IR 05000410/1989018
| ML17056A431 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/06/1989 |
| From: | Todd Fish NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A430 | List: |
| References | |
| 50-410-89-18OL, NUDOCS 8911210283 | |
| Download: ML17056A431 (82) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
OPERATOR LICENSING RE-EXAMINATION l
Report No.:
Facility Docket No.:
Facility License No.:
Licensee:
Facility:
Examination Dates:
Examiners:
Chief Examiner:
50-410/89-18 (OL)
50-410 NPF"69 Niagara Mohawk Power Corporation 301 Plainfield"Road Syracuse, New York 13212 Nine Mile Point Nuclear Station, Unit 2 September
21, 1989 Tracy Walker, Senior Operations Engineer Rich Miller, Sonalysts Marion Daniels, Sonalysts g<- odd H.
>sh, Senior Operations Engr.
BWR Section, Operations Branch, DRS ate Reviewed by:
en Richard
. Conte ief BWR Sect'on-6 erations Branch, DRS
)i 4e D te
Executive Summar Written and,operating re-examinations were administered to seven reactor opera-torss (ROs)
and six senior reactor operators (SROs)
who had failed. one or more sections of the initial requalification exams which were administered during the weeks of July 17, July 24, and July 31, 1989.
Since not all operator s required re-examination in all sections, the applicable section(s) for re-testing varied for each candidate.
Additionally, two crews were re-examined, each crew consisting of two SROs and two ROs.
As graded by the NRC, both crews passed.
In the other sections which were re-examined, one RO failed the writ-ten examination=.
All other operator's passed all applicable 'sections of the re-examinations.
While the NRC',s only purpose was to re-administer requalifi-cation exams, and not to formally. re-evaluate the facility's requalification training program, the examiner made several observations which indicate that the program is improving.
These observations are discussed in section 3 of the Report Details.
This report also discusses the tw'o letters, one dated September 13, 1989, which responded to the NRC concerns with the licensee's Requalification Program Ac=
tion Plan, (Attachment 3) and another letter dated September 29, 1989, which notified the NRC of Niagara Mohawk's intentions to change shift staffing
~
~
(Attachment 4).
The NRC supports the proposed shift staffing changes.
How-ever, there still is a question regarding the Action Plan.
Specifically, it is not clear why the guality Assurance Program did'ot detect or diagnose problems with the requalification training program.
This question is discussed in Section 4 of the Report Details.,
/
l.
Introduction Re ort Details During the examination period, NRC examiners conducted a re-examination of 13 licensed operators (7 reactor operators (ROs)
and 6 senior reactor
'operators (SROs)) at the Nine Mile Point Nuclear Station Unit 2.
The examiners used the process and criteria in NUREG 1021,
"Operator Licensing Examiner Standards,"
specifically, ES-601,
"Administration of NRC Requali-fication Program Evaluation," Revision 5, dated January 1,
1989.
All NRC and facility personnel that attended the entrance and exit meetings are listed in Attachment l.
2.
Individual Examination Results The following is a
summary of the individual re-examination results for the requalification examination.
Only NRC results were used as the basis for a Pass/Fail decision.
Note:
Candidates were only re-examined in the area(s)
that they failed as a result of requalification exams administered in July 1989.
NRC Gradin I
RO I
SRO I
Pass/Fail Pass/Fail TOTAL Pass/Fail Written 2/1 3/0 5/1 Simulator 4/0 4/0 8/0 Walk-through 0/0 2/0 2/0 Overall 6/1 6/0 12/1 Faci 1 ity Gradin I
I I
I RO I
SRO I
TOTAL Pass/Fail Pass/Fail Pass/Fail Written 2/1 3/0 5/1 Simulator 4/0 4/0 8/0 Walk-through 0/0 2/0 2/0 Overall 6/1 6/0 12/1
(RR
2. 1 Individual 0 erator Stren ths and Weaknesses
These were strengths and weaknesses observed more than once during the conduct of the examination.
a.
Individual 0 erator Stren ths
~
SROs displayed ability.to recognize entry conditions into the emergency o'perating procedures (EOPs).
b, Individual 0 'erator Weaknesses Simulat'or
~
ROs displayed an inability Pto cor'rectly determine what emergency core cooling systems (ECCS) were or were not operating properly following. an ECCS initiation signal.
~
ROs displayed an inability to correctly determine whether or not offsite power was available.
Walk-Throu h
Only two operators, were evaluated in the Job Performance Measures (JPMs) section.
Therefore, no determination was made reg'arding strengths or weaknesses.
Written
~
No strengths or weaknesses were noted.
3. ~PR Although the NRC's main purpose was to re-administer requalification exams,'nd not to evaluate the facility's requalification program, the
'xaminer made several observations regarding the program:
~
The command-and-control function of the SRO position was demonstrated satisfactorily.
~
Team interactions and communications between operators were generally satisfactory.
Most SROs periodically briefed the crew on plant status, as well as stating the course of action that they and their crew expected to take.
ROs generally provided feedback to the SROs.
I
These observations, the,fact that all but one operator passed all,areas in which they were re-examined, and a
100% agreement between NRC and faci-lity grading on all sections of the re-examination indicate an improving requalification training program.
Additionally, no specific negative observations were made regarding the program.
4.
Review of NMP-2 res onses to NRC concerns with NMP-2's Revised Action Plan The NRC's Concern 8 with the initial Action Plan noted that-there were no provisions for an independent assessment of the training program actions, The response to this concern states that an independent assessment has now been incorporated into'he Revised Requalification Program Action Plan, and that provisions have been made for a follow-up independent assessment to be conducted once corrective actions have been taken. 'hile these new provisions appear to be satisfactory, the NRC is concerned that:
1) the guality Assurance (gA) Program, a program already in place, apparently did not detect problems with the'requalification program; and, 2) the Revised Action Plan does not address whether or not gA can accurately assess the adequacy of the requalification program.
ATTACHMENT 1 Persons Contacted Durin Re-Examination 1.
Nia ara Mohawk Power Cor oration NMPC L. Burkhardt, Executive Vice President, Nuclear Operations
-
(2)
N. Rademacher, Assistant to the Executive VP, Nuclear Operations (2)
R. Smith, Unit 2 Operations Superintendent (2)
A. Rivers, Training Superintendent (2)
'.
Seifried, Assistant Training Superintendent (1, 2)
- G. Weimer, Unit 2 Training Supervisor (1, 2)
0. Straka, Regulatory Compliance (1'2)
K. Cigler, Unit 2 Operations Training Instructor (1, 2)
S. Dort, Unit 2 Operations Training Instructor
.
(1)
G. Legner, MATS Consultant (2)
M. Shanbhag, MATS Consultant (2)
2.
Nuclear Re viator Commission NRC T. Fish, Senior Operations Engineer T. Walker, Senior Operations Engineer (1, 2)
(1)
NOTES:
(1)
present during entrance meeting on September 18, 1989 (2)
present during exit meeting on'eptember 21, 1989
l
ATTACHMENT 2 RE/VALIFI CATION EXAMINATION TEST ITEMS SCEN NO.
89-14 89-12 No.
SIMULATOR SCENARIOS DBA Loca with Degraded Low Pressure ECCS, Loss of Off-Site Power with Drywell Steam JOB PERFORMANCE MEASURES TASK NO.
Leak LOCATION
Recharge a
CRD Accumulator Transfer UPS2A to the Alternate Power, Supply Individual Control Rod Scram/
Soleniod Deenergization Bypass a Control Rod in RSCS Reset of Recirc FCV Runback Place'eactor Mode Switch in Run Manual Initiation of SGTS Adjust EH" Pressure Setpoint Adjust CRD Pressure Control Valve to Establish Proper d/p Startup Suppression Pool Spray 2620140101 2000290501 2010170101 2029330401
'120070101 2619080101 2450020101.
2010010101 2050150101 IN PLANT IN PLANT IN PLANT CONTROL ROOM CONTROL ROOM CONTROL ROOM CONTROL ROOM CONTROL ROOM CONTROL ROOM 2010040104 IN PLANT WRITTEN EXAMINATION -,
PART A SCENARIO A1 - SSE-A1SRO/RO 89-18 QNUM TEST ITEM NO gVAL 2009160601 2590030101, 2430020101 2000010501 2009060501 2000)0501 3449160503 2000610501 3440270303 (RO only)
(SRO only)
1.0 0.5 0 '
1.0 1.5 1.0 1.0 1.0 0'5 SCENARIO A2 SSE-A2SRO/RO 89-17 gNUN
2
TEST ITEM NO.
2009150501 2269030101
~
2090050101 QVAL 1.5 1.0 1.5
Attachment
REQUALIFICATION EXAMINATION TEST ITEMS (Cont'd)
WRITTEN EXAMINATION PART B QNUM TEST ITEM NO.
QVAL
5
7
QNUM 8'.
12
14 2949070101 2009150501 2390030101 2029330501 (RO only)
3440190303 (SRO only)
TEST ITEM NO.
2439050101
2000350501 2889050101 2490020101 2619010101 2009150501 2239240101 2000200501 2029150101 2859010101 2060020101 3410180303 (SRO only)
2649070101 2020040101 (RO only)
0.75 0.75 0.75 0.5 0.5 QVAL 1.0 1.0 1.0 1.0 1.5 1:0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0
l
.I
ATTACHMENT 3 Licensee Letter Dated Se te'mber
1989
~ NlAGARA u MOHAWK NMP55 280 NINE MILE POINT NUCLEAR STATION/P.O. BOX 32 LYCOMING,NEW YORK 13093/TELEPHONE (315) 343-2110 September 13, 1989 Mr. William Russell Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406
Dear Mr. Russell:
RE:
NINE MILE POINT UNIT 2 DOCKET NO ~ 50-410 Your letter dated August 23, 1989 transmitted the combined.
Inspection Report No.
50-410/89-12.(OL)
on the Requallflcatlon Program Evaluation and BWR Power Oscillation Program Inspection.
This letter requested Niagara Mohawk Power Corporation to provide a
Revised Action Plan to address the concerns discussed ln paragraph 6.2.a of the Inspection Report.
Our internal assessment revealed the potential causes described below for the concerns listed ln paragraph 6.2.a of the Inspection Report.
We are conducting an independent assessment of the Unit 2 Requallflcatlon Program as described ln the attached Revised Action, Plan to identify arid resolve the underlying root causes.
Action Plan Concern 1:
It does not analyze why NMPC was not able to detect the problems with the operator performance and knowledge deflclencles prior to the NRC conducting the requal1 f1 cation examlnatlon.
Potential Causes:
l.
Our review of past examinations and evaluations conducted during the Requallflcatlon Program lacked sufficient depth to allow us to identify these deflclencles so that we could resolve, them prior'to the NRC Requallflcatlon examination.
2.
Neither the instructors nor the operators clearly understood the required performance standards,'specially those related to the simulator portion of the operating examlnatlon.
l
Hr. Mil]1am Russell Page
Action Plan Concern 2:
It does'ot consider whether the simulator scenarios were. real1st1c, manageable, and the operators wer'e not properly trained to handle complex emergency situations.
Potential Causes:
l.
The crew s1ze for s1mulator training was reduced from the normal operating crew size to the minimum Technical Spec1fication shift complement shortly before the NRC Requalificat1on examination, w1thout sufficient training t1me 1n this new configurat1on.
This crew size'eduction was made without -performing an adequate.
assessment of 1ts 'impact on crew function and interaction.
As a-
'result, operators were unfamiliar with their new roles and respons1b111ties and shift supervisors experienced d1ff1culty in establ1shing proper prior1t1es for the crew and 1ts individual members.
2 ~
3.
S1mulator scenarios used to prepare the operators for the NRC
.
Requalification examination were not as complex as those used during the examinat1on.'e incorrectly interpreted'eedback from other ut111t\\es to indicate that the-NRC favored mostly slower paced scenar1os of medium complexity.'ur simulator tra1ning program should have 1ncluded more of the faster paced, complex emergency situat1on scenar1os as we prepared our operators for the new style requal1fication examination.
Examinat1on scenarios were not validated us1ng a
four (4)
man operating crew.
Action Plan Concern 3:
It does not evaluate the organizat1on interface d1fficulties that led to the program deficiencies.
Potential Causes:
l.
The commun1cations between Operations management and Training management was inadequate.
Requalif1cation Program concerns were not effect1vely communicated or d1scussed between the two groups.
Senior level management was not aware of several ma)or Requallfication Program decisions 'ncluding the one to reduce simulator crew size.
Feedback from training to the plant was 1neffective.
2.
A number of conflict1ng demands existed for the operator resources 1ncluding plant startup and operat1on, the development and validat1on of the requalification examination test bank, and the redevelopment of the Requal1fication Program.
Mr. William Russell Page
Action Plan Concern 3:
Potential Causes:
(Cont'd)
3.
Plant Operations had not taken full ownership of the Operator Training program although the degree of ownership had increased over the past several months.
4.
Standards, for conduct of operations (e.g.
communications, roles, and responsibilities)
were not clearly defined for operators or 1nstructors.
Act1on Plan Concern 4:
It does not analyze
- if the tra1ning or1ginally conducted was satisfactorily performed and properly evaluated.
Potential Causes:
Potential causes relative to the performance and evaluation of the training originally conducted have yet to be clearly identified.
The independent assessment be1ng performed will review this area in depth.
=Action Plan Concern 5:
It does not analyze the quality of the training material.
Potential Causes:
Our accreditat1on self-assessm'ent revealed weaknesses in the requal1fication material.
Our Systematic Approach to Training (SAT)
pro3ect 1s intended to correct these deficiencies and ensure a
Job-relevant requalification training program.
Action Plan Concern 6:
It does not analyze if there is an attitudinal problem with some operators.
Potential Causes:
l.
In general, the operators have a pos1tive attitude toward the requalification training program.
Many of the operators have expressed a willingness to work w1th the training department to improve the program.
I
'
Hr. Will1am,,Russel l.
Page
Action Plan Concern 6:
Potential Causes:
(Cont'd)
2..
Lack of clearly def1ned performance standards led to confusion for both the operators and the trainers.
In the absence of establ1shed standards, the operators and tra1ners had become frustrated wh'ile they attempted to define acceptable performance levels.
Th1s frustration may have appeared to be an attitudinal problem while 1n actuality, operators have a positive attitude toward tra1ning.
3.
.. The independent program assessment.
be1ng performed will also review th1s concern.
Action Plan Concern 7:
It does not address the underlying reasons why the performance and knowledge deficiencies exist.
Potential Causes:
See Action Plan Concern gl.
Action Plan Concern 8:
It does not conta1n provisions for independent assessment of your tra1ning prog).am act1ons.
Comment:
An 1ndependent assessment
-
has
'een incorporated into the Requalificat'ion Program Action Plan to invest1gate these concerns and any other concerns which may be 1dentif1ed during the assessment.
A followup independent assessment will be conducted to measure the effect1veness of the correct1ve actions taken.
Hr. William Russell Page-5 C
Action Plan Concern 9:
" It does not consider whether Technical Specification
=changes are required for min1mum Control Room staffing.
Potential Causes:
Me do not feel it necessary to change our Technical Specifications for min1mum Control Room staffing.
Me have demonstrated the ability to manage complex scenarios with the current min1mum crew size, especially with proper training emphasis on roles and respons ibi11t1es and prioritizati on.
It 1 s acknowledged, 'owever, that we are revising our tra1ning program to more a'ccurately reflect our actual operating crew si ze by train1ng and examining with an additional l1censed Reactor Operator that can be sumnoned to the Control Room dur1ng the course of the emergency.
Changes to the or1ginal plan are shown by lines 1n the right-hand margin.
Very truly yours, L. Burkhardt, III
'Executive Vice President Nuclear Operations LB:ck (0684b)
Attachment
I
Mr. William Russe'll Page
I xc: 05rector, Office of Nuclear Reactor Regulation Mr. R. A. Capra, 0)rector Hs.
H. H: Slosson, Pro)ect Manager Mr. W. A. Cook, Res)dent Inspector Records Management
NMP2 REQUALIFICATION PROGRAM ACTION PLAN SEPTEMBER 1989 REVISION
NMP2 REQUALIFICATION PROGRAM ACTION PLAN The Nine Mile Point Unit 2 Operations and Operations Training Department underwent an evaluation of individual performances and Requalification Program during the weeks of July 17 and July 24, 1989.
During this evaluation, 10 of 24 licensed operators failed one or more sections of the examination.
In addition, 1/2 the crews (3 of 6) exhibited sufficient deficiencies to warrant failure as teams by the Nine Mile Point Unit 2 evaluators, Based on this evaluation, Nine Mile Point Unit 2 is implementing an Action Plan to correct these deficiencies.
Our initial evaluation of the program revealed the specific issues discussed below.
Management Analysis consultants will be conducting an independent assessment of the Unit 2 Requal Program to identify the underlying root causes of these weaknesses and to make sure that there are no other weaknesses in the program.
In addition, we will"review the adequacy of the corrective action taken.
The specific actions contained in this document 'are'esigned to correct the program, individual, and crew performance problems noted 'during the evaluation period, with particular emphasis on those issues of examination content and'rew failures in the simulator.
The specific issues include:
1.
The NMP-2 Requalification Program was judged unsatisfactory by both NMPC and NRC.
2.
Evaluation of the written examination by the NMPC Instructional Technologist group raised concerns about examination structure.
3.
Evaluation of the written examination by the NMP-2 Operations Instructional Group raised concerns about Operator knowledge deficiencies.
4.
Heaknesses were noted in crew communications 5.
STA involvement in plant assessment and event control was not consistent between crews 6.
Operator actions were not always in accordance with guidance as provided in the Emergency Operating Procedures (EOP's)
7.
Operator actions were not always in accordance with guidance as provided in normal operating procedures during emergency events-1 September 1989
8.
Dynamic simulator scenarios used in the evaluation were not always realistic, manageable and within the 50 minute.standard as set forth in ES-601
'I 9.
Teamwork, including prioritization, of crew actions, evaluation of plant conditions and communications were weak during emergency events.
-2 September 1989
Specific Issue
¹1 A.
The NHP-2 Requalification Program was judged as unsatis-factory by the NHPC Training Department and the NRC, in that:
l.
>254 of the licensed operators (10 of 24) failed.at least one section of the examination, failing overall.
2.
>25'/ of the licensed operators (7 of 24) failed the written examination.
3.
>ll3 of the crews (3 of 6) failed the simulator team evaluation.
-3 September 1989
B.
Corrective Actions Res oosiaiiities
~im I. Date
~Com
.
Da 1.
Perform an examination analysis of the written (class-room) examination.
2.
Develop an exam development process description.
3.
Perform an examination analysis of the simulator examination.
Seifried Dort
,Smith/Heimer N/A N/A 7/29/89 7/29/89 7/26/89 4.
Interview operators to determine:
1)
Reason for high failure rate
~
2)
Attitude concerning examination process.
Develop Plan and schedule for remediation and for evaluation of D Shift.
Montgomery Kaminski/Cigler/
Smith N/A 7/29/89 N/A 7/29/89 6.
Conduct evaluation of D Shift.
7.
Analyze for cause of exam failures and develop Action Plan to correct.
Heimer/Smi th Heimer N/A 8/3/89 7/29/89 8.
Conduct an independent assessment of the NMP2 Requalification Program which will include, but not be limited to, determining:
a.
Hhy NMPC (Facility Management)
was not able to detect the problems with operator performance and knowledge deficiencies (including BHR Power Oscillation concerns) prior to the NRC conducting the requalification examination and the underlying reasons why the deficiencies exist b.
Determine whether the simulator scenarios were realistic and manageable and why NMP2 operators were not properly trained to handle complex emergency situations prioritization (Corrective Actions (9.B.10)
Rivers 9/15/89 10/15/89-4 September 1989
Speci fic I
¹1: (Cont'd)
~
~
~
~
he extent to which organizational interface difficulties led to program deficiencies.
d.
If there is/was an attitude problems with some operators.
e.
Why NMPC failed to generate an examination bank of high quality written questions and simulator scenarios.
(Corrective Actions 3.B.5 and 8.B.4)
f.
Why NMPC failed to properly time-validate written examination questions and simulator scenarios.
(Corrective Actions 3.B.6 and 8.8.6)
g.
If the quality of the classroom/simulator training including training materials was adequately conducted during the 1988/1989 Requalification Program.
h.
If training and evaluation adequately addressed operator knowledge/performance weaknesses.
i.
If the NMP2 Requalification Program Action Plan adequately addresses all issues pertaining to the Requalification Program and individual operator.-
failures.
9.
Prepare a
summary of "lessons learned" to prevent recurrence.
Develop a process to ensure that lessons learned at Unit 1 (Unit 2) are communicated, to Unit 2 (Unit 1).
10.
Conduct a followup independent assessment to measure the effectiveness of.the actions taken in this action plan.
11.
Prepare a "lessons learned" transmittal to address the importance of ensuring that upper level'anagement is aware of and agrees with major program changes.
-5 September 1989 Rivers/Abbott/
Dahlberg Rivers Rivers/Abbott N/A 4/1/90 10/1/89 9/29/89 4/30/90 11/1/89
Specific I
.¹3:'.
Evalua of the written examination for knowledge area deficiencies by the NMP-2 Operations Training Group raised the following concerns, in that; 1)
SRO's experienced difficulty in; a)
- Determining the actions necessary for a loss of Stator Cooling Water when less than the runback setpoint.
b)
Selecting the necessary response to a short period annunciator.
c)
d)
Determining Primary Containment Isolation Setpoints for,various isolation groups.
Understanding operations of the EHC system Load Limiter Set.
e)
Determining the capacity/limitations for operation with one Reactor Feed Pump.
f)
Determining Limiting Plant Conditions on a'oss of 2NPS-SWG003.
g)
Determining possible scram signals as a result of a Loss of Instrument Air.
Causes and Effects of Reactor Level Swell.
Calculating single Loop MAPLHGR.
Determining Pressure response to an MSIV isolation following a.reactor scram.
I-7 September 1989
Specific I
¹2:
Res onsibi lit
~Im i. Date Com
.
A.
3)
4)
Evaluation of the written examination by the NMPC Instruc-tional Technologist Group resulted in several concerns, in that; 1)
Test item construction is not clear.
2)
Point values for multiple part answers were not specified.
Several double jeopardy questions were noted.
Questions requiring multiple responses were not separated out.
B.
Corrective Actions 2)
3)
Train all Operations Training Instructors involved in writing open reference examinations, on examination development techniques (i.e., test taking, test con-struction, and question construction).
Review all examination questions associated with the requalification examination bank for format and cor-relation to learning objectives.
Review all future requalification examinations for format and organization prior to examination implemen-tation.
Oxford Oxford Oxford N/A 3/1/90 As Developed
"Continuing As Developed
'Continuing 4)
Formulate a plan to complete the Systematic Approach to Training Process.
Heimer/Smith 10/1/89 10/3I/89
This item will be an ongoing process in the requalification program.
-6 September 1989
Specific I 2)
3)
43 (Cont'd):
ROs and ROs experienced difficulty in; a)
Ascertaining Operator actions on a loss of Low Pressure Feed Heater string.
b)
Determining the actions necessary for a sympathetic alert.
c)
Describing the EOP basis which allows for NSIV re-opening during an ATNS.
d)
Defining the effects of Loss of Extraction Steam on Reactor Power.
e)
Calculating total core flow when in a single loop configuration.
f)
Ascertaining the negative response time of the Turbine Control Valves and the Turbine Control Valve Setpoint.
g)
Determining the followup actions required following a Circulating Water Pump Trip.
ROs experienced difficulty in; a)
Determining Operator actions on a loss of RBCLC.
b)
Ascertaining the steps necessary to override Con-tainment Purge Valves following isolation.
c)
Ascertaining the steps required to place CSH System in a Tank to Tank Lineup following initiation.
d)
Determining immediate actions on a Loss of H2 Seal Oil.
-8 September 1989
4, 5.
Observations will be conducted by management personnel (e.g.
Manager-Nuclear Services, Superintendent of Training, Assistant Superintendent of Training and/or other Operations Training Staff) for a minimum of three
- (3) weeks during each Requali fication Cycle that includes simulator training.
This wi 11 aid in identifying and correcting weaknesses in simulator instructor performance.
Schedule the Unit 1 training groups to evaluate, implementation of standards on a selected crew at least once per quarter and provide report to Operations Superintendent.
Include video tape in post simulator exercises to more effectively critique communications teamwork and prioritization (Long term).
Schedule cross crews to evaluations of another crew at least once per calendar quarter (Long Term).
Peifer Weimer/Sanaker Kaminski Weimer/Smith 8/21/89
'10/2/&9 10/9/89 10/2/89
- Continuing
- Contiriuing
'Continuing Jl
- Continuing
This item will be an ongoing process in the requalification program.
-ll September 1989
Specific Is e ¹4:
A.
Heakn were noted in crew communications, in that:
l.
Operators used inprecise language 2.
Directions were non specific 3.
Reports/directives were not always acknowledged 4.
Repeatbacks were often not noted or weak.
5.
Orders were not directed at one individual, sometimes resulting in no accountability.
B.
Corrective Actions Res onsibi 1 i t
~Im 1.
Date
'~om
. Date 2.
3.
Train operators, in the simulator, to ODI 1.06, Verbal Communications.
Add Learning objective to all new and revised Simulator Lesson Plans (Long Term).
Train instructors in the ODI and reinforce the policy to train to these standards during simulator training.
Observations will be conducted by management personnel (e.g.
General Superintendent, Station Superintendent, Operations Superintendent and/or other Operations Management Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes simulator training.
This will aid in identifying and correcting weaknesses in operating crew performance.
Cigl er Cigl er Hillis/Peifer 7/31/89 7/31/89 8/21/89 10/6/89 8/21/89
- Continuing
[.
I I
l 1-I I'I
This item will be an ongoing process in the requalification program.
-10 September 1989
4
e Recognizing indications of an OFG H2 Explosion etermining notifications required as a, communi cations aide.
g)
Recognizing EOP entry conditions for an ATHS situa-tion.
h)
Recognizing feedwater effects on Reactor Pressure.
i)
Describing plant response on a Loss of Vacuum.
Pj)
Identifying limitations placed on operation of Main Condenser Vacuum Breakers.
B.
Corrective Actions 1)
Review examination results with all licensed operators requiring remediation.
2)
Develop a Remediation Plan for examination failures to be conducted between 8/1/89-8/15/89.
3)
Perform re-examination of all examination failures between 8/16/89-8/18/89.
4)
Add alI questions where
>20X of examinees missed the item into the next two year requalification program.
EOP weaknesses and usage deficiencies will be reviewed with all Licensed Operators (See 6.8.1, 6.B.2 and 7.B.1)
5)
Analyze the quality of written examination questions used in the Requalification Program examinations.
(See Corrective Action 1.B.B.e)
6)
Determine why NMPC failed to properly time validate
'ritten examination questions (See Corrective Action 1.B.8.f)
Res onsibi lit Kaminski Kaminski Heimer/Smith Heimer Rivers Rivers N/A 7/31/89 8/16/89 8/18/89 N/A 1/02/90 9/15/89 10/15/89 9/15/89 10/15/89 N/A 7/31'/89-9 September 1989
Specific Is 05:
A.
STA in ment in plant assessment and event control wa not consistent between crews, in that; 1.
Some-STA's provided little or no assessment of events to the SSS/SED other than updating parameters and
,
classifying events.
2.
Some STA's did not provide the SSS with support in ensuring all EOP actions were completed.
- 3.'ome STA's did.not correct inappropriate, actions or
.recommend appropriate actions.
B.
Corrective Actions
~ll ilili: ~ll'. 0 t 2.
3.
4.
Formalize management expectations (beyond what is defined in EPP's and AP's) for the actions of the STA during EOP's.
Train STA's (all SRO's) in the standard during simulator training.
Add learning objectives to all new Simulator Lesson Plan Learning Objectives (Long,Term).
Train instructors in the standard and reinforce the policy to train to these standards during simulator training.
Observations will be conducted by management personnel (e.g.
General Superintendent, Station Superintendent, Operations Superintendent and/or other Operations Management Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes simulator training.
This will aid in identifying and correcting weaknesses in STA performance.
Smith/Abbott Cigler Cigler Ni 1 1 i s 7/31/89 10/6/89 7/31/89 8/21/89 8/21/89
'Continuing
)1 l
I I
I I
I N/A
=
7/2&/89 F
This item will be an ongoing process in the requalification program.'12 September 1989
management perso Peifer Heimer/Sanaker Heimer/Smith Heimer/Randall Specific Is~ ie ¹5:
(Cont'd)
5.
vations wi 11 be conducted by (e.g.
Manager Nuclear Services, Superintendent of Training, Assistant Superintendent of Training and/or other Training Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes simulator training.
This will aid in identifying and correcting weaknesses in simulator instructor'erformance.
6.
Schedule the Unit 1 training groups to evaluate implementation of standards on a selected crew at least once per quarter and provide a report to the Operations Superintendent.
7.
Schedule cross-crew evaluations of another crew at least once per calendar year.
8.
Schedule the Unit 1 Operations Superintendent to evaluate team performance on a selected crew on a regular bas,is.
~tm 1.
Date 8/21/89 10/2/89 10/2/89 10/2/89 Com
- Contin g
)1 I
I I
I I
l I
- Continuing
'Continuing
- Continuing,
This item will be an ongoing process in the requalification program.
-13 September 1989
A.
Operato ctions were not always in accordance with Guid as pro in the EOP's, in that; l.
One crew violated EOP's by securing Standby Liquid Control pumps with all rods not in following an ATHS, l(t!5 VIIb I U I I I 'L Inipl. Date COlllg. Date 2.
although.the RO's knew it was not an appropriate action.
'ne crew never implemented vessel flooding in accordance with EOP's, although the STA knew or suspected that-conditions were met and the requirement existed.
Five (5) crews failed to adequately control water level
~ -
nb ~i1U th 1.
C f i
it with RO's and one (1)
SRO as to what normal water level was in the EOP's.
In three (3) events, the water level rise was slow and controlled.
.One (1)
SRO failed to fully implement guidance for vessel flooding.
Two (2) SRO's failed to recognize that a diamond decision block is not an action statement, in that; when asked if 3(2)SRV's could be open they opened 3(2)
SRV's when.procedurally 7 were to be opened.
6.
One RO suspected that an order to open 2 SRV's was incorrect, but did not question the SSS because he believed the SSS was being guided by EOP's.
B.
Corrective Actions Develop and
~im lement a 2-3 day EOP refresher'training session on EOP usage and basis.
Include portions of Mitigation of Core Damage not covered in EOP's and emphasizing the significance of water level control and overfilling events.
Hi 1 1 i amson 8/21/89 10/6/89-14 September
.1989
3:
5.
R s'pecific EOP 'usage deficiencies and problem areas noted during the requal examination with all licensed operators during the EOP refresher training.
This will include requirement of RO's to question perceived inappropriate orders.
Implement a "closed book" EOP basis examination during each requalification cycle.
Observations will be conducted by management personnel (e.g.
General Superintendent, Station Superintendent, Operations Superintendent and/or other Operations Management Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes simulator training.
This will aid in identifying and
'
correcting weaknesses in EOP usage/implementation.
Observations will be conducted by management personnel (e.g.'Manager Nuclear Services, Superintendent of Training, Assistant Superintendent of Training and/or
. other Operations Training Staff) for a minimum of three (3) weeks-during each Requalification Cycle that includes simulator training.
This will aid in identifying and correcting weaknesses in simulator instructor performance.
Establish formal management expectations for-EOP usag'e, including communications, command control, and'TA responsibilities in carrying out EOP's.
Hilliamson/
Cigler Kaminski Ni 1 1 i s Peifer Smith/Abbott 10/2/89.
'Continuing 8/21/89 8/21/89 N/A
- Continuing
)1 I
I I
I I
- Continuing I
I I
I I
I
7/28/89 8/21/89
~
'0/6/89
~
i 1 C
- This item will be an ongoing process in the requalification program.
-15 September 1989
A.
Operato ctions were not always in accordance with Guida as pro in normal operating procedures during emerge events, in that; 1.'ome crews had difficulty in carrying out N2-0P-97, Section H.2 per EOP-RQ.
2.
"Although crews could work through OP-29 during a recirc pump trip and recovery, two crews wasted 45 minutes doing administrative tasks that were not necessary and one crew did not realize a recirc pump could not be started in the restrict'ed zone and drove recirc flow further into the zone in an attempt to restart the pump.
(Observed during NNPC Evaluation Heck)
3.
-Several RO's did not correctly place RHR in SP Cooling or DN/SP Spray when required in an emergency situation.
B.
Corrective Actions:
1.
Review specific deficiencies concerning EOP.required actions during EOP refresher training.
2.
Implement "closed book" JPH's in the simulator on those emergency tasks that should be able to be performed without the use of a procedure.
3.
Establish formal management expectations for verification of immediate actions taken during emergency conditions.
Hi 1 1 i amson/
Cigler Kaminski Smith/Abbott
~lni I. i)ate 8/21/89
"1 /2/90 N/A
~Com.'ate 10/6/89
- Continuing 8/21/89
This item will be an ongoing process"in the 'requalification program.
-16 September 1989 h
hdOVV IIU ~
A.
Dynami
- mulator scenarios used in the evaluation were alway istic, manageable and within the 50 minute standard as set forth in ES-601, in that:
l.
One scenario involved an ATNS following an MSIV isolation due to failed fuel (>3XNFPB isolation).
In addition, the SDV ruptured in the Reactor Building causing a direct leak from the vessel to the secondary containment.
The SSS was in 14 different EOP's.
a.
This scenario was beyond the boundaries of the NMP2 FSAR.
m b.
This scenario was unmanageable in that two crews took manual pressure control as directed by EOP's, then required'he same operator to inject with both SLC pumps.
Both crews lost control of manually overridden automatic functions resulting in vessel depressurization and subsequent overfill.
2.
All scenarios exceeded the 50 minute time guidelines.
B.
Corrective Actions:
~ltub oII5 I 0 I I I lg 1.
Develop a plan to implement each of the 15 existing Kaminski scenarios into the requalification program for training and evaluation.
2.
Revise each scenario validated during the requal cycle Kaminski and revalidate with one crew.
3.
Develop one new 50 minute scenario each cycle with Kaminski material corresponding to the material taught in the cycle.
- This item will be an ongoing process in the requalification program.
'/A 10/2/89 As Revised N/A As Developed
- Continuing-17 September 1989
~
f
5.
6.
Determine whether the simulator scenarios used in the Annual Requalification were realistic and manageable.
Determine why NNPC was unable to properly time'alidate simulator scenarios used in the Annual Requalification Examination.
(See Corrective Action 1.8.8.f)
4.
An
"
ze the qual i ty of simulator scenarios used in ification Program examinations.
(See Correct Ac son 1.8.8.e)
AVE Ulled I U I~II l.
Rivers Rivers Rivers iuii)t. Uul.e 9/15/89 9/15/89 9/15/89 (Olllp. UBLL 10/15/8 10/15/89 10/15/89-18 September 1989
~
P
Specific I
//9:
A.
Teamw ncluding p'rioritization, evaluation and communication, were weak, in that:
~R<<ibili
~lm 1.
Date Com l.
2.
4, 6.
7.
9.
Several crews tended to "cluster" around problems.
One'rew took an action in violation of EOP's even though the Reactor Operator knew the action was incorrect.
'
Several crews-allowed alarms to continue.for up to ten (10) minutes, trying to verbally communicate above the alarm noise during EOP's.
Some cre~s SSS'ere not aware of sources of water that were injecting into the vessel causing overfill.
Several crew members did not effectively screen plant parameters to ensure pertinent EOP parameters were communicated to the SSS.
Several STA's were more concerned with classification of events than assessment of plant, conditions.
SSS'id not always effectively prioritize crew actions
'during EOP's.-
Two crews did not correctly evaluate system status of recirc.pumps being tripped prior to drywell spray being initiated.
Some RO's did not effectively communicate their actions so that other members could react (i.e.
Rod Insertion following an ATHS that directly impacted vessel depressurization).
B.
Corrective Actions:
l.
Establish formal management expectations for the roles and responsibilities of crew members during emergency conditions.
Smith/Abbott N/A 7/28/89-19 September 1989
Specific I e 09:
(Cont'd)
~Re s o os i~bi i it
~Im i. Date Com 2.
3.
5.
6.
7.
.Thi Cigler
'igler Kaminski
'i 1 1 i s
. Peifer Heimer/Sanaker ogram.
Train crews in the standard during simulator training and add to Simulator Lesson Plan Learning Objectives.
Train instructors to the standard and reinforce the policy to train -to these standards during simulator training.
Perform team and individual evaluations on each crew each requalification training week.
Observations will be conducted by management personnel (e.g.
General Superintendent, Station Superintendent, Operations Superintendent and/or other Operations Management Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes
'imulator training.
This will aid in identifying and correcting weaknesses in crew performance.
Observations wi 11 be conducted by mapagement personnel (e.g.
Manager Nuclear Services, Superintendent of Training, Assistant Superintendent of Training and/or other Operations Training Staff) for a minimum of three (3) weeks during each Requalification Cycle that includes simulator training.
This will aid in identifying and correcting weaknesses in simulator instructor performance.
Schedule the Unit 1 training group to evaluate implementation of standards on a selected crew at least once per quarter and provide a report to the Operations
,Superintendent.
s item will be an'ongoing process in the requalification pr 7/31/89 7/31/89 10/2/89 8/21/89 8/21/89 10/2/89 10/6/89 8/14/89
- Continuing I
'Continuing I
I I
I I
- Continuing
'
I I
I I
I I
- Continuing.
-20 September
.1989
'
Specific Is A'9:
(Cont'd)
Res onsibi 1 it
~Im 1.
Date Com
.
D Neimer/Smi th Heimer/Randall River s/Smith 8.
Schedule cross-crew evaluations of another crew at least once per calendar year.
9.
Schedule the Unit 1 Operations Superintendent to evaluate team performance on a selected crew on a
regular basis.
10.
Determine the reason for operators inability to handle complex emergency situations.
(See Corrective Action 1.8.8.b)
This item will be an ongoing process in the requalification program.
10/2/89 10/2/89 9/15/89
- Continuing I
"Continuing I
10/15/&9-21 September 1989
I
ATTACHMENT 4 Licensee Letter Dated Se tember
1989
r Jr P
t
N~ NBA NMP56826 NINE MILE P0INT NUGLEAA 8TATloN /P.o. Box 32 LYGQMING,NEwYQRK 13093/TELEPHQNE (315) 343-2110
SUBJECT:
Notification of Changes to Shift Staffing at Nine Mile Point Unit 2 to Better Utilize Licensed Operators
Dear Mr. Russell:
I This is to advise you of our intention to change the current shift staffing in effect at Unit 2.
Presently a four'(4) shift rotation of three (3) Senior Reactor Operators (SROs), with one SRO being 'the Shi.ft Emergency Planning Coordinator (SEPC),
and four (4) Reactor'Operators (ROs) is being utilized.
Nine Mile Point Unit 2 will change to a five (5) shift rotation of two (2)
SROa and four (4) ROs with one being the SEPC.
The new schedule provides better utilization of licensed operators and is in compliance with Techni.cal Specifications.
RBQIQHUHM Following the NRC/NMPC co-administered requali.fication examination in July 1989, changes in shift staffing were instituted to strengthen the shifts'emergency response, capabilities while remedial actions were being taken for crews who faiI.ed the simulator examination.
A four-shi,ft rotati.on was establi.shed, comprised of recently re-examined operators to adequately staff operations through the Fall 89 outage.
Addi.tionally, Niagara Mohawk established the Shift Emergency Planning Coordinator (SEPC) to assist the Station Shift Supervisor (SSS)/Emergency Director in executing the Emergency Plan.
This shift staffing was discussed in our Justification for, Continued Operation dated 8/10/89.
During, the requalificati.on examination period in July 1989, the four man simulator crews demonstrated a weakness in the abi.lity to properly prioritize the Shift Technical Advisor functions wi.th initiation of the Si.te Emergency Plan.
In at least one scenario, the Shi.ft Technical Advisor became too involved in the Emergency Plan, diverting his attenti.on from the emergency at hand, and, therefore, could not provide adequate support to the SSS or shift.
One approach to correct this problem was the establishment of the SEPC.
SRO's
I
Nr. M. September 29, 1989 Page
NMP56826 were initially assigned as SEPC's since they already have received training on Emergency Plan= implementation and were therefore able to immediately fillthis function.
Also'uring the requalification examination period, weaknesses were identified in delegation, communication and role definition..Training was started
'immediately for all shift licensed operators as well as for operators who would be re-examined.
A-new procedure (ODI 1.08) was developed and implemented to better define the responsibilities of Control Room personnel
'oles during emergency events.
l Licensed shift operators have attended a specially designed training week to focus on weaknesses identified during requalification.
Crew evaluations
were conducted at the end of the week with noted improvement by all shifts.'uture training sessions will continue to focus on these issues with increased monitoring by management as outlined in our revised
'%MPC Requalification Program Action Plan September 1989".
The duties of the SEPC will be ze-assigned to an extra (above Technical Specification complement) Reactor Operator on the shift.
The Reactor Operators have received additional training and have sufficient knowledge of the Emergency Plan and plant conditions to assist the two SROs on shift.
Addi'tional training was conducted for the Reactor Operators ori EAP-l,
"Activation and Direction of Emergency Plan"; EAP-2, "Classification of Emergency Conditions"; EAP-3, "Emergency Personnel Action Procedures";
EPP-20,
"Emergency Notifications"; EPP-17,
"Communications";
and Operations Department.
Instruction'.08,
"Operations Policy foz Emergency Operating Procedures".
Practice was held in the classification of emezgency events using EAP-2 and completion of notification fact sheets using EPP-20.
Testing was done upon completion of training.
The training, practice, and test results have been assessed by training and operations management and it has been determined that Reactor Operators are qualified to perform the SEPC function.
With the return of our licensed operators who successfully completed the NRC requalification examination, a five-shift rotation has been developed.
The new shift schedule will reduce the amount of hours worked for each individual and make better use of our licensed operators.
The 'change in shift schedule and organization is the next evolution in return-to-normal operation.
The five shift, rotation is an obvious improvement over four shift rotation because of the reduction in hours while still maintaining shift coverage above Technical Specification requirements.
Having a Reactor Operator perform the duties of the SEPC zather than a Senior Reactor Operator is a minor change well within the capabilities of a Reactor Operator to accomplish for three reasons:
~
~
b
) ]
Hr.
W. September 29, 1989 Page
NMP56S26 1)
The Reactor Operator is knowledgeable of those aspects of the Emergency Plan that relate to the duties of the SEPC from his/her-Reactor Operator license class training.
2)
The duties of the SEPC are predominately administrative in nature and relatively easy for a Reactor Operator'o perform.
3)
The recent training and testing of the Reactor Operators confirms their
~
ability to perform'his function.
A change in the Unit 2 operations shift schedule has been. developed as a
result of the expected return of operators following recent remediation training, the re-assignment of the SEPC from an SRO to an RO, and training for all shift operators on weaknesses identified during the annual requalification examination.
It is planned to institute the revised shift staffing as discussed above at
~
~
2400 on September 29, 1989.
Very truly yours, L. Bur ardt, III Executive Vice President Nuclear Operations LB/RS/lmc (0964V)
xc: R. Capra J. Miggins
v