ML17341B466

Improvements in Training & Requalification Programs as Required by TMI Action Items I.A.2.1 & II.B.4 for Turkey Point,Units 3 & 4, Technical Evaluation Rept

ML17341B466
Person / Time
Site:	Turkey Point
Issue date:	08/31/1982
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML17341B465	List: ML17341B466
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-186-029-08, SAI-186-29-8, SAI-I86-029-08, SAI-I86-29-8, NUDOCS 8211100543
Download: ML17341B466 (14)

Text

SAI -186'-029-08 TECHNICAL EVALUATION REPORT IMPROVEMiENTS IN TRAINING AND REQUALIFI CATION PROGRAMS AS REQUiRED BY TMI ACTION ITEMS I.A.2.1 AND II.B.4 for the Turkey Point, Units 3 and 4 (Dockets 50-250 and 50-251)

August 31, 1982 Prepared By:

Science Applications, Inc.

1710 Goodridge Drive McLean, Virginia 22102 Prepared for:

U.S. Nuclear Regulatory Com~ission Washington, D.C. 20555 Contract NRC-03-82-096 82ii160543 821025 PDR. ADOCK P

05000250

, PDR j j Ji Sciance Applications Inc

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INTRODUCTION Science Applications, Inc. (SAI), as technical assistance contrac-tor to the U.S. Nuclear Regulatory Commission, has evaluated the response by Florida Power and Light Company for the Turkey Point Plant, Units 3 and 4 (Docket Nos. 50-250 and 50-251) to certain requirements contained in post-TMI Acti'on Items I.A.2.1, Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and gualificat'ions, 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)P The purpose of the evaluation was to determine whether the license~'s operator training and requalifi cation programs satisfy the requirements. The evaluation pertains to the following Technical Assignment Control (TAC) System numbers:

TAC Nos.

I.A.2.1. II.B.4 Unit 3 44204 44554 Unit 4 44205 44555 As delineated below, the evaluation covers only some aspects of item I.A.2.1.4.

%he detailed evaluation of the licensee's submittals is presented in Section IV; the conclusions are in Section V.

I I. SCOPE AND CONTENT OF THE EVALUATION A. I.A.2.1: Imnediate Upgrading of Reactor Op'erator and Senior Reactor Operator Training and gualificat'ions

'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 recualification; and Section C, which addresses operator requali-fication. Some of these requirements are elaborated in Encl'osures 2, 3,,ind

~E I I 'RRER-3737 d IIRE" 7 3 I 3 3 t I 37 t distinguish four sub-actions within I.A.2.1 and two sub-actions within II.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 I I .B.4.1.

4 of Denton's letter.

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The training requirements under eva'luation 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.

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 of at least.PO 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 provi'de greater assurance of adequate course content when the li'censee's training courses are not described in detail.

Since the licensees generally have their own unique course out-lines, ad quacy 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 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 abnorma'1 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 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 w'ith these.

activi'ties if they direct or evaluate 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 demandirg Enclosure 4 requires about 32 specific manipulations over a two-year .cycTe while 10 CFR 55 Appendix A requires only 10 manipulations over a two-year cycle.

<<A contact t,ur 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.

Figure 1. Training Requirements from THI Action Item I.A.2.)*

Program Element NRC Enclosure I, )ter, A.2.c(l) Requirements~'PERATIONS Training programs shall be aodified, as necessary, to provide training in heat transfer, fluid flo<< and therrodynamics. (Enclosure 2 provides guidelines for the mfnirrvm content of such training.)

Enclosure I, Item A.2.c(2)

PERSONNEL 'Traintng prOOramS Shall be mO ified, AS neCeSSary tO prOVfde training in the TRA ININD use of installed plant systems to control or mitigate an accident in <<hich the core is severely damaged. (Enclosure 3 provides guidelines for the miniaum content of such training.)

Enclosure I, Item A.2.c.(3)

Training programs shall be modified, as necessary to provide increased emphasis on rea tor and plant transients.

Enclosure ). Item A.2.e INSTRO'TOR Instru:tors shall be enrolled in appropriate requalificatior. progranS LO aSSure REQUA' I'ICATION they are COgniaant Of Current OPerating hi StOry, prOblemS, and ChangeS tO prO-CedureS and adminiStratiVe limitatiOnS.

Enclosure I, Item C. I Content of the licensed operator requalification programs shall be modified to include instruction in heat transfer, fluid flo<<, thermodynar.:fcs, anc miti9a-tion of accidentS involving a degraded core. (Enclosures 2 and 3 provide guide-lines for the minimum content of such training. )

PE: SORREL Enclosure I, Item C.2

'The criteria for requiring a licensed individual to participate in accelerated REQOALIEICATION requalification shall be nodified to be consistent <<ith the ne<< passing grade for issuance of a license: 80'verall and 7OS each category.

Enclosure I . I ter.. C. 3 PrncramS SNOu'Id be mqdified tO require the COntrOl manfpulatfqnS 'liSted in Enclcsure C. Normal control manipulations, such as plant or reactor startups, m.st be performed. Control manipulations curing abnomral or emergency opera-tsons m.'st be <<alked throu9h <<ith, and evaluated by, a member of the tra'in'in9 staff at a minfsum. An appropriate simulator may be used to satisfy the requirements for control manipulations.

'Tne requirements sno<<n are a subset of those containe in Ite I.A.2. I.

'References to Enclosures are to Denton's letter of Karen 28, 1990, <<hich is contained in the clarifi-cation of Iten; I.A.2. I in NDREG-D737.

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Figure 2. Enc1osure 2 from Denton's Letter TRAIKIKB IK HEAT TRAKSFER ~ FLUID FLDv AKD THERNODYKAHICS Basic Pro rrties of Fluids and Hatter.

This stet ion should cover ~ basic introduction to matttr and its properties. This section should 1nclude such conctpts as ttmperatvre mtasuremtnts and tffects, dens1ty and its effects, sptc'lf'lc ueipht, buoyancy, v1scos'lty and other proptrt'lts of flu1ds. A uoretnp tno>>>>)edge of steam tables should a)ao be inc)uded. Energy movement should bt discuSstd including such fundamentals as heat exchanpe, SPtCif iC heat, 'latent heat of vapor)xatfon and sensible heat.

2>> Fluid Statics.

This section should cover the pressure, temperature and volume efftcts on fluids. Exa>>vp)e of thest parametric changes should bt 1)lustrated by the 1nstructor and related ca'Iculations shauld bt performtd by the Studerts and discussed in the training stssions. Causes and tffects of pressure and ttmperatvre CnangeS in the Var)OVS COupantntS and SyStemS ShOuld be diSCuSSed in the training SeSS1OnS. CauttS and effects of pressure and temperature changes in tne various covponents and systtms should be discussed as appl icable to the facility vith particular emphasis or. saf ety significant features. Tht characteristics of force anC pressvre, pressure in liquids ~ t rest, principles of nydraulics, saturation prtssure and temperature and subcoolinp should also be inc)uded.

Fluid Dvnavics.

This section should cover the flov of fluids and such concepts as Bernovl'li's principle,, energy in mcvi..g f luidS, f)ov mtasure theory and devicts and prtssure losses due to friction and orificing.

Otner concepts anc tera:s to be discussed in this section are KPSH, carry over, ca~ry under, kinetic energy, head-loss rrlatio'lsnips and tvo phast f)or fundamentals. practical applications relating to the reactor coolant system ana stew. generators should also be included.

Heat Transfer bv Conductior. Convection and Radiation.

Tnis sect'.on should cover the fundamentals of heat transfer by conductions. Tn1s section should 1nc luce ciscussions Cn SuCh COnCeats and teres as specific htat, heat flux and atomic action. Heat transfer characteristics of fuel rods and heat exchangers should be included in this section.

This section should coier the fundamentals of heat transfer by convection. Katvral anc forced circul ~-

tion snov)C be discuSSea as apP)icable to the variOuS SyStemS at tne faC 1'lity. Tne convection current patterns created by expanCing fluids in ~ confintd area should be inclvded in thiS Section. Heat transport anc f )vic f lo reductions'r stoppage should.be discussed due to steam and/or nonconcensiblt gas forr.ation curing norr.al and accident conditions.

'This section should cover the fundamentals of heat transftr by thermal raciation in the form of raCiart erergy. The t)ectromagnetic energy emitted by a body as a result of its temptrature should be ciscussea and illustratec by the use of equations and sample calculations. Comparisons should be made of a black body absorber and a unite body tmitttr.

Change of Phase - Boilin This stction should include descriptions of the statt of matter, the1r inherent characteristics and thermadyramiC praperties Suth.aS enthalpy and entrOpy. C ~ )CulatiOnS Shauld."be perfOrmtd inVOIVing steam quality and void fractior prope.tits. The types of boiling should be discussed as applicable to the feei)ity avring normal evolutions and accioent conditions.

Burnout and f lo>> Instability.

This sect)on shovld cover descriptions and mtchanisms for calculating such terms ~ s critica) flux, critical power, DK= ratio and hot channel factors. This section shovld also includt instructions for preventing ana manitaring fOr Clad ar fue) damagt and f)OV 1nStabilititS. Sample C ~ )CulatiOnS Shauld, be il)utt.aced by the inStruttar and Ca)CulatiOnS Shau)C be perfarmed by the StudentS and'diSCuSSed in the training sessions. Hethads and procedures for using th>> plant co>>puter to determine quantitative values of va-ious factors during plant operation and plant heat balance determinations should also be COvered in thiS StCtiOn.

7. Reactor Heat Transfer Lirits.

Tnis stction should include a discussion of heat transfer 11mits by examinfnp fuel rod and rea.tbr design anC limitations. The basis for the limits shauld be covtred in thiS SeCtion along <<th recomrended methods to enSurt that limits are not approached or exCeededr .This section should COver diSCVSSianS Of peaking fattarS, radial and AX'lal paver diStributiOnS and ChangeS af theSe f attOrS dut to the influence of otntr variables such ~ 5 moderator texperature, xenon and control rod pasition.

Figure 3. Enclosure 3 from Denton's Letter

'TRAIIIING CRITERIA FUR HITIGATING CORE OAHAGE A. Incore Instr~ntation I. Use of fixed or movable fncore detectorS tO determine extent of core damage and geome'tty change5.

2. Use of thermocouples in determin1ng peat temperatures; methods for extended range readings; metnods for direct readsngS at terminal functions.

3. Hetno85 for calling up (printing) incore data fron'he plant coeputer.

8. Excore Nuclear Instrumentation NIS I. Use of NIS for octermination of void fo~mation; void location basis for NIS response as ~ function Of COre temperatureS and dentally ChangeS.

C. vxta Instrumentatxon I. Instrumentation response ir. an accident environment: failure sequence (time to failure, method of failure); ind5cation reliability (actual vs indicated level).

2. Alternative metnods for measuring fio<<5 pre5$ ures ~ levels, and temperatures.

a. Determination of pressurizer level if all level transm1tters fail.

b. Determination of Ietdo~ flo<< <<1'th a c'logged filter (lo flo<<).

c. Determination of othe Reactor Coolant System parameters if the primally method of measurement has failed.

Q. Primer Cne-..>str

l. Expected cnemist y results <<1th severe core damage; consequences of transferring small quantities of lxquxd Cutsxue COntainment; ixOOrtante of using leax tight systems.

2. Expe:ted 55Gtopic breakdo~ for core damage; for clad dama9e.

3. Corrosion effects of extended ixr.ersion in primary <<a\er; time to failure.

E. Radiataon Honitorin"

1. Response Of Process and Area HonitorS te Severe damages; behavior of detectors <<hen saturated; method for detecting radiation readings by direct measuremert at detector output (overran9ed detector); expected accuracy of detectors at different location5; use of detectors to determine extent of core daetage.

2. Hetnods Of determining dose rate inside containment from<< a easurements token outside containment.

F. Gas Gene~ation Hetnoc> of h'2 generation during an accident; other sources of 9as (Ie, Ke); techniques for venting or cssposai of non-condensibles.

2. H2 flan..ability and explosive limit; sources of 02 in contaimxent or Reactor Coolant System.

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Figure 4. Control Manipulations Listed in Enclosure I

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COKTRO'lkhlPULATJONS Plant Or reaetOr Startupa tO inClude a range that reaettVfty feedbaCk frOm nuclear heat additiOn

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1s noticeable and heatup rate 1s established.

2. Plant Shutdovn.

~ 3. iianual control of steam generators and/or feedvater during startup and shutdoun.

C. Sorataor. and or dilution during pover operat1on.

~5. Any signif scant (greater than 1OI) pover changes 1n manual rod control or recirculation fin.

Any rea:to port change of lOs or greater uhere load'change is performed with load limit control or where flue, ter perature, or speed control .is on manual (for HTOR).

Loss o! coolant including:

]. significant Psi steam generator leaks

2. insvde and outsade prima~y contat~ent

3. large and small, inc'luding leak-rate determination

4. Saturated Reactor Coolant response (Pus).

6. LOSS Cf tnStrurent air (if Simulated Slant SpeCifaC).

S. Loss of elect~ical power (and/o~ degraded p~r sources).

~]3. r Loss o! core coolant flo /natural circulation.

1 ~ Loss o. condenser vacuuI .

32. i.oss of service rate 1f requir<<d for safety.

l3. LOSS Of ShJtdavr. COOlsng.

lC. Loss of co-.sonant cooling system or cooling to an individual component.

15. Loss of normal feedvater or norma'1 feedvater system failure.

16. Loss of ~ 'll feed~ater (normal and emergency).

37. Loss cf protective system charnel.

lB. visposotioned control,rod or rods (or rod drops).

lg. )nability to drive control rods.

20. Conditions recu<ring use of'mergency.boration or standby liquid control system.

2l. Fuel cladding failure or high,activ1ty in reactor coolant or offgas.

. 22. Turbine o. generator tr.ip.

23. Nalfunction of a tomatic control system(s) uhich affect reactiv1ty: ~

2C. Kalfunction of reacto~ coolant pressure/volme control syster.

25. aeactor trip.

2f. Hain s'team )ine break (inside or outside contafwent).

27. huclear instr~entatfon failure(s).

~ Starfed 1tems to be performed annually, all otherS biennially.

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~ I B. II.B.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 licensed operators" receive training on the use of installed systems to control or mitigate accidents in which the core is severely damaged.

Enclosure 3 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 responsibilities. 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 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 modifications that might have been made for other reasons subsequent to the response to Denton's 1 et ter.

I I I. LICENSEE SUBMITTALS The licensee (Florida Power and Light Company) has submitted to NRC a number of items (letters and various attachments) which explain their training and requalification proorams. These submittals, made in. response

.to Denton's letter, form the information base for this evaluation:. For the Turkey. Point Plant, Units 3 and 4 there were four submittals with attach-ments, for a total of nine items, which are listed below.

1. Letter f rom R.E. Uhrig, Vi ce Presi dent, Advanced Systems E Technology, Florida Power L Light Co.,

to P.F. Col 1 ins, Chief of Operator Li.censing Branch, NRC. August 1, 1980. (1 pg, with enclosure: item 2). NRC Acc No: 8008060348.

(Transmittal).

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2~ "L i censed Operator Requa1 i f i cation Program",

Florida Power & Light Co., Turkey Point Units 3 &

4, Administrative Procedure 0301. Effective date, July 9, 1980. (15 pp, attached to item 1). NRC Acc No: 8005040536.

/ 3. Letter from Systems &

R.E. Uhrig, Vice President, Advanced Technology, Florida Power & Light Co.,

to D.G. Eisenhut, Director, Division of Licensing, NRC. April 28, 1981.(l pg). NRC Yiicrofiche No:

8421/108. (re:. Response to NUREG-0737, Item II.B.4 requirements).

Letter from R.E. Uhrig, Vice President, Advanced Systems & Technology, Florida Power & Light Co.,

to S.A. Varga, Chief of Operating Reactors Branch

<1, Division of Licensing, NRC. Narch 25, 1982.

(1 pg, with enclosures: items 5 & 6). NRC Acc No:

8203300183. (Transmittal).

5. "Hot License Operator Training Program", Florida Power & Light Co., Turkey Point Units 3 & 4, Administrative Procedure 0300. Effective date, November 19, 1981. (36 pp, attached to item 4).

NRC Acc No: 8203300196.

6; "Licensed Operator Requalification Program" Florida Power & Light Co., Turkey Point Units 3 & 4, Administrative Procedure 0301. August 20,. 1981.

(15 pp, attached to item 4) NRC Acc No:

8203300202.

7.. Letter from R.E. Uhrig, Vice Presi'dent, Advanced Systems & Technology, Florida Power & Light Co.,

to S.A. Varga, Chief of Operating Reactors Branch kl, Division of Licensing, NRC. June 30, )982.

(1 pg, with enclosures: items 8 &. 9). L 263.(re: Transmittal, response to NRC's RAI dated Nay 24, 1982).

8. "Response to Request for Additional Information".

Undated. (2 pp, attached to item 7).

9. "Turkey Point Plant Organizational Chart". Undated.

(1 pg, attached to item 7).

Submittal Items 2 and 5 describe the basic programs at Turkey Point Units 3 and 4. Submittal Items 7, 8 and 9 are the responses. to a request for additional information (Reference 6). These submittal items contain details that are not in the program descriptions and, for purposes of this evaluation, are considered to be an integral part of the licensee's training program description.

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IV. EVALUATION I

SAI's evaluation'of the'training programs at Florida Power and Light Company's Turkey Point Plant, Units 3 and 4, is presented below. Sec-tion A addresses TMI Action Item I.A.2.1 and presents the assessment organized in the manner of Figure 1. Section B addresses TMI Action Item I I.B.4.

A. I.A.2.1, Immediate Upgrading of Reactor Operator and 'Senior Reactor Operator Training and gualification.

Enclosure 1 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.

Florida Power and Light Company submitted a training program (Submittal Item 5) which contains a course outline titled "Heat Transfer and Fluid Flow." .This course outline explicitly identi'fied all,the items listed in Enclosure 2 of the Denton letter and it appears to be a well organized outline. Therefore, SAI judges that this requirement is met at Turkey Point Uni ts 3 and 4.

Enclosure 1 Item A.2.c 2 T

The requirements are that the training programs for react'or 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).

The licensee's Hot License Operator Training Program (Submittal Item 5) provided a course outline titled "Mitigating Core Damage and Transient Analysis." This outline addressed all the items identified in Enclosure 3 of the Denton letter, and it appears to cover more than is required in Enclosure 3. Moreover, the licensee's submitted training program (Submittal Item 5) showed that approximately five weeks of the training time was allotted as guidance in the training area of heat transfer, fluid flow, and mitigating core damage. In additi'on, the licensee stated in Submittal Item 8 that "at the present time, their initial training course for license candidates consist of 180 contact hours of instruction in these subjects." The licensee further. stated that at the "time these special topics were implemented, each license holder received 128 contact hours of additional instruction in these subjects."

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Therefore,. SAI concludes that the licensee's training program meets the NRC requirements.

Enclosure 1 Item A.2.c 3 The requirement is that there be an increased emphasis in the training program on dealing with reactor transients.

'lor'ida Power and

~Light Company's training program

~:. training has a topic titled "Integrated Plant Transients Response" which appears to cover this requirement adequately. In addition, the simulator training included in the training program has 29 control manipulations which address both normal and abnormal transients. Therefore, SAI concludes that this criterion is met at Turkey Point 3 and 4.

Enclosure I Item A.2.e The requirement is that instructors for reactor operator training programs be enrolled in appropri ate requalification programs to assure they are cognizant of current operating history, problems and changes to procedures and admini strati ve limitations.

In Submittal Item 8, the licensee stated that all instructions pertaining to plant safety systems, integrated responses, transient and simulator courses shall require the instructor to have a current SRO license. SAI has examined the submitted requalification program (Submittal Item 5) and found that it does require each SRO to review each plant change/modification, reportable occurrence, FSAR supplement, facility license amendment, and applicable procedure change. Therefore, SAI judges that this requirement is met at Turkey Point 3 and 4.

Enclosure '. Item C.l 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 program is that of .Enclosures 2 and 3 of Denton's letter. In addition, these instructions must involve an adequate number of contact hours..

Since the training and the requalification programs both utilize the same course outlines, as discussed in items A.2.c(1) and A.2.c(2), the material contents in the training areas of heat transfer, fluid flow, ther-modynamics, and mitigating core damage meet this requirement. However, the licensee's requalification program shows approximately 29 contact hours training involvement in this training area, and the licensee's Submittal Item 8 stated that the amount of time spent will be determined on an as-needed basis and generally this will amount to around 30 contact hours per year. Therefore, SAI judges that the 80 contact hours requirement is not met at Turkey Point 3 and 4.

Enclosure I Item C.2 The requirement for licensed operators to:.participate in the accelerated requalification program must be based on passing scores of 80K overall, 70K in each category. The material provided in Sub'mittal Item Z.

shows that the licensee's requalification program meets this requirement.

Enclosure I Item C.3 TNI Action Item I.A.?.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 10

t their per formance frequency are identified in Enclosure letter (see Figure 4 of this report).

4 t of the Denton The licensee's Submittal Item 6 includes 31 control manipulations which explicitly identify all the applicable items included in Enclosure 4 of the Denton letter except one, "Loss of. service water if required for safety." However, the licensee in Submittal Item 8 stated that their Intake Cooling Water System, included in their list, performs the same function as the item identified in Enclosure 4 as Service Water. This appears to be a reasonable explanation. Therefore, SAI judges that the licensee's requali-fication program meets this requirement.

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 advi'sors and operating personnel from the plant manager .to the licensed operators. This includes both licensed and non-licensed personnel.

The training of the licensed personnel does not meet the requirements of Action Item II.B.4 because the licensed personnel receive this training through the requalification program and the requalification program does not meet the 80 contact hours criterion for this training area (the requalification program involves only approximately 30 contact hours training in tt >s area).

Based on in(ormation, including an organization chart, supplied by

"'iorida Power and Light Company in their response (Submittal Item 8) to NRC's request for additional information (Reference 6), it appears that this requirement for the non-licensed personnel is satisfied at Turkey Point 3 and 4. Specifically, this training is given to personnel holding the following positions: Plant Manager Nuclear, Technical Department Suporvisor, Shift Technical Advisor and 5 additional staff members, Opera-tions Superintendent, Operations Supervisor, Nuclear Plant Supervisor, Nuclear Watch Engineer, Nuclear Control Center Operator, Operations Project Coordinator, Reactor Supervisor and two members of Reactor Engineering staff, Training Supervisor and all licensed members of the training depart-ment, Startup Superintendent, ILC Supervisor and all engineers and techni-cians reporting to him, Assistant Superintendent Mechanical Maintenance Nuclear, Chemistry Supervisor and the entire chemistry staff, Health Physics Supervisor and entire Health Physics staff, Assistant Superintendent proj ects, Project Coordinator.

Y. CONCLUSIONS Based on our evaluation as discussed above, SAI concludes that thy licensee does not fully meet the requirements of NUREG-0737 item I.A.2.1~

The deficiency occurs in the requalification program, which'.has less than 80 contact hours involvement in the training for heat transfer, fluid flow, thermodynamics, and accident mitigation with core damage. The licensee also fails to fully satisfy the requirements of NUREG-0737 item II.B.4 because their licensed personnel receive less than 80 contact hours training which relates to mitigating core damage, An upgrading of the requalification program to include 80 contact hours 'on these subjects would automatically satisfy the II.B.4 deficiency for licensed personnel.

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