IR 05000277/1997004

Insp Repts 50-277/97-04 & 50-278/98-04 on 980309-13 & 0330-0403 (Onsite) & 980314-0429 (Inoffice).Violation Noted. Major Areas Inspected:Licensed Operator Requalification Training & Evaluation & Maint Rule Implementation Areas

ML20247L321
Person / Time
Site:	Peach Bottom
Issue date:	05/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247L203	List: IR 05000277/1997004 IR 05000277/1998004 ML20247L279
References
50-277-98-04, 50-277-98-4, 50-278-98-04, 50-278-98-4, NUDOCS 9805220366
Download: ML20247L321 (12)

Text

- _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No ,50-278 License No DPR-44, DPR-56 l

l Report No l I

Licensee: PECO Energy Company Facility: Peach Bottom Atomic Power Station Units 2 and 3 Dates: March 9 - 13,1998 & March 30 - April 3,1998 (onsite)

March 14 - April 29,1998 (inoffice)

Inspectors: J. G. Caruso, Operations Engineer, DRS T. Fish, Operations Engineer, DRS C. Sisco, Operations Engineer, DRS ,

J. Williams, Senior Operations Engineer, DRS I S. Wong, Reliability and Risk Analyst, NRR I Approved by: R. J. Conte, Chief Operator Licensing and Human Performance Branch Division of Reactor Safety I

,

9005220366 DR 990514

, g ADOCK 05000277 l PDR

. - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _

l '

.

I EXECUTIVE SUMMARY Peach Bottom Atomic Power Station NRC Inspection Report 50-277&278/98-04 This integrated inspection report includes aspects of the licensed operator requalification training (LORT) and evaluation and the maintenance rule implementation area Plant Operations:

• The past two annual operating exams did not test senior reactor operators who fulfilled the role of the control room supervisor (CRS) on their ability to execute the emergency plan. This condition was a violation of 10 CFR 55.59(a)(2)(ii).

• For the development of the operating test, the training staff did not adhere to the LORT program procedure reqOements for differences between crews and testing weeks with respect to the job performance measures (JPM) portion of the tes This condition was a violation of 10 CFR 50.54 (i-1), 55.59(c)(4) and the PECO applicable procedur * Four licensed operators missed training for the two year requalification period that ;

ended in March 1996 and never made up this missed training within a reasonable time thereafter. This was unresolved pending NRC staff review for enforcement j action with respect to 10 CFR 55.59 a(1)

• Overall, the examinations reviewed had an appropriate level of difficulty and met the guidelines established in the examiner standards and 10 CFR 55 except for the violations noted abov j i

e The performance of both crews (one operating crew, one staff crew) was good in the areas of event recognition and diagnosis, control board manipulations, technical '

specification usage, and event classificatio l

}

• NRC inspectors as well as PBAPS evaluators identified several crew weaknesses in the areas of: crew briefings, emergency operating procedures (EOPs) markup, and 3-part communications. Shift manager oversight of CRSs to ensure these activities were properly conducted was also noted by NRC inspectors to be wea '

Maintenance

• Seven open items associated with the maintenance rule were reviewed and close * One system was identified which should have been in scope of the maintenance li rule program, but was not. The system was area radiation monitoring system used l in secondary containment control emergency operating procedures. This condition was a violation of 10 CFR 50.65(b).

ii  ;

i

- _____ _ _ ____ - _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - - _

.

.

Report Details Plant Status and Backaround Unit 2 was at power during the inspection period. Unit 3 was shutdown, had a two week outage and returned to power during this period. The major objectives of this inspection, which covered two separate weeks, were to review and assess the implementation of the licensed operator requalification training (LORT) program, and to followup on the resolution of open items (violation, unresolved, and inspector followup items) from the maintenance rule inspection conducted August 5-9,199 l. Operations 05 Operator Training and Qualification (71001)

0 Licensed Operator Reaualification Trainina Proaram Inspection Scope During the week of March 9,1998, two NRC inspectors assessed the Peach Bottom Atomic Power Station (PBAPS) licensed operator requalification training (LORT)

program using NRC Inspection Procedure 71001," Licensed Operator Requalification Program Evaluation". The inspectors observed performance and evaluations during examination for a shift and a staff crew, conducted interviews, and reviewed records supporting medical evaluations and proficiency watche Observations and Findinas LORT Proaram Content and Implementation The inspectors reviewed LORT pmgram attendance records and identified that licensed staff attendance had been hgorica4y poor and lower than that of operating crews. For example,in training cycle 96-07 (a six week period January-February 1997) licensed staff attendance was 53%,in cycle 96-08 (May-June 1997)

attendance was 69%, and in cycle 96-09 (June-July 1997) attendance was 49%. .

i PBAPS management had recently focused on initiatives to improve licensed staff I l attendance; and, in the last three cycles, the improved licensed staff attendance I equaled operating crew attendance (85-90%). The inspectors noted that most of the missed training had been made up by using the method of " read and sign."

The inspectors identified initially that several licensed staff members went beyond j two cycles in making up missed training. This practice was inconsistent with the l LORT program procedure (POC2.4, revision 7, section 6.1.2.3.1) which established I a recommendation that missed training should be made up within two cycles.

l

'

When the inspectors pointed this out to the licensee, they agreed with the finding and stated that they would revise the program guidance to be more definitive, l namely, missed training must be made up within one cycle and that licensed I operators would have to complete all LORT training before taking the annual operating or bi-annual exams, i

!

i

_ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ __-__ __ ____ _ __ ___ _ _ _ - _ _ _ -

l l'

After further review by PECO to determine the extent of this problem, it was determined that four licensed operators never made up missed training after the last two year training period (April 1994 to March 1996). One of these individuals is no longer licensed (i.e., license terminated June 7,1996). However, the three others were still licensed. This area is unresolved pending further review for enforcement with respect to licensed operators attending LORT training, including make-up training, as required by 10 CFR 55.59 (a)(1) (URI 50-277(278)/98-04-01).

The licensee reported by letter, dated April 16,1998, that the missed training was made up during the next requalification period but, in some instances, as late as the March-April 1998 time fram Exam Materials The inspectors reviewed a sample of the requalification exams prepared and l administered by the facility this exam cycle which included six written exams (three l reactor operator and three senior reactor operator), four job performance measure (JPM) exam sets (20 JPMs) and seven simulator scenarios. The exams reviewed had an appropriate level of difficulty and met the guidelines established in the examiner standards and 10 CFR 55 with two exception PBAPS LORT program Procedure POC 2.4, Revision 7, issued August 25,1997, section 7.2.4.6. states that subsequent examinations shall be designed to be greater than 40% different than previous exams developed for the same annual-operating test. However, the JPM exams administered this exam cycle did not meet this requirement. There was a pattern of overlap in that every JPM set was used at least twice on two different crews on different examination weeks. This resulted in 0% difference when comparing any two particular crews which got the

overlapping JPM sets. The inspectors determined this extent of commonality was a l violation of 10 CFR 50.54(1-1),55.59(c)(4), and LORT Procedure 7.2.4.6. (VIO 50-l 277(278)/98-04-02)

i Also, the operating tests and written exams adequately sampled the items required by 10 CFR 55.41,55.43,55.45, and 55.59, with one exception. The past two annual operating tests (administered from January - March 1997 and from January through March 13,1998) did not require licensed senior reactor operators fulfilling

! the role of control room supervisor (CRS) to demonstrate the ability to execute the emergency plan. This subject area was last tested as part of the annual operating test in the December 1995 to January 1996 time frame when CRSs were tested with JPMs. Based in information provided by licensee representatives, the inspectors noted that in March and April 1997 all CRSs received annual four hour emergency preparedness training from the emergency preparedness group. The training included table top reviews and a quiz. A licensee representative did not view these activities as part of LORT training required by 55.59(c). Accordingly, the inspectors determined that this training did not satisfy the requirement of-10 CFR 55.45(a)(11)to test this area as part of the annual operating test and therefore constituted a violation. (VIO 50-277(278)/98-04-03)

_ _ _ _ -- - -

.

.

in response to these findings, the licensee tested, using the JPM method, all CRSs that had not yet been examined in this area by the completion of this 1996-1998 exam cycle in March-April 1998.

,

in a separate matter, the inspectors noted that question overlap on the bi-annual written exams reviewed was typically less than twenty percent. This level of overlap was acceptable and reflected a significant improvement when compared to the level of overlap previously identified as a concern for the last bi-annual exam (Details on past problem are in NRC Inspection Report 96-03.)

Eyam Administration The inspectors observed the training staff administer seven simulator scenarios to one operating crew and one staff crew. Exam administration was very good. The evaluations were independent, objective, and very thorough in documenting crew and individual weaknesses. The NRC inspectors agreed with the facility evaluators'

assessment Operator Exam Performance The performance of both crews was good in the areas of event recognition and diagnosis, control board manipulations, technical specification usage, and event classificatio Performance weaknesses common to both crews, identified by both the facility and the NRC inspectors, were:

--

control room supervisor (CRS) performance was generally weak in conducting formal crew briefs; and, especially after entry into the EOPs, crew briefs were almost non-existen EOP markups were inconsisten Three part communications were inconsisten The inspectors noted that the shift managers did not ensure these activities were conducted. The inspectors also observed that, once the shift manager assumed the role of the emergency director, the oversight of the CRSs was less due to involvement with the emergency director functions. In light of the above, the inspectors considered the shift manager oversight of (CRSs)in this area was considered to be wea During the week of March 30,1998,the NRC inspectors reviewed operating deficiencies identified by the crews through the examination process. The self-assessment function for the identification of performance was considered by the inspectors to be a positive attribute of their program but effectiveness appears to be in question in light of the weaknesses noted abov _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _

.

.

Conformance with License Conditions The inspectors reviewed various training attendance records, grades, operations records including logs, and medical and licensed operator re-activation record Control room logs indicated that operators maintained their licenses active per 10 CFR 55.53(e). Also, records showed that operators reactivated their licenses in accordance with 10 CFR 55.53(f), when applicable. The inspectors observed, however, that PBAPS staff relied heavily on the operators to track the status of their license. While such personal accountability is important, the inspectors noted that this reliance was vulnerable to human error. Operations management agreed with this assessment and stated they would formalize the way the station maintains licenses active and reactivates license The inspectors reviewed the records of twelve of sixty-three licenses and determined PBAPS staff performed the medical examinations required by 10 CFR j 55.53(l). i Examination Security The inspectors determined that exam security was adequate for the observed examinations. Regarding JPM overlap, the inspectors did not identify any examples of actual examination compromis c. Conclusions Four licensed operators missed certain portions of the licensed operator requalification training after the last biannual training cycle which ended in March 199 The exams reviewed had an appropriate level of difficulty and met the guidelines established in the examiner standards with some exceptions. PBAPS exam developers did not adhere to the LORT program procedure requirements regarding commonality between JPM exams. The past two annual operating tests did not require licensed senior reactor operators fulfilling the role of the CRS to demonstrate their ability to execute the emergency plan.

l The performance of both crews observed by the NRC inspectors was good in the areas of event recognition and diagnosis, board manipulations, technical specification usage, and event classification but NRC inspectors and PBAPS evaluators identified and documented several crew weaknesses in the areas of:

crew briefings, emergency operating procedures (EOPs) markup, and 3-part communications. Shift manager oversight of CRSs to ensure these activities were properly conducted was weak.

l

[ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

ll. Maintenance l M8 Miscellaneous Maintenance issues (92701,92702 and 62706)

M8.1 Followup on Maintenance Rule Baseline Insriection issues Inspection Segpa During the week of March 30 to April 3,1998, three NRC inspectors reviewed the actions taken by the licensee to address one violation, two unresolved items, and four inspector followup items associated with the maintenance rule baseline inspection which was conducted on August 5-9,199 Observations and Findinas During this inspection, the inspectors noted that the maintenance rule coordinator closely monitored industry experience with the maintenance rule and updated the Peach Bottom program as necessary. The inspectors considered this to be a good practic CLOSED (URI 50-277(278)/96-07-01): This unresolved item dealt with the need to identify the boundary and components of the alternate ac power source that fell within the maintenance rule program scope. The boundaries and components included in system 51H, Station Blackout, have been defined and described in the PBAPS Maintenance Rule Bases Information Manual. The inspector reviewed documentation and drawings associated with system 51H and discussed the system with the system manager. The boundary is at, and including, the onsite switchyard breakers. No further issues were identified and the item is close CLOSED (URI 50-277(2781/96-07-02): The issue of whether the expert panel's  !

determination of risk significance was adequate for the condensate, feedwater, and core spray systems was unresolved pending review of additional information )

justifying the decisions to categorize the systems as non-risk significant. Re- I evaluation of risk significance for all SSCs was performed in 1997 due to the PBAPS probabilistic safety analysis (PSA) model update. The changes were i presented to and approved by the expert panel. The core spray and feedwater systems were determined to be risk significant and the condensate system was l determined to be not risk significant. The inspectors agreed with these determinations and had no further questions. This item is close CLOSED (IFl 50-277(278)/96-07-03): This item addressed the licensee's approach of using the highest ranked component as a surrogate for the importance of a plant I system. This approach may not provide a more realistic categorization (or a " truer" measure) of a system's risk ranking because the importance of the selected component may be enhanced or obscured by the effects of its direct or indirect contributions. For example, a component may be ranked as high safety significant mainly due to its contribution to common cause failures (CCF's), or a component may be ranked as low safety significant primarily because of negligible or no

- - - - - - - - - - - _ _ _ _ _ _ - - - - - - - - - _ _ - . - - - - - - _ - - - - - - - - - - - - _ - - - - - - - _ - - ._ - - - - - - - - - - - - - - - - _ - - - . - _ - - - - - - - - - . - - - - 1

_ _ _ _ _ _ _ . ____ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ -

.

l I

contribution to CCFs. Thus, a more realistic risk ranking process may require that the system-level modeling for some balance-of-plant (BOP) systems be decomposed to a lower level, i.e., at the component level, to account for the effects of the associated basic PRA events in the plant PRA model.

I in addressing the issue of using system-levelimportance measures for risk ranking and risk significance determinations, the licensee revised the PBAPS PSA model by modifying the simplified system-level modeling of a few BOP systems to incorporate the effects of train-level failures within the systems. Additionally, maintenance unavailability terms were incorporated in the system fault tree models for automatic depressurization system (ADS) logic channels, torus and drywell vent paths, standby liquid control, feedwater, and condensate systems. New calculations of PSA importance measures were performed using the revised PSA model with updated SSC failure data. The inspector identified no concerns with the results of l the revised risk determinations. This item is closed as a result of revisions to the PBAPS PSA model which allowed a more efficient categorization of SSC risk rankin CLOSED (IFl 50-277(2781/96-07-04): This item dealt with the problem of not documenting deviations from NUMARC 93-01 guidance. These deviations included:

-

use of 85% verses 90% as the cutoff value in the cut set methodology of risk assessment

-

not using unplanned capability loss factor (UCLF) as a plant level  ;

performance criteria

- not using unavailability as a performance indicator for risk significant SSCs

-

use of reliability performance criteria not related to the reliability numbers in the PS Based upon discussions with the maintenance rule coordinator and a review of documents, these deviations no longer exist. There is also a heightened awareness

.to better document deviations from NUMARC 93-01. This item is close CLOSED (IFl 50-277(2781/96-07-05): This item dealt with the PBAPS approach to balance reliability and unavailability by balancing planned and unplanned unavailability. With the changes to the program, unavailability and reliability are being monitored for risk significant SSCs and appropriate balancing is being performed. This item is close l i

[

-_ ___ _

.

.

CLOSED (eel 50-277 (2781/96-07-06 and VIO 01013): PBAPS was not adequately monitoring the performance or condition of numerous systems and components against established goals, nor had they demonstrated effectiveness of preventive j maintenance on these SSCs. The monitoring of the effectiveness of preventive l maintenance had not been adequately demonstrated in that selected performance criteria were not demonstrated to be fully effective. This resulted because the ,

licensee had not always followed the NUMARC guidance and did not adequately l justify those criteria selected that deviated from NUMARC. The affected SSCs included:

1 reactor protection system emergency ventilation for diesel generator building and the control room reactor recirculation electrohydraulic control system feedwater turbine bypass valves main steam safety relief valves safety grade instrument gas control rod drive standby pump I

!

The NRC inspectors reviewed and verified the corrective actions described in the PECO Energy Company letter dated January 23,1997,in response to the violatio These actions were also discussed with the maintenance rule coordinator and PBAPS management. Each item listed above was reviewed to verify that the performance criteria had been appropriately corrected. Based upon these reviews and discussions, this item is close CLOSED (IFl 50-277(278)/96-07-07): This item dealt with the lack of information that industry experience was or would be taken into account, where practical, when setting goals or performance criteria. The baseline inspection in 1996 found no i cases where industry experience should have been used but was not. AG-CG28.1,

" Maintenance Rule implementation Program," was revised to provide specific instructions to include and document industry operating experience where practica This item is close t Further, during the review of the open items, the NRC inspectors determined that the area radiation monitoring system (system 63C) was not included in the scope of l

the maintenance rule program. Based upon use in plant emergency operating procedures, specifically T-103, " Secondary Containment Control," this systern l should have been included in the maintenance rule program. Failure to include this l system is a violation of 10 CFR 50.65(b)(VIO 50-277(278)/98-04-05).

After this was identified, the licensee took prompt action to include the system in the program. They also indicated that a fresh review of other systems used in the plant emergency operating procedures would be conducted to ensure that all appropriate SSCs were included in the maintenance rule progra . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _

______ ______ ----- - - - - - - - - -

.

.

8 Conclusions The licensee had taken appropriate actions to address each of the open items identified in the maintenan::e rule baseline inspection conducted in 1996. One system - area radiation monitoring system - was found that was not included in the scope of the maintenance rule program and this is violation of 10 CFR 50.65(b).

The licensee took prompt corrective action to include the system and initiated a review of other systems used in plant emergency operating procedure V. Manaaement Meetinos X1 Exit Meeting Summary Exit meetings were conducted on March 13 and April 3,1998. A final exit meeting was conducted by telephone on April 23,1998. The observations and findings from this inspection were discussed at these exit PARTIAL LIST OF PERSONS CONTACTED PECO Enerav Company J. Doering Vice President -P8APS G. Johnston Director Engineering R. Maldonado Manager BOP Engineering T. Wasong Manager Operations Services R. Gambone Senior Manager Operations P. Nielsen Operations Training J. Lyter Operations Training L. Cobasco Maintenance Rule Coordinator A. Hegedus Maintenance Rule Coordinator H. Abendroth Atlantic Electrical /Delmarva Site Rep D. Wheeler NQA Team Leader M. Taylor Experience Assessment R. Smith Experience Assessment J. McLaughlin ISEG O. Limpias Senior Manager Engineering M. Delong Engineering INSPECTION PROCEDURES USED IP 62706, Maintenance Rule j IP 71001, Licensed Operator Requalification Program Evaluation  ;

IP 92701, Followup '

IP 92702, Followup On Corrective Actions for Violations and Deviations

_ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ - - _

.

l l 9 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened l NUMBER TYPE DESCRIPTION )

l 50-277(278)/98-04-01 URI Failure of certain licensed operators to complete l

requalification training.

! 50-277(278)/98-04-02 VIO Failure to follow LORT program procedures for difference requirement for Job Performance Measures from week to week.

i 50-277(278)/98-04-03 VIO Cailure of annual operating test to sample items required by 10 CFR 55.45 on executing the emergency plan.

!

50-277(278)/98-04-05 VIO Failure to include the area radiation monitoring system within the scope of the maintenance rul Closed NUMBER TYPE DESCRIPTION 50-277(278)/96-07-01 URI Alternate AC power source component (278)/96-07-02 URI Condensate, feedwater, and Core Spray system (278)/96-07-03 IFl Proper interpretation of NUMARC 93-01, 50-277(278)/96-07-04 IFl Poorly documented deviations from NUMARC 93-0 (278)/96-07-05 IFl Balancing reliability and unavailabilit (278)/96-07 06 eel ineffective implementation of the maintenance rul (Also identified as VIO 01013)

50-277(278)/96-07-07 IFl Use of Industry Operating Experience.

I

- - _ _ _ - - _ _ - _ - - - - _ - - _ - _ - _ _ - - - - - _ - - - _ - - - - _ _ _ - - - _ - _ _- _ - _ _ _ _ - _ - - - - _ - - - - _ _ _ _ _ - - _ - - - - _ - - - - - - - - - _ - - - _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ .

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

O O

LIST OF ACRONYMS USED ac alternating current ADS automatic depressurization system BOP balance of plant CCF common cause failure CFR Code of Federal Regulations CRS contiol room supervisor -

EOP emergency operating procedures IFl inspector followup item ISEG independent safety engineering group JPM job performance measure LORT licensed operator requalification training NRC Nuclear Regulatog Commission PBAPS Peach Bottom Atcmic Power Station PECO PECO Energy Company PRA probabilistic risk assessment PSA probabilistic safety assessment SM shift manager SRO senior reactor operator SSC structures, systems, components UCLF unplanned capability loss factor URI unresolved item VIO violation

l

1 I

I

,