IR 05000352/1987007

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Requalification Program Evaluation Rept 50-352/87-07OL for 870309-25.No Violations Noted.Deficiencies Noted:Senior Reactor Opertors Not Trained to Reenter Emergency Operating Procedures Following Reentry Conditions
ML20215J661
Person / Time
Site: Limerick 
Issue date: 05/18/1987
From: Collins S, Keller R, Lange D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215J619 List:
References
50-352-87-07OL, 50-352-87-7OL, NUDOCS 8706250071
Download: ML20215J661 (5)


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I U.S. NUCLEAR REGULATORY COMMISSION

REGION I

REQUALIFICATION EVALUATION REPORT EVALUATION REPORT NO.

50-352/87-07(OL)

FACILITY DOCKET NO.

50-352

FACILITY LICENSE NO.

NPF-39 LICENSEE:

Philadelphia Electric Co.

2301 Market Street Philadelphia, Pa 19101 FACILITY:

Limerick Generating. Station EXAMINATION DATES: March 9, 1987 through March 25, 1987 CHIEF EXAMINER:

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(-/PP 7 David J. Larkyd

Date Lead BWR Exam REVIEWED BY:

3Y/f/fr7 Robert M. Kell'er Date Chief, Project Section 1C APPROVED BY:

$FM 5 h87

' Samuel J.' Collins Date l

Deputy Director j

Division of Reactor Projects j

SUMMARY:

During the period of March 9, 1987 through March 25, 1987 a requalification program audit was performed to evaluate the effectiveness of the Licensed Operator Training Program.

This evaluation was performed under the guidance of a pilot program review which encompassed the following:

1.

An NRC review and modification of the R0 and SRO annual written examinations administered the week of March 9, 1987.

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Observation and parallel evaluation, by NRC examiners, of the facility administered operating examinations administered the weeks of March 9, 1987 through March 25, 1987.

3.

Parallel grading, by NRC and facility examiners, of selected R0 and SR0 written examinations.

8706250071 870522 PDR ADOCK 05000352 V

PDR l

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DETAILS

1.

EXAMINATION RESULTS:

R0 SRO TOTAL Pass / Fail-Pass / Fail Pass / Fail Written Examination 3/0 6/1 9/1 Operating Examinations 3/2 8/4-11/6 Evaluation.of Facility Written Examination Grading:

Sa'ti sf actory

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i Overall Program Evaluation: Marginal f

2.

SCOPE:

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This announced Requalification Program Evaluation entailed 160 direct

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inspection hours reviewing and observing the effectiveness of the Licensed

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Operator Training Program.' Within the areas inspected, no violations l

were identified.

The inspection scope and findings were summarized on l

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March'25, 1987 during an exit interview held at the Region I (NRC) office.

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The licensee acknowledged the inspection findings with no' dissenting comments. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.

3.

WRITTEN EXAMINATION A. detailed review of the R0 and SR0 annual written examinations was performed by.a Region I Operator' Licensing Examiner.

The exams were evaluated as satisfactory. Minor changes were made-(approximately 15% of both exams) as a result of the review.

4.

ORAL EXAMINATION o

Region I examiners audited the administration of six (6) oral examinations.

The first (4) examinations audited resulted in an unsatisfactory evaluation of two examinations conducted by one (1)

contract examiner. The NRC examiner discussed the examinations with the contract examiner and facility management personnel.

The examinations conducted, not the candidates, were evaluated as unsatisfactory.

The specific questions asked were generic, superficial'and not applicable for the depth and comprehension required of licensed personnel.

Facility management discussed the examinations with the license candidates i

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involved.and determined a re-examination was necessary.

The contract examiner was removed from examination assignments and facility licensed management personnel re-examined the candidates involved.

The parallel evaluations and audits of the remainder of the oral examin-ations were evaluated as satisfactory.

5.

SIMULATOR EXAMINATIONS Region I examiners audited the administration of simulator examinations for twelve (12) SR0 and five (5) R0 candidates.

The first day of examin-ations audited resulted in an unsatisfactory evaluation, by both the NRC and the facility contract examiners, for (4) four SRO and (2) two R0

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candidates.

The simulator examination failures were primarily concen-

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trated on one shift -of candidates observed.

Performance deficiencies were observed in diagnosing appropriete entry conditions into TRIP procedures, proper verification of plant parameters, responding to several NSSSS Isolations at once, and overall communication among the shift personnel.

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Immediate corrective action was taken for deficiencies observed, in

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accordance with the Limerick Requalification Program, a

The candidates failing the operating examinations were removed from shift duties, given remedial training on performance deficiencies, and re-examined the following week.

Due to the limited NRC participation during this evaluation ie, observation only, the Chief Examiner determined that additional observation was warranted along with observation and parallel evaluation during the retake examinations conducted for the first group of failures.

The subsequent evaluations observed, during the week of March 23, 1987,-

l were evaluated as satisfactory.

Individual deficiencies noted during these examinations were documented and should be fa:tored into the next full cycle of requalification training.

6.

SUMMARY OF DEFICIENCIES 87-07-01

l Senior Reactor Operators have not been trained to re,-enter the Emergency Operating Procedures (TRIPS) following subsequent re-entry conditions.

i This deficiency was observed during several transient evaluation scenarios conducted on the Limerick Simulator.

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Generic Letter 82-33, (NUREG-0737), Supplement I requires that operators

be trained in accordance with Emergency Pr'cedure Guidelines for upgraded

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E0P procedures.

87-07-02

Senior Reactor Operators have not been adequately trained to enter the'RC (RPV Control) T-101 Trip Procedure.

Discussions between the Limerick training department personnel, the Operations Staff Personnel, and the NRC,

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resulted in a difference of opinion on when to enter T-101 given a scram condition with power above 4% or unknown.

Continuity must exist between l

the Limerick Training Department and Operations personnel to provide

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appropriate upgrade training to licensed candidates on this issue. The i

basis for this deficiency is the same as deficiency 87-07-01 above.-

87-07-03 l

A training deficiency was noted, during the Simulator examinations, on

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the proper implementation of Procedure A-7, Conduct of Operations.

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Specifically, the communicaticn, authority and responsibility of the Shift Supervisor and Shift Superintendent was demonstrated as unsatisfactory, j

This performance deficiency contributed to the failure of four (4) SR0

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candidates.

87-07-04 A training deficiency was noted, during the Simulator examinations, on the proper implementation of Procedure GP-8, Containment Isolation l

Reset.

Both R0 and SRO candidates demonstrated unsatisfactory performance

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using this procedure.

It was noted, by NRC examiners, that discrepancies i

existed between the actual plant and the simulator for control switch

identification.

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PROGRAM WEAKNESSES j

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As a result of the Pilot Program evaluation the following weaknesses were noted in the effectiveness of the Limerick Licensed Operator Requalification Program.

(a). The requalification program, as outlined, does not address what, l

action is to be taken for candidates who perform unsatisfactordly on

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the simuiator examination.

(b). The examiners who conducted the simulator exams were different from those who conducted the oral walk-thru exams for the same I

candidates.

This lack of continuity contributed to no follow-up

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questioning during the oral examinations for deficiencies ider,tif:ed

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during the simulator examinations.

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1 (c). Simulator training scenarios and evaluation scenarios were

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a extremely similar. l Simulator examination scenarios should differ i

sufficiently from training scenarios to conduct an effective performance l

evaluation.

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EXIT' INTERVIEW

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l NRC-ATTENDEESi Curtis-Cowgill Chief,. Reactor Projects Sec. 2A-

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. Robert Keller Chief, Reactor Projects Sec. 1C

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. David Lange

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Chief Examiner Allen Howe Examiner

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Gene Kelly

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Senior Resident' Inspector, Limerick-FACILITY ATTENDEES:

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Robert Bulmer.

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Training Manager John Franz Station. Manager

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John Doering-

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Operations Manager Lawrence Hopkins Operations. Supervisor

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Richard Helt'

Sr. Training Instructor

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COMMENTS The licensee acknowledged the inspection findings with no dissenting comments.

J The Chief Examiner noted the deficiencies identified would have to be responded to within 30 days of the date of this letter. The Chief

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Examiner informed the licensee that a follow-up audit would be conducted

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during the next cycle' of annual requalification examinations, i

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