ML20148M432

Insp Rept 50-424/88-07 on 880125-29.Deviation Noted.Major Areas Inspected:Licensed Operator Training & Emergency Operating Procedures

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: ML20148M432
References
50-424-88-07, 50-424-88-7, NUDOCS 8804050371
Download: ML20148M432 (18)

See also: IR 05000424/1988007

Text

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, -' p (fop UNITED STATES

/j g'o NUCLEAR REGULATORY COMMISSION

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[$ p. REGION il

5 _, j- 101 MARIETTA STRE ET, N.W.

• '- r' 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.: NPF-68

Facility Nare: Vogtle 1

Inspection Conducted: January 25-29, 1988

Inspecto m? ~ )/448 , 3 3 h8

P. Moore, Team Lead (r ' /Date/ Signed

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Team Members: M. Lewis

R. Schin

Approved by: bM ~

M. Shymiock, C61ef

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Date Signed

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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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

Generation Package commicments in writing

Emergency Operating Procedures fc - latural

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i circulation cooldown (paragraph 10.a.)

424/88-07-02 Open Inspector Followup Item (IFI) - Required

! reading program inadequacies (paragraph 8.b.)

! 424/88-07-03 Open IFI - Cover use of Technical Specification

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cooldown limits curve in requal training for

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

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initial training for an RO and SRO candidate. The candidates' NRC

! Form 398, Personnel Qualifications Statement Licensee, was also

reviewed to determine the accuracy of the information contained on

the forms,

i 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.

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Interviews with licensed operators further verified the accuracy of

training records, qualifications of candidates, and information

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contained a the NRC Form 393.

l 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

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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

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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:

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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;

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LO-LP-09202-01, CVCS - Alternate Flowpaths, Rev. 1;

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LO-H0-13001-00-002, Emergency Core Cooling Overview, Rev. O.

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:

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10010-C, Operator Qualification Program, Rev. 6;

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11957-C, Basic Non-Licensed Operator Training Qualification

Checklist, Rev.1;

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11958-C, Auxilia ry Building Operator Training Qualification

Checklist, Rev. 2;

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11959-C, Turbine Building Operator Training Qualification

Checklist, Rev. 2;

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11960-C, Outside Area Operator Training Qualification

Checklist, Rev. 2;

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60605-C, Non-Licensed Operator Training Program, Rev. 2.

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 '

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

I Mechanical Maintenance, Electrical Maintenance, and Instrumentation and

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:

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20011-C, Electrical Maintenance Personnel Training and

Qualification, Rev, 6;

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60606-C, Electrical Maintenance Training Program, Rev. 2;

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20013-C, Instrument and Control Maintenance Personnel Training

and Qualification, Rev. 4; ,

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60608-C, In%rument and Controls Maintenance Training Program,

Rev. 2;

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20012-C, Mechanical Maintenance Personnel Training and

Qualification, Rev. 4;

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- 60607-C, Mechanical Maintenance Training Program, Rev. 2;

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00709-C, Training Review Boards and Working Committees, Rev. 2.

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."

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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 i

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 .

procedure 00709-C referenced above and delineates the following two l

crit =ria for waivers:

a. A previous course of instruction must have been completed which

i contained the same topics and was at least the duration of the

course being waived. The course must have been completed  ;

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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:

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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

Simulator, Rev. 3,

and the following instruction:

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N01-3-330, Operating Experience Program, dated June 26, 1987,

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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INP0 SERs, SOERs, CM&Rs;

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Vogtle Plant and industry LERs;

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NRC Investigation and Enforcement Bulletins, Notices,

Circulars, NUREGs, and Generic letters;

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Temporary and permanent changes to plant procedure;

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Design changes;

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Training feedback forms.

The DRC is responsible for rendering judgement on the importance of

the material with respect to training. The DRC decides if the

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material is pertinent to E0Ps; Emergcncy Plan Implementation

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Procedures; Operations, Plant, or HP and Chemistry training;

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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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

i recommendations and assigns an analysis due date - this is the date

that the supervisor has to return the training recommendations to

i the training center clerk. The supervisor then assigns an

instructor to do an in-depth analysis to develop a plan of action.

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A Corrective Action Assignment Sheet is generated delineating the

j implementation of the material into the trainir.3 course as well as

i all training materials (by identification number) affected by the

information.

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! The inspectors performed a walk-through of the TRASE system with the

j DRC. The inspectors chose IE Notices, IE Bulletins, and recent

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plant LERs to assess the programs expediency in reviewing and

i implementing operational experience. The DRC was able to document

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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

j 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,

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b. Required Reading Program

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The inspectors assessed the required reading program for the

j Operations Department. Procedure 10017-C, Operations Reading Books,

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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.

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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:  !

1 (1) Licensed operators should read the ORRB material witHr. seven

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.

<

The Senior Clerk stated that, each time a Required Reading Notice or

memo to the Operations Superintendent was sent, a cbchart was i

placed next to the delinquent name on the routing sheet. Follon'ng ;

that procedure, names that were delinquent by more than fcur weeks l

should have had two or three checkmarks. A review of the seven '

completed routing sheets (all over four months old) revealed that ,

,

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.

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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? d orcredure has requirements

. incluoed for non-licensed ope,rators to read the ORRB.

2) All licensed and non-licensed Operators are reading the

! required reading.

3) 'he GA department audit of the required reading programs  !

of kil ci?pa r tme n t <- has been completed and inadequacies .

'

iourd by that ausit are being corrected.

l

)

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

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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

the WOG ERG. These reasures include the use of core exit

i

w- ,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

..

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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.