IR 05000277/1988032
| ML20235W679 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/27/1989 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8903130134 | |
| Download: ML20235W679 (3) | |
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December 6, 1988
SUBJECT:
Peac'h Bottom Atomic Power Station
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j-LResponse to Combined Inspection Report Nos. 50-277/88-32;.50-278/88-32
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Dear Mr. Martin:
This is in response to your letter dated November 8, 1988 which
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transmitted Peach Bottom Inspection Report Nos. 50-277/88-32; 50-278/88-32.
4-This report concerned the routine safety inspection conducted at the Peach j
Bottom plant specific simulator during the period August 31 - September 29, j-1988. Appendix A of your letter described concerns regarding Licensed Operator Performance and Requalification Program. The attachment to this i-letter provides a restatement of these items, and provides Philadelphia j
Electric Company's response.
If you have any questions or require additional information, please do not hesitate to contact us.
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Very truly yours,
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Attachment
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Addressee
J.'T. Boettger, Public Service Electric & Gas T. P. Johnson, USNRC Senior Resident Inspector
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i T. E. Magette, State of Maryland W. T. Russell, Administrator, Region I, USNRC l
H. C. Schwemm. Atlantic Electric J. Urban, Delmarva Power d m swe t 7/0
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TO: Mr. Thomas T.-Hartin-
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C'. A. McNeill, Jr..- S26-1
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S. J. Kowalski
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J. W. Gallagher - S25-1 E. P. Fogarty - S7-1-E. J. Bradley - S23-1-D. R. Helwig --S7-1
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L J. F. Franz - PB i
C. J. McDermott - S13-1 G. F. Daebeler - PB T..E. Cribbe - PB i
A. J. Marie - N2-1 G. A.. Hunger - S7-l'
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J. T. Robb/ISED - S7-1 J. A. Basilio/FDL
.S10-1 Commitment Coordinator
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Attachment Page 1 of 5 Docket Nos. 50-277
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50-278
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Response to Concerns l
CONCERN 1 - Licensed Operator Requalification Program The inspector identified four areas of concern within the Licensed Operator Requalification Program. Each area will be addressed individually.
CONCERN la - The lack of attention to training scenario preparation and revision as discussed in Paragraph 2.1 of the inspection report.
RESPONSE -
The Training Division is currently making a concerted effort with Operations to improve the training scenarios.
Performance objectives and evaluation criteria have been developed for each scenario. Operations management is requiring their concurrence of specific scenarios and is developing performance expectation criteria for those attributes which apply to Operations personnel and are generic to all scenarios, such as communications.
Evaluation scenarios will include pass / fail criteria. Simulator Exercise Guides (SEG's) will be validated and identified discrepancies corrected in succeeding revisions.
CONCERN lb - The effect of limited time available for the crew to operate the simulator during training sessions on training effectiveness as discussed in Paragraph 2.2 of the inspection report.
RESPONSE -
Additional simulator time has been allocated for shift operator training. Since the inspector performed this evaluation, each crew has received an additional four days simulator time between 10/3/88 and 11/3/88. This included two days of detailed train Mg on operation of specific equipment, such as HPCI, RCIC, RHR valves, Diesel Generators and other evolutions and operations identified as requiring additional training. The third day was spent responding to operational transient scenarios. Each crew was evaluated on the fourth day while responding to events requiring extensive use of Operation Transient (OT) and TRIP procedures.
Between 11/7/88 and 12/2/88 each crew spent three days additional at the simulator correcting weaknesses identified during previous simulator performances. Each period concluded with a one day evaluation performed by VP - PBAPS, Plant Manager, Superintendent of Operations and the Training Division.
During January / February 1989 each crew will receive two days refresher training to help maintain their operational skills.
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Attachment Page 2 of 5
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Docket Nos. 50-277
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50-278 i
CONCERN Ic - The unclear definition of responsibility between the training department and the Shift Manager for correction of identified i
performance deficiencies as discussed in Paragraph 2.2 of the
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inspection report.
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RESPONSE -
Standards have been developed by Operations management to be utilized by the Training Division and Shift Managers in order to
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insure consistent assessment of crew and individual performance on the simulator.
It has been re-affirmed that.it is a Shift Manager and Operations management responsibility to ensure operator performance deficiencies are corrected. The Training Department is responsible for training, monitoring performance and identifying areas of weakness or inadequacy. The Training Department, Shift Manager and Operations Management are jointly responsible for determining the appropriate corrective actions necessary to resolve any problems noted.
CONCERN Id-Simulation performance deficiencies are being identified but are not being corrected as discussed in Paragraph 3.1 of the inspection report.
RESPONSE -
The Peach Bottom Simulator has remained at the Singer facility in Columbia, MD so that modification updates can be incorporated into its' design to more closely reflect the present day plant. Since the needs of training could be served simultaneous to the development of the modification updates, an agreement was made between PEC0 and Singer that training would take priority and mod development would be done in background.
No unauthorized work was
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performed on the simulator by Singer personnel. Due to needed access by Singer personnel, some problems developed with the use of this access in the beginning and again when a new Singer modeler incorrectly accessed the " Training Load" software. To eliminate this problem, an " Engineering Load" was built and isolated from the master and slave computers. Access to the " Training Load" requires l
a password that is controlled by PECO.
As with any new complex system, the ability to utilize the system to its fullest potential requires time and experience. With the time restraints of the training being performed on the simulator, i
the simulators capabilities have not yet been fully used. The j
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Training Division will be able to develop and use these
capabilities when they are required on site.
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Attachment t
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Docket Hos. 50-277 l
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50-278 A comprehensive configuration control system is in place. The i
mechanism used for identifying problems with the simulator is to I
file a discrepancy report (DR). These reports are logged by the Singer Project Engineer and assigned to an appropriate party for resolution. DR's that have a direct impact on training are handled immediately. DR's that do not severely impact training are resolved on the Engineering Load and placed in the " ready for recheck" category. Resolved OR's are selectively transferred into the Training Load. Because of the extensive amount of modifications being developed on the Engineering Load, and the need to maintain the Training program, the approach has been taken that if a discrepancy can be bypassed, it is better to leave the Training Load as is for now, and fix it when the modification upgrade is installed.
The NRC observed weakness of Simulator Configuration Management Control is not considered to be a concern.
Tracking and corrections of identified simulator problems is performed as described in the preceding paragraph. The DR's are kept in log books by Singer at the simulator.
In addition, a summary of the DR's and their status is maintained by PEC0 personnel in a report kept at the Instructor Station. The list groups the DR's by system for easy referral. Discrepancies that have been corrected have been approved by knowledgeable PECO or General Physics (PEC0's simulator consultant) personnel. The example of the deficiency of torus temperature and drywell pressure not responding to an addition of heat to the torus is detailed in DR #W4583 written 9/15/88. The discrepancy was observed in an " Initial Condition" listed as IC-42. Since this IC is an unprotected IC, and the discrepancy does not occur in the protected IC's, training will not use this IC until the discrepancy can be further analyzed.
Instructors will provide sufficient detail for engineers to analyze identified problems. Although this is a burden on the instructors, the basis of the discrepancy needs to be known to either modify or update the existing data base of the simulator.
CONCERN 2 - Licensed Operator Performance The inspector identified five areas of concern regarding Licensed Operator Performance. Each area will be addressed individually.
CONCERN 2a - Numerous deficiencies in performance of control board manipulations as discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
As previously noted in the response to Concern Ib, an additional two days training was allocated to provide instruction on specific manipulations. This training has proven to be effective as demonstrated by improved system operation proficiency during subsequent evaluation scenarios.
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Attachment j
Page 4 of 5
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Docket Nos. 50-277
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50-278 j
i Special emphasis has been placed on maintaining level control between 0 and 4b inches. Training and evaluation has demonstrated improved water level control and operator recognition that levels greater than 45 inches are undesirable.
Emphasis was placed during training to properly verify isolations and scrams by observing actual position as opposed to the previous practice of using annunciators.
CONCERN 2b - Shift Supervisor difficulties with using multiple TRIP procedures simultaneously as discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
Detailed training performed in October and November reviewed TRIP procedures on a step by step basis with Shift Supervisors, R0's, and C0's.
This review included BASES, Cautions, Notes and proper flowchart marking.
Instructors have demonstrated proper usage on more than one TRIP procedure to the Shift Supervisors during multiple malfunction scenarios. As a result of this training Shift
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Supervisors demonstrated proficiency in the use of multiple TRIP procedures in subsequent evaluation scenarios.
CONCERN 2c - Weaknesses in the command and control ability of one Shift Supervisor as discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
Upgraded / additional training in the use of TRIP procedures has had a positive effect on Shift Supervisor command and cor. trol ability.
Superintendent and Assistant Superintendent - Operations have counseled the Shift Supervisors to clearly define and emphasize PEC0's expectations of them as Operations Management.
Superintendent - Operations is working daily at the simulator with the Shift Supervisors clearly relating his expectations of their command and control performance during TRIP procedure usage.
Evaluations during subsequent training sessions have shown marked improvement in this area with Shift Supervisor performance being rated satisfactory.
CONCERN 2d - The unclear definition of responsibilities and interface between the Shift Managers and Shift Supervisors as discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
The roles of Shift Manager and Shift Supervisor have been clearly re-emphasized during training sessions subsequent to the inspection period. The Shift Supervisor has the responsibility to direct operator actions.
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Attachment Page 5 of 5 j
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Docket Nos. 50-277
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50-278 The Shift Manager has the responsibility to ensure overall' crew performance is proper for the: scenario in progress. The Shift Manager accomplishes this by deterniining plant status through observation, review of TRIP procedures.and consulting the Shift Supervisor. Shift Managers, through additional training, have become.more efficient in dealing with Emergency Plan requirements, allowing more time to be cognizant of plant conditions. The Shift Managers should perform manipulations on the control boards when directed by the Shift Supervisor and then only under conditions of limited operator availability.
It is expected these manipulations will occur on a very infrequent basis and then only during a high, level of crew activity or when a particular action must.be performed in a expeditious manner.
CONCERN 2e - Weaknesses in communications between R0's and Shift Supervisors as
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discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
Since'.the inspection, improved communications has been strongly.
emphasized during'all training and in-plant activities.
It has been stressed by Operations Management and during training critiques that communications shall be in accordance with the guidance given in Section 4 of the Operators Manual. During command and control training use of repeat backs was stressed.
Evaluations recently performed indicate communications are now at a satisfactory level.
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NUCLEAR REGULATORY COMMISSION
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REGION I
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475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 b
November 8, 1988 l
l Docket Nos.
50-277
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50-278 Philadelphia Electric Company ATTN: Mr. C. A. McNeill Executive Vice President-Nuclear Correspondence Control Desk P. O. Box 7520 Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
Inspection Nos. 50-277/88-32 and 50-278/88-32 This letter refers to the routine safety inspection conducted by Tracy Walker of this office on August 31 - September 29, 1988, at the Peach Bottom plant specific simulator, in Columbia, Maryland and to the discussions of our findings held by Tracy Walker with Dickinson Smith, Vice President-Peach Bottom Atomic Power Station, and other members of your staff at the conclusion of the inspection at the NRC Region I Office, King of Prussia, Pa., and to a subse-quent telephone discussion between Robert Gallo of this office and Dickinson Smith on October 4, 1988.
Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter.
Within these areas, the inspection consisted of interviews with personnel and observations by the inspector.
Within the scope of this inspection, no violations were observed.
However, as discussed in Paragraph 2.1, 2.2, and 3.1, several weaknesses were identified in the licensed operator requalification program.
In addition, several dis-crepancies in operator performance were observed as discussed in Paragraph 2.3.
The NRC concerns are listed in Appendix A to this letter.
The NRC requests a response to these concerns within thirty (30) days of the date of this letter indicating the corrective actions taken.
At the exit meeting, Mr. Smith committed to providing additional simulator training to all of the operating crews. The NRC has determined that additional licensed operator proficiency and shift crew evaluations at the Peach Bottom simulator are needed.
Arrangements for these additional evaluations are the subject of separate correspondence.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
The response requested by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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Philadelphia Electric Company-2-
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l Your cooperation with us in this matter is appreciated.
Sincerely
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Thomas T. Martin, Director Division of Reactor Safety Enclosures:
1. Appendix A 2. NRC Region I Inspection Report Hos. 50-277/88-32 and 50-278/88-32 cc w/encls:
John S. Kemper, Sr., Senior Vice President-Nuclear J. W. Gallagher, Vice President, Nuclear Services E. C. Kistner, Chairman, Nuclear Review Board Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
John F. Franz, Plant Manager, Peach Bottom Atomic Power Station Troy B. Conner, Jr., Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Atlantic Electric Bryan W. Gorman, Manager, External Affairs Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alden, Director, Licensing Section Doris Poulsen., Secretary of Harford County Council Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania bec w/encls:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP PA0 Robert J. Bores, DRSS R. Martin, NRR B. Clayton, EDO
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Appendix A NRC Concerns Licensed Operator Requalification Program:
The lack of attention to training scenario preparation and revision as
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discussed in Paragraph 2.1 The effect of limited time available for the crew to operate the
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simulator during training sessions on training effectiveness as discussed in Paragraph 2.2.
The unclear definition of responsibility between the training department
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and the Shift Manager for correction of identified performance deficiencies as discussed in Paragraph 2.2.
Simulation performance deficiencies are being identified but are not
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being corrected as discussed in Paragraph 3.1.
Licensed Operator Performance Numerous deficiencies in performance of control board manipulations as
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discussed in Paragraph 2.3.
Shift Supervisor difficulties with using multiple TRIP procedures
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simultaneously as discussed in Paragraph 2.3.
Weaknesses in the command and control ability of one Shift Supervisor as
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discussed in Paragraph 2.3.
The unclear definition of responsibilities and interface between the
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Shift Managers and Shift Supervisors as discussed in Paragraph 2.3.
Weaknesses in communications between R0s and Shift Supervisors as
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discussed in Paragraph 2.3.
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I U.S. NUCLEAR REGULATORY COMMISSION l
Report Nos.
50-277/88-32 50-278/88-32 License Nos.
DPR-44 DPR-56 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name:
. Peach Bottom Unit 2 and Unit 3 Inspection at:
Columbia, Maryland Inspection conducted:
August 31 - September 29, 1988
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Inspectors:
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7.'Wa1kert'Teni~or Operations Engineer Date
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T. JoVson, Senior Ret dent' Inspe6(or Date
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Approved by:
D.'Lange, Onief, BWR Operations Section Date Summary:
Inspection on August 31 - September 29, 1988 (Report Nos.
50-277/88-32 and 50-278/88-32)
Areas Inspected: A routine, announced safety inspection was conducted to review the Peach Bottom Licensed Operator Requalification Program in order to evaluate the effectiveness of the licensee's simulator training program. The inspection consisted of observation of requalification training on the plant specific simulator, NRC/ facility parallel evaluation of operator performance, and discussions with training personnel.
Results: No violations or deviations were identified. The following strengths were identified: self evaluation during post-scenario critiques, knowledgeable, experienced instructors, Operations and Training department interface, and plans to share requalification program experience and resources with Limerick Generating Station. Weaknesses in the requalification program were observed in the following areas: training effectiveness with respect to real time training on the simulator, instructor / Shift Manager interface, training scenario preparation and revision, and simulator configuration management control.
Weaknesses related to licensed operator performance were observed in the h-(h{h6 N
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following areas: control board manipulations, use of multiple TRIP procedures (Emergency Operating Procedures), Shift Manager / Shift Supervisor interface, command and control ability of one Shift Supervisor, and communications between reactor operators and Shift Supervisors.
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DETAILS 1.0 PERSONS CONTACTED 1.1 Philadelphia Electric Company D. M. Smith, Vice President - Peach Bottom
R. G. Andrews, Operations Training Supervisor
D. McClellan, Senior Requalification Instructor R. Watkins, Requalification Instructor R. Artus, Requalification Instructor F. Polaski, Assistant Superintendent of Operations
R. Helt, Corporate Training The inspector also interviewed other licensed operators during the inspection period.
1.2 Other S. Maingi, Commonwealth of Pennsylvania
R. R. Reichel, Delmarva Power
T. E. Magette, State of Maryland
M. A. Phillips, Public Service Electric and Gas
H. R. Abendroth, Atlantic Electric
1.3 U.S. Nuclear Regulatory Commission W. F. Kane, Director, Division of Reactor Projects
E. C. Wenzinger, Chief, Reactor Projects Branch 2
J. Linville, Chief, Reactor Projects Section 2A
J. H. Williams, Project Engineer
R. Gallo, Chief, Operations Branch
D. J. Lange, Chief. BWR Section
R. E. Martin, NRR Project Manager
Denotes those present at the exit meeting conducted on 9/29/88
2.0 Simulator Training Observation Four shif t crews were observed during requalification training sessions on the Peach Bottom plant specific simulator located in the vendor's facility in Columbia, MD. The training sessions included normal power operations, transients and control manipulations expected during the power ascension program and transients requiring TRIP procedure usage and Emergency Plan implementation. A list of the shift crews that were observed and the scenarios that they participated in is included as Attachment 1.
The inspectors did not alter the training department prepared scenarios or
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schedule. The lesson plans used during the training sessions-were re-viewed and discussed with the training instructors.
Parallel evaluations of the crews were performed by the inspectors and compared with the evaluations made by the training instructors.. Operations and training depart' ment interface was observed during the training sessions. The focus of the observations was on operator actions taken to mitigate transients and actions taken to place the plant in a safe shutdown condition follow-ing a transient.
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2.1 Simulator Exercise Guide Preparation and Revision The simulator exercise guides (SEGS) used during the observed training sessions were prepared just prior to the start of the requalification training cycle. Twenty-eight (28) of the twenty-nine (29) SEGS were signed by the preparer on 8/1/88 and reviewed by the Senior Requalification Instructor and the Operations Training Supervisor between 8/2/88 and 8/4/88.
In several cases, the Senior Instructor both prepared and reviewed the SEG. The remaining SEG was used in hand-written, unreviewed form during the training sessions.
J None of the SEGS had been reviewed by the Operations Department or approved for.use by the Training Superintendent.
In many cases the prepared simulator exercise guides (scenarios) did
not completely define the expected plant response and required I
operator actions.
For example the SEG for plant startup testing did not discuss the expected response of reactor water level for a specified level transmitter failure and did not describe the actions i
required for single 1000 operations following a recirc pump trip.
Also, tus SEG referred to a sample Maintenance Request Form (MRF)
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None of the obscrved scenarios i
. included any references to Technical Specifications when plant
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conditions warranted that they be addressed.
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Numerous deficiencies that were not identified during reviews or
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previous training sessions were identified while running the j
scenarios with the operating crews. These problems interrupted the
real time scenarios and distracted the operators from concentrating l
on operating the simulator as if it was the plant. During one l
crew training session, the plant startup testing scenario had to be l
interrupted and run again due to a combination of failures that-caused a reactor scram that the operators could not reasonably have i
been expected to prevent. This problem was not identified during two previous crew training sessions or during the review of the scenario by training personnel. The objectives of the SEG for a main
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turbine load reject were changed during the third session of crew j
training because the power level would be below the level at which i
a scram occurs on a load reject. This discrepancy was also not i
i identified during previous training sessions or SEG review.
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When problems with the scenarios were identified, the senior requalification instructor noted them. Changes were not made to the SEGS until the requalification cycle was completed, therefore, the instructors had to depend on their personal knowledge and experience to keep track of the expected plant response and required operator actions. A discrepancy was identified in the procedure for response to an earthquake during a training session on 9/8/88. The same discrepancy caused confusion during the training session on 9/22/88.
This indicates that items identified during training are not being adequately tracked and passed on to the following crews.
The weaknesses noted with the preparation and revision of the scenarios indicate a lack of attention to the preparation and documentation of the training..Due to the level of knowledge and experience of the instructors, the training that was administered was adequate, but the weaknesses in the scenario documentation were of concern.
2.2 Training Effectiveness Following each training scenario, the operators and training instructors held a critique to discuss and evaluate crew performance.
The performance evaluations done by the crew members and the training
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instructors during the post-scenario critiques were a strength in the training sessions. Most of the deficiencies noted by the inspectors were recognized by both the crew members and the instructors. The parallel evaluations performed by the instructors were comparable to the evaluations performed by the inspectors.
The knowledge and experience of the instructors was noted as a strength in the licensee's training program. When questions arose, they were able to resolve the issue with accurate and clear answers.
During the training sessions, the instructors demonstrated a high
level of understanding of integrated plant operations and familiarity i
l with the plant systems and components.
In spite of the weaknesses in the simulator exercise guides (see section 2.1), the instructors provided technically accurate training and were able to adequately evaluate the performance of the operators, t
Interaction betwe?n the Operations Department and Training Department l
was noted as a strength in the licensee's program. Operations I-Supervision participated in the training sessions in both evaluating and providing insight and clarification when questions arose. During
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l tne scenarios numerous procedural and simulator fidelity deficiencies l
were identified by the operators and actions were taken to correct the deficiencies.
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n The effectiveness of the training was limited by the amount of l
Ltime the crews spent operating the simulator. The amount of.
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time available for the operators to perform manipulations on the simulator was considered a weakness in the training program.
Numerous situations arose where the crew and the instructors identified areas that required more training on the simulator,:but the training schedule did not allow'for the additional, training.
Post-scram water level control'was identified several times as an area that required additional training, but was not provided for-in the schedule.
Several times the instructors stopped scenarios to.
discuss appropriate actions, but the effectiveness of the training-was limited because the scenarie was not run again to allcw~the-operators to utilize the scen.tric specific training they had. received.
The tight training schedule did not always ensure that all members of the crew benefitted from the objectives of the scenarios.
Post scenario discussions were used to summarize the scenarios and inform all crew members of the results, but there was no opportunity for operators to swap positions and perform the operations they were trained on.
Another weakness was the interface between the instructors and the-Shift Manager.
In many cases the instructors were not specific as to what the appropriate actions should have been and left the determination to the Shift Manager.
Individual deficiencies were identified and tracked by the training personnel, but left to the Shift Manager to present to the rest of the crew.
The Shift Manager is responsible for crew performance, but it was not clear to the inspectors whether'the training department or the Shift Managers would ensure that the identified performance deficiencies are corrected.
In summary, the training that was provided was technically accurate due to the knowledgeable, experienced instructors, but the effectiveness of the training was limited by the time available on the simulator. The instructors and operators were able'to identify performance deficiencies and weaknesses. The training department is tracking the' identified items, but the responsibility for correction of the deficiencies was not clearly defined.
2.3 Licensed Operator performance
'The crew for each training scenario consisted of the Shift Manager, an Inside Shift Supervisor, an Outside Shift Supervisor (acted as an evaluator in some cases), a Chief Operator (R0 licensed), a Unit 2'
Reactor Operator, and a Shift Technical Assistant.
The other RO on the shift acted as either the Unit 3 Reactor Operator or as an extra
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operator.
Several of the operators received their licenses after Peach Bottom was shutdown and have not operated the plant during
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power operations. These individuals hold " cold" conditional licenses and will have to participate in reactor and plant operation at power levels of at least 20% power for one month and performance of five significant control manipulations which affect reactivity or power level under the direction of a licensed operator prior to assuming full licensed duties.
During the training scenarios a number of deficiencies were observed in the performance of control board manipulations by both cold licensed and experienced operators.
In one instance, an incorrect breaker was opened causing a trip of the plant. A cold licensed operator, while attempting to secure HPCI, did not recognize that the turbine was already tripped.
Several operators had difficulty with abnormal RHR system lineups and understanding of RHR interlocks.
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Post-scram water level control was a recurring problem among all the crews observed.
The operators were unable to maintain water level below 45 inches following the restoration of level after a reactor scram.
Several instances of failure to verify automatic actions were observed along with some difficulties with manual initiation when the automatic actions did not occur.
Two Shift Supervisors (SSs) had difficulty using multiple TRIP procedures (EOPs) simultaneously. The deficiencies noted appeared to be a lack of ability to step through the multiple flow charts during real time scenarios rather than a lack of understanding of the procedures. These deficiencies were identified by both the instructors and the inspectors and were acknowledged by the senior reactor operators.
In most cases the appropriate actions were per-formed by the crew with or without direction from the SS. The one action that was not performed in a timely manner was depressurization via the safety relief valves to allow low pressure injection.
In discussions afterward, the Shift Supervisors recognized that depres-surization should have been performed, but had not reached the applicable step in the procedures due to difficulty in following multiple flowcharts in a real time situation.
A weakness was observed in the command and control ability of one
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Shift Supervisor.
In many instances, the SS did not direct the
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actions of the reactor operators during transients and recovery from
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the transients. He allowed the operators to take the required actions, but provided very little guidance or direction, especially in use of the TRIP procedures. Additionally he often checked parameters and plant status himself rather than requesting the information from the reactor operators at the control boards. This action caused him to remove himself temporarily from the procedures and did not allow all members of the crew to be informed of plant status.
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i The interface between the Shift Manager and the Shift Supervisor was determined to be weak, especially during TRIP procedure usage and.
Emergency Plan. implementation.
In one case the Shift Manager was
. involved in the Emergency Plan to-the extent that he was unaware of plant conditions and would not have been able to assist the Shift Supervisor if required. In other. cases the Shift Manager and Shift Supervisor were both directing the' actions of the R0s, causing
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confusion among the crew rrembers.
In one case the chain of command-was not followed in that the Shift Manager performed a manipulation on the control boards. Defined responsibilities for the Shift Manager and the Shift Supervisors are necessary to ensure.that shift supervision is fully aware of-plant conditions but does not cause confusion among the crew by providing contradictory direction.
Communications between the R0s and Shift Supervisors were weak during several of the observed training sessions. The weaknesses in communications that were observed were minor and in most cases did not hinder the operators.in safely operating the plant. The Shift Supervisors did not always give specific directions to the R0s-(i.e.,
did not provide limits or preferred method'of level control)-and.
phrased some directions in question form.
In several cases the SS did not give a direction to a specific person, sometimes causing confusion about responsibilities among the R0s. Both R0s and SSs did not always. acknowledge communications, which occasionally resulted in Shift: Supervisors directing actions that were not performed and R0s-reporting plant conditions that the SS did not hear and had to request again. Acknowledging the communications would have prevented j
the confusion.
In several cases the R0s were deficient in supplying
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plant conditions, specifically not informing the SS of degrading plant conditions. The R0s did not always inform the SS of actions that were performed or completed, therefore the SS was not always aware of plant status.
The deficiencies noted in operator performance indicate that additional training on.the simulator is necessary in two particular areas. The first is in performing control manipulations because the number of deficiencies observed indicated a lack of proficiency in this area. The second area is in use of TRIP procedures because of the difficulties the Shift Supervisors experienced in using multiple
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In almost all cases the crews
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successfully worked together to mitigate the transients and place the plant in a safe shutdown condition. The scenarios were run for training and all of the performance deficiencies were identified by the operators and instructors. The deficiencies were discussed with the entire crew during the scenarios or during the post-scenario critiques.
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3.0 Discussions with Training Department Personnel The inspectors discussed the capabilities and fidelity of the plant specific' simulator with the instructors.
Requalification program documen-tation was also discussed with the senior requalification instructcr.
Preparation for NRC administered requalification examinations was discussed with the requalification instructors and corporate representative.
3.1 Simulator Use and Configuration Management Control The simulator is located in Columbia, MD at the Singer Link-facility where it was constructed. The licensee is presently operating it for licensed operator requalification training. The simulator will be turned back over to Singer Link for modifications prior to delivery to the site. During-the observed requalification cycle, some simulator usage time was lost due to Singer Link personnel performing unauthorized work on simulator, but the problem was corrected after the second occurrence.
The simulator is not being used to its full potential at this time.
The simulator has extensive capabilities for scenario development and training documentation that are not being utilized at this time. The instructors are preparing the scenarios and operating the simulator to provide training to the operators, but do not have enough time to utilize the machine to its full capabilities.
For example, the simulator can be used to keep a training record.for each individual operator, but the instructors have not had the opportunity to learn how to use !.his capability. The simulator has extensive instructor override (10) capabilities that are not often used due to lack of time to test the more complex functions. To provide training to the operators, the instructors are limited to using the basic functions that will accomplish the objectives.
Numerous simulator performance deficiencies have been identified by the instructors and the operators, but have not been corrected. The number of deficiencies is 1ot consideri.d unusual for a new simulator, but the tracking and correction of the deficiencies was observed to be a weakness. Many of the deficiencies impact the training of the operators.
For example, torus temperature and drywell pressure do not respond to an addition of heat to the torus. This deficiency had been identified and documented by the instructors, but did not appear on the simulator discrepancy report.
In many cases, the instructors are required to provide references to the engineers to justify problems with simulator fidelity, which is an additional demand on
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the limited time available to the instructors.
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Simulator configuration management control was considered a weakness due to the problems identified with correcting identified simulator deficiencies and simulator utilization. These problems a9 pear to be
'due to limited training department resources. Simulator fidelity is needed to provide valid training to licensed operators.
3.2 Requalification Examination Preparation The licensee intends to utilize personnel in addition to the requalification instructors to prepare for NRC administered requalification examinations.
The additional personnel will develop the open reference test items and job performance measures that will be necessary for administration of requalification examinations. The licensee intends to share experience and resources with Limerick in preparation for the requalification examinations. This was observed to be a strength in-the licensee's program.
The training department is familiarizing the licensed operators with the new format for the examinations during requalification training.
Static simulator scenarios were utilized during the observed training sessions to acquaint the operators with the open reference written examination format.
4.0 Exit Interview All observations and findings were discussed with licensee representatives during interim exit meetings held following observation of each operating crew. The inspection scope and findings as detailed in this report were summarized on September 29, 1988 during an exit interview with licensee personnel (see paragraph 1.0 for attendees). The inspector determined that no proprietary information was utilized during the inspection.
At the exit meeting on September 29, 1988, the licensee committed to providing an additional four (4) days of simulator training to each of the operating crews prior to release of the simulator to Singer Link for correction of deficiencies and delivery to the site. This training wi11' consist of two days of training on control manipulations and TRIP procedure usage and two days of transient scenarios for each operating crew. Each crew will be evaluated by the licensee during real time scenarios at the completion of the training.
5.0 Telephone Conversation
.The licensee's corrective action to be taken for the weakness in Shift Supervisor use of TRIP procedures and for the individual weakness in command and control ability were discussed in a telephone conversation on 10/4/88 between Mr. R. Gallo, Chief, Operations Branch, Division of Reactor Safety and Mr. D. Smith, Vice President - Peach Bottom. The
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licensee' stated that'the weakness in TRIP procedure usage would be
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addressed by the additional simulator training provided to each crew.
The individual weakness in command and control ability would be addressed-j by licen:-re management' and the NRC would be notified of the corrective j
action. ihe effectiveness of the additional training will be evaluated
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during a followup inspection after the training has been completed.
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ATTACHMENT 1 Shift Crews Observed:
8/31/88 - Warfel, Shift Manager - SEG 101R, SEG 309R 9/7/88 - Mannix, Shift Manager - SEG 101R, SEG 309R 9/8/88 - Mannix, Shift Manager - SEG 404R, SEG 402R, SEG 310R 9/14/88 - Wasong, Shift Manager - SEG 101R, SEG 309R 9/21/88 - Niessen, Shift Manager - SEG 101R, SEG 309R 9/22/88 - Niessen, Shift Manager - SEG 404R, SEG 402R Scenarios:
SEG 101R: Plant Startup Testing -
Full power operation, power decrease with recire, level instrument failure, RFPT trip, Recirc Pump trip, sinle loop operations SEG 309R: Main Turbine Load Reject -
Operation at 30% power, power increase with control rods, trip of #1 breaker (loss of 1/2 of plant auxiliary loads), load reject (no scram)
SEG 404R: Offsite Release /RWCU Line Break -
Full power operations, loss of condenser vacuum due to break in condensate pump suction line, fuel failure, break in RWCU suction line with failure of RWCU to isolate (leads to offsite release), fire in SBGT maximizes release rate, failure of SRVs to manually open SEG 402R: Loss of Conowingo Pond -
Full power operations, earthquake causes dam break (loss of Conowingo Pond) and loss of offsite power, steam leak in MSL Tunnel SEG 310R: Loss of Grid / Steam Leak in Drywell -
Full power operaticas, grid oscillations lead to a load reject and loss of one offsite power source, steam leak in drywell