ML20126L492

Exam Rept 50-155/OL-92-02 on 921201-03.Weaknesses Noted W/ Regard to Security & Implementation of EOPs During Simulator Exam.Exam Results:Both Crews Passed NRC Requalification Exam

ML20126L492
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/24/1992
From:	Jordan M, Leach M, Shembarger K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126L486	List: ML20126L485 ML20126L492
References
50-155-OL-92-02, 50-155-OL-92-2, NUDOCS 9301080052
Download: ML20126L492 (11)

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e U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-155/OL-92-02 Docket Nos. 50-155 Licenses No. DPR-6 Licensee: Consumers Power Company 10269 US 31 North Charlevoix, MI 49720 Facility Name: Big Rock Point Examination Administered At: Big Rock Point Power Station Charlevoix, MI 49720 Examination Conducted: December 1-3, 1992

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RIII Examiner: e' Y s' k 4 # /1/21/ '7 2 M. Leach Date Chief Examiner: b [/ //N / , r /7/[4/ >y K. Shembarger Date ,

Approved By: 34 4 /M // // 1 M. Jordan, Chief, OLS 1 Date '

Examination Summarv Examinat.jpri Administered on December 1-3 J92 (Report.

No. 50-155/011-92/02(DRS)L Written, simulator, and walkthrough requalification examinations were administered to three Senior Reactor Operators (SROs) and three Reactor Operators (ROs). Two crews, one consisting of an SRO and two ROs (an operations crew) and the other consluting of two SROs and one RO (a mixed crew of operations and staff personnel) , were evaluated on the simulator portion of the NRC examination. In addition, requalification retake examinations were administered to three operators; one RO and one SRO were administered simulator examinations and one RO was administered a written and walkthrough examination.

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e Results: Both crews passed the NRC requal examination. The three SROs and three Ros administered an entire examination passed all three sections of the examination. The SRO_and RO administered retake simulator examinations passed their examinations. The-RO administered a retake written and walkthrough examination passed the written examination, but failed the walkthrough examination. Based on'this evaluation and the results of the-previous two NRC administered requalification examinations, and in accordance with the criteria of NUREG-1021, Revision 6, Operator Licensing Examiner Standards, ES-601, the Big Rock Point Requalification Training Program was rated as satisfactory.

The following is a summary of the strengths and weaknesses noted during the performance of this examination.

Stronaths

• The quantity of JPMs in the facility exam bank.

• Simulator performance.

• Administration of the written examination.

• Walkthrough and simulator evaluators.

• RO knowledge'of emergency operating procedures.

• Control board operations.

• Operator performance on the walkthrough examination.

• Operator performance on the written examination.

Weaknesses

• Examination security.

• Exam control and administration.

• Proposed Part A section of the written examination.

• Operator command and control during simulator. examination.

• Clear implementation of emergency' operating-procedures.

during simulator examination.

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• Operators failure to attempt to isolate a recirculation pump when indication of a.LOCA through the seals existed during the simulator examination.

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4 REPORT DETAILS

1. Examiners

• +K. Shembarger, Chief Examiner, NRC, Region III

• +M. Leach, NRC, Region III

2. Persons Contacted Facility

• W. Beckman, Plant Manager

• R. Alexander, Technical Engineer

• L. Darrah, Operations Supervisor

• T. Hagan, Director, Nuclear Training

• D. Hughes, Executive Engineer

• +D. LaCroix, Big Rock Point Training Adm3nistrator

• G. Petitjean, Performance Specialist

• G. Rowell, Big Rock Point Training

+A. Thier, Big Rock Point Training

+K. Thomson, Big Rock Point Training

+W. Trubilowicz, Operations Superintendent U. S. Nuclear Reculatory Commission (NRC)

• +M. Jordan, Chief, Operator Licensing Section 1, Region III

• T. Tongue, Project Engineer, Big Rock Point

+ Denotes those present at the-Training Staff exit meeting on December 4, 1992.

• Denotes those present at the Management exit meeting on December 3, 1992.

3. Reaualification Trainina Procram Observations Although inadequacies were found in the. proposed examination ~

material (as described'below) and several weaknesses in the

• control and administration of the examination were identified-(such as failing to upgrade material prior to exam week and failing to include a member of the NRC during all exam briefings), overall the facility-requalification program was found.to be adequate. A. comparison of NRC and

~ facility grading on the written and operating sections of the examination--indicates that-the facility is in conformance with existing standards.

! The following information-is provided for evaluation by the

! licensee via their SAT based training program. -No response is required.-

a. Written Examination 2

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Strenoths:

• Overall, the proposed Part B exam was good, requiring only minor revision.

• Operator performance on the written examination was onod.

• A( Ition of the written examination was gC Weakneh

• NUREG 102_, ES-602, "Requalification Written Examinations", requires Part A of the written examination consist of two static scenarios, one with the plant in a steady state situation at power and the other a " snapshot" of the plant following a major transient which results in an ESF initiation. The proposed exam consisted of two at power static exams, requiring development of a major transient and ESF initiation static exam prior to exam week.

• ES-602 requires that each Part A static exam consist of a minimum of one major and two to three minor malfunctions to prevent excessive concentration of examining in one knowledge area.

In the proposed Part A exam, one static contained only one malfunction (with no major transient) and the other contained a major transient with only one malfunction.

• ES-602 requires that each static examination be designed to take 45 minutes to complete with 15 additional minutes allowed for review. In addition, an individual time validation of each question is required. Both requirements exist to ensure that the operator has adequate time to complete the examination, without excessive time built into the exam. The proposed Part A questions and exam had not been time validated,

b. Job Performance Measures (JPMs)

Strenaths:

• The number of JPMs in the facility exam bank was extensive.

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• Overall, operator performance during the walkthrough examination was good, e Walkthrough evaluators performed well.

Weaknesses:

• Some JPM cues did not reflect what the operator would actually observe in the plant. For example, after starting an MG set, the cue was "MG set is running" when the operator would actually observe an increase in voltage and frequency. The cues were modified to more accurately reflect the conditions observed in the plant.

• The JPM bank did not include separate JPMs for SROs only. The facility should review the SRO training program and job requirements to identify tasks that are specific to SRos and consider developing SRO specific JPMs for inclusion in the exam bank.

• The JPM bank did not include time critical JPMs.

Time critical JPMs are JPMs that cover tasks that must be performed within an established length of time to ensure safe operation of the plant. The facility should review the licensed operator training program and job requirements to determine if time critical tasks exist and consider developing associated JPMs for inclusion in the exam bank.

c. Dynamic Simulator Scenarios Strenaths:

• The RO knowledge of the emergency operating procedures was good during the dynamic simulator examination.

• Control board operations were good during the dynamic simulator examination.

• Overall,-the simulator performed well during the dynamic simulator and walkthrough examinations.

• Operation of the simulator by the training staff was good.

• Simulator exam evaluators performed well.

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i Weaknesses:

• The description of the scenario content, the evaluator outline, and the scenario outline did not always match in the proposed scenarios, which made it difficult to determine the intended. path of the scenario, and resulted in confusion during exam preparation. All three portions of the i scenario (scenario content, evaluator outline and '

scenario outline) should be consistent to not only eliminate confusion, but primarily to ensure that the post-exam discussion with the licensed operators accurately reflects the events included in the exam.

. Not all_ scenarios were developed with only-one success path. Evaluation scenarios should be designed to eliminate all but one success path to allow evaluation of the operators in a predetermined area.

• Not all proposed scenarios required an entry into Technical Specifications. NUREG 1021 requires evaluation of all SROs in the implementation of Technical Specifications during the NRC-administered requalification examination.

• Command and control during the dynamic simulator examination was weak, which at times led to slow recovery from events, e clear implementation of emergency operating procedures was weak; the lack of markings made on the flow charts to indicate the procedure and step

-being implemented during the recovery would_not only make it. difficult to perform an adequate turnover for a relief crew, but would also make it difficult for an OTA to provide guidance during the recovery.

• During the dynamic simulator examination, all

! crews were either slow to take actions, or failed l

to take actions to isolate a recirculating pump with a LOCA through the seals.

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4. Itaining,_pgerations. Security, Rad _ Protection ,

During exam development, the following weaknesses were identified and discussed with the facility:

• During exam preparation, a breakdown in exam security occurred when a member of tho' requalification exam development team provided training to licensed operators scheduled to take the examination. The facility'took immediate actions to notify the NRC, remove the individual from the exam development team, and substituto portions of the proposed examination previously developed with new exam material. In addition, the actions taken by the facility to prevent recurrence appear to be adequate.

• The licensed operator training program does not provide adequate guidance on the conditions that constitute an ATWS. Specifically, a failure of the reactor-to scram when required is only considered an ATWS condition when-entry into the ATWS contingency procedure is made. As a result, a manual reactor scram due to a failure of the reactor to scram automatically.is not considered-an ATWS, and therefore would not be classified as a site area emergency in accordance with the facility's emergency plan. This weakness'was discussed with and will be reviewed by the facility to determine corrective actions, if any, that will be taken to address the weakness.

• The licensed operator training program does not provide adequate guidance to ensure events requiring notification to the NRC in accordance with 10 CFR 50.72 are reported. Specifically, the guidance provided for a condition (such as an ATWS), which is classified as a site area emergency, would not be reported if the condition was corrected before making an NRC notification. The weakness was discussed with and will be reviewed by the facility to determine corrective actions, if any, that will be taken to ensure' licensed operators properly report events in accordance with 10 CFR 50.72.

• EOP-1, " Primary System Control", indicates that if pressure is less_than 1435 psig, pressure is to be controlled less than 1385 psig by various means, supplemented by the turbine bypass valve, reactor cleanup and reactor-cleanup blowdown. A caution in the l procedure states "The reactor clean-up; system non-regenerative heat exchanger may not have sufficient capacity to remove decay heat until nearly a week following reactor shutdown. Premature use of the ,

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cleanup system as the sole method of decay heat removal will result in an increase in PCS temperature and pressure."

l During validation of a loss of heat sink scenario, a facility exam team member did not believe the operators would attempt to establish reactor cleanup blowdown due to the caution statement although reactor cleanup was sufficient for decay heat removal as observed on the ,

simulator. The issue was discussed with and will be l 1

reviewed by the facility to determine if 1) a weakness in the training program exists, 2) a procedural weakness exists, or 3) a simulator fidelity problem exists.

• EOP-1, " Primary System Control", directs the operator to enter ONP-2.9, " Multiple Rod Insert Failure", if a reactor scram is achieved by either placing the mode switch to shutdown or opening the RPS undervoltage circuit breakers. EOP-1 should direct the operator to transfer to ONP-2.31, " Reactor Scram", if a reactor scram is successful using either method to scram the reactor. The procedural weakness was discussed with and will be reviewed by the facility for procedure modification consideration.

5. Simulator Observations Simulator discrepancies were identified. These discrepancies are noted in Attachment 3.

6. Exit Meeling A preliminary exit meeting with the facility training department was held at Big Rock Point on December 3, 1992, and a final exit meeting with Big Rock Point plant management was held at the station on December 4, 1992.

Those attending the-meetings are-listed in Section 2 of this report. The following items were discussed during the exit meeting:

• Strengths and weaknesses noted in this report.

• The general observations relating to the plant noted-in section 5.

The preliminary rating of the Big Rock Point requalification training program was presented at the exit meeting. The facility was informed that the results will be documented in this examination report.

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ENCLOSURE 2 REOUALIFICATION PROGRAM EVALUATION REPORT Facility: Big Rock PJint Examiners: Kristine Shembarger, Chief Examiner Melvyn Leach, Examiner Date of Evaluation: December 1-3, 1992 Areas Evaluated: X Written X Oral X Simulator Examination Results:

RO SRO Total Evaluation Pass / Fail Pass / Fail Pass / Fall (S or U)

Written Exam: 811 8/0 16/0 E-Operating Exam Oral all 8/0 16/0 E Simulator all 211 15/2 s Evaluation of facility written examination grading E Crew Examination Results:

Crew 1 Crew 2 Crew 3 P_ ass /Fa_il- Pass /Fai.1 Pass / Fall Operating Examination Pass Pass Pass Crew 4 -Crew 5 Crew 6 E_ ass / Fall Pass / Fail Pass / Fall Fall Pass Pass Overall Procram Evaluation Satisfactory.

Submitted: Forwarded: Approved:

W Gr KS $4,4~ -

Shembarger Jordan _Wrig t 12/7q/92 12/A4/92 12/ /92=

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9 ENCLOSURE 3 SIMULATION FACILITY REPORT Facility: Big Rock Point Docket No. 50-155 Operating Tests Administered On: December 1, 1992 The following documents observations made by the NRC examination team during the December, 1992, requalification examination.

These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of non-compliance with 10 CFR 55.45(b). These observations do not affect NRC certification or approval of the simulation facility other than to provide information which may be used in future evaluations. No licensee action is required in response to these observations.

During the conduct of the simulator portjon of the operating tests, the following items were observed:

ITEM DESCRIPTION Diesel Fire Pump Annunciator "Hi Lo Fire Acc Level" alarmed when " Diesel Fire Pump Trouble" should have alarmed.

Steam and Feed Flow Steam and feed flow indication was Indication too high for the power level.

Feedwater Temperature Feedwater temperature was outside the Indication normal band for the power level.

Domineralized Water Demineralized water storage tank level Storage Tank Level decreased unexpectedly and unnecessarily.

Condensate Storage Condensate storage tank low level i

Tank Level Annunciator annunciator did not alarm when level was below the annunciator setpoint.

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Emergency Condenser Simulator was not modelled to-reflect

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emergency condenser operation if the emergency condenser was placed in

. service from the alternate shutdown building.

Emergency Condenser _ Emergency condenser level indicated low Level at all times.

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