ML20027A894

Improvements in Training & Requalification Programs as Required by TMI Action Items I.A.2.1 & II.B.4 for Ja Fitzpatrick Nuclear Power Plant, Technical Evaluation Rept

ML20027A894
Person / Time
Site:	FitzPatrick
Issue date:	08/25/1982
From:	SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	NRC
Shared Package
ML20027A895	List: ML20027A894
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-186-029-49, SAI-186-29-49, NUDOCS 8208310344
Download: ML20027A894 (15)

Text

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t-SAI-186-029-49 i

I TECHNICAL EVALUATION REPORT IMPROVEMENTS IN TRAINING AND REQUALIFICATION PROGRAMS AS REQUIRED BY TMI ACTION ITEMS I.A.2.1 AND II.B.4 J

for the James A. FitzPatrick Nuclear Power Plant (Docket 50-333)

August 25, 1982 Prepared By:

Science Applications, Inc.

1710 Goodridge Drive -

McLean, Virginia 22102 Prepared for:

,U.S. Nuclear Regulatory Commission Washington, D.C. 20555 XA Copy _Hos Been Sent to PDR Contract NRC-03-82-096~

fP (X2d33Jo31/1/D 14P.

~' Science Applications,Inc.

TABLE OF CONTENTS Section g I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . 1 II. SCOPE AND CONTENT OF THE EVALUATION . . . . . . . . . 1 A .' I.A.2.1: Immediate Upgrading of R0 and SRJ Training and Qualifications ..... 1 B. II.B.4: Training for Mitigating Core Damage. . 6 III. LICENSEE SUBMITTALS . . . . . . . . . . . . . . . . . 7 IV. EVALUATION. . . . . . . . . . . . . . . . . . . . . . 9 A. I.A.2.1: Immediate Upgrading of R0 and SRO Training and Qualifications .... 9 B. II.B.4: Training for Mitigating Core Damage. . 12 V. CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . 12 VI. REFERENCES. . . . . . . . . . . . . . . . . . . . . . 13 l l l 1 l ,

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       . .        .                                                                                               1 1          e I. INTRODUCTION i                                    Science Applications, Inc. (SAI), as technical assistance contrac-tor to the U.S. Nuclear Regulatory Commission, has evaluated the response by

, the Power Authority of the State of New York for the James A. FitzPatrick Nuclear Power Plant (Docket 50-333) to certain requirements contained in post-TMI Action Items I.A.2.1, Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualifications, 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  ! the l licensee's operator training and requalification programs satisfy (TAC) requirements. The evaluation pertains to Technical Assignment Control l System numbers 44161 (NUREG-0737, I.A.2.1.4) and 445 * (NUREG-0737, l II.B.4.1). As delineated below, the evaluation covers on' ome 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 R0 and S,R0 Training and Qualifications The clarification of TMI Action Item I.A.2.1 in MUREG-0737 incor-porates a letter and four enclosures, dated March 28, 1980, from Harold R. Denton, Director, Office cf 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 li.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 Danton's letter. The training requirements under evaluation are sum-marized in Figure 1. The ehborstions 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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Figure 1. Training Requirements from TMI Action Item I.A.2.1* Program Element iwtC Requirements ** Enclosure 1. Item A.2.c(1) Training programs shall t modifid. as necessary. to provide training in heat transfer fluid flow and permodynamics. (Enclosure 2 providcs guidelines for the minimum content of such training.) OPERATIONS Enclosure 1. Item A.2.c(2) PERSONNEL Training programs shall be modified, as necessary to provide training in the TRAINING use of installed plant systems to control or mitigate an accident in which the core is severely damaged. (Enclosure 3 provides guidelines for the minimum contentofsuchtraining.) Enclosure 1. Item A.2.c.(3) Training programs shall be modified as necessary to provide increased emphasis on reactor and plant transients. t Enclosure 1. Item A.2.e INSTRUCTOR Instructors shall be enrolled in appropriate recualification programs to assure aEQUALIFICATION they are cognizant of current operating history, problems, and changes to pro-cedures and administrative limitations. Enclosure 1. Item C.1 Content of the licensed operator requalification programs shall be modified to in'clude instruction in heat transfer, fluid flow, thermodynamics, and mitiga-tion of accidents involving a degraded core. (Enclosures 2 and 3 provide guide-lines for the minimum Content of such training.) PERSONNEL Enclosure 1. Item C.2 REQUALIFICATION The criteria for requiring a licensed individual to participate in accelerated requalification shall be modified to be consistent with the new passing grade for issuance of a license: 80% overall and 70% each category. Enclosure 1. Item C.3 programs should be modified to require the control manipulations listed in Enclosure 4. Normal control manipulations such as plant or reactor startups. , must be performed. Control manipulations during abnormal or emergency opera-tions must be walked through with, and evaluated by, a member of the training staff at a minimum. An appropriate simulator may be used to satisfy the

requirements for control manipulations.

l *The requirements shown are a s;bset of those contained in Item I.A.2.? i

                " References to Enclosures are to Denton's letter of March 28, 1980, which is contained in the clarifi-cation of Item 1. A.2.1 in NUREG-0737.                                                                      ,.

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a. Figure 2. Enclosure 2 from Denton's Letter TRAlminG IN MIAT TRANSFER, FLUID FLOW AND TMERM00VNAMICS

1. Basic Prooecties of Fluids and Matter.

This section should cover a basic introduction to matter and its properties. This section should include such concepts as temperature measurements and effects, density and its effects, specific weight, buoyancy, viscosity and other properties of fluids. A working knowledge of steam tables should also be included. Energy movement should be discussed including such fundameitals as heat eschenge, specific heat, latent heat of vaporisation and sensible heat.

2. Fluid Statics.

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This section should cover the pressure, temperature and volume effects on fluids. Enample of these parametric changes should be illustrated by the instructor and related calculations should be performed by the students and discussed in the training sessions. Causes and effects of pressure and temperature changes in the vn us components and systems should be discussed in the training sessions. Causes and effects of pressu;e and temperature changes in the various components and systems should be discussed as applicable to the f acility with particular emphasis on saf ety significant features. The characteristics of force and pressure, pressure in liquids at rest, principles of hydraulics, saturation pressure and temperature and subcooling should also be included.

3. Fluid Dynamics.

This section should cover the flow of fluids and such concepts as Bernoulli's principle, energy in moving fluids, flee measure theory and devices and pressure losses due to friction and orificing. Other concepts and terms to be discussed in this section are NP5H. Carry over, carry under, kinetic energy, head loss relationships and two phase flow fundamentals. Practical applications relating to the reactor coolant system and steest generators should also be included.

4. Heat Transfer by Conduction. Convection and Radiation.

This section should cover the fundamentals of heat transfer by conductions. This section should include discussions on such concepts and terms as specific heat, heat flus and atomic action. Heat transfer characteristics of fuel rods and heat exchangers should be included in this section. This section snould cover the fundamentals of heat transfer by convection. Natural and forced circula-tion should be discussed as applicable to the various systems at the f acility. The convection current patterns created by expanding fluids in a confined aras should be included in this section. Heat transport and fluid flow reductions or stoppage should be discussed due to steam and/or noncondensible gas formation during normal and accident conditions. This section should cover the fundamentals of heat transfer by thermal radiation in the form of radiant energy. The electromagnetic energy emitted by a body as a result of its temperature should be discussed and illustrated by the use et equations and sample calculations. Comparisons should be made of a black body absorber and a white body emitter.

5. Chance of Phase - Bo111no.

This section should include descriptions of the state of matter, their inherent characteristics and thermodynaef t properties such as enthalpy and entropy. Calculations should be performed involving steam quality ar4 void fraction properties. The types of bo111ng should be discussed as applicable to the facility during normal evolutions and accident cor.ditions.

6. Burnout and Flow Instability.

This section should cover descriptions and mechanisms for calculating such terms as critical flus, critical power, DNS ratio and hot channel f utors. This section should also include instructions for preventing and monitoring for clad or fuel damage and fica instabilities. Sample canulations should be illustrated by the instructor and calculations should be performed by the students and discussed in the training sessions. Methods and procedures for using the plant computer to determine quantitative values of various factors during plant operation and plant heat balance determinations should also be covered in this settion. g

7. Reactor Heat Transfer Limits.

This section should include a discussion of heat transfer limits by esamining fuel rod and reactor design and limitations. The batis for the limits should be covered in this section along with recommended methods to ensure that limits are not approached or escoeded. This section should cover discussions of peaking f actors, radial and exial power distributions and changes of these factors due to the influence of other variables such as moderator temperature, menon and control red position. 3

Figure 4. Control Manipulations Listed in Enclosure 4. CONTROL M4h!PULATIONS

                  *1.      Plant or reactor startups to include a range that reactivity feedback from nuclear heat addition is noticeable and heatup rate is established.

2. Plant shutdown.

                  *3.      Manual control of steam generators ar1/or feedwater during startup and shutdown.

4 Boration and or dilution during power operation.

                  *5.      Any significant (greater than 105) power changes in m:nual rod control or recirculation flow.

6. Any reactor power change of 105 or greater where load change is performed with load limit control or where flua, temperature, or speed control is on manual (for HTrsR).

                  '7.      Loss of coolant including:

1. significant PWR steam generator leaks

2. inside and outside primary containment

3. large and small, including leak-rate determination

4. saturated Reactor Coolant response (Pd).

8. Loss of instrument air (if simulated plant specific).

9. Loss of electrical power (and/or degraded power sources).

                 *13.       Loss of core coolant flow / natural circulation.

11. Loss of condenser vacuum.

12. Loss of service water if required for safety.

13. Loss of shutdown ' cooling.

14. Loss of component cooling system or cooling to an individual component.

15. Loss of norma) veedwate or normal feed =ater system failure.

                 *16.       Loss of all feeduster (normal and emergency).

17 Loss of protective system channel.

18. Mispositioned control rod or rods (or rod drops).

Ig. Inability to drive control rods. .

20. Conditions requiring use of emergency boration or standby liquid control system.

21. Fuel cladding failure or high activity in reactor coolant or offgas.

22. Turbine or generator trip.

23. Malfunction of automatic control system (s) uhich affect reactivity.

24. Malfunction of reactor coolant pressure / volume control system.

25. Reactor trip.'

26. Main steam line breat (inside or outside containment).

27. Nuclearinstrumentationfailure(s).

• Starred items to be performed annually, all others biennially.

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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.

2 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 enclosures (and consistent with the 80 contact hour requirement) and whethee 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 Fograms based specifically on the complete INP0 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 (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 with these activities 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 demanding. Enclosure 4 requires about 32 specific manipulations over a two-year cycle while 10 CFR 55 Appendix A requires only 10 manipulations over a.two-year cycle. l B. II.B.4: Training for Mitigating Core Damage i 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.

              *A contact hour is a one-hour period in which the course instructor it 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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Enclosure 3 of Denton's letter provides guidance on the content of this training. " Plant Manager" is here taken to mean the highest rar. king manager at the plant site. 2 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. Sora 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. 4 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 letter. III. LICENSEE SUBMITTALS The licensee (Power Authority af the State of New York) 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 informetion base for this evalua-i tion. For the James A. FitzPatrick Nuclear Power Plant, there were six l submittals with attachments, for a total of 14 items, which are listed below. Submittal six and the attachments thereto was in response to the NRC request f r additional information (Reference 6). I

1. " Licensed Operator / Senior Operator . Replacement Training", Indc< trination & Training Procedure No.

4, Power Authority of the State of New York, J.A. / Fitzpatrick Nuclear Power Plant, Revision 2. August 8,1980. (20pp).

2. Letter from J.P. Bayne, Sr. Vice President, Nuclear Generation, Power Authority of the State of New York, to T.A. Ippolito, Chief of Operating Reactors Branch #2, Division of Licensing, NRC.

April 10,1981. (3 pp). NRC Acc No: 8104170323. (re: Activities concerning Post TMI Requirements). h 7 i

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3. I & E Report No. 50-333/81-09, Office of Inspection and Enforcement, NRC. Approved by H.B. Kister, Chief of Reactor Projects Section No. IC, May 27, 1 1981. (No. of pages,. unknown). NRC Acc No:

8106180346. (re: Status of licensee action concerning TMI Action Plan).

4. Letter from J.P. Bayne, Sr. Vice President, Nuclear Generation, Power Authority of the State of New York, to T.A. Ippolito, Chief of Operating Reactors January 8, Branch 1981. #2, (2 pp, Division withofenclosure Licensing,).NRC.NRC Acc No:

8101160441. (re: 'tatus report on the implementation of NUREG-0737 Items II.B.4).

5. Letter from J.P. Bayne, Sr. Vice President, Nuclear Generation, Power Authority of the State of New York, to T.A. Ippolito, Chief of Operating Reactors Branch #2, Division of Licensing, NRC. March 13, 1981. (4 pp). NRC Acc No: 8103190496. (re:

Request for extension of the Training Program for

,                Mitigating Core Damage).

6. Letter from J. P. Bayne, Sr. Vice President, Nuclear Generation, Pown Authority of the State of New York, to D.B. Vassallo, Chief of Operating Reactors Branch #2, Division of Licensing, NRC.

July 1, 1982. (1 pg, with enclosures: items 7,8,9,10,11,12,13,14). (re: Transmittal, response to NRC's RAI dated May 20, 1982).

7. " Response to NRC May 20, 1982 Request for Additional Information Regarding NUREG-0737, Items I.A.2.1 & II.B.4", J.A. Fitzpatrick Nuclear Power Plant, Power Authority of the State of New York.

July 1,1982. (5 pp, attached to item 6).

8. Indoctrination

                 " Licensed
                 &  Training Operator       Requalificatior.",

Procedure N o. 5, Aev. 4, J.A. Fitzpatrick Nuclear Power Plant, Power Authority of-t M State of New York. August 7, 1980. (25 pp, attached to item 6).

9. " Plant Staff Organization", Fig. 6.2-1. Undated.

(1 pg, attached to item 6). l .

10. " Heat Transfer Lesson Plan", Rev.1. April 1, 1982. (41 pp, attcched to item 6).

l 11. " Fluid Flow Statics & Dyramics Lesson Plan". Undated. (2 pp, attached to item 6).

12. " Elementary Thermodynamics Lesson ' Plan". Undated.

(3 pp, attached to item 6). 8

13. "Requalification Training Report, Mitigating Reactor Core Damage". Undated. (2 pp, attached to item 6).

14. " Selected Course Schedules for Replacement License Training". Undcted. (3 pp, attached to item 6).

IV. EVALUATION SAI's evaluation of the training programs at the Power Authority of the State of New York's James A. FitzPatrick Nuclear Power Plant 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 TMI Action Item II.B.4. A. I.A.2.1: Immediate Upgrading of Reactor Operator and Senior Reactor Operator Training and Qualification. ' 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. Submittal item 1, " Licensed Operator / Senior Operator Replacement Training" August 8,1980, states classroom technical training consists of a minimum of 500 hours of formal instruction and is composed of 14 topical areas which include heat transfer, fluid flow and thermodynamics, but no further details. Submittal item 10, " Heat Transfer Lesson Plan" Revision 1, April 1,1982, is very detailed, consisting of 23 pages and 14 figures. Submittal item 11, " Fluid Flow Statistics and Dynamics Lesson Plan" consists of three pages and submittal item 12, " Elementary Thermodynamics Lesson Plan" con-sists of four detailed pages. Submittal item 7, in response to the NRC request for additional information (Reference 6) indicated 120 contact training hours are devoted to the subject of thermodynamics, heat transfer.and fluids. Examination of the aforementioned submittal items indicate the requirements of Enclosure 2 of Denton's letter are fulfilled. Enclosure 1. Item A.2.c(2) <

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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). Submittal item 1 indicates that 500 classroom hours are devoted to some 14 operator-training topical subjects. Use of installed plant systems to mitigate accidents involving a severely damaged cnre is included in the subject training program, but no further details are provided. 9

4 Submittal item 7, states: " Initial Training in Accident Mitiga-tion - 32 hours. Mitigation concepts are incorporated into existing lesson plans". Submittal item 14, " Selected Course Schedules for Replacement License Training" includes a course outline for Mitigating Core Damage which essentially addresses the topics specified in Enclosure 3 of Centon's ' l_ etter. While more details would be reassuring it appears reasonable to - concitie that the requirements of this Enclosure 1 item are satisified. Enclosure 1,ItemA.E.cM , The requirement is that there be an increased emphasis in the training program on dealing with reactor transients. Submittal item 1 includes in its list of subjects presented during the course of formal classroom training, Reactor and Plant Transients, but no further details are provided. Submittal item 7 states: " Training for license candidates in the areas of operational transients and accident analysis is done in a three step process:

a. Introduction to Emergency Core Cooling Systems (during system training).

b. Introduction to Transient Analysis (during final review phase).

c. Normal and abnormal event analysis as outlined in the FSAR '

and General Electrics Abnormal Events Analysis text". Submittal item 14 contains the outline for a 40 hour classroom course titled, " Transient and Accident Analysis". In view of the foregoing it is concluded that sufficient emphasis is provided in training for dealing with reactor transients. Enclosure 1. Item A.2.e

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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 adnii*nistrative limitations. Submittal item 8, " Licensed Operator Requalification" Section 5.5 indicates that the topics: current operating history, problems and changes to procedures and administrative limitations are included in the program. Section 5.5.12 of this submittal item states: " Licensed facility instructor shall complete the requirements of the licensed operator requalification program. Non-licensed (i.e.: " certified") instructors shall participate in this program to the extent required to assure that they are cognizant of 10

current operating history problems, changes to procedures and administrative limitations". The requirement of this Enclosure 1 item is met. 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 i accident mitigation. The level of detail required in the requalification  ! program is that of Enclosures 2 and 3 of De' n's letter. In addition, i these instructions must involve an adequate numb- of contact hours. I Submittal item 8, section 5.5 indicates that there is training / retraining in the subjects of heat transfer, fluid flow, thermodynamics and core damage mitigation but provides no further details. Submittal item 7, " Response to the NRC request for additional information" (Reference 6): The licensee obviously misinterpreted the RAI question relating to this Enclosre 1, item C.1 in that it thought that 80 contact training hours were required for each subject area, i.e.,80 hours for heat transfer, 80 hours for fluid flow, 80 hours for thermodynamics and 80 hours for accident mitigation. The response therefore, was in the nega-tive. It was indicated that about 64 contact hours were devoted to accident mitigation and related subjects. Despite the confusion, no Niications were found that more than the 64 contact hours mentioned were provided in these subjects in the requalif.ication program. Therefore, while the course content satisfies the requirements of the Denton letter, the 80 contact hour criterion is not satisfied and the requirements of this Enclosure 1 item are not fully met. Enclosure 1 Item C.2 1 The requirement for licensed operators to participate in the accelerated requalification program must be based on passing scores of 80% ' overall, 70% 1~n each category. Submittal item 8, Section 5.5.10d and 5.5.10e state this require-ment as standard procedure and therefore conform with this Enclosure 1 item. Enclosure 1, Item C.3

• TMI Action Itet. I.A.2.1 calls for the licensed operator requalifi-catio.n program to include performance of control manipulations involving both normal and abnormal situations. The specific manipulations required and their lette-p(erformance see Figure 4frequency are identified in Enclosure 4 of the Denton of this report); <

Submittal item 8, Section 5.5.7b indicates'that all licensed personnel shall participate in control manipulations involving reactivity changes or abnormal conditions to demonstrate their skill and f amiliarity I with control systems. As a minimum, abnormal control manipulations must be walked through and evaluated by a member of the training staff. In addition, a control room simulator may be used to satisfy the requirements for abnormal control manipulations provided the control arrangements on.the simulator permit effective use of the plants special emergency procedures. Sections 5.5.7b and 5.5.7e list the manipulations required (an _lly and 11

biennially) which not only conform to those in Enclosure 4 of Denton's letter but exceed those requirements in total number in that the FitzPatrick Plant requires 36 manipulations. The requirements of this Enclosure 1 item are indeed fulfilled. 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 fro ~m the plant manager to the licensed operators. This includes both licensed and non-licensed personnel. The requirements of TMI Action Items I.A.2.1 under Enclosure 1, item C.1 have not been met; therefore while the requirements of II.8.4 have been met in connection with course content, sufficient numbers of contact training hours have not been provided for licensed personnel. Submittal item 7 provides the following additional information. Lectures on the subject of mitigating the consequences of severe core damage have been given to the following personnel: Resident Manager, Superintendent of Power, Technical Services Superintendent, Shift Technical Advisor, Radiological & Environmental Services Superintendent, Operations Superintendent, Maintenance Superintendent, Instrument and Control Superintendent, Reactor Analyst Supervisor, all staff licensed personnel, all station Shift Supervisors (SRO), all Senior Nuclear Operators (RO), and all Nuclear Control Operators (RO). The above listing indicates the final criterion associated with II.B.4 has been met. V. CONCLUSIONS Upon completion of the item evaluations contained in Section IV, SAI concludes the training program of the Power Authority of the State of New York, Jamas A. FitzPatrick Nuclear Plant fails to fully satisfy the requirements of the TMI Action items I.A.2.1 and II.B.4. A deficiency

occurs in satisfying I.A.2.1 in that the licensee's requalification program f alls about 20% short of the 80 contact hours required to be devoted to accident mitigation with core damage and related subjects. The same deficiency applies to II.B.4 for licensed operating" personnel, i

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 .                                            VI. REFERENCES

1. "NRC Action Plan Developed as a Result of the TMI-2 Accident." NUREG-0650, United States Nuclear Regulatory Commission. May 1980.

2. " Clarification of TMI Action Plan Requirements " NUREG-0737, United States Nuclear Regulatory Commission. November 1980.

3. The NRC requirement for 80 ccntact 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.

6. Request for additional information from the NRC sent to the Power Authority of the State of New York, May 20, 1982.

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