IR 05000352/1993027
| ML20058E438 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/29/1993 |
| From: | Conte R, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058E433 | List: |
| References | |
| 50-352-93-27, 50-353-93-27, NUDOCS 9312070014 | |
| Download: ML20058E438 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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INSPECTION REPORT NO:
95-27
FACILITY DOCKET NOS:
50-352 f
50-353
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FACILITY LICENSE NOS:
NPF-39 l
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LICENSEE:
Philadelphia Electric Company Nuclear Group Headquarters
Correspondence Control Desk
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P. O. Box 195
Wayne, PA 19087-0195
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FACILITY:
Limerick Units 1 & 2
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INSPECTION DATES:
November 1 - 5, 1993 INSPECTORS:
D. Florrk, Sr. Operations Engineer
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J. Caruso, Operations Engineer I'
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I EAD INSPECTOR:
Donald J. Florek,yf. Operations Engineer Date f
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BWR Section, Operations Branch, DRS
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APPROVED BY:
Richard J. Conte, CIElf Date BWR Section, Operations Branch, DRS i
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9312070014 931202
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PDR ADOCK 05000352 G
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INSPECTION SUMMARY: Insnection conducted November 1-5.1993 (Insnection Reoort
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No. 50-352/93-27 and 50-353/93/27)
AREAS INSPECTED: An announced safety inspection of the licensed operator
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i requalification (LOR) training program was performed to ascertain whether or not Philadelphia Electric Company was effectively performing those activities necessary to evaluate and enmre an adequate level of competency for licensed operators who operate the
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Limerick Generating Station Units 1 and 2.
I RESULTS: The Limerick LOR training program maintains competent licensed operators, since all operators examined passed a discriminating examination.
The examination outline effectively established the written and JPM examination scope. The written examination was of high quality. Adequate examination security was maintained for
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all parts of the examination.
The simulator portion of the examination was adequate to discriminate unacceptable
performance. Crew performance in the simulator was satisfactory. Facility evaluators
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identified operator actions in the simulator that were not consistent with facility procedures i
or management expectations. Facility standards in the simulator did not always contain
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measurable performance indicators. Improvements can be made in the control room to floor supervisor communication and simulation of the implementation of the T-200 series procedures during the simulator scmarios to avoid negative training.
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The JPM tasks performed were appropriate for the license level. Operators made several
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mistakes using the procedures. Facility evaluators identified the operators mistakes, but the
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facility evaluators accepted significant operator mistakes based on a consideration of
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minimum safety standards. Management expectation standards to evaluate operator i
performance were not used to make the JPM pass / fail decisions. However, management expectations were provided as feedback to the operator at the conclusion of the examination.
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The inspectors did not agree with two of the facility evaluator individual JPM pass decisions.
Despite the individual JPM pass / fail differences, the inspectors concluded that all operators observed would have passed the JPM portion of the examination with no JPM score less than l
80%.
A QA audit of the training programs that included the LOR training program was performed by the licensee and met the Technical Specification requirements.
The current licensee T-200 procedure system is not set up to minimize the time for procedure
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completion. An unresolved item was identified in Section 5.0 regarding reassessing the time validation for completion of T-200 series procedures.
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DETAILS 1.0 INTRODUCTION NRC Temporary Instruction (TI) 2515/117, " Licensed Operator Requalification Program Evaluation," was developed because of proposed rulemaking that would delete the requirement that the NRC staff examine each licensed operator for the purpose of license
renewal. The purpose of this TI was to evaluate the acceptability oflicensed operator requalification training programs through a performance-based inspection of the evaluation process and, to some extent, program revision as a result of the evaluation process. This l
was done in lieu of an NRC staff requalification examination oflicensed operators, the
results of which were used in the past to perform a program evaluation. An NRC-i administered requalification examination was not performed, since licensed operators whose l
licenses need renewal in the next two years have already received NRC-administered
examinations.
i 2.0 REQUALIFICATION EXAMINATION INSPECTION j
2.1 Scope l
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The inspectors reviewed the requalification examination for the week of November 1,1993,
the fourth week of the facility licensee examination cycle, including the examination outline, written examinations, dynamic simulator scenarios, and job performance measures (JPMs).
The purpose of the review was to assess the quality and content of the examinations. The
test items (written exams, scenarios, and JPMs) were reviewed using the guidance provided l
in TI-2515/117, Appendix A. The criteria in TI-2515/ll7, Appendix A, parallel the I
guidance contained in NUREG-1021, " Operator Licensing Examiner Standards (ES)." The l
inspector also reviewed the examination for the first week of the facility licensee examination
cycle for consistency of quality with the fourth week.
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The inspectors observed portions of the administration of the written examination and operating test to two crews, an operating crew and a staff crew. This observation included
the facility licensee evaluation of crew and individual performance on the operating test. The
inspectors also reviewed the results of the examinations that were administered the first week
of the examination cycle.
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Interviews were conducted with licensed operators, training instructors, and supervisory F
personnel to assess the examination process. Selected administrative procedures related to
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the development and administration of the examinations were also reviewed as listed below.
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Licensed Operator Program / Course Plan, Revision 00 dated 4/28/92 l
1992/1993 Licensed Operator Requalification Course Plan Revision 3 dated 10/15/93
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TAP-02.1 Simulator Training Scenario / Evaluation Scenario Development Revision j
and Implementation Revision 2 dated 9/30/93
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TAP-02.1-4 Simulator Crew Evaluation Form Revision 1 dated 2/10/93 AG-47 Operation Training Failure Policy Revision 4 dated 1/20/93 TQ-C-4 Objective and Test Construction Revision 1 dated 11/10/92 2.2 Summary of Facility Results for Examinations Administered 11/1-5/93 SRO RO TOTAL Pass / Fail Pass / Fall Pass / Fail WRITTEN 7/0 3*/0 10*/0
e JPhi 7/0 3*/0 10*/0 SIMULATOR 7/0 4/0 11/0
TOTAL 7/0 4/0 11/0 l
"One RO will take the written and JPM at a later date.
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Conclusion i
For the examinations observed, the NRC inspectors agreed with the facility overall pass / fail f
decisions as noted above.
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2.3 Examination Outline i
The facility licensee developed a reactor operator and senior reactor operator examination
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outline for each week of the examination cycle. The examination outline considerei each training topic during the two year evaluation period as well as topics not covered in training.
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The examination outline established the goal for examination coverage for each topic area.
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Conclusion i
i The examination outline effectively established the written and JPM examination scope.
2.4 Written Examination The written examinatina Lasisted of 35 questions. Part A consisted of 17 questions and part B consisted of 18 questions. The facility licensee time validated each portion of the
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examination to last an hour and a half. The facility licensee also assessed the knowledge level of each of the questions in the examination.
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The week four written examination was consistent with the NRC examiner standards. The written examination was a valid instrument to discriminate between safe and unsafe l
operators. The week four written examination was judged to be of high quality. The week j
one written examination was compared to the week four examination and was of equally high
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quality as the week four examination. The examinations satisfied the facility examination l
outline scope.
The facility licensee administrative procedures do not address the repeatability of questions
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used from one week to the next. The facility licensee used a different static simulator setup
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for each examination week. Using the examination outline summary, the inspector determined that the facility licensee used at least 55% new questions for each of the six l
week's classroom examination. The facility licensee examination development was acceptable.
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portion of the written examination and those who had not. The administration of the written
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examination provided adequate examination security.
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Conclusion
The written examination was of high quality and, therefore, an adequate discriminator of operator performance. The administration of the written examination provided adequate examination security.
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I 2.5 Simulator Examination 2.5.1 Scenario Review
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The scenarios used for week four were compared with the qualitative and quantitative
guidelines of the examiner standards. The scenario content was consistent with the NRC i
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examiner standards. However, many of the evaluation standards in the scenarios for critical j
tasks lacked objective measurable performance indicators as defined in ES-604 Attachment 1.
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All of the facility licensee scenarios reviewed contained at least one critical task standard l
l with an ambiguous performance indicator. Two examples are presented in this report.
Scenario SES-62 contained critical tasks in response to an unisolable leak in the high pressure j
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coolant injection 'HPCI) room. One of the critical tasks was to " Manually scram the
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reactor." The scenario standard is:
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"When it has been determined that a primary system is discharging into the Reactor Enclosure an_d BEFORE/WHEN it has been determined that the Maximum Safe
Operating temperature value (140*F) has been exceeded in the HPCI pump room,
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manually scram the reactor by placing the Reactor Mode Switch in the SHUTDOWN position."
i Transient Response Implementing Procedure (TRIP) procedure T-103 required a scram BEFORE not WHEN a maximum safe operating temperature is exceeded. The facility i
licensee standard exceeded the requirements of the TRIP procedures. Since the rate of temperature rise provided in the scenario was such that temperature quickly exceeded 140*F
and the crew could not reasonably be expected to scram the reactor BEFORE temperatures
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exceeded 140 F in the HPCI room, Mis aspect of the standard was considered reasonable.
However, the standard provided no bounds _on the temperature value in the HPCI room for
which the scram must be performed for acceptable performance. The standard is open
ended.
J The standard is ambiguous in other ways as well. The standard can be interpreted so that, if the crew does not determine that a primary system is discharging into the Reactor Enclosure, then the scram is not required. The standard can be interpmted that, if the crew does not
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determine a safe operating temperature has been exceeded, the scram is not required. The
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facility licensee standard did not contain SPECIFIC CONDITIONS (such as following receipt of the HPCI isolation alarm), contained SPECIFIC ACTIONS (manually scram the reactor by placing the Reactor Mode Switch in the SHUTDOWN position), and did not contain l
SPECIFIC LIMITS (such as BEFORE the HPCI pump room temperature exceeds 190*F)
that were unique to the scenario.
Another example of an ambiguous scenario standard was contained in SES-61, an ATWS scenario. The critical task was " Terminate and prevent injection into the RPV per T-270."
The scenario standard was consistent with the TRIP procedures and was:
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"WHEN suppression pool temperature exceeds 110 F, terminate and prevent injection i
into the RPV (except from boron injection systems and CRD) per T-270."
Based on the standard, the crew could be successful if they waited until suppression pool temperature reached very high temperatures, such as 160*F, to terminate and prevent
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injection. No bounds were identified on when the terminate and prevent action must be
initiated. In addition, T-270 contained multiple sections and steps, some of which were not
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critical for this specific scenario. The facility licensee standard contained SPECIFIC CONDITIONS (When suppression pool temperature exceeds 110*F), did not contain
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SPECIFIC LIMITS (such as and before it reaches 120*F), and did not contain SPECIFIC ACTIONS (such as prevent HPCI injection by closing steam admission valve, tripping RCIC, tripping three feedpumps and closing feedpump discharge valves) that were unique to the i
scenario. Directing the floor supervisor to perform T-270 on the RHR and Core Spray pumps were not critical for this scenario.
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All of the scenarios contained at least one critical task standard that was ambiguously worded and lacked objective performance indicators as defined in ES-604, Attachment 1. The
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scenario standards lacked specific limits, conditions or actions unique to the scenario.
l 2.5.2 Scenario Administration and Observation
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The facility licensee administered simulator examinations to one shift crew of four SROs and
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three ROs and a staff crew of 3 SROs 1 RO and a STA. The facility licensee used three
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scenarios for the operating crew and two different scenarios for the staff crews so examination security was not a problem. The SROs and ROs rotated positions in the scenarios. Each operator was evaluated in at least two scenarios with each SRO being evaluated in an SRO position in at least one scenario. The facility licensee rotation practice l
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was consistent with the NRC examiner standards.
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The crew performance in the simulator was satisfactory. Teamwork, communication and command and control were effective. Notwithstanding the ambiguity of the standards noted above, the crews observed in the simulator clearly performed satisfactorily during all j
scenarios observed.
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The facility evaluators were knowledgeable of the expected operator actioi ' ad facility
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procedures. The facility evaluators identified weaknesses in operator performance beyond
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that specifically addressed in the operator action description of the simulator scenario. The facility evaluators also identified performance weaknesses based on management expectations
in areas not linked to a critical task. The facility licensee evaluators use these observations j
to provide feedback to the operators.
l The crew communication with the floor supervisor when directing the T-200 series
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emergency operating procedure could be enhanced both from a crew and simulator mstructor standpoint. The floor supervisor, an SRO, normally is not in the control room and
supervises in-plant, nonlicensed operator activities. The floor supervisor was called by the
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control room staff to perform the T-200 series procedures. These procedures direct in plant activities such as performing jumper activities in the auxiliary equipment room or i
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manipulating in-plant equipment during emergency conditions. During several of the
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scenarios, the floor supervisor was given a list of 5-6 T-200 series procedures to carry out in paralle'. No priorities were assigned by the control room staff. For those procedures with multiple sections, the control room personnel did not always direct the specific sections of
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the T-200 series of procedures to be performed. The simulator instructors also did not communicate with the control room as would be expected if the in-plant operators were i
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carrying out the T-200 series of procedures. The simulator instructors did not simulate the l
nonlicensed operator call to the control room to verify valve positions prior to installing the jumpers and operation of plant equipment. See section 5 of this report for additional l
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concerns on the simulation of T-200 series of procedures. The facility practices in the
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simulation of the implementation of the T-200 series pmcedures could result in negative
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Conclusion
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The simulator portion of the examination was adequate to discriminate unacceptable performance. Crew performance in the simulator was satisfactory. Facility evaluators i
identified operator actions that were not consistent with facility procedures or management expectations. Improvements could be made in the control room to floor supervisor communication and simulation of the implementation of the T-200 series procedures during l
the simulator scenarios to avoid negative training.
2.6 Job Performance Measures (JPM)
t 2.6.1 JPM Review
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i The facility licensee prepared four sepaste JPM sets for the examinations, one set for the on shift SROs, one set for the staff SROs, one set for the on shift ROs, and one set for the staff RO. The JPMs selected satisfied the facility's examination outline scope. The tasks selected for examination were appropriate for the license level.
i The facility licensee designed the JPM sets to use two JPMs in the simulator and three JPMs in the plant. The facility licensee used three JPMs in the plant because during the two year requalification cycle the operators received a weekly evaluation in the simulator but were not
evaluated in the plant. The facility licensee indicated that they had more chances to observe operator performance in the simulator and wanted to emphasize in-plant JPMs to get a better perspective on remediation needs in the in-plant area.
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The inspector review of the JPMs identified concerns regarding the completeness of JPM steps and the adequacy of JPM standards. The inspector noted that these same concerns were identified by the facility licensee evaluators during the previous three weeks of facility administered examinations.
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The JPMs, which implemented the T-200 series of emergency operating procedures, did not contain steps to obtain the tools and equipment necessary to complete thejob. The facility licensee used the JPM instruction briefing to tell the operators that they were expected to get i
the keys and tools necessary to get the job done, but these steps were not included in the JPM. The inspectors considered that obtaining the correct equipment to get the job done is a critical step. The JPMs also did not include actions normally expected of the operator when starting equipment such as making plant announcements. The facility licensee identified in prior examination weeks the need to identify tools as part of the JPM and the need to include plant announcements.
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Some iPM critical step standards contained noncritical information and were not always sufficiently defined. For example, JPM-106P contained a critical step to " Depress INVERTER STOP red pushbutton and verify: Inverter cooling fans shut off." The standard was " Inverter STOP pushbutton depressed and inverter cooling fans off." In the first case, the critical step for this JPM was only to depress the inverter STOP push button, the verify portion was not critical for this JPM. In addition, as observed during the JPM, because of the type of inverter, the operator had difficulty and evaluator had no standard to measure
whether the inverter cooling fans were off (use panel light information, open the panel or
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some other method). Because of the inability to determine an objective measurable standard based on the procedure step, the completeness of the procedure was also questioned. The facility licensee identified similar findings in prior examination week assessments of JPMs administered.
Conclusion
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The JPM-selected tasks were appropriate for the license level. The JPMs can be improved in the area of the completeness of JPM steps and JPM standards. The need for JPM
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improvements was recognized by the facility esaluators prior to the inspection.
l 2.6.2 JPM Administration and Observation t
The on shift operators and staff operators were administered the JPM examinations on different days. Adequate separation was maintained between those operators who had the same JPMs on the same day to establish exam security.
The facility evaluators were proficient in the implementation of the JPM portion of the examination. The facility evaluators were knowledgeable of the JPM tasks and identified
when operator performance deviated from the established procedures. The evaluators used
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good techniques to administer the JPMs and avoided inappropriate cuing of the operators.
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No problems were noted during the administration of the JPMs.
The facility licensee evaluated the operator performance on JPMs as a group after the JPMs were administered. The stated purpose was to have consistency among the evaluations and to develop lessons learned.
Two concerns were identified during the observation of the JPM administration. The first was the number of mistakes made by the operators using the procedures and the second was the facility acceptance of many of these mistakes as acceptable JPM performance. The second concern is specifically addressed in section 2.7 Operator mistakes noted during the administration of the JPM portion of the examination included using the wrong equipment to perform a T-200 series task, opening the HPCI test return valve prior to HPCI turbine speed increasing and thus violating system precautions,
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operating the wrong breaker when placing a static inverter in service, using the small wheel
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rather than the large wheel during local operation of the recirculation pump motor generator scoop tube, not opening the RHR heat exchanger cooling water inlet valve prior to throttling open the RHR heat exchanger cooling water outlet valve and not throttling open the RHR heat exchanger cooling outlet valve to the maximum obtainab!e position when the RHRSW
pump has been started.
Because of the number of operator mistakes noted during the administration of the JPM, the inspector reviewed the JPM results from week 1. Operator mistakes were similar to those observed during week four. Operator mistakes were noted in securing emergency service
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water, local operation of the recirculation pump motor generator scoop tube, using the wrong
equipment for a T-200 series task, operation of RHR service water, and spraying of the l
drywell.
The number of mistakes using procedures was a concern considering that of the 50 JPMs
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administered during the week, operator mistakes were made during 7 of the JPMs. Four of l
the seven mistakes were considered by the inspector to be significant mittakes using the
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procedures.
j Conclusion No problems were noted with the facility method of JPM administration. The number of f
significant operator mistakes observed during the administration of the JPM portion of the l
examination is an area of concern.
l 2.7 Facility JPM Evaluation Method
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Five examples were observed or noted, which appear to indicate that the facility evaluators
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are accepting the observed significant operator mistakes.
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During an examination observed by the NRC inspector, the operator was given a T-l 200 series task, which required installation of four electrical jumpers. The operator obtained the electrical jumpers prestaged for a different T-200 series activity, which
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also required four electrical jumpers to perform the assigned JPM task. When the operator was simulating using the jumper the evaluator attempted to simulate taking l
the wrong jumpers by providing the cue to the operator that the last jumper did not j
reach the jumper locations. The operator did not try to retrace his steps or verify that he had the correct electrical jumpers but proceeded to determine another way to get l
'.i.e task done. The operator identi5ed an alternate means to get the task done by
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operating ventilation dampers. The alternate means identified by the operator would l
have accomplished the same function as the installation of the electrical jumpers. In
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the process of trying to perform the alternate method, the operator operated the wrong
ventilation dampers.
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As described in section 2.6.1, the facility JPMs for performing T-200 series tasks did not contain steps to obtain the correct tools and equipment needed to perform the task. Absent the step, which the inspector considered as critical, the facility evaluator
determined that the operator passed the JPM. The facility evaluator passed the j
operator on the JPM because the incorrect electrical jumpers taken by the operator
were determined by the facility evaluator, after the JPM was administered, to have
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been physically long enough to have completed the assigned task. The facility evaluator considered that he gave an erroneous cue that the jumper was too short.
The operator would have performed the task with the jumpers used and thus was evaluated as satisfactory.
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The inspectors considered that the operator should have failed the JPM since the operator used the wrong equipment, which resulted in unnecessary missing tools and equipment in the EOP tool cabinet and failed to accomplish the task with the cues
provided.
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A facility evaluator passed the operator on the JPM who opened the HPCI test retum
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valve simultaneously with starting the HPCI pump rather than waiting for HPCI pump speed to increase before opening the HPCI test return valve. The operator did not
perform the cr;tical step in accordance with the JPM standard. The facility evaluator,
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as well as the inspector, noted that the operator did not wuit for pump speed to increase before the operator opened the HPCI test return valve and it took two seconds for pump speed to increase. The procedure specifies the above sequence to l
prevent water hammer in the HPCI piping. The inspector considered that the JPM should not have been passed. When brought up by the inspector at the conclusion of
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the evaluator group review of the JPM examinations, the group subsequently
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determined that the operator failed the JPM.
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During the JPM to start the residual heat removal service water (RHRSW) system to support suppression pool cooling, the inspector observed that the operator did not
" throttle the RHR cooling water outlet valve to the maximum obtainable position without enceding 11,000 gpm or pump discharge pressure dropping below 75 psig
as stated in the critical task. The operator did not throttle the valve and indicated that
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the JPM was finished when system conditions were 8800 gpm and 85 psig. The facility evaluator passed the operator on the JPM.
Prior to the start of the facility requalification examination cycle, the facility evaluators recognized that this JPM standard could be failed by operators as worded.
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The facility evaluators determined among themselves that the JPM task would be met if the operator established flow by performing the initial setup of the RHR cooling water outlet valve and did not have to maximize flow as stated in the procedure. No l
formal revision was made to the JPM before use for evaluation. The inspector requested that the Operations Manager assess the evaluators interpretation. The
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Operations Manager subsequently reviewed the JPM performance and indicated that i
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the operator performance was sufficient to pass the JPM, not strictly in accordance
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with procedures, but that the procedure was too restrictive and would be changed to provide a band for acceptable RHRSW operation. The inspector concluded that the Operation Manager's decision to correct the procedure was appropriate. The
inspector also concluded that the facility evaluators should have formally revised the
JPM prior to use.
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During week number one of the JPM examination administration, another operator also used the wrong equipment to perform a T-200 series task with the outcome
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similar to that observed during week four.
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Another example during week one occuned during a JPM to initiate containment
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spray. The JPM was passed but significant mistakes were noted in the facility
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evaluator notes. The critical step was to * Slowly throttle the F016A Valve." The
evaluator's notes contained the following observations: the operator did not monitor
drywell pressure once while opening the spray valve, the operator operated the valve i
to full open in 45 seconds, the operator needs to be slow and deliberate, and the i
initial bump to 1500 gpm then to 5600 gpm in less than 10 seconds was way too fast.
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The notes also indicated that the operator did not remove from service all the drywell fans cooling fans, but this was not listed as critical for this JPM. The inspector
considered this step to be potentially critical based on the BWR Owner Group's
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Emergency Procedure Guideline, which indicates that it may be more damaging to spray the drywell with the drywell fans on. Based on the information reviewed by the inspector, the inspector was not convinced that this JPM was satisfactorily performed.
i Based on the above five examples of a relatively small sample of examinations, the inspector
questioned the facility licensee representatives on the use of JPM standards for evaluation.
The Operations and Training Managers informed the NRC inspectors that the determination j
of pass / fail on a JPM is whether the task was accomplished safely and not necessarily based
on whether operator performance met management expectations. Safely did not necessarily
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mean using the procedures without mistakes. If the task was accomplished and no i
precautions or limitations were violated by the mistake, then the JPM could be considered to i
be passed. The Operations and Training Managers indicated that their management
expectations are provided to the operator during the feedback of the examination results. In the case where the operator has safely completed the assigned task, but his performance did
not meet management expectations, he is told that he passed the JPM but that he did not
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meet the facility management performance expectations.
The NRC inspectors were concemed that the facility evaluators were accepting significant j
mistakes during the performance of JPMs. The evaluation process observed gave the
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appeamnce to the inspectors that the facility evaluators were attempting to justify the
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observed operator mistakes as acceptable if the task was accomplished. This practice has the potential to provide a negative message to the licensed operators that it is acceptable to depart from the procedures if the task is accomplished.
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Conclusions
Operators made several mistakes using the procedures. Facility evaluators identified the
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operators' mistakes, but accepted significant operator mistakes based on a consideration of
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minimum safety standards. Management expectation standards to evaluate operator i
performance were not used in making JPM pass / fail decisions. This practice has the potential to provide a negative message to the licensed operators that it is acceptable to
depart from the procedures if the task is accomplished. Management expectations were i
provided as feedback to the operator at the conclusion of the examination.
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NRC inspectors did not agree with two of the facility evaluator individual JPM pass decisions. However, in spite of the individual JPM pass / fail differences, the NRC inspectors
concluded that all operators observed would have passed the JPM portion of the examination with no JPM score less than 80E I
3.0 INTERVIEW RESULTS The interview portion of the inspection did not identify any problems with the operations / training interface. In general, the operators are satisfied with the training i
i provided and that the evaluation process resulted in fair examinations and evaluations. The operators indicated that vast improvements in training have occurred in the last few years.
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The operators indicated that training is listening to, and acting upon, the operator feedback.
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The training instructors are knowledgeable and are of high quality
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An example of operation training interface activities is the recent improvement made in the
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written examination development process. Each operator was assigned some of the questions
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in the written examination bank to assess for operational validity. The response from the -
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operators resulted in changes made to about 40% of the questions. Operator feedback from
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the recent written examinations support that the test was operationally relevant.
The interviews identified that operations has assumed an ownership of the training program.
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Operations and Training have developed an Operations Strategic Training Agreement, which includes operator satisfaction based on timeliness, effectiveness, relevancy and resources
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expended. Operations personnel will rotate for a two year assignment as training instructors.
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Shift Managers have been assigned the responsibility to assure that the individual and crew
pass the requalification examination.
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4.0 QA AUDITS l
In the period 8/23/93 to 9/27/93, the Nuclear Quality Assurance (NQA) organization conducted the annual audit of training required by technical specification 6.5.2.8. The audit i
included, nonlicensed operator, licensed operator, technical staff, and management, and shift technical advisor initial and continuing training programs. The scope of the audit was
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approved and included the comments from the Nuclear Review Board. The audit concluded,
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in part, that on the job training, simulator training and training effectiveness are being performed in accordance with the common nuclear procedures. The inspector determined
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i that the audit met the technical specification requirement. The QA audit observed the performance of six JPMs over all training programs audited. Due to the small sample size in
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the JPM evaluation area; and, since the LOR JPM requalification evaluations were not -
performed during the audit period, it is reasonable that the audit did not identify any i
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, neerns with facility LOR evaluation practices during JPMs.
5.0 TRANSIENT RESPONSE IMPLEMENTING PROCEDURES (TRIP) (T-200 SERIES)
The T-200 series procedures are those procedures, which implement specific actions to be carried out in emergency conditions as directed by the flowchart TRIP procedures.
During ATWS scenarios in the simulator portion of the examination, the inspector noted that
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the control room personnel were requesting the floor supervisor to perform 5-6 T-200 series procedures in parallel. The simulator scenarios were designed to have many of the T-200
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procedures performed in the auxiliary equipment room completed in 3-5 minutes. The inspector questioned whether the facility licensee had a basis for the completion times of the T-200 procedures. The facility licensee representative indicated that the only time estimates for these tasks were contained in the JPMs. The JPM time limits were of the order of 15 minutes and do not include travel times. However, the inspector noted that 15 minutes may l
be unrealistically long if these tasks were being performed during an emergency. If the established times for completing JPMs plus travel time were used in the dynamic simulator for completion of the T-200 series tasks, it would result in significantly different and drastic operator actions such as emergency blowdown of a critical reactor. In order not to provide negative training, times used in the simulator need to be at least as long as expected to be
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completed in the plant. In Section 2.4, the inspector also noted some simulation
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communication enhancements to make these tasks more realistic.
The current location of the procedures and tools and equipment for performing the T-200
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tasks for the ATWS do not result in time efficient performance of the task. The individual l
designated to perform the tasks, the floor supervisor or non licensed operator, will most likely be in the plant. The individual will need to go to the control room and in doing so will be required to perform a whole body frisk prior to entry. A copy of the current procedure will need to be inade by the shift clerk or individual. The floor supervisors interviewed indicated that they would probably take the original rather than take the time to make a copy as is the practice in accordance with the administrative procedures. The individual then will need to open the TRIP tool locker in the control room to get the proper tools and equipment. The floor supervisor has the key for the locker but the non licensed operator does not. (It should be noted that twice during the requalification examinations operators obtained the wrong tools and equipment). The operator then will need to go to the work area either in the auxiliary equipment room or the plant to perform the task.
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Since floor supervisors and nonlicensed operators perform the T-200 tasks, the facility
licensee representative agreed to reassess the ability of the T-200 series procedures to be
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implemented in a time period consistent with the times needed based on the accident sequences applicable to the task. For example, the time required to complete T-221 to jumper out the MSIV closure on low level could be based on the time for RPV level to reach
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-129" for a full power ATWS with SLC and rod movement failum and RPV injection sources terminated and prevented when suppression pool temperature reached 110 F.
The inspector had three comments questioning the adequacy of procedure T-217, "RPS/ARI Reset and Backup Method of Draining Scram Discharge Volume." First, T-217 requires obtaining keys for the Auxiliary Equipment Room Panels. This step may be unnecessary for this procedure and other T-200 series procedures and take additional time since the panels are no longer locked. Second, after step 4.1.8, there is no step provided to wait until the
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scram discharge volume is sufficiently drained before a manual scram is attempted. Third, if Step 4.2.1 is not necessary for step 4.2.2 to be effective then performing Step 4.2.2 first can eliminate procedure step 4.2.1.
i Pending the licensee actions on reassessing the time validation of T-200 series procedures, this item in unresolved. (URI 352/93-27-01 and 353/93-27-01). An unresolved item is a
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matter about which more information is required to ascertain whether it is an acceptable issue, a deviation or a violation.
i 6.0 FACILITY LICENSE /NRC STAFF MEETINGS August 5,1993, Meeting On August 5,1993, at the request of the facility licensee, a meeting was held in the Region 1 office to discuss the plans for the facility-administered requalification examinations and to l
discuss implementation of revision 7 of the NRC examiner standards. No handouts were exchanged. The attendees were:
Philadelphia Electric Company
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T. Dougherty, Operations Training Manager L. Hopkins, Operations Manager
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R. Ruff, Principle LOR Instructor i
B. Stanley, Assistant Operations Manager j
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U.S. Nuclear Regulatory Commission D. Florck, Sr. Operations Engineer R. Conte, Chief BWR Section
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October 14, 1993, Meeting (Open) Deviation CVo. 352. 353/92-01-Olh Deletion of Thermal Hydraulic Instability Criteria. On October 14,1993, a meeting was held between the NRC staff and the facility licensee at the NRC Region 1 office. The purpose of the meeting was to provide the facility licensee the opportunity to discuss their response to the NRC Examination Report No. 50-352/353/93-18.
The facility licensee updated all of the issues raised by the NRC in the September,1993, examination report. The meeting provided an open exchange of information about the operator response to positive reactivity events and diagnoses of possible reactor instability indications. The meeting was of mutual benefit to both parties. The facility licensee agreed to provide us with additional information about the power instability issue by November 1,1993. The licensee's response of November 1,1993, should resolve staff concerns in this area pending completion of corrective actions. No handouts were exchanged. The attendees were:
Philadelphia Electric Company T. Dougherty, Manager Operations Training J. Muntz, Director Site Engineering K. Walsh, Manager Rx Engineering D. Neff, Regulatory Engineer S. Tanner, NMS System Manager P. Driehaus, PECo Operations B. Maiers, PADER/BRP P. Jenks, Mercury Pottstown U.S. Nuclear Regulatory Commission M. Hodges, Director, DRS R. Conte, Chief, BWR Sxtion S. Hansell, Operations Engineer
H. Williams, Senior Operations Engineer T. Easlick, Resident Inspector
- L. Phillips, NRR, SRXD
- H. Richings, NRR, SRXB (*) Denotes those personnel in attendance by phon f
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7.0 EXIT MEETING An exit meeting was conducted November 5,1993, following the completion of the site visit.
l The NRC inspector presented the inspection related findings. The facility liccnsee representadves acknowledged the NRC inspector findings. Exit meeting attendees are listed j
below.
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Philadelphia Electric Company
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V. Cwietniewicz, Director Training T. Dougherty, Operations Training Manager
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L. Hopkins, Operations Manager J. Hutton, Shift Manager P. Orphanos, LOR Instmetor R. Ruff, Principle LOR Instructor
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G. Stewart, Engineer Experience Assessment
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U.S. Nuclear Regulatory Commission
J. Caruso, Operations Engineer
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D. Florek, Sr. Operations Engineer i
N. Perry, Sr. Resident Inspector
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Attachment: Simulation Facility Report
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ATTACIIMENT 1 SIMULATION FACILITY REPORT Facility License: NFP-39/85 Facility Docket No: 50-352/353 Requalification Operating Test Observation: November I-5,1993 This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without funher verification and review, indicative of noncompliance with 10 CFR 55.45(b). These obst vations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluations. No licensee action is required in response to these observations.
During the conduct of the simulator portion of the operating tests, the following items were observed.
JTEM DESCRIPTION None hr
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