IR 05000245/1993017

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Insp Rept 50-245/93-17 on 930726-29.No Violations Noted. Major Areas Inspected:Licensed Operator Training Program & Conversion of EOPs from Text to Flowchart Format
ML20056D542
Person / Time
Site: Millstone Dominion icon.png
Issue date: 08/06/1993
From: Conte R, Sisco C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056D536 List:
References
50-245-93-17, NUDOCS 9308170058
Download: ML20056D542 (11)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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REPORT NO:

50-245/93-17

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DOCKET NO:

50-245 LICENSE NO:

DPR-21 LICENSEE:

Northeast Nuclear Energy Company l

l P. O. Box 270

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Hartford, CT. 06141-0270

FACILITY:

Millstone Unit 1 Nuclear Power Station

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INSPECTION DATES:

July 26-29,1993 INSPECTORS:

D. Florek, Sr. Operations Engineer C. Sisco, Operations Engineer

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J. Debor, SEA

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W LEAD INSPECTOR:

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Carl Sisco, Operations Engineer Date BWR Section, Operations Branch Division of Reactor Safety

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APPROVED BY:

<) zu dD Richard J. Conte, C)}I6f Date BWR Section, Operations Branch Division of Reactor Safety

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I 9308170058 930811 PDR ADOCK 05000245 O

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INSPECTION SUMMARY: Insoection conducted July 26-29.1993 (Insoection Reoort 50-245/93-17 AREAS INSPECTED: A regional initiative safety inspectioa was conducted of the licensee's licensed operator training program by observing classroom training and reviewing training materials.

An inspection of the licensee's conversion of the Emergency Operating Procedures (EOPs)

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from text to flowchart format was conducted to address Unresolval Item 50-245/92-32-01.

A Human Factors review of the EOP flowcharts was conducted to address Unresolved Item

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50-245/92-Il-01.

An inspection of the mechanical maintenance training records concerning plant systems training was conducted.

RESULTS: Based on the observed classroom training and the review of training materials, training of licensed operators is adequate to assm safe plant operations. An operating crew demonstrated the flowcharted EOPs are useable and they are trained in their use. On a sampling basis, the inspector determined that mechanical maintenance training records specific to plant systems training are maintained in accordance with licensee procedural requirements.

(CLOSED) URI 92-11-01 concerning Human Factors review of the EOP flowcharts. The flowcharts are constructed using established Human Factors principles.

(CLOSED) URI 02-32-01 concerning a review of the EOPs. The EOPs are consistent with the BWROG Emergency Procedure Guidelines. Deviations are documented in the Deviation Document. Enhancements will be made to the EOPs following the next refueling outage.

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DETAILS 1.0 INTRODUCTION In September 1991 and again in September 1992, the NRC found the licensed operator requalification training program at Millstone Unit I to be unsatisfactory. As a result, Region I initiated additional inspections to assure continuing high quality training of licensed operators with respect to safe plant operations.

All technical issues regarding the EOPs are resolved, and are discussed in Inspection Reports 50-245/92-11 and 50-245/92-32. The scope of this inspection was to verify that the technical

content of the flow charted EOPs is consistent with the text formatted EOPs, are technically accurate, and incorporate Human Factors principles. NRC Inspection Procedure 42001 was used as a guide during the conduct of the EOP inspection.

2.0 REQUALIFICATION TRAINING ACTIVITIES

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Scope

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The inspector reviewed the ongoing training activities the week of July 26,1993. The facility licensee's ongoing training activity included the normally-scheduled requalification crew, portions of one crew in remediation, and the dayshift crew performing simulator training after performing dayshift duties. The inspector observed simulator training and evaluation and a classroom session on the emergency plan.

Findings The training sessions were performed in an organized and structured manner. The instructors were knowledgeable and presented the information in clear and concise manner.

The operators were actively participating in the sessions. Good attitudes were displayed by both the instructors and operators. When a simulatu scenario was completed, the operators self critiqued their performance after reviewing the video tape of the session and then the instructors provided any additional amplification of the operator's performance. The operator's self-critique was consistent with the eveluators. However, the crew in remediation did not always identify the same level of performance as the evaluators. Except for the crew in remediation, the crew performance observed in the simulator was notably strong.

The facility licensee continued to probe in the observed performance for the crew in

remediation and identified additional individual weaknesses in the operators. The training staff then developed additional training techniques to assist the operators development activit.

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e Conclusions

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The training sessions observed were of a high quality. The facility evaluators properly-l assessed opemtor performance. The training staff developed training specific to the-individual weaknesses noted in the crew in remediation.

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3.0 PRIOR REQUALIFICATION CYCLES OPERATOR PERFORMANCE AND j

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ATTENDANCE i

Scope The inspector reviewed the performance records and attendance records for 1993.

Findings q

t The facility licensee records attendance at training sessions and has developed a computer.

l based system to keep track of operator completion of the required training. The facility licensee has documented their requirements for attendance in NTM-3.028, "Requalification

Program," dated April 13, 1993. Missed training must be made up. The instructors assigned to a crew review the attendance records prior to beginning a training week to identify the training that specific operators must make up during the week. Records for

cycle 93-2 and 93-3 indicate that all training has been adequately provided. Records for

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Cycle 93-4 indicate that two operators have some training to make up, and this makeup

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training will be provided in the ongoing cycle 93-5.

Review of the weekly written examination results for 1993 indicate that operator performance is increasing. When less than acceptable performance is identified on a weekly written j

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examination, the operator is placed in a remediation program that, when successfully completed, will enable the operator to return to licensed duties. In cycle 93-1, nine operators needed remediation. In cycle 93-2, three operators required remediation and in cycles 93-3 and 4 one operator required remediation. Cycle 93-5 is in progress, and three operators are in a remediation status. A review of the written examination for cycle 93-5 indicated that the examination was a challenging examination consistent with the NRC examiner standards.

A remediation program also exists for those operators and crews who do not satisfactorily.

perform in the weekly simulator evaluation. One crew failed in cycle 93-2 and one crew failed in cycle 93-5. The crew who failed in 93-5 were observed in training as discussed above.

The results of cycle 93-5, which is ongoing, have had three individuals fail the weekly written examination and one crew failing the weekly simulator evaluation. Two of the three operators in remediation for the written examination performance this cycle have a prior history of knowledge weaknesses, and the third operator is an operator who normally is in

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the upper percentile of good performers. The crew failure is a crew that consists of operators with a prior history of performance weaknesses in the simulator. The facility

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licensee is monitoring those operators with a history of frequent remediation needs for future reassessment of license operator resources. The facility licensee will not return an individual to licensed duties until the operator has successfully mastered the knowledge and abilities identified in the requalification training program cycle.

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Conclusions The facility licensee monitors attendance at requalification classes and assures that missed training is made up. Individual knowledge is improving. Those individuals who have a history of a need for remediation are being monitored by the facility.

4.0 LICENSEE ACTION ON PREVIOUS INSPECTION FINDINGS 4.1 (Closed) Unresolved Item 50-245/92-11-01 Concernine Iluman Factors Review of Flowcharted EOPs Scope The scope of the Human Factors review was an evaluation of the EOPs in the following areas:

o EOP network organization o

Structure and design

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Step type and usage o

Figures and tables o

Flowchart techniques o

Flowpath execution o

Referencing and branching Findings 590 Series Procedures The Emergency Operating Supplemental Procedures (590 series) are text-based procedures used in conjunction with the flowchart procedures. The inspector determined the flowchart

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EOPs correctly reference the appmpriate supplemental procedure (s). However, the supplemental procedures do not correctly reference the EOP flowcharts in five procedures reviewed.

The procedures reviewed and the incorrect references are:

i EOP 590.1, " Maximizing CRD Flow," Rev 0, should reference 570 RPV Control.

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EOP 590.8, " Primary Containment Spray," Rev 0, should reference 570 RPV

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Control" EOP 590.10, " Shifting LPCI Pump Suctions from the Torus to the CST," Rev 0, should reference 570 RPV Contml and 575 Failure to Scram.

l EOP 590.24, " Alternate Shutdown Cooling System," should also reference 570 RPV Control.

EOP 590.26, " Containment Cooling During Accident Conditions," should refer to 580

Primary Containment Control.

Annunciator Alarm and Resnonse Procedures The Annunciator Alarm and Response procedures refer in a number of cases to the EOP flow charts. The inspector determined these procedures have not been updated to transition the

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operator into the correct EOP. As an example, alarm, " REACTOR HI/LO LEVEL,"

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annunciator A-2, control room panel 905 transitions the operator into EOP 571 and 572.

The correct EOP to be transitioned into is EOP 570 RPV Control.

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The licensee stated the 590 series procedces and Annunciator Alarm and Response

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procedures will be revised to reflect the appropriate EOPs. The procedure revisions will be

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made during the in-progress procedure upgrade program and will be completed by the last quarter of 1993.

EOP Flowcharts The inspector reviewed the EOP flowcharts and supporting documentation identified on

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Attachment 1. The review included table top reviews, interviews with procedure writers, and observations of EOP use during simulator scenarios.

The inspector determined the flowcharts are constructed and written in accordance with licensee EOP requirements. In addition, the EOP flowcharts adhere to Human Factors principles. In the simulator, an operating crew clearly demonstrated the EOP flow charts are effective in mitigating plant upset condition n

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Conclusions The inspector determined the EOP flowcharts are constructed and written in accordance with licensee EOP requirements. In addition, the EOP flowcharts adhere to Human Factors principles. In the simulator, an operating crew clearly demonstrated the EOP flowcharts are effective in mitigating plant upset conditions.

4.2 (CLOSED) Unresolved Item 50-245/92-31-01 Concernine Review of Flowcharted E0Ps The inspector reviewed the EOP flowcharts and supporting documentation identified on Attachment 1. The inspector identified that the EOP flowcharts are consistent with the EOP Technical Guidelines and the Boiling Water Reactors Owners Group emergency guidelines (EPGs). Deviations from the EPGs are well documented and supported by a Safety Evaluation Report.

The inspector determined the EOP R echarts provide accident mitignion strategies that are consistent with NRC endorsed ar.:iden. mitigation strategies.

As a result of this inspection, die ins,x:ctor identified, and the licensee concurred, that enhancements to the EOP flow charts should be made These enhancements are as follows:

EOP 570, Sheet 2, " Alternate Level Control," - The procedure will be enhanced by adding the phrase "or ESW is available" to step ALC-15. This enhancement will provide an additional condition to transition into EOP 575, Sheet 5, " Primary Containment Flood."

EOP 570, Sheet 5, " Primary Containment Flood," - The procedure will be enhanced to provide additional criteria to terminate injection from sources external to containment before a given containment pressure is exceeded during the containment flooding evolution.

EOP 575, Sheet 4, ATWS - RPV Flood (Table 3) - The table will be revised to identify the number of Safety Relief Valves OR Turbine Bypass Valves required to be open.

EOP 580, " Primary Containment Control," - The procedure will be enhanced to clarify directions to transfer containment venting from the torus to the drywell in the event torus water level exceeds 24 feet.

Also, the inspector identified, and the licensee concurred, that an enhancement to EOP Supplemental procedure 590.20, " Bypassing All Group I Isolation Interlocks," should be made. The enhancement will provide additional directions to conduct an RPV depressurization during the containment flood evolutio '

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The licensee stated the enhancements to the EOP flow charts and the Supplemental procedure 590.20, " Bypassing All Group I Isclation Interlocks," would be made during the next

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refuelling outage scheduled for January 1994.

Conclusions

The inspector concluded the EOP flowcharts are consistent with the EOP Technical Guidelines and the Boiling Water Reactors Owners Group emergency guidelines (EPGs).

Deviations from the EPGs are well documented and supported by a Safety Evaluation Report.

The inspector concluded the EOP flowcharts provide accident mitigation strategies that are consistent with NRC endorsed accident mitigation strategies.

5.0 USE OF EOPS Scope

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As a part of the inspection of the flowcharted EOPs, the inspector conducted two scenarios using the plant referenced simulator. The purpose of the scenarios was to verify that the EOPs are useable and plant operators have been adequately trained in their use. An operating crew in their training cycle demonstrated the use of the EOPs.

Findings

The first scenario consisted of a leak inside primary containment with the failure of Emergency Core Cooling Systems to actuate automatically. The second scenario con isted of a turbine trip, without turbine bypass valves, concurrent with a failure of the reactor protection system to initiate a reactor scram.

In both scenarios, the flowcharted EOPs provided directions to the operators Juring plant upset conditions. Following each scenario, discussions were held with the operating crew.

Based on the discussions held with the operating crew and observations during the scenarios, the inspector determined the operating crew is trained in the use of the EOPs.

Conclusions The inspector determined the flowcharted EOPs provided directions to the operators during plant upset conditions. In addition, the plant operators clearly demonstrated they are trained in the use of the EOPs.

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6.0 MALVTENANCE TRAINING RECORDS INSPECTION

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Scope The scope of the inspection was to review the training records of mechanical maintenance personnel of Unit 1 in the area of plant systems training.

Findings The inspector reviewed the following maintenance procedures:

NTM 3.121, " Millstone /CY Mechanical Maintenance Training Program Implementing

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Procedure" NU-TI-MIT (88-91.4), " Training Program Description" NTM 1.05, " Validation of Equivalent Training" Following the review of these procedures, the inspector reviewed the training records specific to plant systems training of mechanical maintenance personnel of Unit I for the year 1990.

The inspector determined that not all mechanical maintenance personnel attended the plant systems training; however, the training records indicated that they had attended the training.

The apparent inconsistencies in the training records are because NTM 1.05, " Validation of

Equivalent Training," allows certain individuals to be excluded from plant systems training.

The decision to exclude certain personnel is made by maintenance department managers based, in part, on previous training received and plant experience. A form is placed in the individual's training record indicating the date that plant systems training was waived.

i The training records reviewed by the inspector contains the date in which the plant systems training was conducted or the date in which the individual was waived from attendance of the j

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Conclusions On a sampling basis, the inspector determined that mechanical maintenance training records j

specific to plant systems training are maintained in accordance with licensee procedural requirements.

7.0 EXIT MEETING An exit meeting was conducted at the Training Center on July 29,1993. The results of this inspection were discussed. Personnel contacted during the inspection are noted below.

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NORTIIEAST UTILITIES

  • H. Haynes, Director Unit 1
  • M. Brown, Project Manager Operator Training Unit 1
  • R. Heidecker, Unit 1 Training Supervisor
  • P. Prezekop, Manager, Unit 1 Operations
  • C, Tabone, Supervisor, Operator Training Unit 1
  • W. Noll, Operations Assistant, Unit 1
  • D. Harris, NUSCO, Licensing Engineer B. Ruth, Manager, Operator Training J. Black, Director, Nuclear Training N. Jain, Safety Analysis Branch L. Chatfield General Training U.S. NUCLEAR REGULATORY COMMISSION

'C. Sisco, Operations Engineer-i

  • D. Florek, Sr. Operations Engineer
  • K. Kolaczyk, Resident Inspector i
  • J. Debor, Science and Engineering Associates

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  • Denotes those present at exit meeting conducted July 29,1993.

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Attachment: Procedures Reviewed

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ATTACIIMENT 1

PROCEDURES REVIEWED

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EOP FLOW CHARTS 590 SERIES PROCEDURES EOP 570 RPV Control EOP 590.I, " Maximizing CRD Flow" j

Sheets 1-5

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EOP 590.8, " Primary Containment Spray" EOP 575 (ATWS)

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Sheets 1-5 EOP 590.10, " Shifting LPCI Pump' Suctions From The Torus

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To The CST"

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EOP 580 Pri Cnmt Cntrl EOP 590.24, " Alternate Shutdown Cooling System" l

EOP 585 Sec Cnmt Cntrl EOP 590.26, " Containment Cooling During Accident

Conditions"

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i MAINTENANCE PROCEDURES EOP PROGRAM PROCEDURES j

q NTM 3.121 " Millstone /CY Mechanical EOP 550.3(4) EOP VAV Program

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Maintenance Training Program EOP 550.5 V&V Program for EOP Supplemental

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Implementation Procedure" EOP 560.1 EOP Writers Guide -

EOP 560.2 EOP Supplemental Procedures Writers Guide NU-TI-MIT (88-91.4), " Training EOP 560.3 EOP Technical Guidelines & Safety l

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Evaluation Program Description" I

i NTM 1.05, " Validation and n

Equivalent Training" i

NOTE: V&V is Validation and Verification

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