ML20148M432
| ML20148M432 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/29/1988 |
| From: | Moore P, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148M412 | List: |
| References | |
| 50-424-88-07, 50-424-88-7, NUDOCS 8804050371 | |
| Download: ML20148M432 (18) | |
See also: IR 05000424/1988007
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STRE ET, N.W.
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ATLANTA, GEORGl A 30323
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Report No.:
50-424/88-07
Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket No.:
50-424
License No.:
Facility Nare:
Vogtle 1
Inspection Conducted: January 25-29, 1988
)/448
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3 h8
Inspecto
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P. Moore, Team Lead (r '
/Date/ Signed
Team Members:
M. Lewis
R. Schin
Approved by:
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)[9f //[
M. Shymiock, C61ef
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Date Signed
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Operational Programs Section
Division of Reactor Safety
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of
licensed operator *: raining, non-licensed operator training, maintenance
training, and natural circulation ecoldown emergency operating procedures.
Results:
One deviation was identified wherein the licensee deviated from
commitments made in their NRC approved Procedure Generation Package (PGP) in
writing their Emergency Operating Procedures for natural circulation cooldown,
g405037g S80330
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ADOCK 05000424
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R.-Bellamy, Plant Manager
- G. Bockhold, General Manager
- C, Cross, Nuclear Production Supervisor
- W. _ Kitchens, Operations Manager
- G. Lee, Operations Supervisor
- W. Mundy, QA Supervisor
- W. Nicklin, Regulatory Compliance Supervisor
- J. Schwartzwelder, Nuclear Safety Compliance Manager
- D. Smith, Nuclear Operations Manager
- R. Spinnatu, Independent Safety Engineering Group Supervisor
Other licensee employees contacted included engineers, technicians,
operators, mechanics, instructors, and office personnel.
NRC Resident Inspectors
- J.
Rogge
- C. Burger
- R. Schepens
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were sumarized on January 29, 1988,
with those persons indicated in paragraph 1 above.
The inspectors
described the areas inspected and discussed in detail the inspection
findings listed below.
The licensee did not identify as proprietary any
of the materials provided to or reviewed by the inspectors during this
inspection.
No dissenting comments were received from the licensee.
Item Number
Status
Description / Reference Paragraph
424/88-07-01
Open
DEVIATION - Failure to follow Procedure
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Generation Package commicments in writing
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Emergency Operating Procedures fc -
latural
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circulation cooldown (paragraph 10.a.)
424/88-07-02
Open
Inspector Followup Item (IFI) - Required
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reading program inadequacies (paragraph 8.b.)
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424/88-07-03
Open
IFI - Cover use of Technical Specification
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cooldown limits curve in requal training for
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licensed operators (paragraph 10.b.)
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3.
Licensee Action on Previous Enforcement Matters
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This subject was not addressed in the inspection.
4.
Licensed Reactor Operator (RO) and Senior Reactor Operator (SRO) Training
{,
Programs
(41701)
Inspectors evaluated the licensee's R0 and SRO _ training program by
reviewing programs and records, and conducting interviews with operators
and instructors pertaining to the training curriculum, simulator, and
roqualification program,
a.
R0 and SR0 Candidate Training Program
The licensee's R0 training program is described in procedure
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60602-C, Reactor Operator Training Program, Rev. 3, and the SRO
training program in procedure number 60601-C, Senior Reactor
Operator Training Program, Rev. 3.
These procedures cover initial,
specialty, and requalification training for licensed operators.
In
addition to these,
procedure
10010-C, Operator Qualification
J
Program, Rev.
6,
delineates the qualification requirements for
licensed candidates.
.
The inspectors performed a complete review of the records for
initial training for an RO and SRO candidate.
The candidates' NRC
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Form 398, Personnel Qualifications Statement Licensee, was also
reviewed to determine the accuracy of the information contained on
the forms,
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The review of training records for the two licensed operators
indicated that the operators successfully completed all iequired
training in accordance wuh procedures 60601-C and 60602-C.
The
inspectors
also determined that licensed operators met the
qualification and experience requirements delineated in procedure
10010-C.
The information contained on NRC Form 398 accurately
reflects the training provided to the candidates, including the
completion of the required number of reactivity manipulations.
!
Interviews with licensed operators further verified the accuracy of
training records, qualifications of candidates, and information
contained a the NRC Form 393.
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In reviewing walkthrough trainir.g checklists which are signed by
trainees to document completion of independent plant systems and
area walkdowns, the inspectors noted that one R0 had lost more than
half of his training module checklists.
In particular, modules 3,
4, 6, 8, and 9, had been lost.
The n0 obtained new checklists and
indicated on them that the original cards had been lost, and that
the walkthroughs had been completed during the training process.
Credit is taken for the walkthrough training program on the R0's
Form 398 in the area of control room ope.ations.
The inspectors
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discussed the
lost checklists with the
licensee's training
management to determine if the lost checklists were handled in
accordance with department policy.
It was determined that the
licensee had not formulated a policy on measures to be taken when
checklists are lost. The licensee committed to develop a policy in
this area.
,
No violations or deviations were identified in this area.
b.
R0 and SRO Requalification Training
The licensee's R0 and SRO requalification training programs are
described in procedure number 00715-C, License Requalification
Program, Rev.
2.
This procedure provides the criteria for the
content and conduct of the requalification program, including the
conditions of a license as specified in 10 CFR 55.31.
The
inspectors reviewed the licensed operator requalification
program to determine its compliance with 10 CFR 55.
In addition,
the inspectors performed a complete examination of the records for
requalification training for both a licensed R0 and SRO.
Interviews
were conducted with the licensed operators to verify their
participation and completion of the requalifica:1on training program
as documented in the training records.
The inspectors determined that the requalification program as
outlined in procedure 00715-C appeared to be consistent with the
requirements of 10 CFR 55.
In addition, the review of the training
records for the two licensed operators indicated that the records
were complete,
and requalification training was conducted in
accordance with procedures.
The record
review
included
an
examination of classroom and simulator attendance records and
examinations, as well as documentation of on the job training and
procedure reviews.
Interviews with the licensed operators further
verified the accuracy of the requalification training records.
No violations or deviations were identified in this area.
c.
Instructor Training and Qualification Program
.
The training and qualification requirements for instructors involved
in licensed operator training are delineated in procedure 60100-C,
Training Department Traininq and Qualification Procedure, Rev.
6.
This procedure establishe*
^ process for determining and verifying
that individuals meet th
...uctional capability and the technical
qualifications for specific instructor positions.
The inspectors reviewed the qualifications and training records for
two licensed opert ar instructors.
It was determined that the
instructors met t"e selection criteria, qualification, and training
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requirements of the procedure.
Interviews of instructors verified
the accuracy of the training records.
No violations or deviations were identified in this area,
d.
System Master Plans
The licensee has formalized their various training curriculums for
each discipline into documents called System Master Plans (SMPs).
The inspectors reviewed SMPs for Licensed Operator, Non-Licensed
Operator, Mechanical Maintenance,
Electrical
Maintenance,
and
Instrumentation and Control personnel.
The SMPs serve as the central document for each discipline's
training and qualification requirements.
The Licensed Operato- SMP
introduction lists:
the experience requirements for SR0s, R0s and
STAS; the applicant screening tests; the union agreements; and the
basic training course requirements.
The SMP details the training
curriculum outline.
This outline contains an overview section, a
description of the topics covered, general objectivec, student
learning activities, and student evaluation forms.
The curriculums
defined in the SMPs, like the rest of the training programs, are
still being modified to incorporate changes that are being
implemented as a result of Job Task Analysis.
The committee log, which is the last section of the SMP, contains
the meeting minutes wherein the course outlines or curriculum
changes were made, and the reasoning behind them. This should prove
very useful in the implementation of Job Task Analyses, as well as
providing a readily accessible document detailing the history of the
curriculum development.
The inspectors noted that the SMP is well
established and maintained and is responsive to the needs of the
traineo.
e.
Observation of Classroom and Simulator Training
An inspector observed a classroom training session on the Nuclear
Service Cooling Water (NSCW) system for SR0s, and simulator
requalification
training
on
reactor
power
increases.
The
instructors appeared competent in the areas of instruction, and used
question and answer methods ef fectively to keep students alert.
Both classroom and simulator training sessions appeared adequate.
No violations or deviations were identified in this area,
f.
Plant / Simulator Modifications
Procedure 60005-C, Incorporation of Changes in Training Material and
Simulator. Rev.
3,
describes the program for incorporating plant
design changes into training programs and the simulator.
This
procedure requires that the Document Review Coordinator review all
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plant design changes, enter action items in a computer tracking
system called Training Response to Analyzed Significant Events
(TRASE), and disseminate the TRASE forms to appropriate training and
simulator supervisors.
Upon receipt of the TRASE forms, the
training supervisor assigns an instructor to determine the training
materials that may need revisions, and then assigns an individual to
implement corrections to af fected training ma;.3 rials.
Corrective
measures are documented on a corrective action assignment sheet.
Similarly, proposed changes to the simulator are documented on
Simulator Change Notices (SCN) consistent with procedure 60200-C,
Simulator Maintenance Procedures, Rev. 1.
The inspectors reviewed two plant design modification to determine
if appropriate simulator and lesson plan changes were implemented in
accordance with the training procedures.
These plant modifications
included
change
control
packages
(CCP)
B10130M
approved
September 22, 1986, and CCP B102345 apprnved June 26, 1986.
The
former CCP contained logic and time delay setpoint changes, and
valve midpoint open settings for the Nuclear Service Cooling Water
(NSCW) normal and bypass valves.
The latter CCP removed installed
instrumentation on the Boron Injection Tank (BIT) recirculation
system.
SCN 297 dated May 27, 1987, documents the simulator changes made as a
result of NSCW system change control package.
In addition, lesson
plan LO-LP-06101-04-C, Nuclear Service Cooling Water, Rev.
4,
providos training information related to the NSCW normal and bypass
valves.
The inspectors reviewed SCN 297 and lesson plan LO-LP-06101-04-C to
determine if the appropriate changes had been made. Walkdowns of
the simulator panels were also conducted to verify, to the extent
possible,
that
the
modifications were made.
The simulator
modifications and lesson plan changes appeared adequate and
complete.
SCNs 183 and 266, dated March 4,
1986, and January 12, 1987,
respectively, document simulator changes made as a result of the BIT
recirculation system CCP.
The following lesson plans and student
handout contain information pertaining to the BIT recirculation
system:
LO-LP-13001-01-C, ECCS Overview / Introduction, Rev. 2;
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LO-LP-13101-02, ECCS - Part II, Rev. 2;
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LO-LP-13301-00, Low Head SI and ECCS Recirc, Rev. 0;
LO-LP-09202-01, CVCS - Alternate Flowpaths, Rev. 1;
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LO-H0-13001-00-002, Emergency Core Cooling Overview, Rev. O.
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The inspectors reviewed the above listed simulator change notices,
lesson plans, ahd student handouts for the BIT recirculation system.
Walkdowns of the simulator panels were conducted to verify that the
appropriate modifications were made.
The simulator modifications
were adequately completed. However, several of the lesson plans and
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a student handout relating to the BIT recirculation system had not
been completely revised.
In particular, drawings located in lesson
plans LO-LP-13101-02 and LO-LP-13301-00, and in student handout
LO-H0-13001-00-002 were not appropriately revised to reflect the
proper valve positions in the BIT recirculation system CCP.
The inspectors discussed these drawing discrepancies with the
?icensee, and determined that the oversight was due to an incomplete
review of the lesson plans by the responsible individual.
A
training
feedback
form,
identifying
the
incorrect
training
materials, was immediately issued and the lesson plans and student
handouts were revised,
No violations or deviations were identified in this area,
g.
Status of Simulator
The status of outstanding simulator deficiency reports (DRs) was
discussed with individuals responsible for simulator modifications,
and with the training management.
The training management remains
cognizant of the outstanding simulator DRs, and provided the
inspectors with a list identifying each outstanding DR and a graph
trending the number of opened and closed DRs.
In reviewing this
data, the inspectors noted that the licensee prioritizes completion
of simulator modifications into three categories.
Category 1 is
emergency ors, category 2 is non-emergency ors, and category 3 is
testing / upgrades. The data indicated that the licensee has about 65
outstanding workable DRs with no outstanding category 1 items.
A
decrease in the number of DRs was noted.
No violations or deviations were identified in this area.
6.
Non-Licensed Operator Training (41400)
Inspectors performed a review of the licensee's non-licensed operator
training program.
Areas included in the review were curriculum, training
records, employee interviews, instructor interviews, and exam content.
Non-licensed operators at Vogtle ara called Plant Equipment Operators
(PEOs).
There are four PE0s per unit, per shift: Turbine Building
Operator; Auxiliary Building Operator; Outside Area Operator; and Rover.
a.
Training Program
The inspectors reviewed the following procedures pertaining to the
training of PE03:
10010-C, Operator Qualification Program, Rev. 6;
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11957-C, Basic Non-Licensed Operator Training Qualification
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Checklist, Rev.1;
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11958-C, Auxilia ry Building Operator Training Qualification
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Checklist, Rev. 2;
11959-C, Turbine Building Operator Training Qualification
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Checklist, Rev. 2;
11960-C,
Outside
Area
Operator
Training
Qualification
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Checklist, Rev. 2;
60605-C, Non-Licensed Operator Training Program, Rev. 2.
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Candidates for the non-licensed operator training program are
selected through an Edison Electric Institute Plant Operator
Selection Series Exam.
Selected personnel attend a Basic ten-week
course to ensure familiarity with nuclear prwer plant components and
general operational theory.
Following the ten week basic course, the pE0s must complete basic
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Non-Licensed Operator cluster Requirements per procedure 11957-C.
A
cluster is defined as "a unique and distinct operator responsibility
area which is made up cf those knowledges and/or skills necessary
for an operator to master, to enable him to perform important tasks
in that area." The basic requirements include those area considered
necessary to perform the PE0's basic duties. Af ter completion of
the basic clusters, he PE0 is then required to complete those
cluster associated with the specific area in which they will be
working (i.e. Auxiliary, Turbine, etc...).
The inspectors reviewed lesson plans for Reactor Theory, Electrical
Distribution, Heat Transfer, and PWR Systems. The 1"sson plans were
comprehensive in their coverage of the topics.
No violations or deviations were identified in this area,
b.
Requalification Training
Requalification training for PEOs is limited to "annual training or
exemption testing to ensure adequate awareness of important changes
to plant emergency procedures, radiation protection procedures,
security procedures, and respirator procedures."
The inspectors
review of the requalification training program indicated that it met
all applicable regulatory guidance but was somewhat basic in light
of recent industry trends toward a more comprehensive program.
Some utilities have implemented more extensive requalification
training that includes review of the initial topics taught:
Systems;
Reactor Theory,
Thermodynamics etc. . . as well
as
participation in simulator training.
No violations or deviations were identified in this area,
c.
Training Records
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The inspectors reviewed the training records of four PE0s.
This
included classroom attendance records, examination scores and
examination content, as well as consistency with established lesson
plans.
This was made difficult by the fact that the licensee has
made major improvements over the past two years to their training
programs. Some of these changes consolidated or broke up a training
cluster.
The inspectors did not detect any instances where the
program under whir.h an individual PE0 did not meet the requirements
of the program that was established at the time of their respective
training.
All of the selected individuals met the criteria for
passing their courses.
Inspectors reviewed selected plant LERs that were attributed to
operator error on the part of PE0s.
None of the individuals'
records that were selected based upon personal involvement in plant
events exhibited training deficiencies in the area where the
operational events occurred.
No violations or deviations were identified in this area.
d.
Instructor /PE0 Interviews
The inspectors interviewed a non-licensed operator instructor to
evaluate the quality of the entry level personnel as well as the
improvements made to the program over the past two years.
The
instructor was very positive about the present state of the program
and the direction in which it was headed.
The instructor related
that with the implementation of Job Task Analysis, the paperwork
load for instructors was very heavy at times, but this was expected
with the developmental status of the program at present. Every six
months, instructors are required to spend one week on shif t in the
plant performing tasks and duties with PE0's. The instructor felt
that this was a good practice in that it fostered a better rapport
with the students.
Overall the instructor, who had been at the
plant for more than three years, expressed satisf action with the
training program.
Two PEOs were interviewed on their impressions of the training
program and its relevancy to the tasks that they perform in the
plant.
They considered the instructors to be competent and well
qualified.
Neither of them responded in such a manner as to
indicate problems with the training program.
No violations or deviations were identified in this area.
7.
Maintenance Training (41400)
The inspectors reviewed the programs established for the training of
Mechanical Maintenance, Electrical Maintenance, and Instrumentation and
I
Control.
This
included
interviews
with
selected
personnel
and
instructors, review of classroom attendance records and exam performance
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for selected personnel, and a review of the curriculum requirements and
waiver policy,
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a.
Training Program
The inspectors reviewed the following procedures regarding the
training program for maintenance technicians:
20011-C,
Electrical
Maintenance
Personnel
Training
and
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Qualification, Rev, 6;
60606-C, Electrical Maintenance Training Program, Rev. 2;
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20013-C, Instrument and Control Maintenance Personnel Training
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and Qualification, Rev. 4;
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60608-C, In%rument and Controls Maintenance Training Program,
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Rev. 2;
20012-C,
Mechanical
Maintenance
Personnel
Training
and
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Qualification, Rev. 4;
60607-C, Mechanical Maintenance Training Program, Rev. 2;
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00709-C, Training Review Boards and Working Committees, Rev. 2.
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The training program is divided into three major areas:
Initial
Training, Basic Qualification Training, and Specialty Training.
Initial training consists of General Employee Training and the basic
courses necessary for the trainee to "possess the fundamental skills
and knowledge required to safely perform maintenance at tne plant."
Qualification Training is designed "to supplement Initial Training
,
and . . . to increase the students ability to perform specific job
tasks."
Specialty Training is given to a limited number of
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technicians to enable them to perform more specialized tasks.
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The inspectors review of the curriculum for the training program
indicated that it satisfactorily provided for a complete and
comprehensive maintenance training program.
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The inspectors reviewed the licensee's policy for granting waivers
from required training courses.
The policy is contained in
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procedure 00709-C referenced above and delineates the following two
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crit =ria for waivers:
a.
A previous course of instruction must have been completed which
contained the same topics and was at least the duration of the
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course being waived.
The course must have been completed
within the last three years;
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b.
The trainee completed an exam which is equivalent to a course
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comprehensive final exam. The exam may be written or oral and
must be retained as a record of satisfactory course completion.
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No violations or deviations were identified in this area.
b.
Training Records
Improvements made to the maintenance training program over the past
few years have created a situation where maintenance personnel had
qualified under seemingly different programs.
The training records
of individuals selected from all three maintenance departments were
reviewed for consistency with the training programs under which they
qualified.
In each case, the personnel met the requirements that
were in place at the time they qualified.
This review of training
records did not reveal any inconsistencies between personnel
qualifying at different times under the same discipline.
A revie., of maintenance personnel class attendance records exhibited
no instances where individuals had received credit for a class they
had not attended.
Exam content accurately reflected the course
material being taught.
No violations or deviations were ider.cified in this area,
c.
Classroom Observations
The inspectors observed classroom training on pH measurement for I&C
personnel.
The course material was well presented although the math
aspects appeared to be overemphasized in regards to the abilities of
the trainees. The instructor used his fingers instead of a pointer
on the overhead projector.
The nature of the material did not
require a pointer, however, a pointer is always preferable.
The
instructor answered all questions and made sure that the students
understood the material before proceeding on.
The inspectors toured the licensee's mockup laboratories for
Mechanical, Electrical, and I&C maintenance.
The labs reflected
recent industry-wide commitments to improve training through the use
of mock-ups.
Instructors and trainees alike expressed the view that
the use of mockups greatly enhanced the quality of training as well
as the degree of preparation for performing job tasks in the plant.
No violations or deviations were identified in this area,
d.
Technician / Instructor Interviews
Technicians were selected for interviews in order to get a wide
range of experience and qualification levels for feedback on the
effectiveness of the training program.
All of those interviewed
expressed satisf action in that the program adequately prepared them
for the job tasks they had to perform.
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Interviews with the instructors revealed that again, the paperwork
at times was more extensive than their preparation for their
classes, but they understood that this was a part of the continuing
improvement of the training program and should abate as the program
became more established.
Overall, the maintenance training program was determined to be
satisfactorily fulfilling its objectives and meeting the applicable
regulatory requirements.
No violations or deviations were identified in this area.
8.
Operational Exnaricace Feedback
The inspectors reviewed the licensee's operational experience feldback
program to assess how well the licensee had implemented the requirements
of NUREG 0737, item I.C.S.
The inspectors reviewed the following procedures relating to the
licensee's operational experience feedback program:
00414-C, Operating Experience Program, Rev. 4;
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10017-C, Operations Reading Books, Rev. 2;
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20025-C, Maintenance Experience Assessment Report, Rev. 2;
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60005-C, Incorporation of Changes in Training Material and
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Simulator, Rev. 3,
and the following instruction:
N01-3-330, Operating Experience Program, dated June 26, 1987,
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a.
Training Response to Analyzed Significant Events (TRASE)
The inspectors selected several pertinent IE Notices from the past
five years as well as several recent LERs generated by the licensee
in the past year to assess their incorporation into the training
program.
TRASE is a computerized tracking system used within the training
department to track action items.
The Document Review Coordinator
(DRC) is responsible for the initial review of action items,
feedback form and change material from Regulatory Compliance, and
the subsequent generation of TRASE forms and its implementation into
the TRASE tracking system.
The DRC reviews the following material:
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Vogtle Plant and industry LERs;
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NRC
Investigation
and
Enforcement
Bulletins,
Notices,
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Circulars, NUREGs, and Generic letters;
Temporary and permanent changes to plant procedure;
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Design changes;
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Training feedback forms.
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The DRC is responsible for rendering judgement on the importance of
the material with respect to training.
The DRC decides if the
material
is pertinent to E0Ps; Emergcncy Plan Implementation
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Procedures; Operations,
Plant, or HP and Chemistry training;
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Simulator Modifications; or if it could be covered in a reading
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assignment package. The DRC then fills out a TRASE form with the
identity of the package, the type of information contained therein,
and the supervisor routing, along with comments concerning the
attached information,
If no action is required, the DRC will
complete a Change Material Review Form and the data will not be
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entered into the TRASE system.
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The Training Center Clerk records the initial response and analy is
due dates on the TRASE form and logs them into the computer. hie
supervisors (training and simulator) then review the information and
make initial recommendations.
The training center clerk logs these
recommendations and assigns an analysis due date - this is the date
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that the supervisor has to return the training recommendations to
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the training center clerk.
The
supervisor then assigns an
instructor to do an in-depth analysis to develop a plan of action.
A Corrective Action Assignment Sheet is generated delineating the
,
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implementation of the material into the trainir.3 course as well as
all training materials (by identification number) affected by the
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information.
i
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The inspectors performed a walk-through of the TRASE system with the
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DRC.
The inspectors chose IE Notices, IE Bulletins, and recent
'
plant LERs to assess the programs expediency in reviewing and
i
implementing operational experience. The DRC was able to document
the
requested
information with
either an
evaluation which
'
dispositioned the item or a lesson plan that had incorporated it.
Recent LERs and IE Notices were reviewed to gain a dynamic
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perspective of the program in process.
The program appeared
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satisfactory in regards to the incorporation of operating experience
into the training programs.
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No violations or deviations were identified in this area,
f
b.
Required Reading Program
.
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The inspectors assessed the required reading program for the
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Operations Department.
Procedure 10017-C, Operations Reading Books,
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,
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Rev. 2 was reviewed.
Also, an inspection of selected completed
required reading routing sheets was conducted.
The following
licensee commitments in this area were reviewed:
the FSAR, page
13.5.1-2;
paragraph C;
Procedure for Feedback of Operating
Experience, Amendment 29; and NUREG-0737, page 3-47
Paragr%h
I.C.5,
Procedures for Feedback of Operating Experience to Plant
Staff.
'
An inspection of seven completed required reading routi g sheets,
which routed a total of 44 LERs and Informaticn Notices, was
performed. This inspection revealed a situation where severtl (mo're
than ten) licensed operators had not signed for reading materid
that had been routed to them as long as seven months ago.
This
material was safety significant and included several of the
licensee's own LERs. Also, many of these same 1%nsed operatort
(at least six) had stood operating watches reg 41arly dUring the past
seven months.
Every item of required rearling fe which routir.g
completion was checked revealed one or mon licens#'i olarators and
a number of non-licensed operators, who
h'.d tafled ec incicate
reading of the material.
The safety significance of this required reading is thtt it
functions to provide a means to assur
'at 2f t<cted personnel
become aware of important operatir.g Caf;ormation in a Omely Manner,
This requirement is delineated ir. NUREG 0727, wd:h the licensee has
committed to in the FSAR.
~
!
The licensee's procedure titled ]>et ations Reading looks stctss that
I
the objective of using the Operations Required Reading 8co'
(ORR9)
is to disseminate current important operating irfor.rasion ba
timely concise manner to licensed and non-Pcensed operatles, to
ensure safe and reliable plant operaf.on.
'
The Operations Reading Books procedure states that:
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(1) Licensed operators should read the ORRB material witHr. seven
1
days of the time it is placed in the ORRB.
(2) The Senior Clerk will review the ORRB every two wee n. identity
3
individuals who are delinquent, and send them ORRB Reading
Reminder Notices.
'
(3)
For sign-off sheets more than four weeks overdue, the Senior
Clerk will send a memo to the Operations Superintendant
notifying him of the delinquent readers.
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The Senior Clerk stated that, each time a Required Reading Notice or
memo to the Operations Superintendent was sent, a cbchart was
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placed next to the delinquent name on the routing sheet.
Follon'ng
that procedure, names that were delinquent by more than fcur weeks
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should have had two or three checkmarks.
A review of the seven
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completed routing sheets (all over four months old) revealed that ,
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next to the licensed operator names who had not signed: many had no
checkmarks; many nad one checkmark; many had two checkmarks; and a
few had three checkmarks.
The licensee indicated to the inspectors that all licensed operators
who were delinquent in required reading would be promptly brought up
to date.
The requirements related to required reading in the FSAR and
NUREG-0737 apply to non-licensed operators as well as licensed
operators. While non-licensed operators are included on the ORRB
routing sheets, many of them have not signed the seven completed
routings that were reviewed,
hrther, the "Operations Reading
Books" procedure does not address requirements, for non-licensed
operators to read the ORRB.
The licensee has not assured that
non-licensed operators have received safety significant required
reading.
All of the above deficiencies constitute an apparent violation.
However, the licensee showed the inspectors that the weakness in the
Operations Department requi' jd reading program had recently been
identified (January 1988) by them, and that corrective actions were
intended.
In view of the NRC position in encouraging licensee
self-identification and correction of problems (10 CFR Part 2,
Appendix C,Section V), a violation will not be cited.
NUREG 0737 includes requirements for other departments, such as
maintenance, health physics, and training, to also have programs for
assuring that important information is reviewed by affected
personnel in a timely manner.
Employee interviews indicated that
some of these departmental required reading programs may not include
departmental procedures, routing of information, or the actual
reading of routed material.
The licensee made a commitment to the
inspectors to conduct a QA department audit of the required reading
program of all departments. This audit should include comparison of
written procedures against commitments ( FS AR , NUREG 0737) ar
a
j
check that the required reading was being routed and read in a
i
timely manner,
1
Required reading program deficiencies will be inspector followup
item 424/88-07-02.
This followup will include a review of the
following:
1)
The "Operations Reading Book?
orcredure has requirements
d
incluoed for non-licensed ope,rators to read the ORRB.
.
2)
All licensed and non-licensed Operators are reading the
required reading.
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3)
'he GA department audit of the required reading programs
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of kil ci?pa r tme n t <- has been completed and inadequacies
.
'
iourd by that ausit are being corrected.
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A violation was not cited and no deviations were identified in this
area.
9.
Institute of Nuclear Power Operations (INPO) Accreditation
The licensee submitted the training programs for Health Physics and
Chemistry to
INPO in January 1987 for review and accreditation.
The
training programs for SRO, R0, NLO, and STA were submitted in July 1987.
The maintenance and technical staff training programs were submitted in
January 1988.
INPO performed an on-site audit of the submitted programs
in
November 1987.
The INPO board will
be meeting in May 1988 for
accreditation of the above programs. The licensee expects all to go well
,
with the accreditation board. The inspectors reviewed with the licensee
the open items from the INP0 inspection in November 1987.
None of the
items indicated regulatory concerns or significant deficiencies in the
program.
No violations or deviations were identified in this area.
10.
Natural Circulation Cooldown (25586)
Inspectors evaluated the licensee's Emergency Operating Procedures (EOPs)
for performing Natural Circulation Cooldown in accordance with Temporary
'
Instruction 2515/86.
a.
Procedures
The inspectors reviewed the following E0Ps for natural circulation
cooldown:
19002-C, ES-0.2 Natural Circulation Cooldown, Rev. 3;
-
19003-1, ES-0.3 Natural Circulation Cooldown with Steam Void in
-
Vessel (With RVLIS), Rev. 2;
19004-1, ES-0.4 Natural Circulation Cooldown with Steam Void in
-
Vessel (Without RVLIS), Rev. 2.
The licensee has an NRC approved Procedure Generation Package (PGP).
In that PGP, the licensee has committed to write E0Ps that
incorporate the Westinghouse Owners Group (WOG) Emergency Response
Guidelines (ERG), Rev. 1.
The inspectors compared the licensee's
three natural circulation cooldown E0Ps to the WOG ERG, Rev. I and
found that the licensee's procedures follow the ERG very closely.
Plant specific setpoints and equipment appeared to be properly
incorporated into these E0Ps.
The three E0Ps appeared to contain all of the prevention ana
mitigation measures for reactor vessel head bubble as set forth in
These reasures include the use of core exit
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16
thermocouples for monitoring vessel head temperatures, checks for
unexpected large variations in pressurizer level, instructions on
the mitigation of void formation, and limits on cooldown rate and
subcooling margin.
The PGP requires licensee justification of all steps in the E0Ps,
including justification of any difference from the ERG.
The
inspectors reviewed the licensee's E0P Step Documents for these
three E0Ps.
The E0P Step Documents appeared to be complete and to
satisfy the PGP requirements.
The PGP also includes requirements for verification and validation
of E0Ps.
The licensee's documents indicated that those requirements
were satisfied for the three natural circulation cooldown E0Ps.
During the review of these three E0Ps, the inspectors did find one
feature that was not sufficiently clear.
Each of these E0Ps direct
the operator to maintain reactor coolant system (RCS) temperature
and pressure within the limits of Technical Specification 3.4.9.1
Figure 3.4-3 (cooldown limitations curve).
But Figure 3.4-3 is not
labelled as to which temperature instruments should be used for
comparison to the curve, nor does this information appear in the
E0Ps.
Four licensed operators (3 SR0s and 1 RO) were shown Figure
3.4-3 and asked what temperature instruments they would use to
comply with it as required by these E0Ps. Two stated they would use
T hot or core exit thermocouples, one said T cold or T average, and
one didn't know.
The licensee demonstrated to the inspectors how these E0Ps would
have led the operator to the needed information:
(1) The E0Ps direct the operator to "perform other actions required
to take the unit to cold shutdown by initiating 12006, Unit
Shutdown to Ambient."
(2) On page 12 of procedure .1.2006, the operator is directed to
"commence RCS/ Pressurizer pressure and temperature trending at
30 minute intervals using Data Sheet 1 and Emergency Response
Facility computer (Technical Specification 4.4.9.1)."
(3) Technical Specification 4.4.9.1 refers to the cooldown limits
curve, figure 3.4-3.
(4) Data Sheet 1 of procedure 12006 specifies recording of RCS
temperature by using the lowest channel of T cold it.:lication.
While the procedures could have led the operator to the needed
information, the inspectors found the path difficult to follow and
not suitable for emergency procedures.
The licensee's PGP includes a writers guide for E0Ps, which has
requirements on level of detail:
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17
(1) Details should be given for operators with the minimum expected
skill level and experience.
(2) The operator should have all of the information required for
the task available to him.
The PGP writers guide also has requirements on printed operator
aids, including graphs:
(1) Printed aids must be self-explanatory and legible.
The lack of adequate direction on the use of the cooldown
limitations curve, in all three of the natural circulation cooldown
E0Ps, is a deviation 424/88-07-01.
One deviation and no violations were identified in this area.
b.
Training
The inspectors interviewed three licensed operators, reviewed their
training records, and reviewed lesse* plans.
Adequate training in
natural circulation cooldown, incloo..ig classroom and simulator was
verified.
The training program did include a review of the
St. Lucie event,
and a review of temperature difference in
differents areas of the reactor coolant system during natural
circulation.
Simulator
training
included
natural
circulation
cooldown operations with a void in the reactor vessel.
A commitment was made by the licensee to cover the use of the
Technical Specification cooldown limits curve (including temperature
and pressure instruments to be used) in requalification training for
licensed operators.
This is inspector followup item 424/88-07-03.
No violations or deviations were identified in this area.