluids and such concepts as Beencullt'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, kinetic energy. head. loss relasjonships and two phase flee fundamentalt. Practical applications relating to the reacter cociant system and steam generators should also be included.

4.

Heat Transfer by Conduction. Convection and endiation.

This section should cover the fundamentals of heat transfer by conductions. This section should include discussions on such concepts and terms as spectf tc heat, heat flus 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 transfer 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 espanding fluids in a confined area snould be included in this section. heat transport and fluid flow reductions or stoppage should be discussed due to steam and/or nonce-1 ens 101e gas formation during normal and accident conditions.

This section should cover the fundamentals of heat transfer by thermal radiation in the form of radiant energy. The electromagnetic energy enttted by a body as a result of its temperature shoJ14 he discussed and illustrated by the use of equations and sample calculations. Comparisons should be made o# a black body absorber and a white body emitter.

5.

Chanw of Phase - Bottina.

This section should include descriptions of the state of matter, their innerent characteristics and thermodynamic properties such as enthalpy and entropy. *alculations should be performed involving steam ouality and void fraction properties. The types of boiling shou'd 69 discussed as applicatie to the f acility during normal evolutions and accidert conditions.

6.

Burnout and Flo Instability.

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

T.

$Ctor Meat Transfer timits.

This section should include a discussion of heat transfer limits by examining fuel rod and reactor design and limitations. The basis for the limits should be covered in this section along with recommended methods to ensure that limits are not approached or exceeded. This section should cover discussions of peaking f actors, radial and asial power distributions and changes of these f actors due to the influence of other verisoles such as moderator temperature, menon and control red position.

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W Figure 3. from Denton's Letter TRAINING CRITERIA FOR MITIGATING CORE DAMAGZ A.

Incore Instrumentation 1.

Use of fised or novable intore detectors to deteemire extent of core damage and geometry enanges.

2.

Use of thermocouples in determining peak temperatures; metnods for entended range readings; methods for direct readings at terminal junctions.

3.

Methods for talltag us (priating) incere data from the plant computer.

B.

Encore Nuclear Instrumentation (4!$1 1.

Use of NIS for determination of void formation; void location basis for NIS response as a function of core temperatures and density enanges.

C.

Vital Instewmentation 1.

Instrumentation response in an accident environment; f ailure sequence (time to failure, metnod of f ailure); indication re11ao111ty (actual vs indicated level).

2.

Alternative metneds for measuring flows pressures. levels, and temperatares.

a.

Determination of pressuriter level if all level transmitters fall.

D.

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

c.

Determination of other Reactor Coolant System parameters if the primary metnod of measurement has f ailed.

D.

Petmacy Chemistry a

1.

Espected chemistry results with severe core damage; consequences of transferring small cuantities of liquid outside containment; importance of using lees t1gnt systems.

2.

Espected isotopic breakdown for core damage; for clad damage.

3.

Corrosion effects of entended innersion in primary water; time to failure.

E.

aadiation Monitoring 1.

Response of Process and Area Monitors to severe damages; benavior of detectors when saturatec; method for detecting radiation readings by direct measurement at detector output (overranged detector); espected accuracy of detectors at different locations; use of detetters to determine entent of core damage.

2.

Methcds 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 (Ie, Ke); techniques for venting or disposal di non-condensibles.

I 2 flammaallity and explosive limit; sources of D2 in containment or Reactor Coolant System.

2.

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Figure 4.

Control Manipulations Listed in Enclosure 4.

l CONTROL MANIPULAT!0M5 1

• 1.

Plant or reactor startups to incluae a range that reactivity feestack from nuclear heet addition is noticeaole and heatus rate is established.

2.

Plant shutdown.

• 3.

Manual control of steam generators and/or feed ater during startup and shutdo=n.

4.

Soratiun and or dilution during power operation.

• 5.

Any significant (greater then 105) power changes in manual rod control or rectrediation flow.

6.

Any reactor power change of 13 or greater where lead change is performed utta load limit Control or where flua, temperature, or speed centrol is on manual (for NTsA).

• 7.

Loss of coolant including:

1.

significant PWR steam generator teams 2.

inside and outside primary contatreent 3.

large and small including lesa. rate determination 4

saturated Reactor Coolant resporse (PuR).

8.

Loss of instr went air (if simulated plant specific).

g.

Loss of electrical power (and/or degraded power s wrces).

• 13.

Loss of core coolant flor./ natural circulation.

11.

Loss of condenser vacuum.

12.

Loss of service water if requi-*d f or safety.

13.

Loss of shutdown cooling.

14 Loss of component cooling system or cooling to an individual cosconent.

15.

Loss of normal feed ater or normal feed ater system f atture.

• 16.

Loss of all feed =ater (normal and emergency).

17.

Loss of crotective system.hrinel.

18.

Mispcsitioned control rod or re,es (or rod drops).

19.

Inan111ty to detve control rods.

20.

Conditions requiring use of emergency boration or standoy Itsuid control system.

21.

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

22.

Turtine or generator trip.

23.

Malfunction of automatic cortrol system (s) mien affect reactivity.

24.

Malfunction of reactor coolant pewisure/volme control system.

2$.

Reactor trip.

26.

Main steam line arena (inside or outsioe contatraent).

27 Nuclear instroentation f at ture(s).

• Starred items to be performed annually. all others biennially.

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

Operator Licensing Branch in NRC has taken the position (Reference 3) that j

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-i

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fication programs.

The NRC considers thermodynamics, fluid flow and heat transfer to be related subjects, so the 80-hour requirenent applies to the 4

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 j

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-l 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 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 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 i

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 satisfies the requirements for control manipulations, Enclo-sure 1, Item C.3.

The latter requirement calls for all the manipulations 4

listed in Enclosure 4 (Figure 4 in this report) to be performed, at the j

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 d

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 while 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.

• 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 i

considered contact periods. This definition is taken from Reference 4.

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-II.S.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 Ifcensed operators" receive training on the use of installed systems to control er mitigate accidents in which ~the core is severely damaged. of Dentot.'s letter provides guidance on the content of this tra in_ing. " Plant Manager" is here taken to mean the highest ranking manager at-the plant site.'

j For licensed person'nsl, 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-okrating personnel, notably managers and technicians in instrumentation and cofftrol, health physics and chemistry departments, are supposed to receive those portions of the training which are commensurate with their responsibilities.

Since this imposes no 'idditional demands on the program itself, we do not address it 'n this eval stion. It would be t

appropriate for resident inspectors to ver ry that non v,'erating 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 modificatior.: that might have been made for other reasons subsequent to the response to Denton's letter.

l III. LICENSEE SUBMITTALS The licensee (Philadelphia Electric 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 Peach Bottom plant, there are two submittals with attachments, for a total of five items, which are listed below.

1.

Letter from S.L. Daltroff, Vice President, Electric Production, Philadelphia Electric Co.,

to P.F.

Collins, Chief of Operator Licen,ing Branch, NRC.

j April 30,1981. (1 pg, with enclosures: items 2 &

f 3).

(re:

Transmittal, revised Peach Bottom Training Program).

2.

" Licensed NRC Operator Requalification Program",

Philadelphia Electric Co., Peach Bottom Atomic 7

c Power Station, PA.

Undated.

(5 pp, attached to item 1).

3.

" Replacement Training for Licensd Operators &

Licensed Senior Operators", Philadelpnia Electric Co., Peach Bottom Atomic Power Station, PA.

Undated.

(10 pp, attached to item 1).

4.

Letter from S.L. Daltroff, Vice President, Electric Production, Philadelphia Electric Co.,

to J.F.

Stolz, Chief of Operating Reactors Branch #4, Division of Licensing, NRC.

June 08, 1982.

(5 pp).

(re: Response to NRC's RAI dated May 12, 1982).

5.

Peach Bottom Atomic Power Station organization chart as of February 10,1982, with personnel receiving training in mitigation of core damage worked. (lp, attached to item 4)

The last two items are also in response to an NRC request for additional information (Reference 6).

The information contain is taken to be a firm commitment by the licensee with regard to his training programs.

IV. EVALUATION SAI's evaluation of the training programs at Philadelphia Electric Company's Peach Bottom Atomic Power Station, Units 2 and 3 is presented below.

Section A addresses TMI Action Item I.A.2.1 and presents the assess-ment 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., 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.

The licensee's training programs are comprised of eleven phases.

Phase II is an academic review of 3 weeks duration, one week of which is devoted to heat transfer.

The outline for this training indicates that it covers nearly all the fundamental areas identified in Enclosure 2 of Denton's letter.

Phase V is oriented toward applications and includes one week on BWR operating characteristics and one week on heat transfer and thermal hydraulics in BWRs.

Other phases involve additional time in self-study, review and examination.

In addition, in submittal item 4, the licensee further affirmed that the training covered all of Enclosure 2 and involved at least 80 contact hours.

The licensee :learly meets this requirement 8

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.. Item A.2.c(2)

The -equirements are that the training prograus for reactor and senior reactT operator candidates cover the subject of accident mitigation at the level of detail specified in Enclosure 3 of Denton's letter (see Figure 3 of this report).

The li ensee's t%ining program (submittal item 3 ) includes 3 weeks in Phase VIII, " Mitigating Core Damage and Selected Review". Although

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the division of time between mitigating core damage and the selected review is not indicated, the outline presented is in enough detail to suggest coverage of Enclosure 3.

Moreover, in submittal item 4, the licensee l

indicates that 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> are devoted to mitigating core damage and makes a commitment to cover all the details of Enclosure 3.

As noted above, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> are devoted tc i.ta related subjects of heat transfer, fluid flow and thermodynamics.

In our jcdgement, the licensee complies with this requirement.. Item A.2.c(3) i The requirement is that there be an increased emphasis in the training program on dealing with reactor transients.

The licensee's submittals do not explicitly refer to an increase in emphasis. However, Phase IV provides 2 weeks of simulator training, I week of which is in classroom lectures, related to transients.

Two additional weeks of classroom lectures are devottf to transients.

Much material related to transients is distributed throughout all the phases.

The licensee also notes that additional lecture and simulator time is 1

devoted to transients in the requalification program. We judge that the licensee has complied with the intent of the NRC requirement in this area.. 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.

Training at Peach Bottom is provided by a contractor.

The instructors provided by the contractor are on the distribution for "new or revised procedures, plant modifications, plant experiences, plant upsets i

which are pertinent to operator training". In addition, plant operations personnel review lesson plans for requalification lectures to assure they are current.

While this is not a requalification program, it adtfresses NRC's intent and should be adequate if diligently carried out. We judge that the basic requirement is met, but suggest that an improvement could be made by adding some type of quality control feature that would verify that instructors are in fact cognizant of current situations at the plant.. Item C.1 3

d The primary requirement is that the requalification programs have instruction in the areas of heat transfer, fluid flow, thermodynamics and 9

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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.

The licensee's requalification program is conducted on a two year cycle and is reformulated annually on the basis of examination results so as to emphasize the areas needing it most. A minimum of 9 lectures are given annually and a minimum of 18 lectures are given each cycle. The lecture topics are Pau from a list of 12 major topical areas, one of which includes heat transfer, fluid flow, thermodynamics and mitigation of acci-dents involving a degraded core. Although n; nrther detail is provided, submittal item 4 includes a commitment to cove;.he subject matter set forth in Denton's Enclosure 2 and 3.

However, submittal item 4 also indicates that, in a two year cycle, only 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> are devoted to heat transfer, fluia flow and thermody..amics and 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> are devoted to mitigating core damage.

This falls somewhat short of the required 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in the combined areas., Item C.2 The requirement for licansed operators to participate in the accelerated requalification program must be based on passing scores of 80%

overall, 70% in each category.

The licensee has implemented this requirscent.

In addition, operators needing accelerated requalification are given an cral examination to detmine whether thay thould be removed from shift duties Vnle participating in the accelerated requalification.

Written re-evaluations are made following the retraining until satisf actory performance is demonstrated. The requirement is. satisfied., 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 performance frequency are identified in Enclosure 4 of the Denton letter (see Figure 4 of this report).

Submittal items 2 and 4 together explicitly identify all the manipulations of Denton's Enclosure 4 and indicate that they are performed with the requirad fr mucy. Therefore, this requirement is satisfied.

B.

II.B.4 Training for Mitigating Core Damage Item II.B.4 requires that training for mitigating core damage, as indicated 11 Enclosure 3 of Denton's letter, be given to shift technical advisors and operating personnel from the plant manager to the licensed operators. This includes both liceP ed and non-licensed personnel.

The license" does not describe training directed specifically at the II.B.4 requirement, but the operator requalification program called by I.A.2.1 would serve this purpose since it encompasses requirements essentially identical t o I I.B.4..

As noted earlier, the Peach Bottom requalification program meets thg requirements with respect to content but 10 l

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falls somewhat short (about 20%) with respect to the number of contact hours i

required. It must therefore be concluded that the licensee's compliance with II.B.4 is also deficient in this respect for operations personnel who are licensed operators.

The licensee has provided an organization chart with the positions involved in training for mitigation of core damage indicated (submittal item 5).

These include all positions in the operations chain down to the licensed operators with the exception of the Station Superintendent. Speci-f kally, it includes the Assistant Superintendent, Engineer-0perations, Shif t Superintendent, Shif t Supervisor, Control Operator, and Assistant Control Operator; it also includes Shif t Technical Advisors and numerous other positions not in the operations chain.

The licensee does not indicate whether the higher level managers are licensed operators; if they are not, they are not subject to the 80 contact hour requirement.

Hence, II.B.4 would have been satisfied for non-licensed operations personnel who have had traitting in mitigation of core damage.

The requirement includes the plant manager, in this case the Station Superintendent, among those who must receive training in mitigating core damage. The licensee has not met this aspect of the requirement.

V.

CONCLUSIONS Based on the evaluation described above, SAI concludes that the Peach Bottom training programs are in compliance with most of the requirements of NUREG-0737 items I.A.2.1 and II.B.4.

There are basically two exceptions.

First, the I.A.2.1 requirement relating to requalification instruction in mitigation of core damage and related subjects is not fully satisfied because the contact hours of instruction f all about 20% short of the required 80. This same deficiency applies also to II.B.4 because the requalificiation program apparently provides the mechanism for -this instruc-tion.

Second, II.B.4 is also not satisfied in that the Station Superinten-dent has not received training in mitigating core damage.

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VI. REFERENCES h

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 evalua~ ion.

See t

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

Subject:

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

i 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, John F. Stolz, Chief, Operating Reactors Branch #4, Division of Licensing, USNRC to Edward G. Baner, Jr., Vice President and General Counsel, Philadelphia Electric Co.,

Subject:

Upgraded SRO and R0 Training and Training for Mitigating Core Damage - Request for Additional Information, May 12, 1982.

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