ML20042G382
| ML20042G382 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/02/1990 |
| From: | Conte R, Florek D, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042G374 | List: |
| References | |
| 50-277-90-04OL, 50-277-90-4OL, 50-278-90-04OL, 50-278-90-4OL, NUDOCS 9005140175 | |
| Download: ML20042G382 (25) | |
See also: IR 05000277/1990004
Text
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U.S. NUCLEAR REGULATORY COMMISSION-
REGION I
PEACH BOTTOM ATOMIC POWER STATION REQUALIFICATION PROGRAM EVALUATION
Combined Report Nos.:
50-277/90-04 (OL) and 50-278/90-04_ (OL)
Facility Docket Nos.:
50-277 and 50-278
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Facility Licence Nos.:
License:
Philadelphia Electric Company
P.O. Box 7520-
Philadelphia, Pa. 19101
Facility:
Peach Bottom Atomic Power Station Units 2 and~3
Examination Dates:
March 5-16, 1990
Examiners:
N.'Conicella, Sr. Operations Engineer, NRC Region I'
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T. Bettendorf, PNL
M. Riches, PNL
Requalification Examination Chief Examiner:
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Donald J. Florek, Sr. Operations Engineer
'Date
Reviewed By:
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Richard J. Conte W ef, BWR-Section
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Operations Branch,6T)RS
Approved By:
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Robert M. Gallo, ChieT
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Operations Branch
Division of Reactor Safety
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EXECUTIVE SUMMARY
Written and operating requalification examinations were administered to ten
Reactor Operators (R0s) and twelve Senior Reactor Operators (SR0s). These
operators were divided into four crews, which consisted of three operating
crews and one staff crew. The examinations were graded concurrently by the NRC
and the' facility training staff. As graded by the NRC, all the four crews that
participated in the examination performed satisfactorily on the simulator
' portion of the examination. Twenty of the twenty-two operators examined passed
all portions of the examination. One reactor oper6 tor and one senior reactor
failed the written portion of the examination.
The licensee's licensed operator training program was determined to be satis-
factory based on the criteria established in section ES-601 of NUREG-1021, Rev.
5.
Generic program strengths were identified the most notable being the effect-
ive use of the shift technical advisor and an overall operator attitude of
attempting to restart failed equipment during-simulator scenarios.
Knowledge
weaknesses were noted as feedback to the licensee's training programs.
No
significant operator inabilities were identified.
However, certain administra-
tive control deficiencies were noted involving two apparent violations as
described below.
One violation involved a failure to provide adequate controls to assure that
proficient operators licensed pursuant to 10 CFR ;55 were assigned licensed
duties. This occurred during the time of the extended shutdown order in the
period March'1988 - January 1989 when four reactor operators and four senior
reactor operators fai. led either the comprehensive requalification written
examination or annual operating test. The operators were assigned licensed
duties during the remedial training period-and prior to successfully passing
the requalification reexamination. As a result, they did not satisfy the
requirements of 10 CFR 50.54(k),10 CFR 55.53(h), and 10~CFR 55.59(a)(2).
(Violation 277 and 278/90-04-02).
(See paragraph-6.3).
The other violation involved exceeding the time limits specified in 10 CFR 55.59(c) for an annual operating examination and a comprehensive written exami-
nation every 24 months. This occurred over the period November 1987 through
March 1990 when 4 licensed operator exceeded the 24 month time limit by as much
as 4 months on the comprehensive written examination and 14 licensed operators
exceeded the annual limit for an operating' test by as much as 7 months.
(Violation 277 and 278/90-04-01).
(See paragraph 6.2).
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DETAILS
1.
Introduction
During the examination period, the NRC administered requalification exami-
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nations to 22 licensed operators-(10 R0s and 12 SR0s). Three operating
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crews and one staff crew were evaluated.
The examiners used the process
and criteria described in NUREG 1021, " Operator Licensing Examiner Stand-
ard," Rev. 5, section ES-601, " Administration of NRC Requalification
Program Evaluations."
An entrance meeting was held with the facility licensee on January 9,
1990, at the Regional Office. The purpose of the meeting was to brief the
facility licensee on the requirements of the requalification program
evaluation and to outline a prospective schedule for the examinations.
The personnel contacted duriag the examination a,*e listed in Attachment
1.
The members of the combined NRC/ facility examination team, and the
facility evaluators are also identified in Attachment 1.
2.
Examination Results
2.1 Requalification Individua1' Results
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The following is a summary of the individual examination NRC and facility
results:
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TYPE OF EXAMINATION:
Requalification
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TOTAL
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Pass / Fail
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Pass / Fail
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10 / 0
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12 / 0
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22 / 0
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10 / 0
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12 / 0
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22 / 0
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FACILITY GRADING
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Pass / Fail
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Pass / Fail
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Written
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Simulator
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22 / 0
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Overall
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2.2 Generic Strengths and Weaknesses
The following is a summary of generic strengths and weaknesses noted by
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the-NRC from the results of the individual requalification examinations.
This information is being provided to aid the licensee in upgrading the
requalification training program.
No response to these generic strengths-
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and weaknesses is required.
2 2.1 Generic-Strengths
Recognition of entry conditions into emergency and abnormal proce-
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dures (OT,0N, TRIP).
With the exception of~one of the operating crews, crew teamwork, crew
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communication and crew command and control were good during the simu-
lator portion of the examination. One operating crew was considered
to be adequate but a contrast to the other crews examined.
The shift technical advisors were an asset to each crew evaluated.
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They assisted shift supervision during the major transient effect-
ively.
The one crew that was a contrast to the other three relied
more on.the STA to successfully mitigate the transient.
Operators took appropriate action to restore failed equipment during
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the scenario.
2.2.2 Weaknesses in Written Examination
. Knowledge of actions to remove HPCI from service following an auto-
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matic start.
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Knowledge of feedwater system and plant response to opecing of the
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equalizing valve for the narrow range level transmitter.
Understanding of prevention of a low suction pressure trip of a ESW
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booster pump following a trip of ESW pumps.
Knowledge of reactor water level maintenance for adequate core
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circulation during shutdown cooling.
Technical-specification actions for loss of drywell floor and equip-
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ment drain sump pumps due to loss of 480 VAC power.
2.2.3 Weaknesses in Operating Test
All emergency plan classifications during the simulator portion of
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the examination were within the acceptable classifications that the
scenarios had established, However, some senior reactor operators
did not always consider other possible emergency classifications that
could be established due to plant conditions contained in the scenario.
This occurred during the one scenario when a reactor coolant leak
occurred that was relatively small, but could not ba determined that
it was greater than 50 gpm.
Some SR0s classified this as an Alert
because of leakage considerations, even though specific leakage rates
were unknown; whereas, other SR0s classified the event as.an Unusual
Event due to the other more clearly defined scenario events.
Some SR0s and R0s had difficulty with. torus spray and HPCI. Three
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R0s expet lenced difficulty in spraying the torus properly during the
simulator port. ion of the examination.
Four SR0s did not perform the
torus spray Job Performance Measure (JPM) satisfactorily. The HPCI
JPM was not performed satisfactorily by four SR0s and one RO.
In
addition, as described above in the written examination, knowledge of
actions to remove HPCI from service was also a weakness.
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Knowledge of when to emergency depressurize due to reactor water
level considerations.
Knowledge of where the ESW pump controls are located when operating
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from the Emergency Shutdown Panel.
Procedure SE-1 does not provide
guidance as to where the controls are located.
Understanding of what is meant by " loss of RBCCW" in ON-113.
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Knowledge of what is meant by symmetrical control rods.
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Knowledge of the technical specification requirements for operable
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Knowledge of the location for the reset push button for the local
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' diesel generator air start.
The procedure did not provide cl. ear-
guidance as to where the button was located.
2.2.4 Other Observations
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During the course of the examination the facility examination team
members identified to the NRC team their observations regarding crew
performance.
The facility consistently identified similar concerns
as did the NRC team and in most cases identified additional items.
Another item relating to emergency classification was lack of faci-
lity guidance on the proper emergency classification if a parameter
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has _ exceeded the threshold for upgrading to a higher emergency
classification and subsequently returned to a lower emergency classi-
fication level during the time that a emergency classification
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determination is being made.
This condition occurred during one
scenario and caused some confusion for the SRO in post scenario
discussions.
The Operations Superintendent observing the scenario
noted the lack of facility guidance for the condition that occurred
and independently. concluded that additional facility guidance is
required.
Subsequent to one individual failing the JPM on establishing control
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at the. emergency shutdown panel, the facility identified that the
specified JPM critical step of starting an emergency service water
(ESW) pump did not meet the condition of-a critical' step for the:
initial conditions-specified in-the JPM. After providing justifica-
tion as to why the step was not critical to the accomplishment of the
'JPM (the pump did not have to be started due to the initial condi-
tions specified in the JPM), the combined NRC/fac:ility examination
team agreed that the step was not critical.
The. review was performed
per the guidance of ES-601.D.2.c.1.d. -This decision resulted in one
. individual satisfactorily completing the JPM rather than failing the
JPM. The facility agreed that a more thorough review of the JPM
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critical steps could have identified this condition. As identified
in section 2.2.3, ability to locate the ESW pump control on the
emergency shutdown panel was a generic weakness.
During the performance of the T-200 procedure serias- in plant JPMs,
the NRC "<aminers noted that the control of the procedures and tools
in the E -) tool locker and plant labeling made the task steps-easy to
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accomplish. However, the NRC examiners noted that only one set of
T-200 series tools and equipment are contained in the E0P tool
locker.
Following examiner questioning on what would happen if E0P
tools were required to be used-on both units simultaneously, the
facility agreed to evaluate their current practice.
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The facility provided sampling plan only addressed the written portion
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of the examination.
The sampling plan had to be augmented by additional
facility information to enable the sampling plan to be useable by the
NRC examination team.
Even with the additional facility information
the sampling plan did not identify how the proposed examination satis-
fied the sampling plan.
The facility training representative identified
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in discussions that future sampling plans wil.1 address the entire
examination.
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The operator action description of the simulator scenarios was adequate
for this NRC examination team to assess critical tasks.
However, some
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additional detail could be provided such as specifying which technical
specification is being assessed and adding the procedural activities
that would occur when ON and 0T procedures are entered.
3.
Requalification Program Evaluation Results
The facility program for licensed operator requalification training was
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rated as' SATISFACTORY in accordance with the criteria established in
ES-601, paragraph C 3.b.1, C.3 b.2, D.1.c.2.c, D.2.c.2.b, and'D.3.c.2.b.
3.1 Examination Results
The overall individual pass rate was 91% which meets the criterion of at
least 75% established in ES-601, paragraph C.3.b.1.b.
Four crews were
evaluated and all were determined to be satisfactory which meets the
criterion of no more than one third of the crews may be evaluated as un-
satisfactory by the NRC, established in ES-601, paragraph D.1.c.2.c.4.
Twenty-two out of twenty-two individuals (100%) passed the vi ithrough
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portion of the examination which meets the criterion of 75% established
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in ES-601, paragraph D.2.c.2.b.2,
Twenty out of twenty-two individuals (91%) passed the written portion of
the examination which meets the ' riterion of 75% established in ES-601,
paragraph D.3.c.2.b.
The licensee requalification progiam is INP0 accredited and is based on
a systems approach to training which meets the criterion established in
'ES-601, paragraph C.3.b.1.d.
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3.2 Analysis of Pass / Fail Agreement
The facility, failed one individual in the simulator portion of the exami-
nation that the NRC did not. The NRC does not penalize the facility for
holding a higher standard of operator performance as stated in ES-601,
paragraph D.1.c.2.c.3.
Therefore, there was 100% agreement between the NRC
and facility in the grading of the written and operating examinations.
This meets the criterion of 90% agreement established in ES-601, paragraph
C.3.b.1.a.
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There was 100% agreement between the NRC and facility in the . simulator
crew evaluations which meets the criterion of 100% agreement established
in ES-601, paragraph D.1.c.2.c.1.
There was 100% agreement between the NRC and the facility on pass / fail
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. decisions on the. walk-through and the written examinations. This meets
the program criteria for 90% agreement established in ES-601, paragraphs
D.2.c.2.b.1, and 0.3.c.2.b.
In addition, the facility identified similar weaknesses in the post-scen-
ario critiques as did the NRC examination team.
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3.3 Common Job Performance Measures
A review of the results of five common Job Performance Measures (JPMs)
performed each week indicate the maximum percentage of operators that
missed a common JPM was 27%. . Therefore, none of the common JPMs was
missed by more than 50% of the operators.
Likewise, none of the common
questions about the same JPM was missed by more than 50% of the operators.
Therefore, the criteria of paragraphs C.3 b.2.a and b of- ES-601 are met.
The results indicate that all of the operators evaluated answered greater
than 80% of the common JPM questions correctly which meets the criterion
of at least 75% of the operators score over 80% of the common JPM ques-
tions. -Therefore, the criterion of paragraph C.3.b.2.e of ES-601 is met.
The results of the requalification examinations indicate that the facility
does train-and evaluate their operators in all positions permitted by
their individual licenses. .The operators were also trained for in plant
JPMs as indicated by the examination results and their familiarity with
the walkthrough process.
Therefore, the criteric of paragraphs C.3.b.2.c
and d of ES-601 are met.
The facility evaluators were found to be satisfactory in.accordance with
the standards established.in Attachment S to ES-601.
However,'one faci-
lity evaluator provided leading cues that were questioned by various NRC
examiners on more than one' occasion. After having identified this to the
training supervisor, corrective action was taken and a different evaluator
was utilized.
The NRC examiners determined that no-pass-fail decisions
were affected by the cues provided.
Therefore, the criterion of paragraph
C.3.b.2.f of ES-601 is met.
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The above results indicate that criteria established in ES-601 paragraph
C.3.b.2.are acceptable.
4.
Requalification Examination Preparation
The reference material that was submitted by the licensee met the guide-
lines of Attachment 4 to ES-601.
The material included 6 sample plan, a
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greater than 350 question examination bank for the classroom portion of
the written examination and 29 static simulator examinations with 10-18
questions for the static portion of the written examination, 15 dynamic
simulator scenarios and 78 job performance measures. However as described-
in paragraph 2.2.4 the sampling plan was weak.
The facility proposed written examinations were reviewed and were of high
quality and acceptable. The written examinations sampled a good cross
section of information covered during the requalification year.
The facility proposed scenarios were reviewed during the validation week.
One scenario was changed to add additional malfunctions. The other
changes that were made to the facility scenarios included the clarifica-
tion of critical tasks and expected operator actions. The simulator
scenarios used by the NRC examination team met the guidelines of ES-601.
The NRC examination team selected eighteen facility job performance
measures (JPMs).
For the most part the JPMs reflected the required steps
in the procedures used to perform the task.
Changes to the JPMs' included
the addition of performance steps which require an operator to obtain the-
procedure, tools and equipment, when appropriate, clarifying the informa-
tion to be read to the operator, making the JPM specific to the component
or unit on which the JPM was to be accomplished and rewriting or clarify-
ing JPM questions,
Overall, the validation week went very smoothly with
excellent cooperation by the facility examination team members.
5,
Requalification Examination Administration
The examination was conducted without any major problems or delays. To
assure examination security, common test material each week was admini-
stered the same day with controlled separation maintained between opera-
tors.
The examination content as administered is summarized in Attachment
2.
The dynamic simulator portion of the examination was administered on-
Monday and Tuesday of the first week and Monday of the second week.
Due
to better examination administration efficiency only.one day was required
to administer the dynamic simulator examination on the second week. The
four NRC examiners were usually assigned to one individual, while one
facility evaluator was assigned to evaluate the SR0s, one facility evalu-
ator was assigned to evaluate the R0s and two facility evaluators were
utilized assessing overall crew performance. This did not result in any
problems since there was 100% agreement on pass / fail decisions. The
facility evaluators critiqued the crew performance with the NRC examiners
after each set of scenarios, rather than after each scenario.
This saved
a considerable amount of time.
The dynamic simulator examination was not
video taped due to lack of installed video cameras at the time of the
requalification examination. There were no problems identified with the
simulator or simulator instructor / operators during the requalification
examination.
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During one scenario the NRC examiners noted that a new procedure was
issued between the NRC validation week and the examination which affected
the operator actions. This did not cause any specific difficulty for tos
examiners.
However, it did cause some slight confusion for the operators
since a procedure referenced in the new ON-121 procedure, RT-19.6, was not
issued at the same time.
This was adequately handled by the facility
during the examination.
However, a subsequent check in the plant also
identified that the referenced procedure had not been issued.
During the
course of the examination the new procedure was issued.
The JPM portion of the examination was administered on Thursday and Friday
of the first week and Tuesday and Thursday of the second week.
Eighteen
JPMs were selected by the examination team for use.
Five JPMs were iden-
tified as common JPMs for the first week and a different five were iden-
tified for the second week.
The remainder of the 13 JPMs each week were
randomly distributed over the operators. The common JPMs for each week
were performed on the same day for all operators with controlled separa-
tion maintained between operators. One JPM on resetting a group 2 and 3
PCIS isolation required considerably more time to complete than originally
planned. This was characterized as a JPM time validation problem not an
operator performance problem. As a result, after the first JPM perform-
ance, the JPM was eliminated from the examination and other JPMs were
substituted from the list of prior validated JPMs.
There were also two
JPMs that identified the wrong panel to perform the task and referred to a
label that did not exist in the plant.
These were identified by the
facility evaluators and did not cause problems during the examination.
The operators performance m Ji>M ano JPM questions resulted in completing
the JPM portion of the examination in less time than the facility had
scheduled.
Security, health physics, and operations support in the plant
were very effective in allowing the plant portion of the examination to
proceed as smoothly as it did.
The written portions of the examination were conducted on Wednesday for
both weeks without major problems. Security was maintained for the written
examinations by controlled separation of the operators. The only problems
that occurred were that one static simulator examination could not reprod-
uce the reactor water level condition band specified and one written
question had no correct answer. The static scenario was accepted as is
because it only affected one distractor of one question, still required
the same type of knowledge ni did not affect the overall answer.
The one
question was deleted frot & .'irst examination given and then corrected
for the remainder of the operators. The time validation of the written
examinations was adequate as evidenced by all operators completing the
examination in the allotted time.
The NRC and facility began grading of
the written examination immediately after each operator had finished the
examination. As a result, the NRC and facility grades were available on
the next day.
The entire examination process went very smoothly.
Good cooperation
between the examination teams allowed any problems that arose to be immed-
iately resolved and prevented them from impacting the examination.
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6.
Requalification Program Administrative Findings
6.1 Written and Operating Examination Program Frequency
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As a result of the rule change issued in May 1987, in accordance with 10
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CFR 50.54(1-1) a requalification program must meet the requirements of
55.59(c) and not decrease the scope of its current approved operator
requalification program without Commission authorization. The current
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approved operator requalification program as defined in the FSAR, dated-
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January.1987, requires an annual written examination and an annual oral
examination, which may be accomplished on a simulator.
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The examiner reviewed TP-140 "1.icensed Operator Requalification Program
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Plan" Revision 0 dated May 11, 1989, which requires an annual walkthrough
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and simulator evaluation and a biennial comprehensive requalification
examination consisting of a written examination, walkthrough evaluation
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and simulator evaluation. 10 CFR 55.59(c) requires an annual operating
test and a comprehensive requalification written test every 24 months.
The inspector was concerned that the Peach Bottom requalification program
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decreased the scope of the current approved operator requalification
program without Commission at thorization since they were not performing
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annual written examinations as their FSAR indicated.
The inspector reviewed question / response 347 in NUREG-1262 which indicated
that if the facility has an accredited pro pam then a change can be made
to go from an annual to a biennial written examination. Since Peach Bottom
is an accredited program the inspector was satisfied that the requalifi-
cation program examination frequency was acceptable.
In addition, the
licensee is revising the FSAR to agree with TP-140 in its next FSAR up-
date.
6.2 Written and Operating Examination Schedule
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During the preparation for the examination.the NRC examiner noted that the
facility program TW140 "t.icensed Operator Requalification Program Plan",
Revisio.n 0, dated b y 11, 1989, allowed exemptions from the requalifica-
tion examination for newly licensed operators. As a result, two operators
licensed in October 1989 whro originally were not scheduled to take a
requalification examination entil 1991, were sdded to the list of operators
to receive an NRC administered requalification examination.
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10 CFR 50.54(1-1) requires that the facility have a requalification
program that meets the requirements of 10 CFR 55.59(c),
requires that the requalification program include an annual' operating test
and a comprehensive written examination within the enntinuout rvqualifl-
. cation period not to exceed 24 months in duration. As a result of the
above observation, the examiner requested the facility licensee to review
-the actual dates of exandnations for newly licensed cperators since May
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1987 to determine if the requirements of an annual operating test and
comprehensive written examination every 24 months were satisfied. The
licensee provided the results in a letter dated March 2, 1990, which
concluded that some operators exceeded the 12 month operating and 24 month
comprehensive written examination limits.
The inspector also held additional discussions with facility training
representatives and determined that the same conclusion could be made for
other than newly licensed operators. The results of the licensee response
and examiner followup in the time period November 1987 - March 1990 are
summarized in Attachment 3.
Out of the 19 operator files evaluated, 3
$R0s and 1 RO exceeded the limits for both the operating and written
examination, 2 SR0s m 8 R0s exceeded the limit for the operating exami-
nation and 2 SR0s and 3 R0s did not exceed limits. These limits were
exceeded from 6 weeks up to 7 months.
The inspector concluded that the
licensee program did not assure compliance with the CFR 55.59(c) require-
ments for an annual operating test and comprehensive written examination
every 24 months, and the licensee did not meet the requirements in 14 out
of 19 licensed operator files evaluated.
This is an apparent violation of
10 CFR 50.54(1-1) and 10 CFR 55.59(c).
(Violation 277 and 278/90-04-01).
The inspector concluded that the exemption for newly licensed operators
caused most of the time limits to be exceeded.
The accelerated scheduled
use of the simulator for requalification examinations to support Peach
Bottom restart following the extended shutdown while still at the factory
in Columbia, Maryland in late fall of 1988 was the other major cause.
The
inspector dt:termined that the operators that exceeded the time limits for
annual operating test did receive simulator evaluations as part of their
normal requalification program training between required operating tests.
For the operators that exceeded the time limit for a comprehensive written
examination, two performed satisf actory on all weekly quizzes, one failed
one of the weekly quizzes and successfully passed af ter additional train-
ing and one operator failed multiple weekly quizzes, but successfully
passed each quiz af ter additional training.
In addition, one of the four
operators that exceeded the time limit for the written examination by
approximately three months (11/11/89 - 2/9/90) failed the comprehensive
written requalification examination when administered by the facility in
February 1990.
Had the comprehensive written examination been administered
within the time limits required, the facility could have prevented the
licensed operator with less than satisfactory qualifications from perform-
ing licensed duties for the three month period.
The licensee took immediate corrective action to revise the TP-140 (Revi-
sion 1 dated March 1, 1990) to eliminate the exemption for newly licensed
operators,
in addition, the licensee instituted a computer tracking
system to menitor the scheduled examinations and when the next examination
is due.
As described by the inspector to the facility, the NRC's Operator
Licensing Branch position is that " annual" is 12 months plus 10% (approxi-
mately 6 weeks). This allows an operator to take the examination on the
first week of the requalification cycle and then the last week week one
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year later to accommodate personnel reassignment among the operating
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crews. The operators who took the requalification examination this
February-March 1990 will receive annual operating examinations and compre-
hensive biennial written exaniinations based on the date of their last
examinations.
Those newly licensed operators will receive annual operat-
t
ing examinations and biennial written examinations based on the date of
their. license until they are absorbed into the normal requalification
examination schedule and still not exceed the time limits.
Based on the
review of licensee commitments, the inspector was satisfied that the
,
licensee actions would prevent recurrence,
t
6.3 performance of Licensed Duties After Failure of Requalification
Examination
'
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TP-140 " Licensed Operator Requalification Program Plan," Revision 1, dated
March 1, 1990, identified that an operator who fails a requalification
examination may be returned to licensed duties if an oral interview is
conducted by a License Review Board and the board determines that the
operator can return to licensed shift duties during an accelerated review
period. The current FSAR description dated January 1987 has similar
wording.
The regulations, issued in May 1987, in:
10 CFR 50.54(1-1) requires, in.part, that the licensee have a requali-
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fication program that meets the requirements of 55.59(c),
s
10 CFR 55.59(c) requires, in part, that an annual operating test and
-
comprehensive written examination be administered,
t
10 CFR 50.54(k) requires, in part, that a reactor operator or senior
'
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operator licensed pursuant to Part 55 be present at the controls.
'
10 CFR 55.53(h) requires, in part, as a condition of the individual
-
operator license, an operator to complete a requalification program
as described by 55.59.
10 CFR 55.59(a)(2) requires, in part, a licensed operator to success-
-
fully pass a comprehensive requalification written examination and an
annual operating test.
l
Therefore, it follows that an operator who does not pass a requalification
examination does not fulfill a condition of the part 55 license and should
not be present at the controls.
The facility requalification program
permits individuals who do not pass a requalification examination to be-
present at the controls performing licensed duties,
-The examiner inquired if the facility had in the past permitted indivi-
duals to perform licensed duties while in an accelerated review program
after failing a requalification examination. The licensee identified 8
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14
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,
individuals that performed licensed duties during the time they failed a
requalification examination, were being retrained and then subsequently
reexamined satisfactorily.
The results of the licensee's review are
indicated in Attachment 4.
The 8 operators averaged 22 days (2 days
minimum - 44 days maximum) performing licensed duties in the intervening
4
period between failing and passing a requalification examination. The
inspector notes that this occurred during the time thet the facility was
e
shut down under an extended shutdown order.
This program allowance and
actual use of operators that failed their requalification examination for
licensed duties is an apparent viol.ation of 10 CFR:50.54(k),10 CFR 55.
53(h) and 10 CFR 55.59(a)(2).
(Violation 277 and 278/90-04-02).
.
The examiner also inquired if any operators in the current requalification
examination cycle had failed their examination and were performing
licensed duties. One R0 and one SRO had failed the written portion of the
current requalification examination.
The one RO failed on 2/16/90 was
retrained and reexamined on 2/23/90 prior to returning to licensed duties.
A review of the control room logs for the intervening period identified
that the R0 did not perform licensed duties.
The SR0 had failed on 2/9/90
and was scheduled to be reexamined on 3/30/90.
The SRO was not excluded
)
from performance of licensed duties at the time of the NRC administered
'
requalification examination by senior operations management but was
-
assigned to non-license required duties by his Shif t Manager.
After NRC inquiry, the licensee operations management took positive steps
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to assure that the SRO would not perform licensed duties pending satis-
factory completion of his reexamination.
In addition, the licensee
revised TP-140 revision 2 dated March 16,1990 to administrative 1y assure
that an individual failing the annual operating test or comprehensive
written requalification examination would not be returned to licensed
duties until successfully passing the requalification examination. This
involves signed correspondence by the Superintendent - Operations and
formal acknowledgement from the affected operator.
The inspector was
satisfied that the licensee program modifications, if implemented
properly, will preclude recurrence.
7.
Exit Meeting
At the end of the first week, the NRC informed the facility of the pre-
liminary NRC results of the first week. The NRC team informed the facil-
ity to identify those individuals who were required to be removed from
licensed duties for remediation and reexamination. The facility agreed to
limit the knowledge of the preliminary NRC results to the facility.
personnel present at the meeting until the end of the two week examina-
tion. This was a moot point, however, since the facility results and the
NRC results at the end of the first week were identical.
The facility did
provide their examination results to the appropriate facility personnel.
The individuals in attendance at the meeting are listed in Attachment 1.
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An exit meeting was held at the conclusion of the examination on March 16,
1990. The personnel in attendance are listed in Attachment 1.
The NRC
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results of the examinations were presented.
The facility provided a
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p
summary of their results.
Requalification Examination preparation and
,
administration were discussed along with generic strengths and weaknesses
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of,the program as indicated in this report.
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~ ATTACHMENTS
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1..
Persons Contacted
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2.
Requalification Examination Test Items
.
3.
Facility' Administered Requalification Examinations Since May 1987
4.,
Licensed Operators Who; Failed Requalification and Performed Licensed
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Duties
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5.
Simulator Fidelity Report
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ATTACHMENT 1
PERSONS CONTACTED
Philadelphia Electric company
R. Andrews, Supervisor Operations Training (1,4,6)
R. Artus, Requalification Instructor (3,6)
J. Cotton, Superintendent of Operations (1,3,4,6)
J. Felice, Requalification Instructor (3,6)
J. Franz, Plant Manager (4)
R. Helt, Supervisor NTD, PECO Corporate (3,4,6)
D. McClellan, Senior Instructor for Requalification (1,3)
K. Patek, Simulator Instructor (2,3,6)
D. Rein, Requalification Instructor (3,6)
D. Smith, Vice President Peach Bottom (4)
E. Till, Superintendent of Training (4,6)
A. Wasong, Operations Support Engineer (1,2,3,4,6)
R. Watkins, Requalification Instructor (1,2,3,6)
Nuclear Regulatory Commission /NRC Contractors
T. Bettendorf, PNL (2,4,6)
N. Conicella, Senior Operations Engineer (1,2,4,6)
D. Florek, Senior Operations Engineer (1,2,4,6)
J. Lyash, Senior Resident Inspector (4)
M. Riches, PNL (2,4,6)
Other
S. Maingi, Nuclear Engineer, State of Pa. (4,5)
Notes:
(1) Attended Entrance Meeting, January 9, 1990
(2) Member - Combined Facility /NRC Examination Team
(3) -Facility evaluator
(4) Attended Exit Meeting March 16, 1990
(5) Observed portions of the examination process
(6) Attended March 9,1990 NRC/ facility preliminary results meeting
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ATTACHMENT 2
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REQUALIFICATION EXAMINATION-TEST ITEMS
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. Written Examination - Part- B
Jen Reference Examination Nos. LOR 88-SB-N01.
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-Ld#EE;hB-N01. LDREE!Eh-N02. LOR 88-RN-N02
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TEST ITEM *-
SRO WEEK 1*
RO WEEK 1*
SRO WEEK 2*
R0 WEEK 2*
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2
1.0
-1.0
1.0
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3-
1.0
1.0'
1.0
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4
1.0
1.0
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-
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6
1.0
-
-
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8
1.0
1.0-
-
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9-
1.0
1.0
-
-
b
10
.
1.0.
1.0
1
-
-
I
12
1.0
1.0
.
-
-
'
13
1.0
1
-
-
-
14
1.0
-
-
-
15-
1.0
1.0
-!
-
-
16
1.0
1.0
-
-
L
17
1.0
1.0
1.0
j
-
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18~
1.0
'
.
19
1.0
1.0
1.0
'
-
-
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-
-
20
-_
1.0
1.0
1. 0 -
'
21
1.0'
3.0
1.0
-
22
1.0
1.0
1.0
-
,
23
l1.0
1.0
-
-
24
1.0
1.0
-
-
25
1.0
1.0
-
-
l
27
1.0
-
. - '
-
29:
2.0
2.0
2.0^
-
a
31-
1.0'
1.0
' 1. 0
-
L
32.
1.0
1.0
1
-
-
33-
1.0-
-
-
-
34
1.5
1.5-
1.5
-
I
35:
1.5
1.' S
1.5
-
s
36'
3.0-
'
-
-
-
TOTAL
17.0
17.0
17.0
17.0
^
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Point Value of Test Item Number
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Written Examination - Part A (QVAL - Question Value)
[
.
Week 1
f
Static Simulator Examination No.04 Failure of a recir flow unit, main turbine
bearing failure, loss of 480 VAC load center
TEST ITEM-
SRO QVAL
RO QVAL
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~37
1.0
1.0-
"
38
1.0
1.0
39'
1.0
1.0
40
1.0
1.0
41-
1.0
1.0
.
42
1.0
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43
1.0
1.0
4 4 '-
1.0
1.0
45
1.0
l
-
1.0
1.0
i
1
TOTAL
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Static Sinulator Examination No.03 Main steamline break inside containment
i
., TEST ITEM
SRO QVAL
RO QVAL
46
1.0
1.0
47
1.0
-
48
1.0
1.0
49
1.0
1.0
50
1.0
1.0
51 ;.
1.0
1.0
52~
1.0
1.0
-53
1.0
'!
-
54
1.0
1.0
'
TOTAL
8.0
8.0
Week 2.
'
' Static Simulator Examination No 05 Feedwater heater tube leak, containment
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nitrogen makeup supply fails open-
.;
TEST-ITEM
SRO QVAL
RO QVAL
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75
1.0
1.0
76
1.0
1.0
77
1.0
1.0
78
1.0
1.0
' 79-
1.0
1.0
1
80
1.0
1.0
i
' 81.
1.0
1.0
,
82-
1.0
1.0
1.0
1.0-
>
TOTAL
8.0
8.0
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. Attachment 2
3
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Week 2 continued
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Static Simulator Examination No.02 Drywell steam leak, RHR pump discharge
rupture, diesel generator and ESW
malfunctions
TEST ITEM
SRO QVAL
R0 OVAL
65
1.0
1.0
66
1.0
1.0
67
1.0
1.0
,
1
68
1.0
1.0
l.
-69
1.0
1.0
70
1.0
1.0
72
1.0
1.0
73
1.0
-
l
74
1.0
-
,
TOTAL
8.0
i
Job Performance Measures (JPM)
LP No. Job Performance Measure
Location
2C Load the Diesel Generator to 1600 KW
Simulator-Common-2
8C Reset a recirc motor generator lockup
Simulator-Common-1
10C Manually initiate torus spray
Simulator-Common-1
13C Place a' reactor feed pump on the hydraulic jack
Simulator-Common-2
ISP Plant shutdown from the emergency shutdown panel
Plant-Common-1
180 Manually place SBGT on equipment cell exhaust
Simulator
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24C Perform a Group 1 isolation reset
Simulator
,
34C CAD system nitrogen addition to containment
Simulator
43C Perform a Group 2 and 3 PCIS isolation reset
Simulator
49P Local manual start of the diesel generator
Plant-Common-1
f
55P Maximizing CRD Flow to the RPV
Plant
56P Reset RCIC mechanical overspeed trip
Plant
,
58P Filling the fuel pool
Plant
60P Torus filter pump isolation bypass
Plant-Common-2
-!
62P Restore CR ventilation following high radiation trip
Plant
74P Isolate and vent the scram air header
Plant-Common-2
77C HPCI operation in CST to CST mode
Simulator-Common-1
78C Manual startup of RCIC
Simulator-Common-2
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Dynamic Simulator Examination
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Seen No.
Scenarios
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NRCEVAL-01 - RBCCW blockage with unisolable recire pump seal failure
'
NRCEVAL-02 - ATWS with stuck open SRV
NRCEVAL-03 - Fuel f ailure with unisolable leak in RWCU outside of containment
NRCEVAL-04 - Loss of high pressure feed
NRCEVAL-05 - RPV reference leg instrument line break with break in RHR pipe
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outside of containment
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ATTACHMENT 3-
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FACILITY ADMINISTERED REQUALIFICATION EXAMINATIONS $1NCE MAY 1987*
!
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Based on Facility letter CCN-90-14039 dated March 2, 1990, and addi-
'
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tional discussion with licensee training representatives
t
Operator License
Operating
Written
Comments
R0
11/11/87
12/14/88
3/14/90
Written overdue 4 months
3/15/90
Operating overdue 3 months
~ SR0
12/11/87
12/13/88
3/7/90
Written overdue 3 months
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3/8/90
Operating overdue 3 months
,
e
!
SR0
11/11/87
12/16/88
2/9/90(F) Written overdue 3 months
3/29/90(S)
3/30/90($)0perating overdue 3 months
,
8/19/88
1/12/89
2/23/90
Operating overdu'e <6 weeks
2/20/90
(Considered satisfactory)
12/30/87
12/15/88
2/23/90
Written overdue 2 months
-
2/23/90
Operating overdue 2 months
+
7/8/88
3/24/89
3/2/90
None
2/26/90
R0
3/24/89
2/21/90
2/21/90
None
.
R0
8/19/88
3/22/90(S)
3/23/90(S)0perating overdue 7 months
R0
8/19/88
3/9/90
3/7/90
Operating overdue 7 months-
R0
8/19/88
12/16/88
2/17/90
None
10/12/89
2/14/90
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. RO
11/28/88
10/12/89
2/23/90
None
!
2/13/90
'
4/4/88
12/13/88
3/14/90
Operating overdue 3 months
3/15/90
,
.RO
4/4/88
12/16/88
3/14/90
Operating overdue 3 months
>
3/15/90
,
p
R0
8/19/88
3/15/90
3/14/90
Operating overdue 7 months
,
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R0
8/19/88
3/8/90
3/7/90
Operating overdue 7 months
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- Attachment'3:
2
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. Operator License
.0oeratino
Written
Comments
R0
8/19/88'
2/21/90
2/23/90
Operating overdue 6 months
.1983
4/22/88
3/11/88
Operating. overdue 3 months
[-
12/15/88
3/15/90
3/14/90
SRO'
1982
4/8/88
2/26/88
Operating overdue 3 months
P
12/13/88'
3/23/90(S) Written overdue'<6 weeks.
i._
3/19/90(S)
(Considered satisfactory)
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R0
1984
4/8/88-
2/26/88(F)0perating - overdue 3' months -
!
J2/13/88
5/19/88(P)
t.
3/19/90(S)
3/23/90(S)
h
Notes
I
(S) - Scheduled
(F) - Failed.
(P) - Passed
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ATTACHMENT 4
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LICENSED OPERATORS WHO FAILED REQUALIFICATION AND PERFORMED LICENSED OUTIES
l
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Number of intervening days.
!
Operator Failed exam / Type
Passed exam
performing: licensed duties
-i
3/11/88
Written
4/28/88
21
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R0
.3/11/88
Written
4/28/88
23
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3/4/88
Written
6/6/88
44-
l
2/26/88
Written
5/19/88
38
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12/16/88
Operating
1/6/89
8
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SRO-
3/25/88-
Written-
5/12/88
21
'!
-3/18/88
Written
.5/6/88
15
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4/1/88
Written
5/19/88
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ATTACHMENT 5
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SIMULATION FACILITY REPORT
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Facility Licensee: Philadelphia Electric Company
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Peach Bottom Atomic Power Station
.
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FacilityDocketLNos::
50-277 and 50-278
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'Requalification Examination Administered on March 5-16, 1990=
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.This form is~to used to report observations.
These observations do not
!
constitute audit or inspection findings and are not without further verifi-
sw
scation and review,. indicative of.non-compliance with 10 CFR 55.45(b).
These-
observations do not effect NRC' certification or approval of the simulation
facility other than to provide information which may be used in-future evalu-
,
ations.- No licensee action is required in response to these observations.
.
\\
'During the conduct of the simulator portion of the requalification examina-
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tions,.no items were observed,
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. POST-INSPECTION SALP DATA SHEET
,
1.
Facility:
Peach Bottom Units 2 and 3
2.
Inspectors:
D. Florek, N. Conicella
3.
Docket / Report Nos:
50-277 and 278/90-04 (OL)
~ 4 ._
Inspection Dates:
March 5-16. 1990
5.
Functional Area:
Operations
6.
Category Rating (1,2 of 3):
1
7.
SALP Input:
Written and operating examinations were administered to ten Reactor Operators
-(R0s) and twelve Senior Reactor Operators (SR0s). These operators were divided
into four crews, which consisted of three operating crews and one staff crew.
The examinations were graded concurrently by the NRC and the facility training
'
staff.
As graded by the NRC, all the four crews thatiparticipated in the
examination performed satisfactorily on the simulator portion of the examina-
tion.
Twenty of the twenty two operators examined passed all portions of the
examination. One reactor operator and one senior reactor failed the written
portion of the examination.
The licensee's licensed operator training program was determined to be satis-
!
factory based on the criteria established in section ES-601 of NUREG-1021, Rev.
5.
The licensee provided a comprehensive, well written examination to the NRC
for the raqualification examination.
Two violations are identifieo. One violation involves exceeding the time
limits specified in'10 CFR-55.59(c) for an annual operating examination and a
comprehensive written examination every 24 months.
This occurred over the
period November 1987 through March 1990 when 4 licensed operator exceeded the
24 month time limit by as much as 4 months on the comprehensive written exami-
nation and 14 licensed operators exceeded the annual limit for an operating
.
test by as much as 7 months.
-
The other violation involves a failure to provide adequate controls to assure
that proficient operators licensed pursuant to 10 CFR 55 were assigned licensed.
duties. This occurred during the time of the extended shutdown order in the
period . March 1988 - January 1989 when four reactor operators and four senior
reactor operators failed either the comprehensive requalification written
examination or annual operating test. The operators were assigned . licensed
duties during the remedial training period and prior to successfully passing
the requalification reexamination. As a result, they did not satisfy license
conditions per 10 CFR 55.53(h) and 10 CFR 55.59(a)(2).
9.
Submitted by (Sign /date):
10. Approved by Sectiun Chief.
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~ DISTRIBUTION:
DRS Files (4)
DRP Section Chief for Reactor Inspected
Sr. Resident inspector
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R. Conte, DRS
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