ML20153E686
| ML20153E686 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20153E670 | List: |
| References | |
| NUDOCS 8809060389 | |
| Download: ML20153E686 (5) | |
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ENCLOSURE 2 SAFETY EVALUATION OF REVISION 3, THI-2 LICENSED OPERATOR REQUALIFICATION PROGRAM BACKGROUND t
By letter dated December 28, 1987, GPU Nuclear Corporation requested a review of Revision 3 of the THI-2 Licensed Operator Requalification Program. Since there is a reduction in scope of the program, this review is required in accordance with 10 CFR 50.54 (1-1). The staff's review of the revisions to the program follows.
Lectures In requesting an exemption from the lecture requirements of 10 CFR 55.59 (c)(2), the licensee states:
10 CFR 55.59(c)(2), "Requalification Program Requirements," subsections (iv) and (v) respectively require lecture topics for "Plant Protection Systems" and "Engineered Safety Systems" as part of the licensed operator requalification program.
In lieu of this requirement, the monitoring capabilities of the THI-2 installed systens are addressed under "Plant Instrumentation and Control Systems" in Attachment 1 to the Licensed Operator Requalification Training Program. The Reactor Protection Systems at THI-2 have been disabled and are used for plant monitoring.
The "Engineered Safety Systems" at THI-2 have also been disabled and training on these systems is not included in this program. This exception was previously contained in Revision 2 to the THI-2 Licensed Operator Requalification Training Program (reference GPU Nuclear letter 4410-84-L-0138 dated Septec6er 15,1984).
This exception was approved in Revision 2 to the program and is acceptable as part of Revision 3 as it is consistent with the current condition of.the plant.
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. On the Job Training The licensee has requested exceptions to the control manipulations required by 10 CFR 55.59(c)(3)(1), subsections (A) to (AA) as follows:
In lieu of the above requirement, Attachment 2 to the THI-2 Licensed Operator Requalification Training Program identifies the abnormal and emergency evolutions that are applicable to THI-2. These evolutions provide a more meaningful requalification training program for the TMI-2 licensed operators.
Additionally, the requalification program specifies completion of the evolutions through the plant drill program. GPU Nuclear believes this to be acceptable per 10 CFR 55.59 (c)(4)(iv), "Evaluation," which states:
"The requalification program must include...(iv) simulation of emergency or abnormal conditions that may be accomplished by using the control panel of the facility involved or by using a simulator. Where the control panel of the facility is used for simulation, the action taken or to be taken for the emergency or abnormal conditions shall be discussed; actual manipulation of the plant controls is not required."
Verification by a subject matter expert has confirmed that these exceptions are appropriate and relevant to the present condition of THI-2. They are,
,therefore, acceptable.
l Program Hours of Instruction j
Revision 2 of licensee's operator requalification training program required approximately 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of instruction per year. The proposed revision (Revision 3) does not specify a minimum time requirement. The time scheduled will be appropriate to the time needed to accomplish the program requirements, i
which licensee indicates is a performance-based approach consistent with the current condition of THI-2. Since the licensee's approach does appear to be performance based and 10 CFR 55.59 does not specify any minimum time requirement for the training program, this change to the program is acceptable.
3-Reactivity Manipulations Revision 2 of the requalification training program requires that each licensee perform a variety of reactivity manipulations, including:
Observation of suberitical multiplication.
Observation of reactivity feedback from nuclear heat during startilp.
Demonstration of the effects of fuel displacement in suberitical multiplication and observed effects on '1uclear insi.rumentation.
Licensee prop 3ses to delete the requirement to perform these three manipulations and has stated:
Experience gained through defueling operations has demonstrated that fuel movements have no observable effect on subcritical multiplication or nuclear instrumentation.
Classroom lectures on the theory and principles of suberitical reactors are considered to be adequate training coverage of these topics.
Verification by subject matter expert confirms that performing the above i
reactivity manipulations is no longer necessary due to the current condition of the THI-2 reactor. This reduction in scope is, therefore, acceptable.
Research Reactor Training Time l
Revision 2 of the licensee's requalification program required 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per year of resaarch reactor or basic principles training simulator training. The purpose of this requirement was to perform the reactivity manipulations mentioned above. Since these manipulations no longer need to be performed, the i
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. need for this sirrulator training is obviated. The deletion of this requirement in Revision 3 is, therefore, acceptable.
Written Examination Revision 2 of the requalification program required administration of an annual written requalification examination.
In Revision 3, the period for administration of this examination has been increased to biennial. This change is consistent with 10 CFR 55.59(a)(1) and is, therefore, acceptable.
Fuel Handlina Senior Reactor Operator (FHSRO) Training Procram Licensee's submittal indicates that the FHSRO training program has been deleted because the initial training for this specific position has been completed.
In addition, the requalification training for the FHSR0 position has been incorporated into the THI-2 licensed operator requalification training program. This reduction in scope is acceptable since the status of THI-2 precludes the need for future initial training for the FHSR0 position.
The licensee also states that the required reactivity manipulations in:1uded in the initial training program are not contained in the requalification program. The purpose of these manipulations was to maintain familiarity with plant systems, controls, and procedures. The licensee has determined that those individuals holding the FHSRO license perform these evolutions on a frequent basis and have done so throughout the TNI-2 defueling experience.
In that this is a performance-based approach to skill acquisition and maintenance, the staff finds it acceptable.
Licensee has also reduced the frequency of administration of the written examination from annual to biennial. This change is consistent with 10 CFR 55.59 (a)(1).
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. Watchstanding In its submittal dated Decen6er 28,1987, the licensee proposes a reduction in the watchstanding requirements of 10 CFR 55.31 (e) and (f). However, the licensee stated that the actual details of the request for such exemption would be subnitted under separate cover. The staff will therefore evaluate the merits of that request by separate memorandum.
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