ML20071L900

Forwards Draft Responses to Personnel Qualification SER Items 1-3, Mgt Technology Items 1 & 2 & Draft Rev to FSAR Section 13.2.2.1.7 Re Performance Review Program.Changes Will Be Incorporated Into June 1983 FSAR Rev

ML20071L900
Person / Time
Site:	Limerick
Issue date:	05/25/1983
From:	Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8305310009
Download: ML20071L900 (20)

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s PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 7,^ " f,,[;[,^,,",'"' '"'

(2151841-4000 aaso esman AL counssL EUGEN E J. BR ADLEY assoceATs esqueak counssk DON ALD BLANKEN RUDOLPH A. CHILLEMI E. C. KI R M H A LL T. H. M AM ER CORN ELL PAUL AUERBACH Eo !!,"o"~.'CUJLE,.' ' ~ ' ^ ' ' ' ". ~ " '

May 25, 1983

^

T r40M AS H. MILLER, J R.

IR ENE A. Mc K ENN A mesesTANT counsel Mr.

A.

Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.

S.

Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

Limerick Generating Station, Units 1&2 Request for Information from the Licensee Qualification Branch

Reference:

Telecon between B.

Benedict and C.

R.

Endriss dated May 6, 1983 File:

GOVT 1-1 (FSAR)

Dear Mr. Schwencer:

The attached documents are draft responses to Personnel Qualification Section DSER items 1 through 3 and Management Technology Section DSER items 1 and 2.

A draft revision to FSAH Section 13.2.2.1.7 is also attached.

These changes will be formally incorporated into the FSAR revision scheduled for June, 1983.

Sincerely, Euge eJ Bradley RC/gra/11 See Attached Service List cc:

B305310009 830525 ig PDR ADOCK 05000352 PDR g

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J o

cc:

Judge Lawrence Brenner (w/o enclosure)

Judge Richard F. Cole Judge Peter A. M' rris o

Troy B. Conner, Jr., Esq.

Ann P. Hodgdon Mr. Frank R. Romano Mr Robert L. Anthony Mr. M'rvin I. Lewis a

Judith A. Dorsey, Esq.

Charles W. Elliott, Esq.

Jacqueline I. Ruttenberg Thomas Y. Au, Esq.

Mr. Thomas Gerusky Director, Pennsylvania Emergency Management Agency Steven P. Hershey James F. Neill, Esq.

Donald S. Bronstein, Esq.

Mr. Joseph H. White, III David Wersan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bush, Esq.

Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board Panel Docket and Service Section l

. -. -. = -. -

lh0 Ph6 bhm W A cc. crahensive hqualification t' raining program'ccnducted by the applicant for all licensed cpe-ators and senior licersed operators will be irplemented withir. 3 nor.ths after issuance of the unit's operating license.

This program ~

will be conducted on a 2-year cycle and will be followec' by successive 2-year -

programs which consist cf the following areas:

Lecture Series

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The recualificetien prcgram will include plar. red lectures en a regular and continuing basis.

A nual writter examir.ation results will indicate i

the secpc ard depth needed in the ic11cwinc areas:

F Reactor Theery and Principles of Reacter Operatien

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General arc Specific Operatinc Characteristics cf the Fiant 7

Instrumentaticn and Contrcl Systers

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Reacter Frctecticn and Encireered Safety Systens Nor,ai, Abne-al, and E ergency Operating Procedures

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Rad #aticr Centrol and Safety; Radioactive Material Handling Fuel Mancling anc Cere Farane:ers Adniniscrative Procedures and Technical Specificatiens I

A;plicable Fertiens of 10 CFR, Chapter I

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Nuclear Fower Flart Desicn Features f

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n add.itien te tne abcve areas,,Iwe require the applicant to modify the

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Irequalification procran, as specified in H. R. Denton's March 28, 1980 letter, to include instruction in heat transfer, fluid flow, (themodynamics, and mitigation of accicents involving a degraded core.

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We will review the applicant's ncdification to the requalification prcgran and report cur safety evaluatter in the SSER.

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(,g 13.2.1.5 Fire Protection Trainino The objective of fire protection training is to ensure that the shift and plant staff Fire and Damage Teams are prepared and capable of responding to fire emergencies.

Leaders of the Fire and Damage Teams receive initial training at the PECo Gas Operations Fire School or equivalent facility providing equivalent in-depth training.

The' remaining Fire and Damage Team members receive formal instruction which covers equipment and system usage and locations, methods, and procedures.

Fire drills will be performed quarterly for the Fire and Damage Team and annually a fire drill will include participation by an j

off-site fire company.

i j

Fire protection training is included in General Employee Training i

for staff members and others described in Section 13.2.1.4.

Personnel responsible for maintenance and inspection of fire protection equipment employ routine methods, such as review of vendor documents, drawings, and instructions, as necessary to perform their job functions as would be done for maintenance or inspection of other plant systems.

13.2.1.6 Coordination with Preoperational Tests and Fuel Loadino Figure 13.2-1 shows the schedule for training in relation to the km/

schedule of preoperational testing and fuel loading.

In the event fuel loading is delayed significantly, a refresher training course could be implemented or appropriate portions of the operator requalification program could be initiated.

13.2.2 REQUALIFICATION TRAINING PROGRAM 13.2.2.1 Licensed Operator Requalification Training The Licensed Operator Requalification Training Program for licensed and senior licensed operators will be established and ready for implementation no later than three months following issuance of the station operating license.

The program is

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conducted on a two year cycle and will be followed by successive two year programs which meet or exceed the requirements of 10 CFR, Part 55, Appendix A as described below.

The program, which takes into consideration holders of conditioned licenses (such as for fuel handling only), consists of the following:

13.2.2.1.1 Lecture Series j

The requalification program will include preplanned lectures on a regular and continuing basis.

Annual written examination results will indicate the scope and depth needed in the following areas:

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a.

Reactor Theory and Principles of Reactor Operation b.

General and Specific Operating Characteristics of the Plant c.

Instrumentation and Control Systems d.

Reactor Protection and Engineered Safety Systems e.

Normal, Abnormal, and Emergency Operating Procedures f.

Radiation Control and Safety; Radioactive Material Handling g.

Fuel Handling and Core Parameters h.

Administrative Procedures and Technical Specifications i.

Applicable Portions 10 CFR, Part 1 N~~,,g.

Nuclear Power Plant Design Features The lectures will be planned by the plant staff training l

organization and presented by that organization, by designated licensed or senior licensed operators, or by consultants.

Films, videotapes, and self-study material may be used to supplement the lectures.

An instructor shall participate in at least 50% of the lecture series.

Lectures will be scheduled at a rate of not less than six per year, appropriately spaced through the year, and taking into consideration expected personnel availability and plant operations.

Lectures may be deferred due to unexpected plant operations; however, these lectures shall be conducted as soon as practicable thereafter.

l During the course of the Lecture Series, written examinations l

shall be administered.

A Grade of less than 80% will require retaining and retesting in the subject matter covered by the examination.

i The method of determining required attendance at lectures shall be defined.

If attendance by all licensed individuals is not required, those exempted from attendance shall have demonstrated proficiency in the lecture topic by achieving at least a grade of 80% in that topic on the previous annual written examination.

13.2.2.1.2 Reactivity Control Manipulations Each licensed operator shall minipulate equipment and reactor controls within his license period.

l Each senior licensed operator shall direct the activities of l

individuals or manipulate controls within his license period.

All licensed and senior licensed operators shall participate in simulator programs as part of the requalification program.

The following control manipulations and plant evolutions are acceptable for meeting the required reactivity control

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manipulations.

The starred (*) items shall be performed on an annual basis; the remaining items shall be performed in a two-year cycle.

Those control manipulations that are not performed l

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Managers and technicians in the health physics and chemistry depart. rents will receive mitigating core damage training-con ensurate with their responsibilities. [owever, thi~t;iclicant"h'as 'n'ot',

dressed such training for the managers and technicians in the

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'd (9/3 LCS FSAR OUESTION 630.17 Provide a training program for mitigating core damage as described in Item II.B.4 of NUREG-0737 in accordance with the guidance an specified in Enclosure 3 of H.

R.

Denton's letter dated March 28, 1980.

Provide a listing of those individuals and their qualifications who must participate in the training program and provide a schedule for that training as related to the presently scheduled fuel load date.

RESPONSE

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A+ training program for mitigating core damage will be ;r: i_;l prior to fuel loading and ompleted prior to full power operation.

The course ou lin

's presented below.

~ Y#h M' Core Cooling Mechanics Alternate methods of core cooling l

Core spray and core flooding Heat removal paths Boron precipitation l

Fuel cladding quenching

(,g Limiting core conditions Steam and water cooling Potentially Damaging Operating Conditions Vulnerable plant operating conditions Core cooling with systems unavailable Gas / Steam Binding Affecting Core Cooling Sources of gas / steam vapor Symptoms / effects of gas / steam binding Recognizing Core Damage Data collection, instrumentation, and systems Fuel / clad behavior Reporting requirements Core Recriticality Reactor Shutdown margin-Maintaining subcrituality Standby liquid control system Instrumentation response Hydrogen Hazards During Accidents Sources of hydrogen and oxygen Hazardous concentrations and reduction 4

Gas venting k./

630.17-1 Rev. 18, 03/83 m

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Monitoring Critical Parameters During Accident Conditions Parameter identification i

Instrumentation reliability, accuracy, and failure Radiation Hazards and Radiation Monitor Response Emergency plan implementation High radiation areas Sampling Radiation monitor response and failure s

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Criteria for Operation and Cooling Mode Selection

=

Core cooling procedures j

Core cooling equipment and methods Shift Technical Advisor and operating personnel from the Station Superintendent through the operations chain including the i

licensed operators will receive this training.9 Other plant managerial personnel and technicians in the, health physics,and chemistry groups willyreceive training commensurate with their responsibilities Also (fgg yfg

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TABLES t.

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Title, Table Rhod Nk$ 7

?l 13.1-1 Oteff resital,ne end E. r i.ed Och& del: f;r Fillir.;

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'r 13.1-2 Shift Crew Composition - Minimum Requirements 13.1-3 Qualification Resumes s

13.1-4 Enginee'r-In-Charge Resumes a

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consultation and services in the areas of calibration, maintenance, and testing of transformers, switchgear, protective relays and devices, instrumentation, and controls.

In regard to the support provided, supervisory personnel in the Metallurgical i

1 Group and the Station Tests Section meet the qualifications of

" engineer-in-charge" as defined in Section 4.6.1 of ANSI /ANS-3.1 3

- 1978.

Personnel in these sections have the benefit of experience gained through years of providing technical support to the Peach Bottom Atomic Power Station - Units 2 and 3 operating staff.

13.1.1.2.4 Construction Division The Construction Division is under the direction of the General Superintendent.

The Construction Division has expertise and provides consultation and servicet in the areas of electrical and mechanical modification installation.

In regard to the support provided, supervisory personnel and a substantial number of construction engineers meet the qualifications of

" engineer-in-charge" as defined in Section 4.6.1 of ANSI /ANS-3.1

- 1978.

Also, personnel in the Construction Division have the benefit of experience gained through years of providing support to the Peach Bottom Atomic Power Station - Units 2 and 3 Y

operating staff.

13.1.1.3 Contractors and Suppliers The extensive experience of PECo in the nuclear industry may be supplemented when necessary by qualified contractors and suppliers.

The capability of the PECo technical staff ensures that areas requiring the special expertise of certain contractors and suppliers are identified and that the work of such contractors and vendors is adequately monitored and evaluated to ensure proper completion.

13.1.1.4 Status of Preoperational Activities The Electric Production Departmen't reviewed the control room and control panel layout to ensure that operating experience and human engineering objectives were incorporated into the design.

Staff recruiting for Limerick Generating Station commenced in 1978 and

h:duled to procc:3 as shown in Table 13.1-1.

Training j; discussed in Section 13.2.

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The control program for preoperational testing has been prepared and issued.

The implementation of the program was tested for the turnover and initial testing of certain nonnuclear systems that were subsequently operated to support construction.

The preoperational testing ir conducted in accordance with the control program and as described in Chapter 14.

Development of the plant maintenance program, which includes planning for spare parts, commenced in 1978 and is expected to be an ongoing function through initial startup and operation.

Also, rigging drawings are being prepared to show lifting points and access requirements.

Such drawings are reviewed by PECo.

13.1.2 OPERATING ORGANIZATION 13.1.2.1 General The station organizational chart for Limerick Generating Station is shown in Figure 13.1-2.

This figure shows the title of each position, the number of persons expected to be assigned, and the positions for which reactor operator and senicr reactor operator licenses are required.

Table 13.1-1 shows the schedule for

(

filling the station operating positions.

13.1.2.2 Station Superintendent The Station Superintendent, who reports to the Superintendent, l

Nuclear Generation Division, has the direct responsibility for all phases of plant operation and maintenance.

The Station Superintendent is responsible for strict adherence to the operating license and technical specifications, safeguarding the general public and station personnel from radiation exposure, and for the safe, reliable, and efficient operation of the Limerick Generating Station.

In regard to the PECo as-low-as-reasonably-achievable (ALARA) program, the Station Superintendent is responsible for applicable functions of Regulatory Guide 8.8 (Rev 3) as follows:

a.

Ensuring support for the ALARA program from all station personnel 9

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TABLE 13.1-1 l

l ILLING VAC"CIES-ttWrSE D ON n

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DATE S eftBIM H 6 -

POSITION APPOINTED Fun TILLI"G'O Station Superintendent 1975 Assistant Station Superintendent 1976 Operations Engineer 1982 Shift Superintendents 1981 Shift Supervisors 1981 Control Operators 1980 Assistant Control Operators 1980 Plant Operators 1982 Assistant Plant Operators 1982 Auxiliary Operators 1982 Technical Engineer 1979 Senior Health Physicist 1982 Physicist-Applied 1983 Q

Physicist-Technical Support 1983 Chemist-Supervisory N

l Instrumentation and Controls Engineer 1981 Reactor Engineer 1982 Maintenance Engineer 1982 Training Coordinator 1980 (2) h;i c Otefuny-i.,-.my.ct d -te u 4;;;;;t; -in-4 ^ehwrth r

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OUESTION 630.7 How many people are presently in the Plant Organization and what kind of professionals in each section?

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RESPONSE

There are 107_ people in the plant operatino organization (as of The kind of professionals in each section are:

fg3 erg A - Administrative Title Number Type of Decree Plant Superintendent 1

B.S. Mechanical Engineering

& M.S. Mechanical Engineering Ass't Plant Superintendent 1

B.S. Mechanical Engineering Administrative Engineer 1

B.S. Mechanical Engineering B - Operations Title Number Type of Decree 4

Operations Engineer 1

B.S. Mechanical Engineering Engineer 1

B.S. Engineering C - Health Physics & Chemistry Title Number Type of Decree Senior Health Physicist 1

B.S. Environmental Health

& M.S. Health Physics Health Physicist 1

B.A. Geology &

M.S. Environmental Science Chemist 1

B.S. Chemistry &

M.S. Nuclear Chemistry

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D - Technical Title Number Type of Decree Technical Engineer 1

B.S. Mechanical Engineering Engineer Supervisory 2

B.S. Mechanical Engineering Engineer Supervisory 1

M.S. Mechanical Engineering Engineer Supervisory 1

B.S. Engineering Engineer 1

M.S. Mechanical Engineering Engineer 7-B.S. Mechanical Engineering Engineer 7

B S. Electrical Engineering Engineer 4

B.S. Chemical Engineering Engineer 1

B.S. Nuclear Engineering E - Maintenance Title Number Type of Decree Maintenance Engineer 1

B.S. Mechanical Engineering Engineer 1

B.S. Mechanical Engineering

& B.A.

Physics F - Startup Title Number Type of Decree

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Startup Director 1

B.S. Mechanical-Industrial Engineering Engineer Supervisory 1

B.S. Mechanical Engineering Engineer 1

B.S. Mechanical Engineering G - Test Review Title Number Type of Degree Chairman of Test Review 1

B.S. Mechanical Engineering Board H - Environment & Regulatory Title Number Type of Decree Environment & Regulatory 1

B.S. Mechanical Engineering Engineer

& M.S. Mechanical Engineering k

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• GS FSAF OUESTION 630.9 Fire Brigade: Discuss the Fire Brigade Organization and Membership.

RESPONSE

s The Limerick fire brigade of at least 5 members will be maintained onsite at all times.

The fire brigade composition may be less than the minimum requirements for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to accommodate unexpected absence, provided that immediate action is taken to fill the required positions.

The fire brigade will not include the minimum shift crew necessary for safe shutdown of the unit (s) or any personnel required for other essential functions during a fire emergency.

The brigade leader and at least 2 brigade members will have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability.

The qualification of fire brigade members will include an annual physical examination to determine their ability to perform strenuous fire fighting activities.

The brigade leader will be competent to assess the potential safety consequences of a fire and advise control room personnel.

Such competence by the y

brigade leader will be evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems.

The responsibilities of the fire brigade are:

a)

Respond to fire alarms with appropriate equipment and protective clothing.

b)

Advise the Interim Emergency Director or Emergency Director as to the need for assistance from the plant staff or from offsite fire fighting groups.

c)

Coordinate the actions of offsite fire fighting groups if onsite assistance is requested.

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l Evaluations will be critiqued with the individual concerned and filed in the individual'c training records, 13.2.2.1.7 Performance Review Program I

A Performance Review Program will be implemented when the performance of a licensed operator or senior licensed operator falls below the following criteria:

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a.

An annual written examination score of less than *0%

overa11 er 70'A N M.) mkgwy b.

A substandard rating on the walk-through examination.

c.

Observation of inadequate performance of licensed responsibilities which is indicative of a need for special or accelerated retraining.

i The Station Superintendent or Assistant Station Superintendent, the Operations Engineer, and a member of the plant staff training i

organization shall jointly determine a course of action to upgrade the individual's performance and/or plant knowledge and shall define the method (s) and criteria for evaluating the adequacy of the upgrading effort.

The action to be taken in a particular case may depend upon factors such as identified weak areas, written and walk-through examination results, observed operational ability, theoretical understanding, or the results of km/

supplementary oral or written examinations.

As a minimum, an individual who receives less than 2d%doverall on the annual

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written examination shall remain in the Performance Review

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f-Program until a score of at least JbFP"is obtained on a written /

examination in each of those areas in which less than JA%#wss obtained in the annual written examination.

If determined appropriate by the Station Superintendent, an individual will be i

removed from licensed responsibilities until completion of all or specified portions of the upgrading action.

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13.2.2.2 Non-licensed Operator Requalification Trainina i

Non-licensed operators assigned to the shift positions of Auxiliary Operator, Assistant Plant Operator, and Plant Operator shall participate in the Non-licensed Operator Requalification Training Program.

The program consists of the following:

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13.2.2.2.1 Design, Procedure,',and License Change Review This program ensures that appropriate revisions to the Operating Technical Specifications, Environmental Technical Specifications, procedures, and plant design are reviewed.

When determined by the Plant Operations Review Committee, the Operations Engineer, or the plant training organization, document revisions and descriptions of plant design changes are attached to a signoff

(,j sheet and placed in a review notebook.

As indicated on the signoff sheet, shift operators will review the attached document 13.2-27

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