IR 05000245/1997085

Insp Repts 50-245/97-85,50-336/97-85 & 50-423/97-85 on 971001-17,1120-21 & 1204-12.No Violations Noted.Major Areas Inspected:Simulator Portion of Annual Operating Tests of Licensed Operator Requalification Training Programs

ML20202F678
Person / Time
Site:	Millstone
Issue date:	02/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202F649	List: IR 05000245/1997085 ML20202F645
References
50-245-97-85, 50-336-97-85, 50-423-97-85, NUDOCS 9802190274
Download: ML20202F678 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

i Docket Nos: 50 245;50-336;50 423 Report Nos: 50 245/97 85;50-336/97-85and 50-423/97-85

Licensee: Ncrtheast Nuclear Energy Company

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Facility: Millstone Stations Units 1,2&3 r Location: Waterford, CT

Dates: - Ocuber 1-17,1997 November 20 21,1997-December 4 5 & 11-12,1997 d

- Inspector: Donald J. Florek, Sr. Operations Engineer

!- Julian H. Williams, Sr. Operations Engineer John Caruso, Operations Engineer Joseph M. D' Antonio, Operations Engineer Todd Fish, Operations Engineer l

Approved by: G. Meyer, Chief Operator Licensing and Human Performance Branch Division of Reactor Safety

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9002190274 990206

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PDR G ADOCK 05000245 PDR

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EXECUTIVE SUMMARY poeratiorn Five inspectors conducted an announced inspection of the simulator portion of the annual operating tests of the licensed operator requalification training programs for Millstone Units 1,2 and 3. A total of eleven crews was observed. In addition, the inspectors reviewed the progress on the nine items of Confirmatory Action Letter (CAL) 197-010, evaluated a facility identified issue on Unit 1 training department staffing, and reviewed a Unit 3 unresolved item concerning operator response to a steam generator tube ruptur The inspectors judged the crews' performance in their annual operating tests to be acceptable. The simulctor scenarios were at an appropriate difficulty level, and facility evaluations were detailed and thorough. One Unit 3 crew failed their simulator test due to misinterpretation of an emergency operating procedure foldout page step and was remediated. Crews passed the remaining scenarios. SIL 86 on operator performance remained open to address reviews of additional operator training on Unit 3, including training on roodifications and restart operational evolution The inspectors closed CAL ltems 4 and 5 regarding Unit 3 initial operator training, based on corrective actions and the successful performance of eight Unit 3 operator candidates on the July 1997 NRC license examinations. The inspectors closed CAL ltem 6 regarding reviews of medical certifications of licensed operators, based on the cempleted corrective actions. The remaining six CAL items were reviewed but remain open. The inspectors reviewed the facility resolutions of training deficiencbs on Unit 2 and Unit 3 operators and agreed with the facility regarding which of the affected licensed operators could perform licensed dutie The inspectors agreed with the facility conclusion on a CR that Millstone 1 training management had allowed licensed operator requalification training staffing to decline to levels unable to support continuing training. Personnel and priorities have been reassigned to address this problem. An unresolved item was issued to address the consequences of the staffing problem and the possibility of similar staffing issues at Units 2 and The facility appeared to be addressing the concern raised in a previous unresolved item on steam generator tube rupture by operator training and reanalyses of accident assumption Analyses were not complete and this unresolved item remained ope ii

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Reoort Details 04 Operator Knowledge and Performance a. Scope The inspectors observed numerous crews for each of the three Millstone units perfoi... the simulator evaluation portion of their annual operating test for the licensed operator requalification training program. On Units 2 and 3 the observation involved three operating crews (two scenarios per crew) on each unit - a total of 12 scenarios. The Units 2 and 3 observations occurred during the first three weeks of October 1997. On Unit 1 the observations involved tiaree coerating crews and two staff crews (two scenarios per crew)- a total of another 10 scenarios - during three weeks in late November 1997 and early December 199 Crew performance, scenario quality, and facility grading were evaluated. The Examination Standards (NUREG 1021) was used as a standard, b. Observations and Fhdinos Scenario ouality For all units, all scenarios and scenario sets met the criteria of the Examination Standards. The scenarios had an appropriate level of difficulty and were comparable in difficulty level to scenarios used at other facilities. The scenarios provided an effective means to evaluate operator performance during their use of normal, abnormal, and emergency procedure In a previous requalification inspection, NRC had found the Unit 2 scenarios to generally be weak and lack diversity among different scenarios, in this inspection, one of the three sets administered on Unit 2 was less challenging than the remaining sets, but was nonetheless an adequate evaluation tool. This represented an improvement in scenario quality at Unit 2. Training representatives noted that efforts to improve the scenario bank were uriderway but minimal progress had been mad Qew Performance and Evaluation On Unit 1 the crews performed acceptably and all crews passed. The facility evaluators identified severalinstances where crew communications and briefings were not at the level expected by operations management. Also, the facility evaluators determined that one SRO in an operating crew should be placed in a remediation program because of command and leadership performance belaw the facility standards. These performance issues, including the individual performance issue, did not affect the scenario outcome. All operators would have been graded as satisfactory in a NRC-administered exam. The facility standards specified a higher level of performance than required by the NR __

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On Unit 2 the crews successfully implemented the actions required to mitigate the scenario events, and all crews passed. The level of crew performance represented a noticeable improvement from the two previous times the inspector had witnessed Unit 2 operators perform simulator scenarios. The notable difference existed in the ability of the crews to use the EOPs in a controlled manner to mitigate the events with all crew members being aware of the plant's status; previously, examples existed in which crew members were poorly coordinated or had miscommunicate The facility evaluators identified several instances where crew briefs, communication practices, supervision of reactivity, or general command did not meet their expectations and needed improvement. These performance issues did not affect scenario cutcomes, would not have resulted in any adverse results in NRC stand alone grading, and represented areas for improvement of operator performance. These issues were recorded in the facility's performance improvement system, 7 On Unit 3 two operating crews passed and one operating crew failed, due to an improper procedure transition resulting from misinterpretation of a foldout page criterion in the steam generator tube rupture (SGTR) emergency operating procedure (EOP). The foldout page requirement for safety injection (SI) reinitiation criteria stated that if pressurizer level decreased to 17%, emergency core cooling system (ECCS) pumps should be operated as necessary, and a transition to another procedure be made. The crew made this transition at 17%, but the problem was that they had NOT terminated safety injection (they had only shut down one charging pomp); therefore, the transition was unnecessar One of the crews that passed was weak in recognizing failed automatic actions. In one cenario, this crew took 5 minutes to realize that containment depressurization actuation had not automatically occurred, and in another scenario they faisod to recognize that the terry turbine auxiliary feed pump should have started on a reactor trip from 100% power. Neither of these deficiencies had any effect on a scenario outcom Fcr both units, the facility evaluations were appropriately detailed arH critical. The Unit 3 evaluators failed the crew that made the improper EOP transitio Rem 3diation The crew that had failed had a specific knowledge deficiency which was remediated and retested the following week. The facility provided the remediation package and retake simulator exam scenarios by mail. The inspector reviewed this material and considered the remedial training and evaluation to be appropriat _-

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c. - : Conclusions F All eleven crews observed were competent and$ generall'y performed acceptabl ~

One crew failed due to a specific _ knowledge deficiency, which was remediated the following week. All of the five inspectors who observed these crews considered -

- their performance adequate for the observed crew to support tl e restart of their >

unit The scenarios had acceptable quality to properly evaluate the operators, and the resulting evaluations were good with effective involvement from the operations departmen SIL (Startup Issue List) 86 on operator performance remains open pending further NRC observation and review of crew performance with a focus on Unit 3 crews, particularly training on modifications and restart operational evolutions.:

- 05 Operator Training and Qualification Confirmatory Action Letter (CAL) 1 97 010 Confirmatory Action Letter 197-010 was issued on March 7,1997,in response to a March 3,1997 letter from Northeast Utilities which transmitted an Independent -

Review Team report (IRT) concerning Millstone 1 examination failures. The inspectors reviewed the IRT, the corrective action plan (CAP), submittels in-response to CAL items, and facility actions addressing deficiencies regarding all -

three Millstone units.E The purpose was to determine the status of corrective actions and what CAL items could be closed. Each of the nine CAL ltems is -

addressed separatel a.: CAL ltem 1

" Submit L.e complete correctihe action plan, including a schedule for -

addressing each of the identified IRT weaknesses and a review of the extent of the problems and root causes for the training area to the NRC staff by April 2,1897. As part of the corrective action plan, clearly define roles and j

' responsibilities for completing NRC Form 398."

- Observations and Findinas The inspector reviewed both the IRT and the CAP and determined that the approximately forty recommendations of the IRT have been incorporated into the CAP, and that the CAP has expanded this listing to more than 70 items and sub- -

items. The specific requirement concerning Form 398 had been completed by the

. development of a procedure for the preparation and review of operator license applications. The inspector reviewed the facility's files for Unit 3 candidates for a license exam administered in July 1997 and determined that this procedure had been used acceptably, with applicable forms in the individual's application fil .

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4- Conclusion This item remains open pending further inspection of individual CAP ltem actions, CAL ltems 2 and 3

" Complete corrective actions for the Millstone Unit 1 LOIT/ LOUT (licensed operator initial / upgrade training) program prior to restarting respective classes."

" Complete corrective actions for the Millstone Unit 2 LOIT program prior to restming LOIT classes."

' Observations and Findinas These items committed to complete corrective actions for the Millstone 1 and 2 initial and upgrade license programs prior to restarting classes. At the time of this inspection, there have been no initial or upgrade license training programs in progress at Urits 1 and 2.

l l- Conclusion These items remain ope . CAL ltems 4 and 5 '

" . Complete corrective actions for the Millstone Unit 3 LOIT/ LOUT program prior to NRC examinations of the current LOIT/ LOUT class."

" Conduct a thorough review of the Millstone Unit 3 LOIT program against the accredited program requirements prior to submittal of the license applications to the NRC." Observations and Findinas These items committed to a review of the Millstone 3 initial licensed operator training programs against the accredited program requirements and completion of corrective actions for the Millstone 3 initial and upgrade training programs prict to the administration of NRC examinations in July 199 .The above commitments were completed prior to the NRC examinations of four upgrade senior reactor operators (SROs) and four reactor operators (ROs) on July 7 - 11,1997. All eight license candidates passed the examinations, and the results are documented in Examination Report 50-422/97-04(OL) dated August 12,1997. In the report the examiners concluded that "the candidates performed well on both the written and operating exams."

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Further, during this inspection the inspector reviewed the facility evaluation of the most recent Unit 3 initial training program against the accredited program requirements. No instances were identified of failure of students to complete program requirements, c. Conclusion Based on the inspector review of the corrective actions and the successful performance of the candidates on the July 1997 NRC license examination, these CAL ltems are closed, a. CAL ltem 6

" Forward the scope of NRC Form 396 (medical certification) process review and its expected completion date for Millstone Units 1,2, and 3 and the Haddam Neck plant (HNP) by April 2,1997."

b. Observations and Findinas in a letter to the NRC dated March 31,1997, Northeast Utilities provided the scope ar,' complution date for this review, and in a letter dated April 22,1997, Northeast Utilities reported the rosults of the medical review. Subsequent transmittals addressed any necessary changes to the licenses of operatort, and NRC actions on these requests were complete The facility review had identified 13 instances in which the NHC should have been notified of changes in an operator's medical statu Ten of these were for notification of use of corrective lense Two were a result of a medical difference of opinion between the examining physician and the reviewers over whether the particular condition needed to be reporte One was an oversight by the examining physician who did not realize that the inoividual did not meet visual acuity criteri The review also identified a number of instances of missing documentation for individual medical examination and laboratory element Facility corrective actinn for these discrepancies wac to submit updated Forms 396 where necessary, and to develop a computer database to track the completion of all required examination element The inspector judged the facility corrective actions for ensuring all medical examination elements are performed and medical condition chacges reported to be adequat While reviewing the medical database, the inspector observed that it consisted solely of dates items were performed with no entry of quantitative date for checking against limits. The facility physician stated that he is the only individual who reviews examination resultc, and the only second check is that he looks at the

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E results again when he enters the applicable dates into the new database. There were no routine quality assurance audits of physical examination and labcratory results. The inspector noted that this did not appear to prevent the potential for future errors, and the facility agreed to further evaluate whether any additional process changes were appropriate, c. Conclusion Based nn the satisfactory completion of corrective actions, this CAL in n is close The inspector concluded that the missed notifications of medical status changes (all medical actions had been appropriate) constituted a violation of minor significance and are being treated as a Non-Cited Violation consistent whh Section IV of the NRC Enforcement Policy. (NCV 97-85-01)

a. SAL ltems 7 and 9 l

" Submit the results of HNP data review of LOIT/ LOUT findings to the NRC by April 2,1997."

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" Complete specific reviews of the HNP LORT (licensed operator requalification trainingi program by April 4,1997."

5. Observations and Findinas These items address initial and requalification training programs at the Haddom Neck Plant. Northeast Utilities has ceased operation of this facility and suamitted o certified fuel handler training program to replace licensed operators. Although facility analyses and evaluations existed, the inspector determined that these CAL items did not merit any further review as part of restart evaluations. However, some review of the certified fuel handler program may occu c. Conclerdgn These CAL ltems remain open, a. CAL ltem 8

" Subr. lit the results of initial reviews of additional classes on all the units to the NRC by March 15,1997."

b. Observations and Findinas in this item Northeast Utilities committed to review records from additional license classes of all units for instances where individuals had not met all program requirements. The facility performed an audit. The inspector review'd the results of this facility audit and the facility disposition of discrepancies regaming under-instruction watchstanding, reactivity manipulations, and required on-the-job training

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iOJT) for the following RO and SRO license classes at Units 2 and 3e The -

inspector's review was for the purpose of determining whether any identified discrepancies would adversely affect any operator's ability to perform licensed dutie Discrepancies andd' ispositions were as follows:-

Millstone 2 - 1994 Class: -

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No discrepancies were identifie t ROs-

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Administrative errors existed in OJT cards, but the level of significant.e was minimal -

and no individual corrective actions were neede One individual had 512 hours0.00593 days <br />0.142 hours <br />8.465608e-4 weeks <br />1.94816e-4 months <br /> ratner than the specified 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on-shift training time; this was dispositie.. o as having no impact on the ability to perform licensed duties, because the indiviusal had considerably more than 8 shht hours as a licensed _ control operator.

(- ' Millstone 2 - 1996 Class:

SROUa-Despite facility confusion as to whether the program had specified 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> or 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br />, four of four individuals did not have 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of under instruction on-shift time; one of the four did not have 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />. Two individuals had OJT j omissions.< One of these individuals has terminated employment with the facility. _ j For the others, the facility determined that they were qualified to remain on watch,

-because they had already accumulated more than 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> counting under- i instruction watches for their actual position subsequent to licensing, and because any missing OJT had been completed. All have also accumulated more than the 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> currently specified in the training program implementing procedure (TPIP).

SROls-Five of five individuals did not have the specified time on shift. . Four of these individuals also did not meet the required five reactivity manipulations. Thesei "

have been removed from licensed duties. The fifth met the on-shift time specification after counting shift time subsequent to licensing and remained on shift, l

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Seven of seven individuals did not have the specified time on shift. One individual had received a waiver to take his examination but has not been issued a license pending completion of reactivity manipulations. Five of the other six were initially

removed from watch, but were returned after recoids review indicated they had more than 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> after counting post licennig time on shift. The sixth individual was not using his license on shift (i.e., an inactive license).

MWrtone 3 - 1994 Class:

This class consisted of 5 ROs. Two of these individuals did not have the required 5 reactivity manipulations; three had incomplete OJT cards; one did not have 240 -

hou.s at greater than 20% power. The facility resolution was a review of the logs, which determined that since licensing all pe.sonnel have accumulated the requireo -

reactivity manipulations and time at power. The OJT discrepancies were evaluated, and the facility concluded that all objectives of the specified training had been met and that the discrepancies represented modifications and administrative errors. All personnel remained on shif Millstone 3 - 1995 Class:

This class consisted of 4 ROs,3 SROUs, and 3 SROls. One RO was 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> short of the specified 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of shift time. Nine of the ten individuals had improperly completed or modified OJT cards. Missing OJT was made up, and action items were generated to correct deficiencies. All of these personnel remained on shif One SROI had no documented reactivity manipulations and did not meet program

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prerequisites. His license has been terminate c. Conclusions The inspector reviewed the identified training deficienclos of the individual licensed operators at Millstone Units 2 and 3 for their ability to perform licensed duties and concluded that the resolutions had been acceptable regarding the continuation of licenred duties for the affected individual Pending further evaluation of the identified discrepancies, the inspector concluded that the identified training program deficiencies as they affect compliance to P~ 55 requirements represented an unresolved item. (URI 97-85-02) Review of thb i will also include evaluation of discrepancies at Millstone Unit 1 and Haddam Neck that were not reviewed during this inspectN.. Accordingly, this CAL ltem remains ope ._ - _ - _ _ _ - _

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06 Operations Organization and Adrninistration Score The inspector reviewed the facility response to CR M197 2104 issued September 15,1997 nnd interviewed Unit 1 training management and staff. This CR identified that training resources were inadequate to support Millstone Unit 1 licensed operator requalification training (LORT) cycle,97 5 and to develop LORT cycle 97-6 training, Observations and Findinas The CR response noted that due to reassigning training staff to othe activities (i.e.,

development of exam banks and new program development), and removal of one instructor due to a failure of a requalification examination, Millstone 1 LORT resources had dwindled to one full time instructor, one part time instructor and the program coordinator. The facility concluded that resources were insufficient for LORT, and the CR had been initiated by tl.e LORT program cooruinato The CR response noted that Millstone 1 training management had been aware of the limited qualified training staff resources and the increasing demand on these training resources. Northeast Utilities concluded that Millstone 1 training management was not as aggressive as necessary to establish priorities for the existing resources l based on the increasing demands on training and as a result allowed the training resources to dwirH!a to a level unable to support LOR The CR response noted that Millstone 1 training management was attempting to secure qualified training staff. Additional staff had been needed due to instructor j departures as well as by the additional work load. In October 1997 Northeast IMities had 13 instructors (9 fully qualified and 4 partially qualified), and five contractor instructors with three mcre contractor instructors authorized, but not yet hired, to support Millstone 1 training programs. The contractors were in various stages of qualification. The Millstone 1 training programs that needed training instructors included the LORT, preparations for licensed initial operator training (LOIT), non-licensed initial and continuing training (NLIT/NLCT) and shift technical advisor (STA) training program In combination with delaying some Unit 1 LORT training and the annual opersting tests, Northeast Utilities reassigned priorities for the instructors and has re-established the needed resources for the LORT program. Northeast Utilities has assigned the program coordinator and 5.5 fully qualified instructors to the LORT program, in some cases Northeast Utilities has used partially qualified Millstone 1 instructors and contractors on tasks that were appropriate for their capabilities and qualification leve During the final three weeks of inspection, as documented in Section 04, the Ur'it 1 operators performed acceptably and passed their annual operating tests in the LORT program. This demonstrated that operator abilities continued to be maintained at acceptable level .. .. .

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The inspectors were unable to review the extent of this condition on Units 2 and 3 training staffs or to determine whether Unit 2 or Unit 3 training had been affecte Nonetheless, inspections of Unit 2 and Unit 3 requalification annual operating tests (discussed in Section 04) and the July 1997 Unit 3 NRC license examination did not provide evidence of adverse training resource impacts, c. Conclusions Millstone 1 training management had not been sufficiently aggressive in establishing training staff priorities and allowed the LORT training staffing levels to dwindle to levels unable to support LORT training. Pending further inspection, the consequences of the training resource problems at Unit 1 and the possibility of such problems on Units 2 and 3 represent an unresolved item. (URI 97-85-03)

08 Miscellaneous Operations issues a. Scoce The inspectors reviewed the status of a Unit 3 URI 96-0816 regarding operator response to a steam generator tube rupture (SGTR).

b. Observations and Findinag URI 96-0816 addressed a problem where the Unit 3 FSAR SGTR accident analyses ( assume the total time from break initiation to SI (safety injection) termination is 30 l minutes, but facility crews had been unable to routinely accomplish this on the simulator. The facility had done another analysis using a combination of operator pt.rformance times and plant response times totaling 46.5 minutes and showed they still bad an adequate margin to overfill; however, at the time of the URI crew performance was once again slower than the times used in the new analysi As of this inspection, the facility has retrained and evaluated all their crews so that they can perform their actions within the assumed times. The facility has also incorporated this performance time as a critical task in evaluation scenarios. Two crews were observed :n SGTR scenarios. One crew met the criteria; the other crew was the one that made the improper procedure transition and failed their exa Both crews were aware of this criterion and made use of a kitchen timer to nonitor how they were doin The inspector asked whether the longer response times in the most recent analysis affected the offsite dose calculation and determined that the facility was currently performing a new site specific dose calculation, because the FSAR calculation was not site specific but had been scaled from a Beaver Valley calculat!on, in addhion, the facility was performing another overfill analysis because of other changes which the facility considered might erode the margin to overfill. The facility intended to update the FSAR when these analyses were complete, which it estimated would be approximately six weeks. The safety analysis personnelinterviewed stated that

[ these assurmons would not necessarily be identical since Unit 3 has addrested the issue of timely responsa to an SGTR by retraining crews to move through the

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EOPs within the times assumed in the most recent analysis, and has incorporated

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. these times as a critical task in evaluation scenarios to prevent performance deterioration. URI 96-08-16 remains open pending the FSAR update and verification that analyses in progress are acceptable using the presently achievable performance

. times, including NRC assessment of any safety evaluation performed in support of the analyses and FSAR change, Conclusions The facility appeared to have addressed the concern raised in the URI by operator training and reanalysis of accident assumptions. This item remains open as discussed abov X1 Exit Meeting An exit meeting was held on October 17,1997. The results of the inspection were discussed. The facility licensing and medical department representatives stated that a corrective action request had been issued to address the inspector's comments concerning CAL ltem PARTIAL LIST OF PERSONS CONTACTED B. Carnes Chief Nuclear Operations R.. Johannes Director Nuclear Training Department M. Ross Manager Training Assessment A. Price Director MP2 -

D. Hicks Director MP3 M. Wilson Operations Manager MP2-B. Pinkowitz Operations Manager MP3 P. Przekop Manager Nuclear Oversight

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