ML18152A475
| ML18152A475 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/20/1988 |
| From: | Breslau B, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A476 | List: |
| References | |
| 50-280-87-32, 50-281-87-32, GL-81-21, NUDOCS 8802030359 | |
| Download: ML18152A475 (12) | |
See also: IR 05000280/1987032
Text
Report Nos.:
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
50-280/87-32 and 50-281/87-32
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
Inspection Conducted:
November 16-20, 1987
/
/'
!
Inspector: : )4, /µ~-o--
8. Breslau, Team Leader
Team Members:
R. Aiello
M. DeGraff
P. Kel~og
Approved by: '7?i:J:i . ~ie':id
M. Shyml6~ ef
Operational Programs Section
Division of Reactor Safety
SUMMARY
Date Signed
Scope:
This routine, unannounced inspection was conducted in the areas of
non-licensed staff training, licensed operator training, and implementation of
Generic Letter No. 81-21, Natural Circulation Coldown.
Results:
One violation was identified involving failure to have an adequate
Emergency Operating Procedure for Natural Circulation Cooldown.
One deviation
was identified involving the failure to meet Procedure Generation Package
commitments for documentation of justification for steps in an Emergency
Operating Procedure for Natural Circulation Cooldown.
8802030359 880127
ADOCK 05000280
G
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- J. Bailey, Superintendent Operations
- D. Benson, Station Manager
- C. Elmore, Supervisor Training - PSI
- A. Friedman, Superintendent Nuclear Training
- E.* Grecheck, Assistant Station Manager
- R. Gwaltney, Supervisor Training PSS/EM!
- S. Haberstroh-Timpano, Supervisor Nuclear Training Development
- H. Mccallum, Supervisor Training - PSO
- G. Miller, Licensing Coordinator
- R. Miller, Supervisor Training PSS/RPC
- T. Williams, Manager Power Training Services
Other 1 i censee emp 1 oyees contacted included engineers, technicians,
operators, mechanics, and office personnel .
NRC Resident Inspectors
- W. Holland
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on November 20, 1987,
and in subsequent phone ca 11 s through December 21, 1987, with those
persons indicated in paragraph 1. above.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below.
No dissenting comments were received from the licensee.
Item Number
280,281/87-32-01
280,281/87-32-02
Status
Open
Open
Description/Reference Paragraph
VIOLATION
- Inadequate
Emergency
Operating
Procedure
for
Natural
Circulation Cooldown:
Cooldown curves
exceed
those
in
the Technical
Specifications {paragraph 11)
DEVIATION - Failure to meet Procedure
Generation Package commitments
in
generating
Emergency
Operating
Procedure for Natural
Circulation
Cooldown (paragraph 11)
2
The licensee did not identify as proprietary any of the material provided
to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92702)
This subject was not addressed in the inspection.
4.
Licensee Actions on Previously Identified Inspection Findings (92701)
This subject was not addressed during this inspection.
5.
Evaluation and Corrective Action of the 1985 LORP Examination Failures
(41701)
On March 3, 1986, a meeting was held in the Region II offices to discuss
NRC
findings (documented in examination report 50-280/0L-85-02)
concerning the results of the operator requalification examinations
(administered in December of 1985) and licensee proposed corrective
actions.
The proposed corrective actions were to identify operator
knowledge weaknesses, provide additional training and implement a
11 Check Operator
11
The Check Operator's role is to provide operational
evaluations and
11 in plant
11 observations.
The NRC inspectors verified
that all the appropriate corrective actions, applicable to Surry, have
been taken or implemented in a timely manner as outlined in the meeting
summary dated April 14, 1986.
No violations or deviations were identified in this area.
6.
Licensed Operator Training (41701)
The inspectors interviewed senior reactor operators (SROs) and reactor
operators (ROs) regarding their perception on the effectiveness of
licensed operator training.
Of the personnel interviewed, all currently
maintain an active license and have all passed their NRC license examina-
tion within approximately the last year.
Among those individuals interviewed, no negative comments were received
pertaining to the training program.
The general comments indicated the
individuals perceived the license course as being taught in a controlled
manner and presented in a logical sequence.
This was evidenced by the
inspector's review of the license course sequence guide, which presents
the various segments of the license course in chronological order.
The individuals indicated that the instructors, during both the classroom
and simulator sessions of the training program, were knowledgeable about
the subjects being taught, and were able to convey the material to the
trainees at a level consistent with the knowledge level of the class .
3
The control room or on the job training segment of the license course was
discussed and the individuals stated it provided an opportunity to observe
and put into practice what had been taught during the classroom and
simulator sessions, thus building upon and reinforcing previous knowledge.
The inspectors interviewed SRO 1 icensed instructors who are currently
teaching an RO/SRO license course.
Currently, there are three principal
instructors involved in teaching two license courses.
The instructors
indicated this allows sufficient time to adequately prepare for lectures,
review lession plans, and prepare and grade examinations.
The RO/SRO
License Course Program Guide, Revision 1, delineates a requirement that
feedback be obtained from the students in the form of a course critique
following completion of the training program.
The instructors interviewed
indicated the feedback solicited from students when brought to the
attention of management is addressed in a timely fashion.
The instructors indicated that information resulting from plant design
changes, license event reports (LERs), etc, which could impact training
was being properly reviewed and if applicable, incorporated into lesson
plans.
This portion of the licensee's program was reviewed for
implementation and is discussed within the text of this report.
The inspectors reviewed training records for. licensed individuals, to
ensure training requirements as specified in the RO/SRO License Course
Program Guide, Revision O had been completed.
The inspectors determined
from the cases reviewed, the requirements had been satisfied.
The inspectors attended a training lecture for replacement licensed
operator candidates on EP-1.02A, Natural Circulation Cooldown, Revision 1.
The lesson plan was the most current revision, free of any pen and ink
changes.
The instructor adhered to the lesson plan, and appeared to be
effective in his presentation.
The trainess were presented with the
lesson objectives, major action categories of the procedure and finally
the procedural steps along with their basis. Student participation during
the class was encouraged through questions concerning not only the ongojng
lecture but also material which had been previously covered which was
applicable to the current lecture.
One problem noted during the class was with lesson plan ND-95-3-LP-5,
Revision 0, for Natural Circulation Cooldown.
There was an incorrect
reference made to a setpoi nt for the Overpressure Mi ti gati on System.
The lesson plan stated that a pressure of 410 psig decreasing closes
pressure control valve (PCV)-1456.
This was identified by the instructor
and students as being incorrect.
Following the lecture, the instructor
stated a change would be made to the lesson plan and the correct setpoint
of 400 psig decreasing would be incorporated.
The change to the lesson
plan was initiated in a timely fashion as verified by the inspectors
during a later portion of the inspection .
7.
4
The inspectors attended a simulator session which encompassed training for
licensed operator candidates in the area of emergency response guidelines.
As stated in the lesson plan, this portion of the training is designed to
reinforce the classroom lecture by allowing the trainees an opportunity to
perform .the procedures in a low stress environment.
As in the classroom
portion of the training, the instructor adhered to the lesson plan well.
The instructor, after stating the lesson objectives, questioned the
students on both the major action categories and immediate actions of the
procedures.
Additionally, the trainess were questioned concerning the
instrumentation and location through which the immediate actions could be
verified.
The simulator scenarios used were taken from the lesson
plan.
Upon completion of the session, the instructor did critique the
students identifying both strengths and weaknesses observed.
The inspector reviewed various lesson plans to ensure that information
resulting from design changes, LERs, etc. was being properly reviewed and,
if applicable, incorporated into lesson plans.
The licensee has in place
Training Administrative Guide (TAG) 2.2, Training Impact Report Tracking
System, Revision 2 and
TAG 2.3., Instructional Material Revision,
Revision 2.
These procedures collectively delineate requirements through
which information which could impact training is tracked, reviewed and
routed.
The inspectors selected design changes to insure that relevant
information was incorporated into the applicable lesson plans.
The
changes reviewed were design change package, DC-85-10-1, Upgrades to the
Core Cooling Monitoring System and design change package DC-85-33-1,
Station Black Battery Additions.
The *1esson plans affected were
ND-03.4-LP-3, Inadequate Core Cooling Monitoring, Revision O (changed as a
result of DC 85-10-1); ND-90-1-LP-4, Hydrogen Seal Oil System, revision 1;
and ND-89.2-LP-2, Turbine Lube Oil System, Revision 1 (changed as a result
of DC-85-33-1).
For all cases reviewed, the inspector found the
incorporation of relevant information into the applicable lesson plans
complete.
Plant Design Changes were reviewed to ensure their incorporation in LORP
classroom training and into modifications of the simulator.
The inspector
reviewed a design change concerning inadequate core cooling monitors
(DC-85-10-1).
This change had been incorporated in to lesson plan RQ
86.5-LP-7 Inadequate Core Cooling and the modification has _been installed
in the simulator.
Based on this review, and interviews with personnel,
the training program administrative controls appear to be adequate to
ensure plant system changes are incorporated into the LORP and simulator.
No violations or deviations were identified in this area.
Licensed Operator Requalification Training (41701)
The inspectors reviewed the Licensed Operator Requalification Training
Program (LORP).
The previous LO_RP program dated March 1, 1985 and the
current program dated October 30, 1987 were reviewed to verify they
contained administrative controls for the following:
~I
5
(a)
Provision for instruction in the areas of heat transfer, fluid flow,
thermodynamics and Mitigation of Core Damage.
(b)
Requalification examinations require 80% overall and 70% in each
category.
(c)
Licensed personnel are removed from licensed duties and placed in an
accelerated requalification program if the annual exam is less than
80%.
(d)
An annual comprehensive requalification exam is given to all NRC
licensed personnel.
(e)
The results of the exam are utilized in scheduling the following year.
requalification program and exam preparation.
(f)
Instructors and backup licensee's are included in the requalification
program.
(g)
Instructors and staff are included in proficiency training on the
plant by cycling onto shift on a regular basis.
During this inspection, the requalification program was in a self study
phase while preparing for the annual comprehensive exam.
For this reason
specific requalification lectures and simulator sessions could not be
observed.
Since much of the replacement operator training material such
as classroom lesson plans and simulator lesson plans are also utilized in
the requalification program, the inspectors observed replacement operator
sessions.
The inspectors observed a replacement licensed operator classroom training
session on Basic Measurement Devices and Control Systems, ND-93.1-LP-2.
The lesson plan for this class was up to date and free of hand written
notes.
The instructor foll owed the 1 es son pl an and appeared to be
effective in his presentation.
Student participation was encouraged by
specific questioning by the instructor and students questions were
answered.
A handout was provided to the students for their note taking.
Classroom facilities were adequate.
The inspector observed a replacement operator training simulator training
session on Emergency Response Guidelines, ND-95.3-SM-1,
Reactor
Trip/Safety Injection Recovery.
The instructor provided the trainees
with a brief description of the lesson objectives, structure and expected
results.
The instructor kept to the outline of the lesson pl an and
departed only to demonstrate related concepts and answer questions as they
arose.
The instructor exhibited good control of the session and a
thorough grasp of the subject matter. A recent operating event, loss of a
reactor coolant pump, was incorporated in the session.
The instructor
presented a summary of the subject matter and provided the trainees with
specific briefings at the end of the session.
6
Interviews were conducted with two ROs regarding their perception of the
effectiveness of requalification training.
Areas addressed included
classroom and simulator sessions, operational experience feedback and
instructor kn owl edge of the subject matter.
The personnel interviewed
indicated general satisfaction with the requalification program.
Interviewees felt that adequate depth of knowledge was presented and that
instructors were well qualified to teach the subjects covered.
The check
operator program was felt to be effective in upgrading performance while
on watch.
Operators interviewed were knowledgeable of selected
operational .events and felt they were adequately informed in a timely
manner of these events.
The inspector reviewed specific 1 es son p 1 ans and conducted personne 1
interviews to determine that current opera ti ona l events were being
factored into the requalification program.
Two operational events, LER
87-024-00 dated October 20, 1987 and LER 87-001-00 dated April 13, 1987
were reviewed to ensure that training was provided on a timely basis, that
information was incorporated into 1 es son pl ans as necessary,, and that
licensed individuals had completed the training.
Review of specific
lesson plans and interviews indicated that operational feedback was being
incorporated into the requalification program and that the operators were
comfortable with the information provided~
Training records for two SROs and two ROs were reviewed to verify
requalification attendance, remedial training for examinations failed,
required procedure reviews, and annual examination performance.
The
records were adequate, no deficiencies were noted.
Requalification exam results for the previous three years were reviewed.
The result of this review are as follows:
Year
1984
1985
1986
Pass/Fail (in%)
84.1 / 15.9
85.7 / 14.3
95.7 /
4.3
Avg. Grade RO/SRO
83.6 I 85.2
83 .-6 I 83. 7
85.7 / 87.8
These results indicate an
improvement in the quality of the
requalification training provided.
The records concerning required procedure reviews indicated that several
months (five) were signed off on one day.
Interviews with selected
individuals indicated that the procedures had been reviewed during other
time periods and that all the signoffs on one day were done to bring the
records up to date.
Interviewees were aware that they were delinquent in
these reviews but some were not aware of the number of months they were
delinquent.
As these procedures are the target of periodic examination
during the requalification cycle it would appear.that adequate controls do
exist to ensure the procedures are reviewed sometime during the cycle.
No violations or deviations were identified in this area.
7
8.
Requalification Exam Reviews and Security of Question Banks (41701)
The inspectors reviewed five RO and five SRO comprehensive examinations
administered during the 1986 requalification program.
The exams were
reviewed to determine adequate depth of subject knowledge and that all
areas of the 1985 LORP were covered.
The exams appeared to be adequate to
test the subject areas and all required areas were covered.
Additionally,
the inspectors reviewed 1987 comprehensive examinations (SRO/RO) which
were to be administered the week of November 16, 1987.
These exams also
appeared to require an adequate depth of knowledge and all areas required
by the 1987 LORP were covered.
Exam security is ensured by maintaining exams in the locked
training/records vault.
Administrative controls are in place for the
contra 1 of the exams when they a re removed for use.
No examination
question bank is used.
Each exam is prepared by utilizing some questions
from areas where inadequate performance was obtained on previous exams and
new questions generated by the instructor preparing the exam.
The inspectors interviewed two SRO instructors to determine their
perception of the requalification training program.
The instructors
indicated the program had been greatly improved in the last two years.
The recent addition of another instructor has enhanced the program by
allowing additional time for preparation and lesson materials upgrading.
The instructors also indicated the Check Operator Program appeared to be
improving licensed operator performance.
No violations or deviations were identified in this area.
9.
Simulator Procedure Review (41701)
A review of procedures used in the simulator was conducted to ensure
consistency between the procedures used in the plant and those in the
simulator.
Several procedures were not current with the procedure index.
These procedures were:
AP-10.5, Loss of Semi-Vital Bus 1 and AC
distribution Panel 1-1; lF-43 and 44, Steam Generator IA and 18 Channel 4
Hi Steam Line Flow; lG-9, Approach tb Saturation Temperature Alarm; and
lH-37, 38, 39; Steam Generator lA, 18, lC, Feedwater Flow/Steam Flow.
Additionally, the following procedures were not in the simulator;
OP-5.1.1, 5.1.2, Filling and Venting the Reactor Coolant Systems; OP 31.2,
Steam Generator Auxiliary Feedwater System; and OP-52.'2, Fire Water
Protection System.
There were no requalification or replacement operator classes utilizing
these procedures at the time.
The 1 i censee should upgrade procedure
control in this area to ensure consistency between the procedures used in
- the plant and the simulator.
No violations or deviations were identified in this area.
i
8
10.
Non-Licensed Operator Training (41400)
The inspector reviewed the implementation of the non-licensed operator
training programs by reviewing the following:
Power Training Services Five Year Plan, 1987-1991
Power Training System Manual and Appendix
Power Training System Organization Manual
Nuclear Operations Department Standard Manual
Program Guides for:
Health Physics Technicians Training
Chemistry Technicians Training
Mechanical Training
. Electrical Training
Instrumentation and Control Technician Training
General Employee Training
Nuclear Foundation Training Program
Nuclear Control Room Operator Development Program
Technical Specification Section 6
Final Safety Analysis Report, Section 12.3 Training
Quality Assurance Training Audits
Licensee Event Reports
Lesson Plans and Transparencies
, Training Impact Reports
Student Evaluations of Classroom Instruction and Material
Instructor Evaiuations
Program Evaluations
Training Records
Job Performance Measure Fonns
The inspector noted during this review that the program guides were
adequate, but have not been updated to conform to the style, format and
content of the current Power Training System Manual.
The licensee is
presently pursuing updating the program guides.
9
The inspector noted lesson plans with handwritten changes, and it was not
evident from review of these 1 es son p 1 an whether the changes were
approved.
Further discussions revealed that the instructor or originator
of the lesson plan submits a Training Impact Report (TIR) which describes
the reasons for the changes.
The TIR also receives review and approval
signatures prior to utilization of the lesson plan changes.
The licensee
agreed that, if a copy of the TIR was attached or TIR number noted on the
lesson plan, then the lesson plan would be readily noticeable as to
whether the handwritten changes were approved.
The licensee will pursue
a method of identifying approved handwritten changes to lesson plans.
The licensee uses watch station specific and job specific job performance
measures (JPMs) to improve the quality and consistency of on-the-job
training.
These JPMs replaced the previously used task checklists.
A
review of completed JPMs indicated several, approximately 27, were signed
off.as completed on the same day.
Discussions with supervisors who sign
JPMs, indicated some supervisors interpret
11date completed
11 block as the
date the JPM card is completed; other supervisors believe it means date
when each item listed on the JPM card was performed.
The licensee
has
previously noted this inconsistency and is currently rewriting
instructions to clarify an adequate method of addressing JPM signoff.
The NRC inspector discussed Information Notice (IN) 86-64
11Deficiencies in
Upgrade Programs for Plant Emergency Operating Procedures," dated
August 14, 1986, with the licensee.
The inspector determined from this
discussion and review of training records that the licensee training
department has addressed the training concerns noted in the Information
Notice.
The inspector reviewed previous QA training audits for 1984, 1985
and 1986 to determine if the licensee's QA department responded to the
deficiencies which were noted at other licensed facilities in
implementation of EOP programs.
The licensee's audits do not appear to
address IN 86-64, and the NRC is concerned that the licensee may not have
assessed the quality of the EOP upgrade program.
This concern will be
reviewed during a future NRC inspection of the licensee's EOP program.
The inspector determined from his reviews, coupled with interviews with
instructors, students, and supervisors that the non-licensed training
program appears to be adequately implemented in accordance with INPO
guidelines and meets the requirements as specified in the TS and FSAR.
No violations or deviations were identified.
11.
Natural Circulation Cooldown (41701)
The licensee has implemented Revision 1 of the Westinghouse Owners Group
(WOG) Emergency Response Guidelines (ERG) for Natural Circulation
Cooldown.
The procedures utilized by the facility are EP-1.02a, Natural
Circulation Cooldown, Revision 1 and EP-1.02b, Natural Circulation
Cooldown with a Void in the Reactor Vessel, Revision 1.
10
The inspector reviewed the training conducted by the. licensee for Revision
l to the aforementioned procedures.
Lesson plans RQ-86.2-Lp-12 and
RQ-86.2-Lp-12t covered the material pertaining to EP 1.02a, and lesson
plans RQ-86.3-Lp-4 and RQ-86.2.Lp-4t covered material pertaining to
The lesson plans detail the class objectives, major action
categories of the procedures, and a step by step review of the procedure
including the basis behind the steps.
To verify that training had been
completed on these procedures, the inspector reviewed selected training
records for 1 i censed personne 1.
Licensed operator re qua 1 ifi ca ti on
schedules for 1986 were also reviewed to determine the sessions when
the subject matter was taught.
Attendance records were then reviewed
to ensure that the selected licensed individuals had in fact attended.
In a 11 the cases reviewed, no prob 1 ems were noted.
The 1 i censee al so
conducted simulator training on both EP-1.02a and EP-l.02b.
This
training was covered under the 12t and 4t lesson plans.
Additionally, the licensee has in place lesson plans which provide
training on the procedures to replacement licensed operator candidates.
The inspector reviewed these lesson plans and found them to be structured
as well as the lesson plans which provided the initial training.
In all
cases reviewed, no problems were noted.
In the area of technical adequacy, EP-1.02a provides sufficient guidance
on pressurizer level increases during RCS depressurization, including
direction to repressurize the RCS to collapse potential voids and
transition points to EP-1.02b if RCS depressurization must continue.
Additionally, direction has been included in EP-1.02a that due to
restraints, if a rapid cooldown must be accomplished at a rate that may
form a steam void, then EP-1.02b, Natural Circulation cooldown with a void
should be used.
Once EP-1.02b is entered, there is sufficient guidance
for establishing pressurizer level to accommodate void growth.
The *
pressurizer is monitored to insure that level is maintained within the
normal span, and this should prevent a loss of pressure control.
also monitors reactor vessel level indication system (RVLIS) to ensure the
void does not enter the hot legs, thereby interrupting natural circulation
flow.
Due to the facility technical specifications being more restrictive, the
licensee, for the case with less than two control rod drive mechanism fans
running in EP-l.02a, could not implement the WOG requirements of 200°F
subcooling below 1900 psia.
To account for this, the licensee reduced the
cooldown rate to less than 10 °F/hr while maintaining 130°F subcooling at
the hot leg.
These parameters are maintained until the RCS reaches
approximately 660 psig.
At this point, a six hour hold period is
initiated to allow the upper head to cool to a temperature less then
saturation for 400 psig.
Following the hold period, the RCS is
- depressurized to a point where RHR flow can be established.
The problem
that arises is that while the RCS is being depressurized, the subcooling
margin is also decreasing.
This represents a significant deviation in
that the WOG guidelines do not reference a straight depressurization to
~-
'~-
11
establish RHR but instead maintain a constant subcool ing margin with
no straight line depressurization.
Conversation with licensee personnel
indicate there in fact may be sufficient subcooling to preclude upper head
void formation during the depressurization, however there is insufficient
documentation to support this position.
The 1 icensee uses a Step
Deviation Document (SOD) for each EOP to identify and justify any step
However, the SOD for EP-1.02a failed to
identity or justify this step deviation.
The licensee committed to the
NRC, in both the procedure generation package submittal, dated July 1,
1983, and by a letter dated June 29, 1987 (serial number 095A) to justify
any significant deviation between the ERG step and the procedure step.
Based on the above information, this item is a deviation and will be
identified as (50-280,281/87-32-02),
A second problem noted during the procedure review was with attachment 2
to EP-1.02a.
The licensee indicated that attachment 2 was prepared using
Technical Specification (T.S.) heat-up/cooldown curve Figure 3.1-1 as a
reference.
Initially, the licensee thought the T.S. curve was based on
Tavg.
It has since been determined that the T.S. curve is based on Tc
and not Tavg., therefore attachment 2 is less conservative.
This could
result in a condition wherein an operator conducting a cooldown using
attachment 2 could violate T.S. limits for cooldown.
Based on the above
information, this item is a violation for failure to provide an adequate
procedure and will be identified as (50-280, 281/87-32-01).