B13379, Discusses Corrective Actions to Justify Continued Operation of Facility,Per Requalification Exams During Wk of 890918. Corrective Actions Sufficient to Adequatlely Address NRC Concerns Identified in 890925 Meeting

Discusses Corrective Actions to Justify Continued Operation of Facility,Per Requalification Exams During Wk of 890918. Corrective Actions Sufficient to Adequatlely Address NRC Concerns Identified in 890925 Meeting

ML20248H956
Person / Time
Site:	Millstone
Issue date:	10/03/1989
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
B13379, NUDOCS 8910120176
Download: ML20248H956 (18)

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.e NORTHEAST UTIEJTIES cen rai omee . seiden street, seriin. Conn.ciicut 1 sIE Es$eNcU"~ P.O. BOX 270 HARTFORD, CONNECTICUT 06141-0270 k L J 7[.[:$[,%~., (203) 665-5000 October 3, 1989 Docket No. 50-423 B13379 Re: 10CFR55.59 Mr. William T. Russell Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pa 19406

Reference:

(1) E. J. Mroczka letter to W. T. Russell, Justification for Continued Operation, dated September 22, 1989.

Dear Mr. Russell:

Millstone Nuclear Power Station, Unit No. 3 00erator Reoualification Examinations INTRODUCTION AND BACKGROUND During the week of September 18, 1989, the NRC Region I Staff administered requalification examinations to three crews (two operating and one staff) consisting of nine (9) senior reactor operators (SR0s) and three (3) reactor operators (RO) of Millstone Unit No. 3 and also evaluated the Millstone Unit No. 3 requalification training program. Based on the preliminary results of this examination, the Staff identified the failure of six individuals and two crews, one staff crew, and one operating crew. This result was not consistent with the Northeast Nuclear Energy Company's (NNEC0) results in that four individuals and one operating crew did not satisfactorily pass the examina-tion.

In light of these findings, on September 22,1989, NNEC0 was verbally request-ed by the Staff to provide our justification for continued operation (JCO).

In a letter dated September 22,1989 (Reference (1)), NNEC0 submitted a JC0 describing the interim measures taken to assure continued safe operation of Millstone Unit No. 3 and also agreed to meet with the Staff on September 25, 1989 to discuss the results of this examination. At the September 25, 1989 mer. ting, NNECO agreed to provide a letter to the Staff identifying the correc-tive actions taken or to be taken to justify the continued safe operation of Mill st'one Unit 3. This letter fulfills that commitment. A copy of the handouts used at the Septem'oer 25, 1989 meeting is provided in Attachment 1.

In addition, it was agreed that an additional simulator evaluation for two additional crews would be conducted on September 28, and 29, 1989. This 7-8910120176 891003 )

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. l U.S. Nuclear Regulatory Commission B13379/Page 2 i October 3, 1989 letter summarizes the discussions of the Septem!:er 25, 1989 meeting and documents the agreements reached as understood by NNECO.

SEPTEMBER 25, 1989 MEETING

SUMMARY

As stated above, a meeting was held on September 25, 1989 in Region I with the NRC Staff to discuss the results of the NRC administered requalification examination to 12 licensed operators of Millstone Unit No. 3. At the meeting, NNEC0 stated that it endorses the new process being used by the NRC to administer the requalification examinations. NNEC0 believes that this process, given time to resolve implementation concerns, provides the best measure developed to date of an operators ability to safely operate the plant in accordance with both NRC regulations, and management expectations. It allows the operator the opportunity to demonstrate his or her proficiency in the control room and plant environment rather than relying solely on a written examination.

NNEC0 discussed the requalification program for licensed operators as it is applied to Millstone Unit No. 3. Details of the program including training contact time and training content were provided. NNECO later described the Millstone Unit No. 3 emergency operating procedure (EOP) program and E0P usage. It was stated that the Millstone Unit No. 3 E0Ps are consistent with ,

and are based upon the Westinghouse Owners Group (WOG) emergency response guidelines (ERGS). Millstone Unit No. 3 licensed operators are trained on these E0Ps. During the initial development of the Millstone Unit No. 3 E0Ps, specific exceptions were taken to the WOG writers guide. Although these exceptions were not formally documented, they were an integral part of the training process. NNECO committed that a procedure for E0P rules of usage will be developed and provided for the operators use.

ANALYSIS OF THE NNEC0/NRC EXAMINATION RESULTS DIFFERENCES The NRC's preliminary results of the requalification examination were not consistent with NNEC0's results. NNEC0 evaluated four individuals and one operating crew as not satisfactorily passing the examination. NNECO analyzed the major differences between NNEC0/NRC findings, and presented the results of this analysis. The discussion of these differences focused upon three common job performance measures (JPM) and the simulator portion of this examination as described below.

The NRC failed one simulator crew based upon a single individual's lack of proficiency in the manipulation of controls. Specifically, the Staff indicat-ed during a steam generator tube rupture event, the balance of plant operator (80P) failed to promptly open the steam dumps which caused a steam generator pressure transient. This in turn caused the ruptured steam generator safety valve to lift for a short period of time (s 30 sec.). Although NNECO and NRC are in agreement with the failure of that individual, NNEC0 does not believe there is justification for failing the entire crew since supervisory personnel promptly took the appropriate actions to correct or mitigate the performance

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U.S. Nuclear Regulatory Ccmmission B13379/Page 3 October 3, 1989 of.the B0P operator. The B0P Operator committed three errors in the manipula-

- tion : of controls. After the crew correctly identified the ruptured steam generator, the B0P operator began closing the feedwater valves for the wrong steam generator. This was promptly corrected by the crew prior to the B0P

. operator's completion of the error. Second, the BOP operator was unable to open the steam dump valves for initiation of-cooldown. .After a brief period of advice and questioning from the other crew me'nbers, the supervisor properly decided to apply the alternate procedural method of dumping steam, which was performed successfully. Finally, when the atmospheric relief valve automati-cally opened on the ruptured steam generator, the BOP operator manually shut it without concurrence from supervision. The supervisor immediately directed the reopening of the valve; however, these actions caused a safety valve to momentarily lift (<30 sec.) because of the minor pressure transient.

An additional point of disagreement involves an individual failure on a second operator crew. .Specifically, the NRC failed an individual in this crew based upon actions that were not substantiated during reviews of the evaluators' documents and the videotaped events. The NRC stated that the individual transitioned out of one emergency procedure, and subsequently returned to an improper point in this same procedure. In fact, this transition was not executed, and therefore, the actions were proper The NRC also stated that actions in one circumstance were not being initiated in accordance with the plant Technical Specifications. The crew correctly logged into the Limiting Condition for Operation (LCO) for the loss of a motor control center and began to methodically evaluate the LC0 for each specific component that was deener-gized. The rough log written by the crew verifies that this action was initiated. Finally, the NRC stated that this individual did not direct the R0 to reposition motor-operated valves, as required by procedure. In the review of videotapes, it is clear that this individual understood that these. valves had no electrical power available, and their repositioning would not be possible from the control room as required by procedure. Based upon this analysis of the individual's actions, NNEC0 does not believe a failure is warranted.

The NRC and NNEC0 are in agreement concerning the status of the third crew and its individuals with respect to simulator examination results.

In the job performance measure (JPM) portion of this examination, NNECO believes that the large discrepancy between the NRC's results and NNECO's results is primarily due to the E0P step sequencing issue in JPM Numbers 01 and 29, and JPM Number 42 where the diesel generator (D/3) breaker was not opened at the kilowatt (KW) value identified in the operating procedure.

NNEC0 examiners did not fail individuals on JPM numbers 01 ard 29 because step sequence was not identified as a criterion for successful performance of the specific tasks. This was consistent with the guidance received from training management relative to performing JPM examinations, and the NRC examiners did not advise NNECO prior to or at the time of JPM administration that this would be considered a success criterion. In all instances where tasks were omitted

U.S. Nuclear Regulatory Commission B13379/Page 4 October 3, 1989 or otherwise improperly performed on these JPM's, both the NRC and NNEC0 results are in agreement.

JPM Number 42 was slightly modified by NRC examiners during the actual admin-istration of the examination. One element within the JPM had originally been structured to unload and shutdown the D/G in accordance with a specific procedure, OP-3346A.

This requirement was modified because this procedure for shutdown would consume an excessive amount of time, given the number of JPM's to be adminis-tered. Since the originally specified shutdown procedure was not to be completed as written, the NNEC0 evaluator did not understand that the OP-3346A step to reduce load to 50 KW would be considered a criterion for successful comple+. ion of the JPM. This step was difficult to perform. The lowest increment on the diesel power meter is 200 KW. Many candidates chose to reduce load to 200 - 400 KW to prevent tripping the diesel on reverse power.

This is not consistent with NNEC0 management policy for procedure use. NNECO policy requires that personnel verify with supervision any actions that do not comply with the procedure requirements, place the equipment or system in a stable condition, then write a procedure change. Our review indicated the people who successfully completed this task by reducing load to 50 KW were experienced operators generally assigned to the control boards. Interviews with additional board operators confirmed the procedure could be completed as written, but 50 KW was not the optimum load reduction. This procedure has been changed to reduce load to 200 - 300 KW.

Finally, a major disparity exists between NNEC0 and NRC results in the case of one individual's JPM performance. This disparity is mainly attributable tc the lack of proficiency in performance of tasks within the time allotted for several JPM's. Based upon review of evaluation results, the NRC and NNECO records do not agree regarding the time consumed by this individual to perform selected actions. This forms the basis of the difference in NNEC0/NRC results for this individual.

In summary, NNEC0 believes that there is sufficient evidence that only one crew and three individuals should have failed the simulator portion of this examination. Further, with consideration for this and the above discussion of JPM Numbers 01, 29, and 42, a detailed analysis would reveal less than 10%

disagreement in the overall results of this examination.

RE00ALIFICAT10N EVALUATION EFFECTIVENESS NNECO recognizes and acknowledges that some instructor examiners were not as effective as they should have been.

The simulator instructor examiners, through the lead examiner, indicated that all crews and individuals passed the simulator portion of the examination.

However, several of the decisions made by the instructor examiners were over-turned by Millstone Unit No. 3 Operations and Training management

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U.S. Nuclear Regulatory Commission B13379/Page 5 October 3,-1989 representatives based on their own observations and assessment of individual and crew performance. Maagement's expectation is that the examiners themselves should . have reached failure decisions for those cases where the g results were overturned. The NNEC0 results of the simulator portion.of this examination, as presented to the NRC at the site exit meeting on September 22, 1989, are reflective'of this expectation. - However, it is significant to note that the simulator instructor examiners did identify' and critique specific individual and crew weaknesses, even through they did not reach failure-decisions. The prin'ary reason they did not reach failure decisions was that they attempted to apply the criteria contained in NUREG-1021, Operator Licensing Examiner Standards, Section ES-601 Attachment 8 literally and did not consider the observed performance deficiencies major in that the crews did not omit procedural steps, nor did their actions. impede recovery or cause unnecessary degradation. However, while the identified weaknesses were critiqued, the lead. examiner . tended to over-emphasize positive observations i and deemphasize negative observations. Management believes that this 1 technique minimized the effectiveness and impact of the critique on the crews i being examined.  !

To ensure simulator instructors assigned to do examinations understand manage-ment's expectations, Millstone Unit No. 3 will take the following short and long term actions:

Short Term o One. Millstone Unit No. 3 management representative and the Millstone Unit i

'No. 3 Supervisor, Operator 1 raining will participate on each examination 'l team for Licensed Operator Requalification Program examinations until simulator instructor examiners are trained and qualified. The management representatives will no longer be required when examination teams are comprised of instructors who have successfully completed examiner qual-ifications. Additionally, one of the management representatives identi-fied above will lead requalification examination critiques until lead )

instructor examiners are qualified.

Lona Term o Revise Millstone Unit No. 3's simulator crew evaluation checklist to more closely reflect management's expectation versus the literal verbiage i contained in Attachment 8 of ES-601. i o The Nuclear Training. Department will establish and implement a. Simulator Examiner Training and Qualification program. The content of this program will include observation skills, listening techniques, and simulator examination criteria. Qualification will be based on examination. This 1 program will be added as a module to the already developed Simulator i Instructor Skills Training Program.

1 U.S. Nuclear Regulatory Commission B13379/Page 6 October 3, 1989 For JPM examinations, NNEC0 believes that the major discrepancies between the NRC's results and NNEC0's results are primarily due to the E0P step sequencing

' issue in JPM Numbers 01 and 29 and JPM Number 42 where the D/G breaker was not opened at the kilowatt value identified in the operating procedure. NNEC0 believes that increased sensitivity and the E0P usage procedure and associated  ;

training address this issue. In the case of JPM number 42 with respect to D/G unloading, the examiner exercised judgement that is counter to management philosophy with respect to procedural compliance. The issue was discussed with the individual examiner, and he understands that strict procedural compliance is a success criterion for all JPM examinations. This criterion has been discussed with the Millstone Unit No. 3 JPM examiners at a meeting conducted on September 26, 1989. Therefore, NNEC0 is convinced that JPM examiners are competent to conduct JPM examinations. Additionally, since simulator examiners also conduct Jr.1 examinations, the training referenced above provided to simulator examiners is expected to increase their effec-tiveness.

MANAGEMENT INVOLVEMENT IN THE TRAINING PROGRAM To ensure that Millstone Unit No. 3 continues to meet the high standards of performance expected by both NNEC0 and the NRC, NNEC0 will increase management involvement in the evaluation and examination process for license holders.

Ser 'al areas of concern raised by the NRC for which additional management involvement in the training program will enhance performance are:

1. Clear definition of control room command - This was noted as an area of concern when positions are interchanged for examination. An operations department procedure will be prepared listing the responsibilities of the contro? room personnel. This will be a compilatio1 of present require-ments contained in various station and unit procedures.

2. Communications - clear, concise, complete, and closed loop communications particularly during emergency operations will be emphasized.

3. Evaluations / Examinations - This will provide additional emphasis on the high performance standards needed to ensure license holders are capable of handling any and all upset conditions through direct management participation in training evaluation.

EMERGENCY OPERATING PROCEDVRE (EOP) PROGRAM During the week of requalification examinations, one area of concern was consistent application of the E0P network by different crews. To address this concern, it is necessary to discuss how the present usage rules were devel-i oped.

The Millstone Unit No. 3 E0P's are derived from the WOG ERG. These E0P's were developed prior to initial plant startup. During this development phase,

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l U.S. Nuclear Regulatory Commission B13379/Page 7 l October 3, 1989 )

NNECO documented detailed step deviations whenever NNECO differed from the i Westinghouse documents or were required to enter plant specific details.

Exception was taken to the WOG guidance of using " bullets" to designate those substeps in the E0P's for which order of performance is not crucial. Instead NNEC0 relied on a consistent training program content to ensure all crews q performed important steps in order. This was not formally documented nor were i other rules of usage differences except in the E0P writers guide which requires sequence to be one of the areas addressed when writing or changing an E0P.

The E0P's had been extensively used during the cold license program for initial training of the crews, and crews demonstrated that consistency of usage of the E0Ps existed. Based on the results of the examinations last week NNEC0 recognizes that there has been some diverging of application between Crews.

The following corrective actions in the area of E0P usage rules are planned:

1. E0P usage rules will be promulgated by Operating Department Procedures.

2. The licensed operators will be trained on applying the operating proce-dure for E0P usage rules. The successful completion of this training will be assessed by a written test for each of the operators. A grade of 2 80% will be required for passing.

3. The E0P writer's guide will be revised to provide guidance on the incor-poration of E0P rules of usage when writing E0P's. This will be complet-ed by November 15, 1989.

4. The E0P's will be revised as necessary to incorporate the E0P rules of usage. This will be completed by March 15, 1990.

At the completion of items 1 and 2, the purpose for establishing the manage-ment representative on shift will have been addressed and the management representative established as an interim measure will be discontinued.

MILLSTONE UNIT NOS. 1 AND 2 Based on the requalification examination experience with respect to E0P step sequencing and rules of usage, NNEC0 evaluated Milhtone Unit Nos. I and 2 to determine if similar issues existed. The results of these evaluations are summarized below.

Millstone Unit No. 1 Revision 4 of the Millstone Unit No.1 E0P's was implemented on September 1, 1989. These procedures are written and formatted consistent with guidance contained in the General Electric Emergency Operating Procedure Guidelines.

Therefore, specific E0P step sequencing guidance is integral to the Millstone

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U.S. Nuclear Regulatory Commission B13379/Page 8 October 3, 1989 Unit No. 1 E0P!s. Additionally, each license holder received approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of training, half of which was on the Mil.lstone Unit No. I plant simulator, prior to implementation of the revised. procedures. Problems related to rules of usage or step sequencing were not observed during this preimplementation training. Therefore, NNECO concludes that the problems

- observed on Millstone Unit No. 3 do not apply to Millstone Unit No.1.

- Millstone Unit No. 2 Like Millstone Unit No. 3, an E0P usage procedure has not been implemented and

. specific step sequencing guidance is not contained integral to the procedure.

While the Combustion Engineering Owner's Group guidance on step sequencing appears to be less rigid than the WOG guidelines, NNECO believes that it is possible that a sequence issue could arise in a requalification examination setting. Accordingly, NNEC0 has taken or will take actions as described below.

In June 1988, the Millstone Unit No. 2 Operations Supervisor initiated a program of simulator observation intended to:

1) share " good practices" among all shifts,

2) communicate management expectations on control room operations, and

3) conduct an ongoing evaluation of the serviceability of E0Ps.

Since the inception of this program, the Millstone Unit- No. 2 Operations Supervisor has observed each operating shift perform under simulated emergency conditions on at least three occasions. No step sequencing or other E0P problems have been observed. Recent special NRC E0P inspection (50-336/88-10) on the Millstone Unit No. 2 E0Ps identified no violations. In addition, NNEC0 has incorporated CEN-152, Revision 3 guidance into the Millstone Unit No. 2 E0Ps. Also, other improvements as recommended by the NRC E0P inspection, INP0, and our licensed operators and trainers are also included in the Millstone Unit No. 2 E0Ps.

The following additional actions have been or will be taken to further improve in this area:

1. A memo has been issued to each Millstone Unit No. 2 license holder on management's expectations with respect to E0P procedural usage.

2. Each Millstone Unit No. 2 operating crew has been briefed on the Millstone Unit No. 3 requalification examination findings relative to E0P usage and procedure compliance.

3. By March 1, 1990, Millstone Unit No. 2 will implement an E0P user's document which will resolve all step sequence and human factors

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U.S. Nuclear Regulatory Commission B13379/Page 9 October 3, 1989 related issues which may be applicable to the Millstone Unit No. 2 E0Ps . . ,

4. The Millstone Unit No. 2 E0Ps will be revised as necessary to incorporate the guidance of the E0P user's document. This will be  ;

completed by August 1,1990. ,

REEXAMINATION SCHEDUE V The NRC examined two additional crews, one on September 28, and one on September 29, 1989. The preliminary results show that both crews passed. l NNEC0's retraining plans include immediate upgrade of existing operating crews J in the specific contents of the E0P usage document. For the NRC's reexamina-tion of those individuals who failed the examination during the week of September 18, 1989, NNECO intends to request waivers for the sections that each individual successfully passed. Retraining for these individuals will occur during October - December 1989. Each individual will be required to pass NNEC0 examinations prior to NRC reexamination. For the requalification program evaluation by the NRC, NNEC0 plans to submit twelve individuals (in addition to those failed individuals) for the complete testing in mid to late January 1990.

SUMMARY

As a result of certain deficiencies identified by the NRC, NNEC0 has taken actions to correct these deficiencies. Interin corrective measures specified in the JC0 (Reference (1)) have been implemented. Additional , corrective actions planned are discussed herein. NNECO concludes that the above correc-tive actions are sufficient to adequately vidress the Staff's concerns identi-fied in the September 25, 1989 meeting. Based on the above, we are confident that public health and safety will be adequately protected during continued operation of Millstone Unit No. 3. Any questions on this matter can be directed to me or my staff.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

/ YM W LJ.pcika'~ //

Seniot Vice President cc: D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 U.S. Nuclear Regulatory Commission i Attention: Document Control Desk l Washington, D.C. 20355

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Docket No. 50-423 B13379 Attachment 1 Millstone Unit No. 3 September 25, 1989 Meeting Handouts l

1-October 1989 1 - . - _ _-- _ -__ _

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AGENDA l

LICENSE REQUALIFICATION PROGRAM MILLSTONE UNIT 3 SEPTEMBER 25, 1989 KING OF PRUSSIA J

OPENING REMARKS ED MROCZKA INTRODUCTION STEVE SCACE REQUALIFICATION PROGRAM BRAD RUTH MILLSTONE 3 EOE PROGRAM MIKE GENTRY EXAMINATION ANALYSIS RON STOITS MILLSTONE 1 & 2 CONSIDERATIONS BRAD RUTH CORRECTIVE ACTION CARL CLEMENT

SUMMARY

STEVE SCACE CLOSING REMARKS ED MROCZKA I

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I REQUALIFICATION PROGRAM BRAD RUTH REQUALIFICATION PROGRAM REFRESHER TRAINING PLANT / PROCEDURE CHANGE TRAINING EVALUATE KNOWLEDGE AND COMPETENCY REMEDIAL TRAINING CORPORATE POLICY ON REQUALIFICATION TW6 YEAR TRAINING CYCLE MINIMUM 12 WEEKS / TRAINING CYCLE MINIMUM 5 WEEKS / CALENDAR YEAR

} VP APPROVAL FOR DEVIATIONii -

TRAINING' CONTACT TIME

>60 HOURS SIMULATOR TRAINING

h. APPROX. 120 HOURS OTHER ENVIRONMENTS PERIODIC PROGRESS EXAMINATIONS ANNUAL EXAMINATIONS e

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j; REQUALIFICATION TRAINING CONTINT BASED ON JOB / TASK ANALYSIS

, IMPORTANCE / DIFFICULTY / FREQUENCY i

PLANT CHANGES PROCEDURE CHANGES OPERATING EXPERIENCE I l EVALUATION FEEDBACK OPERATIONAL NEEDS / SCHEDULES PROBABILISTIC RISK ASSESSMENT TRAINING PROGRAM CONTROL COMi4ITTEE REVIEW i

.c a I 10 CFR 55 IMPLEMENTATION g.

. NEW RULE ISSUED - 3/87 i

PROGRAMS' EVALUATED AGAINST INPO 86-025 PROGRAMS CERTIFIED TO NRC MP 1,2 - 2/88 MP 3 - 7/88 ERAM EANK DEVELOPMENT COMMENCED - 8/88 NEW PROCESS IMPLEMENTATION PARTIAL - 1988 FULL - 1989 NRC PARTICIPATION HADDAM NECK'- 5/89, 1/90 MILLSTONE 3 - 9/89 MILLSTONE 1 - 10/89 MILLSTONE 2 - 6/90 i

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MILLSTONE 3 EOP PROGRAM MIKE GENTRY l

EOP DEVELOPMENT EOP USAGE '

MANAGEMENT EXPECTATIONS m

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JOB PERFORMANCE-MEASURES- ANALYSIS s

t6 - PLANT CONTROLROOM.

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Sm F F F NOTES:

JPM (1) VERIFY DILUTION PATHS ISOLATED JPM (29)- ATWSIMMEDIATE ACTIONS JPM - (42) . LOP RECOVERY, REMOVING DIESEL FROM SERVICE BOX- NRC UNSAT F. NNECOUNSAT l ,

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SIMULATOR EXAMINATION PRELIMINARY RESULTS' L

t, CREW LIST NRC FAILURE' NU FAILURE OPERATING SRO CREW 1 OPERATING SRO SRO CREW 2 SRO SRO STAFF CREW 10 FO i

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,e CORRECTIVE ACTION INTERIM MEASURES EOP USAGE DOCUMENT TRAINING PROGRAM REVISION MANAGEMENT INVOLVEMENT IN THE TRAINING PROCESS ADDITIONAL EXAMS i

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