ML17157B090

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Mgt Meeting Repts 50-387/92-10 & 50-388/92-10 on 920214. Major Areas Discussed:Licensees Action in Response to Weakness Identified During Licensed Operator Requalification Program Evaluation
ML17157B090
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 03/11/1992
From: Conte R, Walker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157B087 List:
References
50-387-92-10-MM, 50-388-92-10, NUDOCS 9203190099
Download: ML17157B090 (74)


See also: IR 05000387/1992010

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

REPORT NOS.:

DOCKET NOS.:

50-387/92-10

50-388/92-10

50-387

50-388

LICENSE NOS.:

NPF-14

NPF-22

LICENSEE:

Pennsylvania Power and Light Company

2 North Ninth Street

Allentown, Pennsylvania

18101

FACILITY'EETINGAT'usquehanna

Steam Electric Station

Region I Office, King of Prussia, Pennsylvania

MEETING CONDUCTED: February 14, 1992

Submitted by:

T. Walk, Senior Operations Engineer

BWR Section, Operations Branch

Division of Reactor Safety

Date

Approved By:

Richard J. Con, Chief

BWR Section, Operations Branch

Division of Reactor Safety

J)

Pm

ate

Summary:

A meeting was held at the licensee's

request on February 14, 1992, to discuss the

licensee's actions in response

to weaknesses

identified during the Licensed Operator

Requalifiication (LOR) program evaluation performed in January

1992.

The licensee

presented

the results of the root cause analysis performed by their Event Review Team

(ERT) ~

They also described their response plan for correction of the identified weaknesses

in the LOR program.

The root cause analysis was thorough and comprehensive

and the

corrective actions adequately address

the identified weaknesses.

DETAIL/

1.0

Lntnr duct~in

On February 14, 1992, at the NRC Region I Office, the below listed personnel

participated in a meeting to discuss Pennsylvania Power and Light's (PP&L's) actions

in response to weaknesses

identified during the LOR program evaluation conducted by

the NRC in January

1992.

2.2 M~i<<d

2.1

Penns

lvania Power & Li ht Com an

H. G. Stanley, Superintendent of Plant - SSES

H. J. Palmer, Manager - Nuclear Operations

T. R. Markowski, Day Shift Supervisor

W. H. Lowthert, Manager - Nuclear Training

A. S. Fitch, Operations Training Supervisor

J. Kenney, Licensing Group Supervisor

R. M. Peal, Supervisor - Nuclear Compliance

H. Lloyd, Compliance Evaluator

G. Jones, Manager - Nuclear Engineering

H. Woodeshick, Special Assistant to the President

2.2

~her

R. Janati, PA DER/BRP

D. Ney, PA DER/BRP

J. Henrich, International Representative

- IBEW

E. Fox, Local 1600 - IBEW

2.3

Nuclear Re ulato

mmi

i n

M. W. Hodges, Director, Division of Reactor Safety (DRS)

L. H. Bettenhausen,

Chief, Operations Branch (OB), DRS

J. White, Chief, Reactor Projects Section 2A, Projects Branch 2,

Division of Reactor Projects (DRP)

T. E. Walker, Senior Operations Engineer, OB, DRS

S. Barber, Senior Resident Inspector, Susquehanna,

DRP

J. Raleigh, Project Manager, Office of Nuclear Reactor Regulation

3

3.0

Licen ee Pr

entati

n

The Superintendent of Plant - SSES explained the purpose of the meeting.

The

Manager - Nuclear Operations discussed

the history of the LOR program leading up

to the program evaluation conducted in January

1992.

He explained the actions taken

in response to the identified deficiencies and discussed

the results of the root cause

analysis.

He also introduced the Evaluation and Response

Plan that PP&L has

developed to identify and correct the weaknesses

in their LOR program.

His

presentation is included as Attachment 1.

The Event Review Team Root Cause

Analysis is included as Attachment 2.

The Manager - Nuclear Training presented

the details of the Evaluation and Response

Plan and discussed

the status of the corrective actions.

His presentation

is included as

Attachment 3.

The Evaluation and Response

Plan is included as Attachment 4.

4.0

Qgn~cl i~in

The root cause analysis appears to have been thorough and comprehensive in

identifying the causes of the weaknesses

in the requalification program.

The

conclusion that PP&L lost focus on superior operator performance and accepted

performance that should have been rejected during normal training and evaluation was

insightful. The corrective actions described in the Evaluation and Response

Plan

adequately address the identified root causes and causal factors and should prevent

recurrence of the problems.

PENNSYLVAI.'GAPOWER AI%3 LIGHT COMPAXED

SUSQUEHAN'M STEAM ELECTRIC STATION

LICENSED OPERATOR REQVALIFICATION

PROBLEM STATEMENT

HOWAIG) J. PALMER, JR - SRO

MANAGER- NUCLEAR OPERATIONS

HOW WE GOT HERE

PROCESS FOCUS INSTEAD OF PERFORI'NANCE FOCUS

WHERE WE AjRE NOW

PROPER EXAMS ARE BEING CONDUCTED

OPERATORS A)RE COMPETENT Al%) FULLYQUALIFIED

WHERE WE ARE GOING

EVALUATIONA2'6) RESPONSE PLAN

LEADINGTO

FLAWLESS PERFORMiANCE

HOW WE GOT HERE

19SO

19S6

1987

19S9

1990

THE DENTON LETTER (1 1/2 PAGES)

10CFR CHANGE

ES601, REV. 4 (14 PAGES)

ES601, REV. 5 (79 PAGES)

ES601, 602, 603, 604, 605, REV. 6 (121 PAGES)

PRIOR TO 1992, 543 EXAMS, 24 PARTIALFAILUIRES

NRC PAIW.LLELGRADING

19S9

1990

1991

16, ONE RO,

20, TWO RO,

20,

DRAFT

REV. 5

100%

REV. 5

100%

REV. 6

100%

1992

12~ ONE SRO, 2 RO, 1 TEAM REV. 6

100%

PPdkL

1992

40, 2 RO TO DATE

26, TO GO

PROCESS FOCUS

MMARC/MAlVl"G/BWROG/NRCMEETINGS

TRAINIINGON TEST CONDUCT

TEST MATERIALDEVELOPMENT

REV. 5

REV. 6

JPMS/QUESTIONS

75

10/YR (125-150)

LIMITSAND CONTROLS

350

75/YR

STATIC SIIVHJLATOR

SIMULATOR SCENARIOS

350

75/YR

5/YR (30)

NUIREG 1021 "EXPERTS"

ISCT LAWYERS REV 5/6

SAVE THE PROGRAM

FATALFLAW

GOOD

EVAL

BAD

ISCTS VS. COMPETENCIES

WjHERE WE ARE NOW

JAI%7ARY 6 - 9

NRC EXAMS/STOPPED SIlVHjLATOR

EXAMS

JANUARY 13

MEETINGWITHSHIFT SUPERVISORS

SIMULATORINSTRUCTORS

JANUARY 15

MANAGER- NVCLEAROPERATIONS

PERSONI&L ASSESSMENT PROVIDED

TO THE PLANT SUPEM1%TENDENT

JANUARY 13 - 23

ERT/ROOT CAUSE

JANUARY 17

MEETING WITHJOHN KAUFFMANTO

REVIEW RESPONSE PLAN

JAZ'AJARY 24

EVALUATIONTRAINIING

JAIAJARY2S

RECOMMENCED SIIVHJLATOREXAMS

FEBRUARY 6 - 7

COMBIMD SHIFT SUPERVISOR A2'G)

SIIVHjLATORINSTRUCTOR MEETING

FEBRUARY 14

KmG OF PRUSSIA

ROOT CAUSE RESULTS

12 TEAMMEMBERS

3 PROBLEM STATEMENTS

TIMELINE

20 INTERVIEWS

ANALYSIS

ROOT CAUSES

CAUSALFACTORS

12 RECOMMENDATIONS

CAUSES

RO T CAUSES

EVALUATORS

LACKEDFORMAL GUjlBANCE

PLACED EMPHASIS ON RECOVERY VICE

INAPPROPRIATE ACTION

DID NOT CONSIDER WHAT COULD HAVEHAPPENED

INADEQUATEPERIODIC ASSESSMENT OF OUR PROGRAM

COMPARED TO CUIRENT STANDARDS

AUSALFACTORS

EVALUATORS

BOTH SCENARIOS INSTEAD OF ONE

CRITICALS'j.'EPS ONLY, DID NOT INCLUDE

COMPETENCY

NOT FORMALLYTRAINED

TECKACALSIGNH. ICANCE, COLD WATER WITHTWO

RODS OUT

PROCEDURES

EOPS DO NOT REFLECT EPG REV. 4

CAUSES

CONTINUED

EXTERNALFA T R

"CRASH/BUKN"SCENARIOS

IMPORTANCE OF ISCTS

LOWER RISK BEHAVIOR

SELF/TEAM LOOK BAD DUE TO QUESTIONS

TAKINOTHERS'CSTS

STRESS

EXTRA OBSERVERS

CAREER IMPLICATIONS/PRESSURES

UNKNOWNEVALUATORSTAI%3ARDS

POTENTIALFOR A THIRD SCENARIO

RECOINIVK<NDATIONS

ADDITIONAL

COINIVKMCATIONS

TEAMWORK

FUNDAMENTALOPEIUTIONS

PAIMVKTERCONTROL

PROCEDURES

USAGE DURII'%G TRANSIENTS

EQUIPMENT RESTORATION

IMPLEMENTEOP EPG REV. 4

EVALUATORS

SCENARIO DEVIATIONS

PERFORMANCE NOT JUST ISCTS

INSTRUCTORS/SUPERVISION

OPERATING EXCELLENCE

CONSISTENT DIRECTION

COMMUNICATERESULTS

LICENSED OPERATORS

1VRMAGEMENT

WHERE WE AjkE GOING

EVALUATIONue) RESPONSE PLAN

LEADINGTO

FLAWLESS PERFORMANCE

LIVINGDOCUMENT THATWILLBE UPDATED TO INCLVDE

ALLLESSONS LEARj.'WDDtjRINGJANUARYAND

FEBRUARY TO SET OUR NEW DIRECTION IN LICENSED

OPERATOR TRAININGAND EVALUATION.

I

LICENSED OPERATOR REQVAL

EXP'VENT

REVIEW TEAMREP

RT

TABLE OF CONTENTS

Page

Executive

Summary

II.

Introduction

III. Background

IV.

Analysis Techniques/Root

Cause Analysis

V.

Interview Summary

13

VII. Recommendations/Actions

to Prevent Recurrences

16

Attachments

A.

B.

C.

D.

Historical Requal Timeline

Cause

and Effect Chart

Team Failure

Cause

and Effect Chart

RO Failure/Associated

Timeline

Cause

and Effect Charts

D.1

SRO Failure

(PP&L/NRC Disagree)

D.2

Team Failure

(PP&L/NRC Disagree)

E.

Cause

and Effect Symbols Legend

January

23,

1992

Page

1 of 17

EXECUTIVE 8UMMARY

During the week of January

6,

1992, the

NRC participated in the

Licensed Operator Requalification

exams at

SSES.

While the

NRC

evaluated

our Requalification Program

as satisfactory,

there were

several

problems that could easily have resulted in our program

being rated unsatisfactory.

This could have resulted in severe

ramifications for PP&L.

The problems were:

~

Three of 12 operators failed the simulator exam.

~

One of three operating

teams failed the simulator

exams.

~

PP&L evaluators initially passed

individuals and

a team

that the

NRC failed.

Our analysis of this event identified several

causes

as described

in the root cause analysis.

The key item is that

PP&L lost focus

on superior operator

performance

as the path to exam success.

In

our normal training and evaluation

we accepted

performance that

we should have rejected.

We will re-establish

our performance

standards

and implement

training to meet them.

We will train our evaluators to focus

on performance.

We will help our operators

understand that the path to exam

success

is the

same

as the path to flawless operation every day.

We believe the recommendations

identified by this analysis will

correct the underlying problems

and restore

our operation to the

performance

levels that

PP&L demands.

January

23,

1992

Page

2 of 17

INTRODUCTION

During the week of January.

6,

1992, the

NRC performed their

annual Licensed Operator Requalification

exam and inspection at

Susquehanna

SES.

The purpose of their visit was to perform

requalification examinations

on a selected

group of licensed

operators

and to evaluate

our Licensed Operator Requalification

Program.

Twelve licensed operators

were scheduled for examination:

1

SRO from Operations

(Unit Supervisor)

5

SROs from Training (Simulator Instructors)

6 ROs from Operations

(PCOs)

PP&L evaluators

were:

Manager

Nuclear Operations

primary management

contact

Day Shift Supervisor

team evaluator,

SRO evaluator

Operations Training Supervisor

SRO evaluator

Shift Supervisor/Procedures

RO evaluator

Unit Supervisor

RO evaluator

At the conclusion of the week,

one

SRO,

two ROs,

and one team

failed the simulator portion of the

exam.

In addition,

PP&L

evaluators

and

NRC evaluators did not initially agree

on any of

the failures but agreement

was reached

before the exit meeting.

These results

allowed the

NRC to ultimately find our

Requalification Program acceptable.

One more individual failure,

one more team failure, or failure to reach

agreement with the

NRC

on our final evaluations,

would have meant our Requalification

Program would have been found unacceptable.

An unacceptable

Licensed Operator Requalification Program has severe

ramifications for the company.

As a result,

a team of

individuals was assembled

to perform a Root Cause Analysis on the

problems that occurred during the week of January

6,

1992.

January

23,

1992

Page

3 of 17

BACKGROUND

Annually, all licensed operators

are given requalification

examinations.

The examination consists of three parts:

Written exam

Plant walkthroughs

(JPMs)

Simulator

exam

All operators

are evaluated

by a team of PP&L management

individuals.

In addition,

a selected

group is also evaluated

by

a team of individuals from the

NRC.

Each operator

must be

evaluated. at least

once every six years

by the

NRC.

The existing

process

has

been in place at PP&L since our 1989 annual

exams.

For the simulator portion of the exam, the individuals are

assembled

into four man teams.

One

SRO is designated

Shift Supervisor

One

SRO is designated

Unit Supervisor

One

RO is designated

PCO-U (Unit)

One

RO is designated

PCO-X (Extra)

Each team is also provided with an STA.

The team is then given two transients/accident

scenarios

to

combat.

A third scenario

may be required depending

on

performance in the first two.

Each licensed operator is

evaluated

on his individual performance

and the team is evaluated

on overall performance.

To aid in the evaluation,

individual

simulator critical tasks

have

been developed for both individual

operators

and team performance

on tasks that have

a plant or

public safety significance.

It is intended that these "critical

tasks"

be objective measures

by which NRC and

PP&L evaluators

can

determine whether

an operator or team's

performance is

satisfactory.

Each individual should be exposed to at least

one critical task

per scenario.

Failure of a team to perform all critical tasks

results in team failure and at least

one individual failure; the

individual who was expected to perform the critical task.

Performance of an individual's critical tasks

by others

on the

team is allowed as long as

each individual performs at least

one

critical task per scenario set.

If any individual does not

perform a critical task in both scenarios,

there are two options:

Option

1

backfit a critical task

Option

2

perform a third scenario

January

23,

1992

Page

4 of 17

ANALYSIS TECHNI UES

The Event

H.A.J.

L.D.

R.M.

D.F.

Review Team

Lloyd

Dominguez

O'eil

Peal

Roth

was comprised of the following individuals:

Compliance Evaluator

(Team Facilitator)

NSAG Site Supervisor

Project Manager

Supervisor

Nuclear Compliance

PNSS

Systems

Engineering Supervisor

J.M.

A.S.

W.H.

T.R.

H. J.

D.J.

B.R.

Boiwka

Fitch

Lowthert

Markowski

Palmer

Steffenauer

Stitt

- Plant Control Operator

Operations Training Supervisor

Manager

Nuclear Training

Day Shift Supervisor

-'anager

Nuclear Operations

Shift Supervisor

Simulator Instructor

To perform a Root Cause Analysis on the events that occurred

during the week of January

6,

1992, the team developed three

problem statements

to be analyzed.

Problem Statements

1.

Team 1,

an

SRO and an

RO, failed scenario

1 during their

evaluation.

Scenario title:

Loss of RPS,

Loss of 125

VDC,

MSIV Isolation.

2.

An RO on Team

2 failed during their scenario

1.

Scenario

title:

Startup at 204 Power with a Main Transformer Fire

and

ATWS.

3.

PP&L and

NRC evaluators did not initially agree

on these

results for problems

1 and 2.

Data for the analysis

was gathered

by the following means:

Interviews with licensed personnel

Discussions with evaluators

(PP&L)

Document review

Scenarios

Examiner's

standards

Industry experience with exam process

January

23,

1992

Page

5 of 17

The Event Review Team then constructed

a timeline of the history

of the

NRC monitored requalification exams,

including SSES

exam

history.

The cause

and effect technique

was utilized for analysis of each

problem statement.

Following the initial analysis,

a review

meeting was held with the operating

crews for problems

1 and

2

and with the evaluators for problem 3.

The interview process

consisted 'of two phases.

Phase

one was for

interview information necessary

for performance of root cause

analysis.

Phase

two involved a formal interview process

of a

larger sample of operations

personnel

and provided valuable

feedback to assess,

in addition to the root cause analysis.

Refer to attachments

A D.2 for timelines, individual event

and

causal factor charts,

and interview summary.

Attachment

E

provides

a symbols

legend which was specifically tailored for

this analysis.

This symbols legend

was developed

since the

programmatic evaluation varied somewhat

from typical plant event

evaluations

which use standard

symbols.

January

23,

1992

Page

6 of 17

Problem

1

Problem statement:

Team 1,

a

SRO and

a RO, failed scenario

1 during their

simulator evaluation.

'imeline/scenario

description:

~

Initial conditions

804 power.

~

During a HPCI surveillance,

a steam supply valve is

shut and will not re-open.

Operators

recognized that

HPCI was inoperable

as expected.

The 'B'PS

bus was de-energized

and an outboard

MSIV

went shut simultaneously.

Operators

responded

to the

loss of RPS, detected

the MSIV valve closure,

and

stabilized the plant as expected.

~

Before the

RPS isolation was reset,

1D622

(125

VDC bus)

was lost, resulting in full MSIV isolation and

a scram.

The loss of 125

VDC also prevents the 'B'uxiliary bus

transfer

and disables

a

CRD pump.

Two rods fail to

insert.

The crew is expected to control reactor vessel level

and pressure

with only RCIC,

one

CRD pump,

and

SRVs

available.

The crew's response

was good, initially,

recovering

RCIC and working to restore

DC power.

But

the Unit Supervisor did not realize that feedwater

was

not in start-up level control and the

PCO misled him.

This resulted in an uncontrolled level increase to

about

80 inches.

The Unit Supervisor,

the

PCO,

and the

team failed due to uncontrolled condensate

injection

into a non-shutdown reactor.

The cause

and effect analysis is attached.

Root causes

identified were:

Less than adequate

communications

by the team.

Less than adequate

level monitoring by the team.

Note:

Problem

2 indicates

lack of teamwork as

a

root cause.

This is implied by the numerous

communication concerns for this problem,

even

though not directly concluded

by the cause

and effect process.

January

23,

1992

Page

7 of 17

Problem

2

Problem statement:

A RO on Team

2 failed scenario

1 during his simulator

evaluation.

Timeline/scenario description:

The scenario

begins at 204 power during start-up.

The crew

transferred auxiliary busses

to the generator

and placed

feedwater in three-element

control without incident.

The power supply to division

1

SRV acoustic monitors failed

and the team entered the expected

LCOs and started repair

efforts.

A winding short in main transformer

1A caused

a turbine trip

and transformer fire, and while the crew responded

to this

transient,

rod 26-35

scrammed

causing

a hydraulic ATWS.

The

crew responded initially by stabilizing level and pressure

and started to work on getting rods in.

Because

level control was in automatic

(3 element)

at about

8% power, level began to swing and reached

54" (feed

pump

trip) prior to taking control of feedwater.

Level dropped while the

PCO tried to recover

a feed pump.

The

PCO assured

the

US that he'd recover the feed

pump

several times, but HPCI. and RCIC started automatically

on

low level before the feed

pump was available.

The

PCO failed due to failure to control vessel level during

an

ATWS event.

He did not recover feedwater which resulted

in auto initiation of HPCI and RCIC.

The cause

and effect analysis is attached.

Root causes

identified were:

Lack of level control by the

PCO.

Less than adequate

communications

from the

PCO to the

US 'and from the team to the

PCO.

Less than adequate

monitoring/responding/controlling

vessel level by PCO and team.

January

23,

1992

Page

8 of 17

Problem

3

Problem statement:

PP&L and

NRC evaluators did not agree initially on the exam

failures.

Timeline/scenario description:

The scenario timelines were given in problems

1 and

2 and

need not be repeated.

The grading timeline is as follows:

~

After each simulator exam,

PP&L informed the

NRC

of our preliminary grades.

This occurred three

times:

Monday, 1/6, approximately

12:00 p.m.

Monday, 1/6, approximately 5:00 p.m.

Tuesday,

1/7, approximately

12:00 p.m.

All of these preliminary grades,

team and

individual, were passes.

~

On Tuesday afternoon,

1/7, the

NRC informed PP&L of

their grading on simulator exams.

Their grades

included three individual failures and one team

failure.

~

On Wednesday

morning, 1/8,

PP&L evaluators

discussed

the results

and changed their grading to agree with the

NRC on the team failure and both

PCO failures.

We

decided to discuss the

SRO failure with them again.

~

On Wednesday

afternoon,

the PF&L exam team discussed

the results with the

NRC again.

The

NRC maintained

their stance

on failing the

SRO.

~

On Thursday,

1/9,

PP&L gave their official grades to

the

NRC.

Our final stance

agreed with the

NRC

completely, failing three individuals and one team.

Two cause

and effect analyses

are attached.

The team developed

one cause

and effect analysis for the disagreement

on team

grading and one for the disagreement

on individual grading.

This

was done because

the subject

became too complicated to use only

one cause

and effect analysis effectively.

January

23,

1992

Page

9 of 17

Note:

The recommended

actions to prevent recurrence for this

problem statement

addresses

both root causes

and causal

factors.

The root cause:

"Our evaluation standard is

not defined" and its proposed solution will eliminate

those causal factors which do not have specific

solutions.

Root causes

identified were:

~

PP&L evaluators

lacked formal guidance

on the

evaluation process.

~

PP&L evaluators

placed

more emphasis

on recovery

actions than on the inappropriate action itself.

~

PP&L has

no formal mechanism to maintain awareness

of

industry expectations.

Therefore,

yearly assessments

of our program,

compared to new regulatory issues

and

current industry experience,

is not always complete.

~

PP&L evaluators

did not employ a "what could have

happened

approach"

but rather the actual

consequences.

Causal factors identified were:

PP&L emergency operating procedures

do not reflect rev.

4 of the

BWROG EPGs.

PP&L made their decision

based

on both scenarios

where

NRC based theirs on only one scenario.

PP&L evaluated

based

on critical steps only, where the

NRC evaluated

based

on performance,

as well as critical

steps.

PP&L evaluators

are not formally trained

on requal

evaluations.

PP&L evaluators did not consider the technical

significance of cold water injection with two control

rods not inserted.

Operators belief that there is a lower risk behavior

during examination to reduce the potential of:

Self or team looking bad due to questions

Taking others'ritical steps

January

23,

1992

Page

10 of 17

Several external factors-were identified.

While external factors

may not be totally resolvable,

they are worth noting:

Stress level during the

exam

Extra observers

in simulator

Career implications/pressures

Unknown evaluator standards

Potential for a third scenario

Importance of individual critical steps

Emphasis

on "crash/burn" scenarios

versus

expected

transients.

January

23,

1992

Page

11 of 17

ROOT CAUSE

SUMMARY

Problem Statement

1

Less than adequate

communications

by the team.

Less than adequate

level monitoring by the team.

Problem Statement

2

Lack of level control by the

PCO and the team.

Less than adequate

communications

from the

PCO to the

US and from the team to the

PCO.

Less than adequate

monitoring/responding/controlling

vessel level by

PCO and team.

Problem Statement

3

PP&L evaluators

lacked formal guidance

on the

evaluation process.

PP&L evaluators

placed

more emphasis

on recovery

actions than on the inappropriate action itself.

PP&L has

no formal mechanism to maintain awareness

of

industry expectations.

Therefore, yearly assessments

of our program,

compared to new regulatory issues

and

current industry experience,

is not always complete.

PP&L evaluators did not employ a "what could have

happened

approach"

but rather the actual consequences.

January

23,

1992

Page

12 of 17

REQUAL ERT

INTERVIEW 8%SCARY

INTERVIEW SAMPLE

Shift Supervisors:

Unit Supervisors:

Assistant Unit Supervisors:

Plant Control Operators:

Simulator Instructors:

2

2

1

10

5

Total:

20

Total Number of Licensed Operators

73

January

23,

1992

Page

13 of 17

REQUAL ERT

UESTIONNAIRE SUMMARY

SIMULATOR ONLY

1.

How do you feel about the requal

exam process?

~

A lot of stress.

~

It's not a true test of operators'bilities.

The time

being seen during the

exam

(two hours simulation)

does

not truly reflect the operator's ability.

~

The simulator scenarios

are too ambiguous to grade.

They are subject to the examiner's interpretation.

~

Rules change,

always something

new year to year

(supposedly

enhancements).

la.

Has it changed

over the past several

years?

Yes

16

No 2

1b.

How?

2 ~

3 ~

~

Emphasis

has

changed

as to what is successful.

~

Changing rules just prior to exam.

~

Don't know the rules

now.

How did you

(do you) feel going into this particular

exam?

~

Nervous.

~

Don't know what to expect.

In your words what is a critical step?

Something that, if not performed correctly, could

adversely affect plant operation

and safety of public.

Something that will pass or fail an individual (for an

exam) .

January

23,

1992

Page

14 of 17

3a.

Do critical steps

influence your performance during an

exam?

Yes

11

No-8

~

Don't want to take someone's critical step.

If you do,

you get another scenario.

~

More time spent

on critical steps

which inhibits team

work identifying plant status.

5.

Does the requal program adequately

prepare

you for the

requal

exam?

Yes

3

No 11

5a.

How could it be improved?

~

More simulator time focusing on basic system operation.

~

Do individual skills training.

6.

Is crew performance,

during the requal

exam, affected

by the

exam process?

Yes

19

No-

0

6a.

How?

Nervous.

Team effectiveness

and communication are reduced

because

individuals are reluctant to ask questions

or

make

comments for fear of looking incompetent or saying

the wrong thing.

January

23,

1992

Page

15 of 17

yP

4

RECOMMENDATIONS ACTIONS TO PREVENT RECURRENCE

1 ~

Provide additional training to licensed personnel

on control

room communications

and teamwork.

2 ~

~

Question

when in doubt.

~

Provide specific information.

~

Don't use slang.

~

Repeat

back complex commands.

~

Listen for critical plant parameters.

Provide additional simulator training.

~

Fundamental

operations.

~

Control of reactor vessel

parameters.

~

Feedwater

system manipulations.

3 ~

Review Operations'olicy

on procedure

usage during plant

transients.

4 ~

Review Operations'olicy

on the need for equipment

restoration procedure/procedure

sections.

5.

Implement rev.

4 of EPGs

and provide training to licensed

personnel.

Safety significance of "not all rods in."

Cold water transients.

6 ~

Develop guidance for evaluators.

Scenario deviations.

Use of multiple scenarios.

Proper weighing of mistakes

and recovery

and

considering

"what could have happened

approach"

versus

actual consequences.

Evaluating performance

and not just critical steps.

January

23,

1992

Page

16 of 17

7.

Identify methods of continually updating the evaluation

standard/process

to stay abreast

of new regulatory,

as well

as industry experience

issues.

8.

Train PP&L evaluators.

~

Evaluator guidance.

~

Rev.

4 of EPGs.

9.

Provide additional training to simulator instructors to

attain the goal of operating excellence

and transfer this

skill during simulator training.

10.

Ensure shift supervisors

and simulator instructors provide

consistent direction relative to operational

performance in

the simulator.

11.

Provide appropriate

feedback to the

NRC on this evaluation

and recommendations.

12.

Review the event,

the root cause analysis,

and the

recommended

corrective actions with licensed personnel.

January

23,

1992

Page

17 of 17

1992

ANNUAL OPERATE

TIMELINE FOR

RQtj1

Haf; 80

Jan,

85

Jan,

86

Jan,

87

May, 87

Ma

Dentan

Letter

Annual

Requal

I

Pllcrb NRC observed

Exam

3-RO's fafled wrftten

1-SRQ fafled wrftten

Annual

Requal

4 RQ's failed

wrftten

Annual

Re qual

ESWOf, Rev. 4

14 Pgs.

1 RO Walled Sfmulatar

2 SRO's fatled wrttten

Lax

on

Exc

Exc

Ind

Chc

Aug, 89

Jan,

90

GP-002 fssued

Annual

Requal

I

Jun,

90

ESW01,2,3,4+

121 Pgs,

Jul,

90

gRC EQP

Lope ctfon

Jan,

91

Annual

Requal

I

4 RQ WalLed Sfm

1 SRO Walled Sfm

2 af 20 NRC

observed fafled

Sfmulator

Type B Exam

1 Examfner far

2 Students

1 RO fafled wrftten

1 SRQ fafled wrftten

1 SRQ fafled Sfm

'3 PB.d

Sfmulator

Inftfal scenarfo

wrftten

Scenarfo

submftted to NRC

11/01/91

cenarlo

a

Reduce

one

.

fram 'crtterl

'obser v',

a~

malfunc.

8 cr

ep to reef

act on 2l

out

12/16/91

HSIV Isa+Scram

HPCI lost

No FV Lvl Cntl

REQ UALIFICATION

AU'SE 'ANALYSIS

OPERATGR REHUAL ERT

PAGE

1 OF

37

Jun,

88

Aug, 88

Late

88

Jan,

89

ange

ual

lve

'y

5

Annual

Re qual

1 RQ fatled

Stnulator

Hack Exan

of New

Progr an

Pilots run

at 5 plants

Senhars

held

for Uttllttes

Constdered

change

Annual

Re qual

Tean Tests

Started

RQ's Walled S

observecI

PalFed

Stnulator

ESM01, REVo 5

79 Pgs.

Crlttcal Step Concept

Jan,

9P.

Annual

Re qual

I

ERT Establtshed

3 of 12 Indtv.

1 of 3 Teans

failed NRC observed

Scenar lo run,

results

tn

uncontrolled

InJ.

'With 8

I ods out

1/06/9R

NR@t gcognlzes

step

was rdssed

(t.e.~co tr lied

1/06/92

NRC adds crlttcal

step to SRQ and

RQ

1/06/92

SRQ, Tean

8

RQ

falled

ONE

OF

THREE

TEAMS FAILED THE ANNUAL

UNCONTROLLED INJECT

Could not

~ F.V. tn

S/U LeveL

CantroL

tta Power

ta FVP

Dtschar ge

Valve

Equtpnent

Fatlure

Scenarto

Destgn

EH1"

PCO-x

dtd nat

questton

conn and

One Tean

Fatted the

Re qual

Exon

Fatted

a

Crtttcal

Step

Tean

aUowed

UncontroUed

InJecttan

of'old

Vater

etta non S/D

Reaator

aUowed ta

go below

e00 PSI

halluaLLlj

opened

LS. Dtrected

Press to

550W00 PSI

ustng SRV

l

Scenarto

Oper attan

Destgn

PCO-U dtd

nat

questtan

Action

RS. dtd

nat

questtan

action

STA dtd

not

questton

8 Corrtr ol

Rods were

not

tlserted

Equtpnent

Fatlure

Scenar to

Destgn

step added

durtng NRC

r evtew

A>TAGHFVIENT E3

O&GRATOR RED UAL EAT

PAGE

1 OF

NRC OBSERVED

LICENSE

REQUAL EXAMINATION

GN 2

CONTROL

RODS

GUT

Feedwater

not

Available

HSIV

Isola+on

Scenario

HPCI not

Available

Scenarto

I not

ow FV <<as

t ln S/U

vel Control

LTA

Connunlca4on

1 CRD Punp

no't

Available

Scen arfo

END

Stlc?dng

EO. Du.ects

control to

13-54'

< 1037 PSI

Band cBctated

by RPS set

pcsnt

and

EQP

Vanted to

use

Conden.

to Recover

Level

Hot enough

Qgh Press.

In~ctlon to

contr o'l level

and Pr ess.

wtt?wn band

RCIC had

Inrttal

trfp

Scenario

Crtttcal

step

l not

htland

llS. not

aware lvl

recover?ng

wtth RCIC

Not told

love'l was

Recovering

Less than

Adequate

Cannuntca+on

Thought

level was

at -3S to

Std not

Flofwtol

adequately

iolved

k

Plan

ted

"tlctpa

1

CQAPIAg

?ual

US did not

realtze FV

BtC Loop

Bosch Vlvs

were open

PCG-u

stated

I

have S/U

level

control'otential

f'r a

thh d

scenario

be

ldressed

rately

Less thon

Adequate

Co~

perators

eUeve

ere ts a

o er rts?c

TaJeng

others'rrttcal

steps

Iafornatlon contcdned

ln this box

applicable to all ss

Addrbonal

observers

ECCS

AUTO INITIATl

(FAILURE TQ

CQNTRQ

RQ FAILL

OPERATOR

UNABLE TC

QUICKLY Rl

RO FAILED NRC

OBSERVED

ANNUAL REQUAL

ALLOWED

UNCONTROLLED

NJ OF

COLD WT

DURING ATWS

RX LVL DECR TO

POINT OF HPCI/

RCIC INITIATION

FEEDWATER NOT

AVAIL TO FEED

VESSEL

FEEDW*TEl

PUMP TRIP.

ON

54'TA

COMMUNICATION

DID NOT

HANUALLY

INITIATE HPCI/

RCIC

PCO

REPORT

COHFORT

NOT AWARE OF

LEVEL

TRAINING

INADEQUAI

ANTICIPATED

QUICK RECOVERY

OF FEEDWATER

NORHAL

EXPECTATION

LACK OF

TEAMWORK

COMMUNICE

OPERATOR REHUAL ERT

PASH

1 OF S

CIN jjLIRING ATWS

VESSEL LEVEL)

RE

OPERATOR

USED

PROCEDURE

CLEAR ON PLAN

QLICYi UNCLEAR QN

EXPECTATION FOR

IMPLEHENTING POLICY

(I,F

EMERG

SITUATIONS)

STORE

PED

PROC

DID NOT

SPECIFICALLY

ADDRESS

MOT

RESTART

REQUESTED

CHANGE NOT

IHPLEHENTED

NOT CONSISTENT

WITH OPS

POLICY

PROCESS

TO

EVAL AND/QR

CONTROL CHANGE

REQUESTS

IS UNCLEAR

END

DID NOT EXPECT

54'ND

DID NOT

GO TO

S/U LEVEL

CONTROL

TEAH NQT AWARE

OF LEVEL

DID NOT HONITOR

LVL ADEQUATELY

DID NOT TAKE

HANUAL CONTROL

CONFIDENCE IN

3-ELEHENT

CONTROL AT

LQW POWER

DID NOT

RESPOND

TO

HI LVL ALARM

DISTRACTED BY

OTHER SCENARIO

PROBLEMS

END

/

TION

TIMELIr

ECCS

AUTO INITIATION DURING ATi

RO

FAIL'CENARIO

2

S/U 8 20/

TRANSFORMER

FIRE L ATVS

1. SWAP

HOUSE

LOADS TO

GEN

2. FW IN AUTO-3

ELEM CONTROL

HI TEMP ALARM

HAIN

TRANSFORMER

TURBIn

GEN L,I

AWARE

FAI

RESL

IN

RECOG, ATVS

MMEDIATE ACTIQ

MAN. SCRAM *RI

SRM/IRM POWER

9/

EO-102

RPV

CONTROL

PWR >5/,

SCRAM IN

U,S DIRECTED

PCO'S

TD

MONITOR SRV'S

L

DV PRESSURE

SLC

PC

MAX C'

PAGE 2 OF 3

'L

E

S

(F AILURE TQ

LQNTRQL LEVEL)

RE

TRIP

TEAM

FORMER

.D

l ING

~5

MIN, FIRE

QUT. DELUGE

LEFT ON TO

COOL XFORMER

SCRAM DISCH

FILLING DUE TO

SCRAM VLV

OPEN

1/2

SCRAM

U,S, DIRECTS

PCO-U

TO TAKE

NODE SWITCH TO

S/D AND PCO

COMPLIES

%SIMULATOR PROBLEM REPORT

,QN SIMULATOR MAY NOT

REFLECT PLANT UNANSWERED

JECT

X

FLOW

PCQ-X'JtQLD

TO

INHIBIT ADS

VERIFY CLEANUP

ISOL,

PCO

REPORTS

SLC INJECT

RX LVL +54

TURB L FW TRIP

WATER LEVEL

DECREASING FAST

UNEXPECTED BY

TEAN

U,S. DIRECTS

RECOVER

FEED

PUMP

-10

>1

ROD OUT

ARE ALL SCRAM

VLVS OPEN'l

NPO SENT

TO

CK

SCRAM AIR HDR

NPQ

REPORTS

SCRAM AIR

HEADER

IS Bl ED QFF

PAGE

1

QF

2

TIMEI INE

CCI

US DIRECTS

RESET SCRAM-

PCO-X

US

QUESTIONS

WHEN RFP WILL

BE IN SERVICE

PCQ-U

STATES

WORKING QN IT

US EXPECTS

RFP

SOON,

KNEW

LEVEL WAS

DECREASING, DID

NQT EXPECT

-38'O

PROCEDURE

TO RECOVER

TRIPPED

FEED

PUMP

RESET

DELAYED

DUE TQ IRM U/S

US DIRECTS

RANGE UP

SCRAM RESET

REi

13'NO

Rj

PCQ-X

CONTROL

HPCI SPEED

> 2300

US DIRECTS

PCO-X OVERRIDE

RCIC

PCO-X TAKES

RCIC

TQ

3000

RPM

US

RECOGNI2

DECREASE

PR

TELL PCO-)

MONITOR HPC

RCIC DISCI

PRESS

TO AV

INJ, PCO

TA,,'PCI

TQ

0

SF

PCO

REDUCES

RFP

SPEED

ON'TINUATION

PAGE

S OF 8

-30'CIC

-38" HPIC

INITIATION

LEVEL STOPPED

DECREASING

US DIRECTED

PCO-X OVERRIDE

HPCI

RX FEED

PUMP

ROLLING

RFP

LARGE VESSEL

LVL INCREASE

ALL MONITORING

POWER

RX PRESSURE

DECREASING

ECEIVED

SCRAM

ROD MOTION)

ZES

lESS

XI/

H

iOID

KES

'EED

RCIC BEGAN

INJECTING

US DIRECTS

PCO

TO STOP

RCIC

INJECTION

RFP

NOT

FEEDING

+49; 475I

POWER

4

FREEZE

PAGE

2

OF

6

UNCONTROLLED INJECTIPN,

CAUSE

8,

E

PPE L AND NRC

DISAGREED

~NRC

US MISSED

CRITICAL STEP

WATE

CONTROL

WITH 2

RGD

QUT

CGULDN'T FAIL

W/G MISSING

CRITICAL STFP

PL PASSED

US

NRC

F AILED US

NRC DID NGT

CONSIDER BOTH

SCENARIOS IN

MAKING

DECISION

CRITICAL STEP

ADDED BY NRC

AFTER THE FAC

~NRC

OVERALL

PERFORMANCE

INADEQUATE

~PaL

US DID NGT

MISS CRITICAL

STEP

PPC L CONSIDERS

OTH SCENARIOS

IN MAKING

DECISION

~PS L

OVERALL

PERFORMANCE

WAS ADEQUATE

PERFORMANCE

WITH KNOWN

INFO WAS *DEQ)

BASED

ON

ACTIONS TAKEN

TO RECOVER

LVL CONTROL

RECOVERY

ACTIONS OUT-

WEIGHED

PROBLEMS

h

THERE WERE

NQ

CRITICAL PERF.

ERRORS

IN THE

RECOVERY

I ~

CONTROL

RODS

OLIT

FECT

IN

SRO

PERFORMANCE

PAGE

1 OF

1

NRC

PROGRAM

END

UNCONTROLLED

INJECTION CIF

COLD VATER

VITM 2

CR OUT

END

EVALUATOR DID

NOT REALIZE

IMPClRTANCE OF

COLD VTR INJ

V/2 RODS

CIUT

SEE

TEAM

CAUSE

8

EFFECT

CHART

EO-102 RPV

PRESS.

LEG

PROCEDURE

FRROR VAS NOT

RECOGNIZED

EVAL PROCESS

DIDN'T INCLUDE

RECCINSTRUCT ION

OF ACTIONS

TAKEN

NO TRIGGER

TO

DO

SO

OUR

EVALUATION

STANDARD IS

NOT DEFINED

THIS VAS

OUR

PRACTICE

UNCONTROLLED INJECTION,

CAUSE

8,

EF

PPS L AND NRC

DISAGREED

SCENARIOS LOSS

OF RPS/DC-MSIV ISOLATION-

2

CONTROL

RODS FAILED TO INSERT

POST

SCENARIO

REVIEW ADDED THE

CONTROL GF LEVEL/

PRESSURE

AS

CRITICAL STEP

NRC h PPKL CRITERIA/

EVALUATQRS DID NGT

AGREE ON ACCEPTABLE

PERfORMANCE

THE TEAM WAS

NRC

UN-SAT ON UNDER-

STANDING PLANT

RESPONSE

COMPETENCY

BASED QN SCENARIO,

THE TEAM DID NOT

MEET NRC CRITERIA

PL EVALUATQRS

PASSED

A TEAM THAT

NRC FAILED

PLL

THE TEAM

COMPLETED ALL

PRE-DETERMINED

CRITICAL STEPS

SATo

ALL INDIVIDUALS

PERFORMED CRITICAL

STEPS

SATISFACTORILY

BASED ON BOTH

SCENARIOS, THEY MET

OUR CRITERIA FOR

PASSING

POST

SCENARIO

REVIEW ADDED THE

CONTROL GF LEVEL/

PRESSURE

AS

CRITICAL STEP

WEAKNESSES

LVL CONTROL

CQQLDOWN

Fw OPS

KNOWLEDGE

EG-102

PRESS

PPLL EVALUATORS DID

NOT CRITICALLY

EVALUATE COLD WATE

INJECTION (2

CR GUT)

RESULTED IN

1'N

UNDERSTANDING

SYSTEM RESPONSE

FROM SRO

CAUSE a EFFECT

CHART

CONT'ROL

ROI3S

OUT

.f T,

N

TEAM PERFORMANCE

PAGE

1 OF

1

- EVALUATED

'ICAL TASKS ONLY,

PERFORMANCE

WE SUBSTITUTED

ES-601

FQR

QUR

EVALUATION

EXPECTATION

OUR EVALUATION

STANDARD IS NOT

DEFINED

- EVALUATORS

CTATIQN WAS

i RIGOROUS THAN

DON'T UNDERSTAND

SOME FACETS OF

CURRENT NRC

STANDARDS

WE DO NOT HAVE

SUFFICKNT MECHANISM

TO ENSURE UNDER-

STANDING OF, AND

MAINTENANCE QF

CURRENT INDUSTRY

EXPECTATIONS

PPCL EVALUATORS ARE

NOT FORMALLY

TRAINED TO PPCL

QR

NRC STANDARDS

CURRENT INDUSTRY

EQP

STANDARDS ARE

NOT PPLL STANDARDS

PPCL

CONSIDERED

REV. 3 GUIDELINES

ACCEPTABLE

HAVE NOT ADOPTED

EPG REV. 4

PREVIOUS

MANAGEMENT

DIRECTION

END

EVALUATORS DID

CONSIDER 2 RODS

AS SIGNIFICANT

EVALUATED

CONSEQUENCES

OF

ACTIONS INSTEAD OF

POTENTIAL

CONSEQUENCES

DO NOT EMPLOY

'WOULD HAVE;

COULD

HAVE'PPROACH

NO POWER

CHANGE

SEEN

SCENARIO DESIGN

NOT CONSIDER

'IATION FROM

CEDURE

DEVIATION WAS NOT

RECOGNIZED BY PPKL

EVALUATQRS

END

~

a

a ma navacN

I

PAHE

1 OF

1

EVENT REVIEV REPORT

ANNUAL LICENSED OPERATOR

REQUALIFICATION

SYMBOLS LEGEND

ROOT

CAUSE

CAUSAL OR

CONTRIBUTING

FACTOR

NO FURTHER STEPS

BY

CAUSE

L EFFECT

TE CHNIQUE

REFER

TO OTHER

ON

SAME CAUSE

L EFFECT

CHART

TEXT NOT BOXED

INFORMATION NOT PERTINENT

TO SPECIFIC

ANALYSIS

TO

OR

FROM ANOTHER

CAUSE-8

EFFECT

CHART

OPERATOR AEGUAI EAT

PENNSYLVANIA POWER

AI%3 LIGHT

COMPA2'A'ICENSED

OPERATOR REQUALIFICATION

EVALUATION AND RESPONSE

PLAN

DELAYREQVALIFICATIONEXAMS

PS'ORM NRC OF DELAY

COMPLETE JANUARY 13

RESM4ED EXAMS JANUARY27

PERFORM ROOT CAUSE ANALYSIS

COMPLETE JANUARY23

JUSTIFICATION FOR CONTIM3ED OPERATIONS

PROVIDED: MANAGER- NUCLEAR OPERATIONS, JAM7ARY 15

APPROVED: SUPERINTENDENT OF PLANT, JM67ARY 15

VERBALUPDATES PROVIDED WE~EKLY

OBSERVE AI%3 EVALUATE

azgvar.v rcmrox pROCESS

PERFORMiANCE OF EACH SIlVHJLATOREXAMINER

MANAGER-

CLEAR

OBSERVED:

S EXAIVIKNERS

7

EXPLANATIONS

2 MANAGEMENTREPRESENTATIVES

5 SIIVHjLATOROPERATORS

ALLPERFORIVKD SATISFACTORY

UPERINTENDENT

F PLANT

OBSERVED:

3 EXA1MP'lERS

1 MAI'MGEMENTREPREiSENTAIIVE

j. EXA1MII'%ATION

INDU TRY PEER EVAL ATIONS

COMPLETED: LASALLE- 2 EXAIVIINATIONS

HOPE CREEK - 2 EXAIVHNATIONS

PLANNED:

THREE MILEISLA&8)

PEACH BOTTOM

INDEPENDENT CONSULTANT

GENERAL PHYSICS

PARALLELGRADED ALLSI1VH3LATOREXAlVHNATIONSAFIER

RESUMPTION

ALLGRADINGIN AGREEMENT WXI'HPAL

RECOlVIIMENDATIONSTO IMPROVE OUR PROCESS

SIIVH3LATOREXAINSTATUS TO DATE

SRO

EXM4II.'R',D

20

PAAP5ED

FAILED

RO

20

TEAMS

10

SINCE

N

SRO

RO

14

TEAMS

RETEST SRO

RETEST RO

VAUTTENAI%3 JPM EXAMS

ON ORIGINALSCHEDULE

56 EXAMS COMPLETE

1 VAUTTENEXAMFAILU]RE

EVALVATOR

LEARNEDFROM

NRC TEAMINTERACTIONS

SELF-ANALYSIS

INDEPENDENT CONSVLTAJA" (GENEX4V PHYSICS)

G COVRSE (ED BOWLES)

JOINT MEETING- OPERATIONS APG)

G GROUPS

MANAGERS, SHIFI'UPERVISORS, SIMULATORINSTRUCTORS

REVIEWED:

ROOT CAUSE ANALYSIS

SURVEY RESULTS

ACTIONPLAN

Btu3NSTORMED POSSIBLE CHANGE<S:

IMPROVE EFFECIIVENESS OF FEEDBACK

INCREASED INDIVIDUALTASK

EMPHASIZE COlVB4VNICATIONS

FUTlURE PLANNED ACTIONS

OPERATOR

G (1992)

IMMKCH

REINFORCE CRITICALPARAlMETER CONTROL,

INFOMCATIONSHANXNGWFIHINTEAM,

COLD WATER RESTARTS,

MAKUALCOXHXOLOF HPCI, RCIC, AND

FEEDWATER

DETAILEDTRAININGON TARliAIEIRRCONTIIOL,

INFORMATIONSHING, QUESTIONING

ACTIONS OF OIHER TEAMMEMBERS, COLD

WATER ACCIDENTS,

ADS LOGIC, IKN/APRMOVERLAP,

MANUALCOXIROL OF HPCI, RCIC, AlitD

FEEDWATER

APRIL/JUNE

EVALUATIONSCENARIOS ON ABOVETOPICS

INDEPENDENT CONSULTANTEVALUATEAND

VERIFYEFFECI'IVENESS OF CORRECTIVE

ACTIONS

JUNE/AUGUST

TITANON REV 4 TO EOPS

MAY/AUGUST

REINFORCE IDEÃIIFIEDTOPICS

FUTVl&PLANNED ACTIONS

FACTOR LESSONS LEARNED INTO OUR SYSTEMATIC PROCESS TO

CONTROL REQUALIFICATION(MARCH 1992)

PROVIDE EVALUATOR

6 ANNUALLY(DECEMBER 1992)

PROVIDE EVALUATORPREP TBNE (DECEMBER 1992)

INDEPENDENT CONSULTANT ASSESS OUR EVALUATORSAND OPERATORS

PERIODICALLY(SEPTEMBER 1992)

EVALUATIONAZ'6) RESPONSE PLAN

LICENSED OPERATOR REQUALIFICATION

PENNSYLVANIAPOWER R LIGHT CO.

REVISION 2

UPDATED: FEBRUARY 14, 1992

Submitted:

H.Z. Palmer

Manager - Nuclear Operations

Submitted:

R.H. Lowthert

Manager - Nuclear Training

Approved:

H.G. Stanle

Superintendent

of Plant - SSES

Evaluation and Response

Plan

Licensed Operator Recpxalification

Rev. 2, 2/14/92

Page

1 of 11

Overview

Susquehanna's

performance during the Licensed Operator Annual

Requalification examinations

administered

during the week of

January

6,

1992: was unsatisfactory.

It does not meet

PP&L

standards.

The Susquehanna

SES Evaluation and Response

Plan was developed to

identify specific weaknesses

and correct them. It consists

of

four major initiatives:

Program Evaluation

Operator Performance

Evaluation

Training

Program Corrections

and Improvements

In the program evaluation initiative we evaluate

our

requalification training and evaluation program utilizing

internal

PP&L resources

and outside support including independent

consultants,

INPO,

and sister utilities.

Important questions

we

must answer include:

Why were our passing

standards

lower than the

NRC?

Why did three operators

and one crew fail?

What errors did we make in responding to the changing

regulatory climate?

What fundamental

weaknesses

do we have in our program?,

Is continued operation justified based

upon operator

performance?

Are we capable of performing simulator examinations

that meet

PP&L performance

standards?

What lessons

learned

from industry experience

can be

incorporated into our programs?

Evaluation

and Response

Plan

Licensed Operator Requalification

Rev.

2, 2/14/92

Page

2 of 11

In the operator performance

evaluation initiative, with the

support of INPO and independent

consultants,

we are performing

critical evaluations of individual operator

and crew performance

to ensure safe operation

and identify weaknesses

and areas for

improvement.

Particular attention will focus on evaluating

control of critical parameters,

team members backing each other

up, ensuring all team members receive

needed information and

ensuring

team members

ask questions to gain needed

data or

direction.

During training we direct operators'ocus

back toward

fundamental operating principles.

Management will train

operators

on weaknesses

identified and evaluate their performance

to ensure mastery of the identified competency.

This plan is

updated continually as training needs

are identified in the

evaluation process.

Training identified, to date, will strengthen

operator

competency

on operating practices

such

as parameter control and team work.

Specific technical knowledge

and skill topics will also

be

relearned.

Training is scheduled for individuals who fail any

requalification exam, for all operators

on revision

4 to the

Emergency Operating procedures

and for all operators

on general

examination weaknesses.

Additionally, evaluators

who perform

simulator evaluations will receive training on PP&L standards

and

the exam process.

Program correction and improvement initiatives upgrade the

Licensed Operator Requalification Program to correct deficiencies

and enhance

the program.

This includes action using independent

consultants to ensure the program and our operators

maintain the

high level of performance that we demand.

Implementation of revision

4 to the Emergency Operating

Procedures

has already

been scheduled.

The addition of a week

for examination preparation for PPGL examiners

and an evaluator

training course are planned actions.

Other actions will be identified and scheduled

as results of the

evaluation

and self-assessment

activities become available.

These actions will preclude this unsatisfactory situation from

occurring again.

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

3 of ll

Team members responsible for the implementation of this

evaluation

and response

plan are:

Arthur S. Fitch, Supervisor Operations Instruction

William H.. Lowthert, Manager

Nuclear Training

Thomas

R. Markowski, Day Shift Supervisor

Operations

Howard Z. Palmer,

Manager

Nuclear Operations

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

4 of 11

Program Evaluation

This initiative reviews

and evaluates

our Requalification

Training and Evaluation process.

This review and evaluation uses

PPGL resources

and includes

assessments

by an independent

consultant

and industry peer evaluators.

After corrective

actions are implemented

INPO will be asked for an evaluation to

verify that needed

improvements

have been achieved.

1 ~

2 ~

3 ~

Delay performance of requalification simulator

examinations

during this annual cycle until clear

pass/fail standards

are understood

by all examiners

and

the Manager of Operations

has verified that exams will

be given consistently with those standards

(H.J.

Palmer,

January

13, 1992).

Complete

Inform NRC Region I of our delay in completing

simulator examinations

(W.H. Lowthert, H.J. Palmer,

January

13, 1992).

Complete

Use the root cause analysis process to accomplish these

activities

(R.M. Peal,

begin January

15,

1992).

Complete

Identify fundamental

problems or programmatic

weaknesses

in the Licensed Operator

Requalification Training and Evaluation Program.

Determine why, initially, PPGL evaluators

graded

no operator

as failing on the simulator, while NRC

evaluators

graded

one

SRO, two ROs,

and one team

as failures.

Determine

why 25% of the operators

examined failed

the exam during the week of January

6,

1992.

Determine if PP&L response to the changing nuclear

regulatory climate has

been appropriate.

Areas of

inquiry should include examining methods,

examining material,

emergency operating procedure

revisions,

operating philosophy,

procedural

compliance,

and operator performance

standards.

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

5 of ll

0

4 ~

Provide justification for continued operation

considering the examination results of January

6 and 7,

1992.

Use data from recent operating experiences

at

Susquehanna,

the

INPO E&A visit, the

1992

requalification examinations,

in-plant operator

performance,

weekly exam results,

previous annual

exam

results,

SOORs,

and

NSAG surveillances to determine if

operator performance currently meets

Susquehanna

standards

(H.J. Palmer,

B.S. Stitt).

Preliminary justification to the Superintendent

of

Plant

(January

15, 1992).

Complete

5.

On-going justification based

upon exam results

(January

15

March 7, 1992).

In Progress

Observe

and evaluate the requalification process

and

the performance of Susquehanna

evaluators

during the

current requalification examination period

(W.H. Lowthert, complete by March 20,

1992).

Manager-Nuclear Training evaluate the Susquehanna

requalification process

including evaluating

each

examiner during the performance of two simulator

examinations

(W.H. Lowthert, complete

by March 20,

1992).

In Progress

Superintendent

of Plant

Susquehanna

evaluate the

Susquehanna

requalification process

including

evaluating

each examiner during the performance of one

simulator examination

(H.G. Stanley,

complete

by

March 20, 1992).

In Progress

Have an industry peer with recent experience in NRC

Licensed Operator requalification examinations

evaluate

the Susquehanna

requalification process

including

evaluating examiners

and

exam material during the

performance of simulator examinations

(W.H. Lowthert,

complete

by March 20,

1992).

In Progress:

Hope Creek

and La8alle Complete

A consultant with recent experience in NRC Licensed

Operator requalification examinations

evaluate the

Susquehanna

requalification process

including

evaluating examiners

and

exam material during the

performance of simulator examinations

(W.H. Lowthert,

start January

17,

end March 20,

1992).

In Progress:

General Physics is the Consultant

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

6 of 11

6.

Utilize an independent

consultant to verify that

corrective actions

have been effective in improving the

Requalification Program after corrections identified

through the root cause analysis

and the evaluations of

simulator examiner performance

have been incorporated

into the program

(W.H. Lowthert, June 1992).

7 ~

After the implementation of our corrective actions .and

program modifications including operator training,

utilize INPO and other utilities to assess

the results

of our corrective actions.

These

assessments

include

both program evaluations

and examinations of operators

to ensure that desired

improvements

have been

made

(W.H. Lowthert, August 1992).

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

7 of 11

~

~

Operator-Performance

Evaluation

This initiative'uses

PP&L,. an independent

consultant,

and

INPO

resources

to identify operator

competency to perform licensed

operator duties at Suscgxehanna.

It includes completing the

operator examinations during this cycle and

a mid-program

INPO

assist visit.

Using PP&L and independent

consultant resources,

evaluate the remaining licensed operators

and

supervisors

using approved examination material.

Identify individual operator

competency

and each team's

ability to operate

as

a unit.

Identify individual

weaknesses

and overall operational

areas for

improvement

(H.J. Palmer,

January

13 to March 7, 1992).

In Progress

2.

Using PP&L and independent

consultant resources,

provide critical evaluations of operator performance in

the simulator.

Pay particular attention to control of

critical parameters

and to team members

backing each

other up, ensuring all members receive

needed

information and ask questions to gain needed

data or

direction (T.R. Markowski, A.S. Fitch, January

27 to

March 7, 1992).

In Progress

3 ~

Complete written and

JPM examinations for all operators

per schedule

(T.R. Markowski, A.S. Fitch, January

13 to

February

21, 1992).

In Progress

4 ~

Using an INPO assist visit, assess

the performance of

our operators

by evaluating at least two control room

teams in the simulator during the performance of

emergency operating procedure

scenarios

(W.H. Lowthert,

H.J. Palmer,

August 1992).

Evaluation and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

8 of 11

Training

,This initiative ensures that as deficiencies

are identified

through evaluation processes all necessary training is received.

This plan is updated continually as training needs

are identified

in evaluation initiatives.

Provide training to annual requalification

exam

simulator evaluators for 1992 that includes the exam

process,

management

expectations,

and standards

for

acceptable

operator performance

on simulator

examinations

(H.J. Palmer,

January

24,

1992).

Complete

2.

Manage the remedial training and examining of operators

who fail requalification examinations

(A.S. Fitch).

In

Progress

Remove individuals from licensed duties

(H.J. Palmer).

Develop an individual remedial training and examination

plan for each operator

(A.S. Fitch).

Provide remedial training (A.S. Fitch, T.R. Markowski).

Examine the operator

and return to licensed duties or

identify future training or non-licensed

duty

assignments

(H.J. Palmer).

Evaluation

and Response

Plan

Licensed Operator Requalification

Rev. 2, 2/14/92

Page

9 of 11

3 ~

Provide prompt remedial training for all operators in

areas identified as general

weaknesses.

Immediately after the exam cycle (February

21 to

March 16) reinforce critical parameter control, sharing

information among the team members,

cold water restarts

and manual control of HPCI, RCIC, and feedwater.

This

will include approximately two hours of training for

each operator

(T.R. Markowski, March

2 to March 20,

1992) .

Cycle

1 (March 16 to April 24) Conduct detailed

training on:

parameter control

information sharing

among team members

questioning actions of other team members

manual control of HPCI

manual control of RCIC

manual control of feedwater

cold water accidents

ADS logic

IRM/APRM overlap

(T.R. Markowski, A.S. Fitch)

Cycle

2 (April 27 to June

5) Evaluate operators

on the

topics identified in cycle

1 to assess

performance

improvement status

(T.R. Markowski).

Cycle

3 and

4

(June

8 to August 28) Train operators to

use revision

4 Emergency Operating Procedures

(A.S.

Fitch).

Note:

Operations will begin using revision

4 of the

EOPs

on September

11.

Cycle

4

(May 20 to August 28) Review and reinforce

training covered in cycle

1 (T.R. Markowski).

Evaluation

and Response

Plan

Licensed Operator Recpxalification

Rev. 2, 2/14/92

Page

10 of ll

Program Corrections

and Improvements

Correct and improve the Licensed Operator Requalification

Training and Evaluation Program based

upon evaluation information

received utilizing independent

consultants to ensure

problems to

not reoccur.

This plan will grow with the addition of action

items to correct problems

found in the evaluation process.

Identify actions

and develop

a plan to improve the

Licensed Operator Requalification Training and

Evaluation Program in response

to the outcome of the

root cause analysis effort (A.S. Fitch,

W.H. Lowthert,

March 27, 1992).

2.

Begin using revision

4 to the

EOPs

(H.G. Stanley,

September

11,

1992).

3.'or future year requalification examinations,

provide

evaluator training to all examiners that includes

standards

for acceptable

performance

(A.S. Fitch,

December

1992).

4 ~

5.

For future year requalification examinations,

provide a

prep week to examiners similar to the

NRC examiner's

prep week to review examination material

and rehearse

simulator scenarios

and Job Performance

Measures

(A.S. Fitch,

December

1992).

During each requalification year, three months prior to

the annual examination,

have

an independent

consultant

perform an assessment

of our evaluators

and examine

a

representative

sample of our operators,

that includes

at least three control room teams, to identify and

correct problems prior to NRC administered

examinations

(W.H. Lowthert, H.J. Palmer,

September

1992).

Evaluation and Response

Plan

Licensed Operator Requaliflcation

Rev. 2, 2/14/92

Page

11 of ll

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