ML20071L384
| ML20071L384 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/31/1982 |
| From: | SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY |
| To: | NRC |
| Shared Package | |
| ML20071L387 | List: |
| 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-186-029-28, SAI-186-29-28, TAC-44152, NUDOCS 8209030325 | |
| Download: ML20071L384 (15) | |
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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 Davis-Besse Nuclear Power Station (Docket 50-346)
August 31, 1982 e
Prepared By:
l Science Applications, Inc.
1710 Goodridge Drive McLean, Virginia 22102 Prepared for:
U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Contract NRC-03-82-096
(
XA Gopyh geen Swif fo PDR ll Science Apphcations inc.
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i TABLE OF CONTENTS Section Page I.
INTRODUCTION.....................
1 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......................
8 A.
I.A.2.1:
Immediate Upgrading of RO and SRO Training and Qualifications
.8 B.
II.B.4:
Training,for Mitigating Core Damage..
11 V.
CONCLUSIONS......'...............
11 VI.
REFERENCES......................
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I.
INTRODUCTION Science Applications, Inc. (SAI), as technical assistance contractor to the U.S. Nuclear Regulatory Commission, has eva'luated the response by Toledo Edison Company for the Davis-Besse Nuclear Power Station (Docket 50-346) to certain requirements contained in post-TMI Action Items I.A.2.1, Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualification, and II.B.4, Training for Mitigating Core Damage.
These requirements were set forth in NUREG-0660 (Reference 1) and were subsequently clarified in NUREG-0737 (Reference 2).*
The purpose of the evaluation was to determine whether the licensee's operator training and requalification programs satisfy (TAC) the requirements. The evaluation pertains to Technical Ass'gnment Control System numbers 44152 (NUREG-0737, I.A.2.1.4) and 44502 (NUREG-0737, I I.B.4.1).
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.2.1:
Immediate Upgrading of Reactor Operator and Senior Reactor Operator 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 (hereaf ter 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-narized 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
- Enclosure 1 of NUREG-0737 and NRC's Technical Assistance Control System distinguish four sub-actions within I.A.2.1 and two sub-actions within I I.B.4.
These subdivisions are not carried forward to the actual presentation of the requirements in Enclosure 3 of NUREG-0737.
If they had been, the items of concern here would be contained in I.A.2.1.4 and II.B.4.1.
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Training Requireeents from TMI Action Item I.A.2.1*
Figure 1.
program Element NRC Aseuttgments". Item A.2.c(1)
Training progress shell be socified, as necessary, to provice tretning in heet transfer, flute flow and themedynamics. (Enclosure 2 provtses guiselines for tne minimum content of sucn training.)
OPERATIONS. !te A.2.c(2) ptR50NNEL Tretning programs shall be seeiftee, as necessary to provice training in the use of installes plant systems to control or mitigate an accioent in unica tne 7gggggg core is severely cameges. (Enclosure 3 provices guidelines for the minimum i
l content of sucn treintng.)
fEnclosure1.ItemA.2.c.(3)
Training programs shall be seeified. as necessary to provtse increased amenasis I
on reactor and plant transients.. Item A.2.e INSTRUCTOR Instructors snail be enrollee in sopropriate reevalification programs to assure my am cognuant of cum wating MsW. Mm. aM cMnges 2 &
4E*;;ALIFICATIO4 I coeures one administrative Ilmitations.
t. Item C.1 Content of tne licensee operator'regualification progrees shell be moetfies to include instruction in heat transfer, flute flow, enemosyneates. ano mitiga-tion of acciaents involving e segreses core. (Enclosures 2 ane 3 provtse gutee-Itnes for the minisus content of seen tretning.). Item C.2 PER53NNEL The criteria for requiring a licensee incivieval to participate in accelerates RE M IFICAT O recua11fication shall be moeified to be consistent with the new passing grade for issuance of a license: 80% overall ane 70'. seen category.
.. Item C.3 progeons snould be moeifies to reoutre the control senioulations Itstee in Enclosure a.
normal control sentoulations, sucn as plant or reactor startuos.
must be performes. Control mentpulations during annomel or emergency ooere.
tions must be melkee througn witn, one evaluatea by, a sameer of the training staff at a minisua. An appropriate simulator may be uses to satisfy the reeutrosents for control manipulations.
- The reoutrements snoen are a subset of tnose containes in Itsu I.A.2.1.
"eeferences to Enclosures are to Denton's letter of Meren 28. 1980 unich is containes in the clarifi-cation of Item I.A.2.1 in MuREG-0737.
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Figure 2. from Denton's Letter TRA!n!NG In HEAT TRANSFER. FLUID FLOW an0 THElse00 Team!CS 1.
Basic erosecties of Fluids and sattee.
This section should cover a tesic introduction to matter and its properties. This se'ction should f aciude such concepts as temperature measurements and effects, density and its eff'ects, specific seignt, buoyancy, vtscostty and other properties of fluids. A sorting knowledge of steam teoles should also be tactueed. Energy movement should be discussed including sucn fundamensels as heat enchange, specific heat. latent heat of vaportsation and sens181e heat.
2.
Fluid Statics.
This section should cover the pressure. toestrature and velues effects on flutas. Esasole of these parametric changes should be illustrated by the instructor and related calculations should be performed py the students and discussed in the training sessions. Causes and effects of pressure and toeperature Causes and changes in the various components and systems should De discussed in the training sessions.
effects of pressure and temperature changes in the various conoonents and systees should be discussed as applicaole to the f actitty with particular esonasts on saf ety signtf tcant f eatures. The characteristics uf f orce and pressure, pressu*e in liewias et rest, principles of hyeraulics, saturation pressure and touperature and suecnoling should also se included.
3.
Fluto Ovaemes.
This section should cover the flow of fluids and such concepts as Bernoulli's principle. energy in
. moving flutes, flow eessure theory and devices and pressure losses due to friction and orificing.
Otner concepts and teres to se discussed in this section are NP5N. Carry over Carry under 11netic head. loss relationships and two phase flow fundamentals. practical aselications relating to eneegy.
the reactor coolant system and steen generators should also be included.
l 4
neat Transfer av Conduction. Convection and eadiation.
This section should cover the fundamentals of heat transfer by conductions. This section snould heat include discussions on such concepts and teres as specific heat, heat flua and ateetc action.
transfer characteristics of fuel rods and heat.eachangers should se included in tats section.
this section should cover the fundamentals of tiest transfer by convection. Natural and forced circula.
tion should be discussed as applicaele to the various systems at the facility. The convection current Neat patterns created by espanding flutas in a confined area should be included in this section.
transport and flute flow reductions or stoepage should be discussed due to steam and/or --z
.sible gas formation during normal and accident conditions.
This section should cover the fundamentals of heat transfer by thermal radiation in the fore of rsciant The electromagnetic energy eettted by a body as a result of its toeperature should se energy.
Cooperisons should be nace discussed and illustrated by the use of eeustions and sample calculations.
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of a black body assorter and a unite body emitter.
5.
Chance of phase - toiline.
This section should include descriptions of the state of matter, their inneeent characteristics and thermoi.yneetc properties such as enthalpy.nd entropy. Calculations should se performed f avolvtag steam evality and void fraction properties The types of to11tng should be discussed as applicaole to the f ac111ty during normal evolutions and accident conettfons.
6.
Burnout and Flow Instan111tr.
This section should cover descriptions and mechanises for calculating such teres as critical flua.
critical power. Due ratto and not channel f actors. This section should also include instructions for preventing and eenitoring for clad or fuel damage and flow instasilities. Samole esiculations should se illustrated by tw instructor and calculattens should be performed by the stueents and discussed in the training sesstens. methoes and procedures for ustng the plant computer to determine eventitative values of verteus f actors during plant operetten and plant heat balance determinations should also se covered in this section.
7.
Reactor Neat Transfer Limits.
This section should include a discussten of heat transfer Itatts by esasining fuel rod and reactor design and 1tattations. The basis for the limits should De coveret in this section tiong with reconsensed methods to ensure that iteits are not asproached or exceeded. This section should cover discussions of peettag f actors, radial and asial power distributions and changes of these f actors due to the influence of other vertaoles such as esseestar tesserature, senen and control red position.
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I Figure 3. from Denton's Letter TRAIN!hG CRITERIA FOR mlTIGATIns CWit DAMAGE A.
Incore instrumentation 1.
Use of f tsed or novaole incore estectors to estermine estent of core saeage and geometry changes.
2.
Use of inersecouples in determining peak temperatures; metnoes for estended range resetags; metnods for direct receings at terminal junctions.
j 3.
Metnoes for calltag up (printing) incere data from the plant camouter.
I 8.
Escore euclear fastrumentation (4151 l
1.
Use of 415 for setermination of void formation; vote location basis for NIS response as a function of core temperatures and constty enanges.
vita 1 !n'trumeatation C.
s 1.
Instrumentation response in an accisent environeent; failure sequence (time to f atture metnod of f attore); iM1:stion reliaotlity (actual.vs indicated level).
2.
Alternative setnod, for measuring flows, pressures. Tevels, and toneeratures.
Determination of pressuriter level if all level transmitters f ail.
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D.
Determination of leteoen flom with a clogged filter (Iow flow).
i Determination of otner Reactor Coolant,5ystem parameters if the primary metnos of measurement c.
a has f ailed.
0.
Peteaev C$emistry 1.
Espected chemistry results with severe core damage; consecuences of transferring small euentities of lieutd outside containment; tueertance of using less tignt systems.
2.
Espectes tsotopic prestenen for core asunage; for clas samage.
3.
Corrosion effects of estences isonersion in primary eater; time to fatture.
E.
Radiation monitorino Response of Process and Area monitors to severe damages; benavior of estectors unen saturated; 1.
setnoe for detecting radiation reasings my direct seasurement at setector output (overeenged eetector); esoected accuracy of setectors at sifferent locations; use of ostector, to setermine entent of core eamage.
2.
Metnoas of estermining oose rate insies contatnoont free seasurements taaen outstee contatament.
F.
Gas Generation t generation auring an accident; other sources of gas (Ie. se); tecnnieues for venting 1.
metnods of M l
l or disposal or non-consensibles.
1 in containment or Reactor Coelant System.
flammaetlity and emplosive liett; sources of 02 2.
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Figure 4.
Control Manipulations Listed in Enclosure 4.
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CQWTROL lenm!PULATIoms Plant er reactor startups to include a range that reactivity feceDeck free nucleer heat aseitton
- 1.
is noticeable and heetuo rete is estaaltsnes.
2.
Plant sautseen.
- 3.
manual control of steam generators and/or fenesater sharing starte and snutsomn.
4 Soretion ene or 611stien auring pomer agoretion.
Any significant (greater then 105) poner changes in menwel coe control er rectreslation flow.
Any reactor seeer cnange of 105 or greater where leas enange is performed witn loas limit control 6.
or enere flus, temperature. er speed control is en manual (for WTER).
'7 Loss of coolant including:
1.
significant Piet steen generator leses 2.
instae and outstee primary contatment 3.
large and small, including teen-rate sete-uinetton 4
satarates Reactor Coolant ressonse (PWe).
8.
Loss of instrument str (if staulated plant specific).
g.
Loss of electrical power (ene/or segraces peer sources!.
- 10.
Loss of core coolant flom/ natural circulation
- 11.
Loss of consenter vacuum.
12.
Loss of service meter if reeutree for safety.
13.
LossofsnatsenEcooling.
14 Loss of cemeemet cooling syst m or cas!1pg to an indivieust component.
15.
Loss of normal feesmater er normal fosemeter system f attare.
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Loss of all fossmater (normal ans emergency).
17.
Loss of protective system enannel.
18.
miseositiones control ree or rees (or res.eroes).
13.
Inantlity to erive control rees.
Canettions reeutring ues of emergency heretten er stansey Ifoute control system.
20.
21.
Fuel classing failure or nign activity in reacter coolant er effges.
22.
Tur.. or -.ter tri.
23.
malfunction of automatic control system (s) mica affect reactivity.
24.
malfunction of reacter coolant pressure / vel se control system.
25.
Reetter trip.
26.
Mein steen line troem (instes or outsiee containment).
27.
mucleer insteenentation f ailure(s).
- Starred items to be perforsee annually, all others tiennially.
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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
.i 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 INPO documents are expected to satisfy all the requirements pertaining to training material which are addressed in this evaluation.
The licensee's response concerning increased emphasis on tran-sients is considered by SAI to be acceptable if it makes explicit reference to increased emphasis on transients and gives some indication of the nature of the increase, or, if it addresses both normal and abnormal transients (witnout necessarily indicating an increase in emphasis) and the requalifi-cation program s.atisfies 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 er tvaluate control manipulations as they are performed by others.
Although these manipulations are acceptable for meet-ing the reactivity control manipulations required by Appendix A paragraph 3.a of 10 CFR 55, the requirements of Enclosure 4 are more demanding. requires about 32 specific manipulations over a two-year cycle l
while 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.
B.
II.S.4:
Training for Mitigating Core Damage Item II.B.4 in NUREG-0737 requires that " shift tech.nical advisors j
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 darraged.
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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 students; lectures, seminars, discussions, problem-solving sessions, and examinations are considered. contact periods. This definition is taken from Reference 4.
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. 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 raponsibilities.
Since this imposes no additional demands on the program itself, we do not address it in this evaluation. It would be appropriate for resident inspectors to verify that non-operating personnel receiva the proper training, The required implementation dates for all items have passed.
Hence, this evaluation did not address the dates of implementation.
Moreover, the evaluation does not cover, training program modifications that might have been made for other reasons subsequent to the respons~e to Denton's letter.
III. LICENSEE SUBMITTALS The licensee (Toledo 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 Davis-Besse plant, there were 3 submittals with attachments, for a total of 9 items, which are listed below.
l.
Letter from R.P. Crouse, Vice President, Nuclear, Toledo Edison, to H.R.
Denton, Director, NRC.
August 4, 1980.
(1 pg, with enclosure: item 2).
NRC Acc No: 8008120498.(re: Response to. NRC letter dated March 29, 1980; Transmittal).
l 2.
Response to Item 2.C. of Enclosure 1 of H.R.
Denton's letter dated March 29, 1980; Davis-Besse Nuclear Power Station. Untitled. August 4,1980.
(8 pp, attached to item 1). NRC Acc No:
j 8008120502.
(Notes:
Contents include a chart and an overview of the revised training program).
3.
Letter from R.P. Crouse, Vice President, Nuclear, Toledo Edison, to J.F. Stolz, Chief of Operating Reactors Branch #4, NRC. July 6,1981.(1 pg). NRC l
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Acc No: 8107100037.
(re: Activities concerning the development of the training program for mitigating core damage).
4.
Letter from R.P. Crouse, Vice President, Nuclear.
Toledo Edison, to J.F. Stolz, Chief of Operati..g Reactors Branch #4, NRC.
May 10, 1982.
(1 pg, -
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with enclosures: items 5,6,7,8 & 9). NRC Acc No:'
8205170322. ( re: Response,to NRC's RAI).
5.
Attachment, Untitled.
M ay 10, 1982.
(4 pp, attached to item 4). (re: Response to NRC's ques-tions.given in the RAI).
6.
" Simulator Training Program Documentation, Training Information Notice" from N.S. Elliott, Manager of Training Services, Babcock & Wilcox. December 8, 1980.
(12 pp (includes the Simulator Training Summary Sheet), attached to item 4).
7.
"TECO 1981 Requalification Simulator". Undated.
(3 pp, attached to item 4).
8.
" Operator Training-Degraded Core Recognition and Mitigation; Study Guide", Phase 1, Volume 1, Davis-Besse, Nuclear Power Station.
May 1981.
(104 pp, attached to item 4). NRC Acc No: 8205170328.
9.
" Operator Training-Degraded Core Recognition and Mitigation; Study Guide", Phase 1, Volume 2, Davis-Besse, Nuclear Power Station.
June, 1981.
(270 pp, attached to item 4).
The last six items were in response to a request for additional information (Reference 5).
IV. EVALUATION SAI's evaluation of the training programs at Toledo Edison Company's Lavis-Besse 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 TM1 Action Item 11.8.4.
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 rea'ctor 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.
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In Submittal Item 2 the licensee stated that they had reemphasized
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the importance of this subject by restructuring the content of the programs dealing with heat transfer, fluid flow and thermodynamics. The licensee explicitly stated that the restructured programs address the needs as outlined in Denton's Enclosure 2.
This meets the NRC requirements in this specific area.
~. Item A.2.c(2)
The requirements are that the training programs for reactor and senior reactor operator candidates cover the subject of accident mitigation at the level of detail specified in Enclosure 3 of Denton's letter (see Figure 3 of this report).
In Submittal Item 2, the licensee stated that the training program had been modified to emphasize the installed systems to be used in accident situations.
The modification places emphasis on the use of systems in normal, emergency and abnormal modes. About three weeks of training in this area are given and involve both lectures and the use of simulators. A brief listing of the topics covered was provided. The topics covered are:
Potentially damaging operating conditions Core cooling mechanics Recognizing core damage Gas / steam binding effects on core cooling Hydrogen hazards during severe accidents Monitoring critical parameters during accident conditions
- Radiation hazards and radiation monitoring response Criteria for operation and cooling mode selection.
In Submittal Item 5 the licensee provided additional details of the training program relative to the use of installed instrumentation. This was supplemented with Submittal Items 8 and 9 which comprise the study guide for the Davis-Besse accident mitigation program.
This latter material pro-vides considerable detail on the accident mitigation training at Davis-Besse.
It is judged that all the requirements of Enclosure 3 are met.
The instructions in the areas of heat transfer, fluid flow, thermodynamics and accident mitigation is estimated to involve about 280 contact hours based on the information in Submittal Item 2.
This far exceeds NRC requirements.. Item A.2.c(3)
The requirement is that there be an increased emphasis in the training program on dealing with reactor transients.
In Submittal Item 2, the licensee stated that an increased empha-sis was placed on systems integrated performance.
In Submittal Item 5, the licensee elaborated on this issue by identifying both normal and accident initiated transients.
The current number of contact hours associated with transient training is estimated to be about 640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br />.
This portion of the Davis-Besse training p~ ogram meets NRC require-ments.
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.,. 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.
In Submittal Item 1, the licensee stated that all instructors hold In Submittal Item or have held a Senior Operator License for Davis-Besse.
5, additional information was provided to support the licensee's claim that instructors stay cognizant of operating history, problems and changes to The licensee stated that the procedures and administrative limitations.
instructors are cognizant because:
They initiate required readings and lectures.
They review all licensee event reports, transient assessment reports for Davis-Besse and other B&W units.
These activities, coupled with the normal senior reactor requalification program, appear to be adequate for meeting the NRC requirement.
_ Enclosure 1. Item C.1 The primary requirement is that the requalification programs have instruction in the areas of heat transfer, fluid flow, thermodynamics ~and accident mitigation. The level of detail required in the requalification In addition, program is that of Enclosures 2 and 3 of Denton's letter.
these instructions must involve an adequate number of contact hours.
The requalification program for the Davis-Besse plant is the same Because the initial training program meets as the initial training program.
the requirements for instruction in the areas of heat transfer, fluid flow, thermodynamics and accident mitigation and because the requirements are the same for both the initial training and the requalification program, the requalification program also meets the NRC requirements.. 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.
In Submittal Item 5, the licensee stated that accelerated requalification is required for all operators who score less than 80% on an overall basis or in any category. This exceeds the NRC requirements.. Item C.3 TMI Action Item I.A.2.1 calls for the licensed operator requalifi-cation program to include performance of control m:nipulations 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).
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,Submi ttal Item 5 states that the B&W simulator is used in performing most of the control manipulations identified in Denton's.
The only noted exception was the ' loss of instrument air' manipulation which is handled on a walk-thru basis. Submittal Item 6, which is used for documentation of the control manipulations, was compared against the required list of Enclosure 4.
All the necessary manipulations were found in Submittal Item 6 although no frequency of performance for the manipulations was found.
It is assumed, however, that the frequency is compatible with the requirements of Enclosure 4 because the introduction specifically refers to the requirements of Denton's Enclosure 4.
(Six of the manipulations must be. performed annually, the others biennially.) On plies with the,is judged that the Davis-Besse requalification program com-this basis it requirements of Enclosure 4.
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 shift technical advisors and operating personnel from the plant manager to the licensed operators. This includes both licensed and non-licensed personnel.
In Submittal Items 2 and 5 the licensee provided information about the accident mitigation training given to licensed personnel in both the initial training and requalification program. This information was analyzed in previous paragraphs and the conclus" ton was reached that the instruction involved the required topics and number of contact hours.
In Submittal Item 5 the licensee provided some information about the accident mitigation training of shif t technical advisors.
The information indicates that the shift technical advisor receives instructions and quizzes on accident mitigation subjects the same as licensed personnel.
This meets the requirements of Action Item II.B.4 for shift technical advisors.
There is however, no indication that non-licensed operating personnel, in this specific case the station superintendent, receives the training as required.
V.
CONCLUSIONS SAI has reviewed the Toledo Edison submittals in order to evaluate the status of the programs at Davis-Besse relative to the requirements of TMI Action Items I.A.2.1 and II.B.4.
The evaluation focused primarily on the establishment and content of these programs.
Our findings are sumarized in the following two paragraphs.
The licensee has provded reasonable assurance that all of the requirements of TMI Action Item I.A.2.1 are met by the training and requali-fication program at Davis-Besse. We would suggest verification that the control manipulations which are part of the simulator training program are performed with the frequency specified by Denton's Enclosure 4.
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SAI has concluded that the requirements of TMI Action Item II.B.4 are only partially met at the Davis-Besse Nuclear Power Station Unit One.
in this The submittal information does not indicate that tne plant manager, case the station superintendent, receives the required accident mitigation training. All other aspects of the I:.B.4 requirements are met.
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VI. REFERENCES 1.
"NRC Action Plan Developed as a Result of the TMI-2 Accident." NUREG-0660, United States Nuclear Regulatory Commission. May 1980.
2.
" Clarification of TMI Action Plan Requirements," NUREG-0737, United
- States Nuclear Regulatory Connission. November 1980.
3.
The NRC requirement for 80 contact hours is an Operator Licensing Branch technical position.
It was included with the acceptance criteria provided by NRC to SAI for use in the present evaluation.
See letter, Harley Silver, Technical Assistance Program Management Group, Division of Licensing, USNRC to Bryce Johnson, Program Manager, Science Applications, Inc.,
Subject:
Contract No. NRC-03-82-096, Final Work Assignment 2 December 23, 1981.
4.
" Guidelines for Heat Transfer, Fluid Flow and Thermodynamics Instruction," STG-02, The Institute of Nuclear Power Operations.
December 12, 1980.
5.
" Guidelines for Training to Recognize and Mitigate the Consequences of Core Damage," STG-01, The Institute of Nuclear Power Operations.
January 15, 1981.
Letter from John F. 5tolz, NRC,- to Richard P. Crouse, Toledo Edison 6.
Co.,
Subject:
NUREG-0737 Items-I.A.2.1 and II.3.4 - Request for Addi-tional Information, dated April 5,1982.
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