ML20247G878

Responds to NRC 890801 Request for Addl Info on FSAR Chapter 13.2 Re Training & Qualification Program.Individuals Selected for Supervisory Positions Requiring Senior Operating License Will Receive Instruction in Listed Areas

ML20247G878
Person / Time
Site:	Comanche Peak
Issue date:	09/15/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.008, RTR-REGGD-1.008 TXX-89699, NUDOCS 8909190161
Download: ML20247G878 (5)

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' Log # TXX-89699 i 1 C File # 10010 l r C 913.2 1UELECTRIC September 15, 1989 W. J. Cahill iJecutive %ce l' resident U. S. Nuclear Regulatory Commission Attn: Document' Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET.NOS 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON FSAR CHAPTER 13.2 REF: NRC Letter to W. J. Cahill, Jr. dated August 1, 1989 l

Gentlemen:

f In response to your request for additional information on the CPSES Operations Training and Qualification Program in the FSAR Chapter 13.2, TV Electric is submitting the changes to the FSAR suggested by the NRC as shewn in the-Attachment. These changes are scheduled to be incorporates in a future FSAR amendment.

Sincerely, ih' William J. Cahill, Jr.

,yflo By: erM -

4 RogeVD. Walker Manager, Nuclear Licensing rLB/grp Attachment c - Ms.-M. Malloy, NRR-0SP Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) MO

'I 8909190161 890915 PDR ADOC.K0500g5 A

400 North Oli e Street LB81 Dallas, Texas 75201 Y. _-_-__________-----_____2___----______-----___.__._. _

. . Attachment to TXX-89699 SeptembQr 15, 1989 Page 1 of 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION COMANCHE PEAK TRAINING AND QUALIFICATIONS NRC Item 1.

FSAR Section 1A(B), page 4 shows a commitment, with exception, to Revision 1-R (5/77) of Regulatory Guide 1.8, " Personnel Selection and Training." Please describe how this commitment is an acceptable alternative to following Revision 2 (4/87) of Regulatory Guide 1.8.

Response 1.

The following proposed text will be added to Section IA(B) regarding Regulatory Guide 1.8:

CPSES is developing a training program which will meet Institute of Nuclear Power Operations accreditation as discussed in Section 13.2.1. The training program will also incorporate the standards included in Regulatory Guide 1.8 Revision 2 (4/87). Compliance with Regulatory Guide 1.8 Revision 2 will be achieved prior to start-up of Cycle 2.

NRC Item 2.

FSAR Section 13.2.1.1, paragraph 3 states cold license candidates will meet the requirements of ANSI N13, 1-1971. Section 5.2.1. This appears to be a typographical error. Please clarify reference in view of Question 1 above.

Response 2.

The reference will be corrected. FSAR Section 13.2.1.1 should read as follows:

All Unit 1 cold license candidates will meet the requirements of ANSI N18.1-1971, Sect; a 5 2 1 NRC Item 3.

FSAR Section 13.2.1.1(2), page 13.2-3 states candidates will receive " hands-on" experience relating to subjects a, d, and e earlier in the section. From the list on page 13.2-2, " hands-on" experience will be gained in the areas of principles of reactor operations, reactor instrumentation and control systems, and fundamentals of heat transfer, thermodynamics and fluid flow related to transient analysis. ANSI ANS-3.1-1981. Section 5.2.1.1 requires " hands-on" l experience related to principles of reactor operation, reactor instrumentation and control systems, and radiation control and safety provisions. Please explain why radiation control and safety provisions does not appear on the Comanche Peak list as a required " hands-on" training subject.

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l 1 Attachm'ent to TXX-89699 September. 15, 1989 Page 2 of'4 Response 3.

The folicwing proposed text will be added to Section 13.2.1.1(2) as item e, and the current item e (in Amendment 76) will be changed te item f:

e.. Radiation Control NRC Item 4.

1 FSAR Section 13.2.1.1(3), page 13.2-3 does not require system malfunction training. System malfunction training is required per ANSI ANS-3.1-1981, Section 5.2.1.2. Please describe the system malfunction training to meet the intent of ANSI ANS-3.1-1981.

Response 4.

The following proposed text will be added to Section 13.2.1.1(3) as Item j:

j. System and component malfunction.

NRC Item 5. I FSAR Section 13.2.1.1(5), page 13.2-4, does not mention establishment of a check-off list of minimum operations to perform or observe as required in ANSI ANS-3.1-1981, Section 5.2.1.3.1. Please describe the check-off list to be used.

Response 5.

The following proposed text (in bold type) will be added to Section 13.2.1.1(5) as item a:

a. Replacement license (operator) candidates will participate in three months of control room operating experience as an extra person in the control room. This experience will include manipulation of plant controls under the direct supervision of a licensed operator and will be documented in a checklist. At a minimum, five significant control manipulations will be performed which affect reactivity of power level.

NRC Item 6.

FSAR Section 13.2.1.1(6), page 13.2-5 states that simulator participation "is normally limited" to groups of no more than four people manipulating controls.

ANSI ANS-3.1-1981, Section 5.2.1.3.2 states that participation "shall" be in groups of no more than four people manipulating controls. Please clarify the intent of "normally limited".

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2'7- A'tachment.to t TXX-89699 September 15, 1989 Page 3_of 4 Response 6.

The following proposed text will be added to Section 13.2.1.1(6):

Participation is limited to groups of no more than eight (8) people manipulating the controls or directing the activities of individuals during plant exercises.

NRC Item 7.

FSAR Section 13.2.1.1(8), page 13.2-7 makes no mention of duration of the

. practical work' assignments. ANSI ANS-3.1-1981 requires this training to be a minimum of six months in duration. Please describe the duration of practical work assignments at Comanche Peak.

ResDonse 7.

The following proposed text (in bold type) will be added to Section 13.2.1.1(8):

Operator and senior operator cold license candidates participate in work assignments for a minimum of 6 months'that will provide an opportunity to gain additional knowledge of CPSES. These assignments may, depending on plant activities, include: Operating procedure preparation and verification, pre-operational testing, providing instruction on plant system, or other activities that could provide additional operating knowledge.

NRC Item 8.

FSAR Section 13.2.1.1(9), page 13.2-7 contains an unexplained space in the second line of the paragraph where it appears that a portion of this paragraph is missing. Refer to ANSI ANI-3.1-1971, Section 5.2.1.5 for additional information. Please clarify whether there is a portion of the FSAR description missing.

Response 8.

The omission will be corrected. Section 13.2.1.1(0) should read as follows:

A comprehensive examination to determine the candidate's ability to operate the plant in a safe and competent manner is administered prior to certification of competency of the candidate to the NRC.

NRC Item 9.

FSAR Section 13.2.1.1(12), page 13.2-8 does not require supervisors to receive training in motivation of personnel and the administrative requirements for the particular supervisory position as required in ANSI ANS-3.1-1981 Section 5.2.1.8. Please clarify whether supervisors will receive this training.

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Att'achminttoTXX-89699 September 15. 1989

.Page 4 of 4

-Response 9- .

The following proposed text (in bold type) will be added to Section 13.2.1.1(12):

Individuals selected for supervisory positions requiring NRC Senior Operating Licenses will receive instruction in interpersonal communicating, problem and decision analysis, leadership, command responsibilities, administrative requirements, and motivation of personnel.

NRC Item 10.

FSAR Section 13.2.1.1(13), page 13.2-8 does not require Shift Technical Advisors (STAS) to receive training in accidents analyzed in the FSAR and the consequences of these accidents or the duties and responsibilities of the STA as required in ANSI ANS-3.1-1981,.Section 5.3.3(1) and (2). Please clarify.

whether STAS will receive this training.

Response 102 STAS-at CPSES receive the same training as SR0s which includes training in accident analysis; therefore, no action is necessary.

NRC Item 11.

FSAR Amendment 76 makes no mention of the retention of training documentation for those personnel completing the initial operator training program as required by 10CFR55 and noted in ANSI ANS-3.1-1981. Section 5.6. Under 10CFR55.31(a)(4), the applicant shall " provide evidence that the applicant has successfully completed the facility licensee's requirements to be licensed."

Please describe how this documentation requirement will be supported.

Response 11.

' The following proposed text (in bold type) will be added to Section 13.2.2.1.8:

Requalification and Replacement License Training Records The Director, Nuclear Training will maintain records documenting the participation of each licensed operator and senior operator in the requalification program and replacement license training program records.

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