3F0785-15, Clarifies Commitment to Modify Licensed Operator Requalification Training Program to Include Instruction in Heat Transfer & Fluid Flow,Per TMI Items II.B.4 & I.A.2.1(4)
| ML20128N710 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/23/1985 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-2.B.4, TASK-TM 3F0785-15, 3F785-15, NUDOCS 8507260258 | |
| Download: ML20128N710 (3) | |
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q\\e.!Po Power CORPORATION July 23,1985 3F0785-15 Director of Nuclear Reactor Regulation Attention: Hugh L. Thompson, Jr., Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NUREG-0737, Item I. A.2.l(4) & II.B.4 Licensed Operator Requalification Training Program Commitment Clarification Deir Sir:
Florida Power Corporation (FPC), with this letter, is clarifying its commitment to modify the Licensed Operator Requalification Training Program so as to include appropriate instruction in heat transfer, fluid flow, thermodynamics and mitigation of accidents involving a degraded core.
The following references are applicable to the clarification and helpful in drawing a perspective on the requirements for requalification training program modification, FPC's original statement of commitment, and the basis for commitment restatement.
1)
NUREG-0737, I.A.2.l(4) & II.B.4 (Denton letter, 03/28/80, Enclosure 1, C.1
& Enclosures 2 & 3) 2)
FPC's letter dated 9/15/80,3. A. Hancock to P. F. Collins, Items 2C.1 and 3C.1 3)
FPC's letter dated 12/15/80, P. Y. Baynard to D. G. Eisenhut, Item I.C.5 4)
NRC Inspection Report 50-302/81-15, dated 9/24/81, paragraphs 8.b. & 8.c.
5)
FPC's letter dated 5/5/82, D. G. Mardis to 3. F. Stolz, Question / Response Nos.1, 2, 3, 4, & 8 6)
FPC's letter dated 2/21/83, P. Y. Baynard to 3. F. Stolz, Question / Response Nos.1, 2, & 4 7)
NRC Safety Evaluation dated 4/6/83, J. F. Stolz to W. S. Wilgus 8)
FPC's Licensed Operator Requalification Trainin;; Program (Rev. 1,3/15/85) 8507260258 850723 l
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GEN ERAL OFFICE 3201 Thirty-fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 a 813-866-5151
July 23,1985 3F0785-15 1
Page 2 The requirement stated in (Ref. (1)) Denton's letter, Enclosure 1, C.1 regarding Requalification - Programs is: " Content of the licensed operator requalification programs shall be modified to include instruction in heat transfer, fluid flow, thermodynamics and mitigation of accidents involving a degraded core."
Enclosures 2 and 3 are acknowledged as providing guidance for the requalification training as well as for initial training in the subject material.
The Denton letter subject requirements in NUREG-0737, Items I.A.2.l(4) and II.B.4 related first time training in the material for RO and SRO candidates (as well as for some other specific personnel). In that the subject material training was predominantly new, licensed operators participating in the Licensed Operator Requalification Training Program, participated in the same, or essentially the same, training as all other personnel for their initial training in this subject material.
This environment existed at the time of FPC's responses to NRC questions regarding scope of training in the subject material in the Replacement Operator Training and Licensed Operator Requalification Training Programs.
FPC's responses dealt simultaneously with the replacement training and requalification program content, even committing to the same number of hours of specific training (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> of heat transfer, fluid flow and thermodynamics as well as 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of recognition and mitigation of core damage). Correspondence built a rather strong link, by early 1982, between the straight forward requirements of paragraph C.1 (Enclosure I to Denton's letter) and NUREG-0737, Items I.A.2.l(4) &
4 II.B.4 and therefore between initial training and requalification training requirements.
The NRC did focus on the requirements, however, and issued the related Safety Evaluation Report on Aprl! 6,1983. The SER's subject was NUREG-0737, Items I.A.2.l(4) and II.B.4, and dealt specifically with (see particularly " Evaluation" and
" Conclusion") requalification training in the subjects of heat transfer, fluid flow, thermodynamics, and accident mitigation. In this regard, the SER concluded that there was no basis for requiring a specific number of hours of particular training and that refresher training in subject material can be accomplished in fewer hours than initial training.
In light of the SER, and continued evaluation, it is essential that FPC clarify its commitment as follows:
FPC's Licensed Operator Requalification Training Program will include refresher training and instruction in heat transfer, fluid flow, thermodynamics and mitigation of core damage involving a degraded core. The number of hours will be as determined by appropriate program control, such as review of examination results. This is acceptable because the operators receive significant training in this subject matter during their non-license and replacement operator training programs.
This is in keeping with 10 CFR 55 Appendix A requirements for selection of requalification program topics.
The above clarified commitment is addressed by the current Licensed Operator Requalification Training Program description, Ref. (8), as follows:
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-July 23,1985 3F0785-15 Page 3 1)
Paragraph 5.1.1.(1) and (14) describe that the subject material is among the Lecture Series Topics that form the Fundamentals Review part of the Pre-Planned Lecture Series.
2)
Paragraph 5.1.2 describes the determination of depth and breadth of subject coverage presented in the Fundamentals Review Lecture Series.
This FPC commitment continues to be consistent with the Safety Evaluation Report on the subject items (Reference 7).
If there are any questions, please contact this office.
Sincerely, G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management DEP/feb cc:
Dr. 3. Nelson Grace Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323
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