ML20148T986
| ML20148T986 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/20/1988 |
| From: | Moore P, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148T757 | List: |
| References | |
| 50-338-87-39, 50-339-87-39, NUDOCS 8802030434 | |
| Download: ML20148T986 (18) | |
See also: IR 05000338/1987039
Text
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So oro ullTED STQ7ES
o WUCLEAR REGULATORY COMMISSION
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g, . j 101 MARIETT A STREET, N.W.
- *c ATLANTA, GEORGI A 30323
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.....
Report Nos.: 50-338/87-39 and 50-339/87-39
Licensee: Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7
Facility Name: North Anna 1 and 2
Inspection Conducted: October 16-20, 1987
Inspectop $ k
P: Mocre, Tea'm Leader (
Edgd j3/1 ~
fate /S'igned
Team Members: C. Rapp
R. Schin
L. Watson
Approved by: 7
M. Snymiock, Chief /
M4 Iv f 20 %
Date Signed
Operational Programs Section
Division of Reactor Safety
SUMMARY
Scope: This routine, unanncunced inspection was conducted in the areas of
licensed operator and non-licensed operator training anJ requalification
training as well as maintenance training, and natural circulation cooldown
procedure implementation.
Results: One violation was identified in which the licensee's Emergency
Operating Procedures for natural circulation cooldown contained cooldown curves
that exceeded those specified in Figure 3.4.3 of Technical Specifications. One
deviation was identified wherein the licensee's procedures for natural
circulation cooldown and related Step Deviation Document did not follow the
guidance committed to in their Procedure Generation Package for Emergency
Operating Procedures.
8802030434 080127
PDR ADOCK 05000338 ,
o PDR
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- L. Edmonds, Superintendent, Nuclear Training
"R. Enfinger, Superintendent, Operations
+T. Harding, Licensing Staff Engineer
- E. Harrell, Station Manager
- T. Johnson, Supervisor, Quality Assurance
- G. Kane, Assistant Station Manager
- J. Leberstien, Licensing Engineer
+0. VandeWalle, Licensing Supervisor
Other licensee employees contacted included engineers, technicians,
operators, mechanics, and office personnel.
NRC Resident Inspectors
- J. Caldwell
- Attended exit interview
+ Participated in subsequent telecons
2. Exit Interview
The inspection scope and findings were summarized at an exit meeting o;.
November 20, 1987, and in subsequent phone calls through December 23,
1987, with those persons indicated in paragraph 1 above. The inspector
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 Paragr(gh
338,339/87-39-01 Open Violation -
Inadequate Emergency
Operating Procedures for natural
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circulation cooldown: cooldown curves
exceed those in the Technical
Specifications (paragraph 9.a).
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338,339/87-39-02 Open Deviation - Failure to follow Procedure i
Generation Package commitments in
acnerating Emergency Operating
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procedures for natural circulation
cooldown (paragraph 9.a)
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338,339/87-39-03 Open IFI -
Licensee commitment to review
incorrect exam questions with licensed
operators to assure that they
understand correct answers (paragraph
6.c).
338,339/87-39-04 Open IFI - Simulator cannot perform Mode 5
or 6 operation (paragraph 6.f).
338,339/87-39-05 Open IFI - Superseded procedures in use at
simulator (paragraph 6.f).
338,339/87-39-06 Open IFI - 3ecurity of assembled exams at
word processor (paragraph 6.g).
338,339/87-39-07 Open IFI - Training in clearance and tagging
for non-licensed operators with prior
experience (paragraph 7.a).
338,339/87-39-08 Open IFI - Training in natural circulation
cooldown (paragraph 9.b).
3. Licensee Action on Previous Enforcement Matters
This subject wa'; not addressed in the inspection.
4. Gereral Comments
a. Training
In the training area, substantial improvements were observed.
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Systematic, task-oriented training had been implemented for those
, programs reviewed. Management involvement in program planning and
implementation was evident and well-defined in procedures. Training
materials were detailed and student contact hours were well above
minimum requirements.
The training facilities were noteworthy; including the mockups for
general employee training and the mockups for maintenance training.
The training department staff were competent, appeared to have good
morale, and were very helpful in the conduct of this inspection.
Also, comments received from students about the current quality of
training were generally very positive.
The licensee indicated that INPO accreditation had been achieved for
the following programs: Rev.ctor Operator Licerse Course, Licensed
Operator Requalification Program, Senior Reactor Operator License
Course, Non-Licensed Operator Course, Electrical Technician,
' Mechanical Technician, Health Physics, Technical Staf f and Manager
Training, Chemistry, and Instrument Technician,
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4 b. Natural Circulation Cooldown j
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In the natural circulation cooldown procedures, some concerns were
identified. In an NRC approved Procedures Generation Package (PGP),
the licensee has committed to implement the Westinghouse Owners Group ,
. Emergency Response Guidelines (ERGS), Rev.1, in their Emergency ;
Operating Procedures (EOPs). Also, the PGP includes commitments on
identifying, j usti fying , and documenting any procedural step i
deviations from the ERG. The NRC considers the E0Ps to have direct i
safety significance. Accordingly, the NRC has reviewed for safety !
- and approved the ERGS, including the methodology used for setpoint L
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! calculations contained in the ERGS. Use of a setpoint that is
i different from one specified in the ERG constitutes a significant i
Uep deviation, which the licensee has committed to justify. During (
! this inspection, concerns arose in the area of step deviations - [
l specifically wi+h 'the licensee's identification, justification, and :
! documentation t them. One violation and one deviation were cited in [
l the area of natural circulation ecoldown E0Ps. PGP commitments will 1
- be reviewed in a subsequent NRC inspection of all Emergency Operating i
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Procedures. [
h 5. Corporate Oversight
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The structure of the training program appeared to be well defined. The i
licensee utilized the Nuclear Operations Department Standards Manual to '
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set forth the corporate standards and policies for the licensee's training
programs. The corporate organization responsible for training is Power ,
j Training Services (PTS). The program manual for PTS, the Training Systems t
Manual (September 1987 revision), was reviewed by an inspector. This !
manual provides guidance and direction for the development, implementation j
j and evaluation of training programs based on a systematic approach to t
training. The PTS also issues program guides for individual training i
i programs. The inspectors reviewed various program guides during the j
l inspection as documented in this report. These program guides appeared to !
l. comprehensively address each training area. In addition, the PTS had an :
- Organizational Manual which described the responsibilities of managers in
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the organization.
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The North Anna Training Department (NATO) reports to PTS. The NATO has a !
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- set of Training Administrative Guidelines to provide detailed direction at j
i the site level on administration of the training programs. *
The licensee has corporate staff dedicated to the evaluation of the
i training program. The inspector reviewed the program and conducted l
! interviews with responsible personnel. The program states the :
following goals for ensuring that the training program is adequate: l
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Training materials cover the occupational skills and knowledge i
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Training occurs as specified in the program guide;
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Trainees demonstrate mastery of occupational skills and
knowledge at the end of training; ,
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Trainees demonstrate competency in occupational knowledge and
skill on-the-job;
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The demonstrated occupational knowledge and skills support
effective power station operation.
The program includes evaluation indicators and criteria for determining
the adequacy of each area. A schedule is maintained that evaluates each
area on a monthly, quarterly, semi-annual, or annual basis. A discrepancy
report is written when an indicator does not meet its acceptable level.
This discrepancy report requires the person responsible for the indicator
to sign and attach an action plan if necessary. Management is then
required to review the discrepancy report and sign off. The inspector
found the program evaluation to be complete and comprehensive.
The inspector discussed the Operational Experience Report (GER) program
with the corporate personnel responsible for implementing it. The main
point of discussion was the amount of time it was taking for OERs to move
through the review and implementation process. A number of Licensee Event
Reports (LERs) were noted to be taking four to five months from the
issue date before they were incorporated into the training program or
dispositioned. The inspector was concerned that the program may not be
adequately sized or organized to assure prompt review or implementation.
The minimum documents reviewed by the Independent Operating Experience
Report (10ER) group are NRC Inspection and Enforcement (I&E) Information
Notices, Institute of Nuclear Power Operations Significant Operating Event
Report, and LERs. These documents are reviewed for applicability and
distributed to the following groups:
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Engineering / Construction;
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Station Licensing (Surry and North Anna);
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PTS (responsible for distribution to Surry and North Anna
training departments);
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l The action date for these reports is three months as defined by Nuclear
Operations Department Standard (N005) LR-03, The Standard for Operating
l Experience Review Rev. 1. These reports are to have a completed review
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and disposition within this time period. The inspector discussed the
LERs that were past due. The individual in charge of the PTS OER group
stated that back to back forced outages (pipe break at Surry, tube
rupture at North Anna), had pulled a number of the 10ER personnel away
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from their tasks to support the outages. The individual was able to track
down the late LERs and demonstrated the ability to locate and identify
those OERs that were overdue. Overall the inspector found the OER program
to be adequate in addressing the training of personnel with regard to
operating events in the industry.
No violations or deviations were identified in this area.
6. Licensed Reactor Operator (RO) and Senior Reactor Operator (SRO) Training
Programs (41701)
a. R0 Candidate Training Program
The training program to prepare non-licensed operators for a reactor
operator license was documented in the Reactor Operator License
Course Program Guide dated September 1985. The program guide sets
forth training goals; roles and responsibilities of management;
prerequisites; a program of instruction including classroom and
simulator instruction, trainee performance evaluation methods; and,
documentation requirements. The inspector noted during the program
review that Appendix B of the Program Guide, Instructional Program,
listed approximately 19 weeks of contact hours for the required
courses, 13 weeks of in plant training, and additional time for
startup certification, specialized subjects, and exam preparation.
However, the times listed in the Program Guide generic course
schedule, Appendix C, R0 License Course Generic Schedule, and in the
Course Schedule, Reactor Operator License Class 87-1, January 1987,
were different. A review of these differences indicated that the
January 1987 course schedule was more conservative, requiring
approximately 52 weeks of training in the initial RO class. Specific
hours for individual courses had been reduced in some cases, but the
training appeared to be captured in non-licensed operator training or
simulator training. The licensee indicated that as improvements had
been made to the course schedules, the program guide had not been
updated to reflect the changes. The licensee stated that the Program
Guide would be revised to clarify the contact hour differences. The
licensee indicated that a new job task analysis was being conducted
that would effect the reactor operator licerse course target hours
and that the Program Guide would undergo a comprehensive corporate
and site review and update af ter complet'on of the new job task
analysis.
The R0 License Course Program Guide also contained a training program
for SRO candidates with no previous North Anna c.orational
experience. This allows highly qualified candidates to obtain
appropriate systems knowledge at North Anna. The program requires
completion of in-plant training by utilizing a qualification standard
for each required watch station. Completion of Shif t Supervisor job
performance measures are also required.
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l The inspector interviewed two reactor operatoes and reviewed training
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records for these operators. The inspectors attended a portion of
simulator training for the reactor operator license class.
Observation of simulator classes revealed no major problems with
simulator training, however, the following comments were communicated
to the licensee:
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The instructors asked questions of students during complex
, operations, which was distracting.
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While the instructors were attentive to student difficulties.
l they were sometimes too quick to assist students to resolve
i problems. This interfered with good operator communication and
did not promote understanding of integrated plant operation.
No violations or deviations were identified in this area.
b. SR0 Candidate Training Program
l The training program for upgrade for a licensed R0 to a licensed SR0
was documented in the Shif t Supervisor Training Program - Program
l Guide, Rev. 1, October 1, 1987. The program guide specified program
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entry requirements and completion criteria, a program of instruction
l including classroom, simulator and in plant training, evaluation
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methods, and documentation requirements. The program emphasizes
! advanced skills in plant operation and design, supervisory training,
l and development of diagnostic capabilities. The Course Schedule,
- Shift Supervisor Class 87-1, January 1987, lists approximately 39
l weeks of training for the SR0 candidate class.
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No violations or deviations were identified in this area,
c. Licensed R0 and SR0 Requali fication Training
The training program for annual requalification of R0s and SR0s is
provided in the Licensed Operator Requalification Program (LORP) -
Program Guide, Rev. O, datd October 1987. The LORP Program Guide
provides a program description, entry requirements, program of
instruction, student evaluation methods, and program documentation
requirements. The inspector reviewed the LORP against the require-
ments of 10 CFR 55. The requalification program met the requirements
of the regulations.
The inspector reviewed the training records and conducted interviews
with three reactor operators and two senior reactor operators. Two
areas of concern were identified during the reviews. A case was
identified where accelerated requalification training had not been
adequately structured by the training department. When questioned
concerning the training, licensee management indicated that the
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problems had been identified at the time of the training by feedback
from the Operations Department, and that provisions had been included
in the program to assure that accelerated requalification training is
st ructured. The inspector reviewed the LORP, Section 3.3. A. and
determined that the program required that accelerated requalification
training requirements be specified, documented, and approved by
management.
The operators also indicated that test results were not reviewed in
class. The inspector was concerned that individ0als may not be aware
of incorrect responses since it appeared that the only feedback from
the exams was the grade. The inspector discussed this concern with
management. The licensee representative indicated that answer keys
were provided to the students. The licensee com:nitted to review
incorrect exam questions with students and assure that students
understood the correct answers. Review of corrective action in this
area is identified as inspector followup item 338, 339/87-39-03.
The inspector attended a portion of requalification training
involving industry feedback and plant modification and event
training. The instructor appeared to be prepared and good class
participation was noted. The inspector reviewed the lesson plans,
which contained material derived from Training Impact Reports. No
problems were identified.
Operational event feedback for the requalification program was
reviewed. The licensee utilizes required reading programs to assure
that non-licensed and licensed operators are aware of industry and
plant events. In addition, for selected major events, lectures were
given to all operating crews. Four operational events affecting
licensed operators were selected for inspector review of required
reading implementation. In all of the cases, required reading
packages were routed by the Superintendent of Operations within four
days of the LER issue date. Each package included a cover sheet with
the names of the addressees and due dates for completion and return.
All of the LER cover sheets that were reviewed were signed and
returned within one month of the LER issue date. Overall, the
required reading system appeared to be complete, timely, and well
documented.
No vio;etions or deviations were identified in this area,
d. Lesson Plans
The inspector reviewed the following seven lesson plans:
- NCR00P 83, Thermodynamics, Fluid Flow, and Heat Transfer, Rev. 0
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NCRODP 86.2, Reactor Operating Principles, Rev. 0
- NCR00P 86.3, Reactor Energy Removal, Rev. O
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- NCR0DP 88.3, Chemical Volume and Control System, Rev. 3
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NCRODP 88.5, Technical Specifications, Rev. 2
- NCRODP 90.3, Vital and Emergency Oistribution, Rev. 1
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NCRODP 91.1, Engineered Safety Features, Rev. 1
The inspector found the course material to be very detailed. The
learning objectives, however, were too broad, vague and addressed low
knowledge and ability values. The licensee is presently revising the
learning objectives te be more specific and address areas of operator
performance. The licensee is also reassessing the Job Task Analyses
for better definition of training scope and learning objectives.
No violations or deviations were identified in this area,
e. Instructor Training / Certification Program
Instructors involved in operator training are required to meet
technical competency requirements and complete a certification
program. The Instructor Training / Certification Program - Program
Guide, November 1, 1986, was reviewed by the inspector. The program
requires a seven-day basic program in teaching skills fc11 owed by a
two year advanced training program, consisting of independent-study
units, advanced skills group workshops, and a continuing education
program. The certificacion process includes training and demonstra-
tion of proficiency in preparing lesson plans and other training
materials, conducting classroom and, as appropriate, simulator
sessions, and evaluating student progress.
Interviews with R0s and SR0s indicated that instructor preparation
and technical capabilities were adequate and in most cases above
average. Interviews indicated, however, that during past requalifi-
cation classes, at least two systems classes were conducted by
instructors with marginal systems knowledge. The licensee indicated
that action had already been taken to correct this problem based on
operator feedback to training management by placing instructors into
SRO training classes. The licensee currently has three instructors
in an SRO training class which should be completed in March 1988.
Two instructors will be placed in the next SR0 training class.
Completion of this training will significantly improve the technical
capabilities of the training staff.
Interviews were conducted with two instructors. The qualifications
and training records of these instructors were reviewed. The
instructors appeared to be well-qualified to teach the courses
assigned. Each instructor indicated that he utilized approved lesson
plans and routinely upgraded lesson plans to provide more detail and
incorporate experience feedback. Both instructors had completed the
basic certification process and were working on the advanced
certification process. One instructor held an SRO license and had
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attended specialized simulator instructor training. The instructors
indicated a strong commitment to assuring that students received high
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quality training.
No violations or deviations were identified in this area.
f. Simulator
The licensee is in the process of upgrading the North Anna simulator
for future NRC certification. The inspectors were t.oncerned that
this spgrade process appeared to take precedence in some cases over
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correction of problems affecting the quality of the evolutions being
I performed for operator training. The inspector also noted that
i attempts to interface additional computers has caused forced
maintenance outages which reduced the amount of contact hours.
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(Contact hours have been maintained well above the minimum
requirements however.) The following concerns were identified during
the inspection:
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Instructors were not always getting prompt information on the
completion and results of simulator modifications from the
simulator maintenance group in that modifications are sometimes
installed without instructor knowledge causing different or
unexpected responses that could render an evolution ineffective.
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Instructors are the primary identifiers of simulator problems
and initiate simulator maintenance requests but do not appear to
have significant involvement with the development of corrective
actions for simulator problems.
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The simulator cannot simulate mode 5 or 6 operations.
Correction of this deficiency will be inspector followup ,
! item 338, 339/87-33-04. l
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These concerns were discussed with the licensee. The licensee .
indicated that these concerns had been brought to the attention of I
management and that actions were being taken to assure that they were l
addressed. The licensee had held meetings between the training
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< department and the simulator maintenance group to provide a
- coordinated schedule to achieve certification and address problems i
currently affecting training. The licensee's actions in these areas i
appeared adequate to address these concerns.
- A review of procedures on file in the simulator revealed that
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document control was not providing updated procedura indexes or
- procedures on a timely basis. The inspector noted that the most
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current index was not on file and several procedures were not !
l current. This is inspector followup item 338, 339/87-39-05. l
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g. Exam Security
The inspectors reviewed the licensee's control over the security of
the assembled exams. Inspectors observed that while exams are being
assembled on a word processor, they are not controlled in a manner to
prevent an unauthorized individual from making a copy of a future
exam. Interviews with staff involved in this area revealed no formal
training on the responsibilities or requirements of exam security.
Also, there is no access or authorization 14 5 t for exams or exam
, banks. This is inspector followup item 338, 339/87-39-06.
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No violations or deviaitons were identified in this area.
7. Non-licensed Operator (NLO) Training (41400)
a. Operational Experience Feedback
The inspectors reviewed incorporation of experience feedback into the
NLO training and retraining programs. A plant event involving NL0s
i was selected for the review. The event, LER 87-015-00, on Unit 1,
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was a reactor trip due to SA feedwater heater High-High level. The
cause was improper valve lineup of instrument air valves, resulting
frv: fsilure to follow ad,7.inistrative controls for removing clearance
tags and returning valves to service. The tagout and subsequent
removal of clearance tags had been accomplished by NL0s.
Training prior to the event (of NL0s in tagout and configuration
control) was covered in step 1 of NLO training program. During
interviews with NL0s, it was determined that some were never given
training in tagouts, system alignments, or configuration control
procedures. Those with prior experience (i.e. Navy nuclear) were
exempted from steps 1 through 3 of the NLO training program. It
should be noted that all NL0s have to complete a Job Performance
Measure that requires them to satisfactorily perform a clearance
tagout. Nonetheless, in light of the large pertion of operational
events within the nuclear industry relating to improper tagouts, this
training should receive more attention. Plant procedures for tagout,
system alignment and configuration control should be taught to all
NL0s, regardless of past experience. Also, this should be included
in requalification training. The inspector discussed this concern
with the licensee and the licensee agreed to provide training on
tagouts system alignments and configuration control to all NL0s.
This is inspector followup item 338, 339/87-39-07.
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Training immediately following the event included lectures to each
, oporating section and required reading of the LER by all NL0s. This
t post-event training appeared to be adequate.
LER 87-015-00 was tracked for incorporation into the ongoing training
programs. As of November 18, 1987, LER 87-015-00 had not yet been
routed for review by the training department staff for potential
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inclusion into the ongoing training programs. The event occurred on
June 29,1987, and the LER was issued on July 28, 1987. Tracking of
several other LERs revealed a typical delay time of 4-1/2 to 5 months
between issuing an LER and routing it to the training department
staff for review and implementation into training programs. This
delay appeared to be due to corporate review.
When the OER is reviewed at the site training department, it is
tracked, routed, and implemented under two procedures: Power
Training Services Operating Experience Review Policy and Procedure,
and Training Impact Report Tracking. The Program Change Coordinator
(PCC) receives each OER from the corporate offin , reviews it for
applicability, and enters it into a computer tracking system. It is
then routed to Power Training Services staff members for review of
its impact on training. The reviewer initiates a Training Impact
Report (TIR) or Simulator Modification Request (SMR). The OERs,
TIRs, and SMRs are tracked on a computer through completion of action
and the reporting of results back to the corporate office.
The computer tracking system of the PCC appeared to be quite helpful
in tracking OERs and maintaining a readily accessible record of the
status of esch. The status of implementation in the training lesson
i plans was verified for two OERs, for which the inspector reviewed the
modif!ed lesson plans.
Another tool used by management in event followup was the Human
l Performance Evaluation System (HPES). A HPES repurt to management,
dated November 9,1987, was reviewed by the inspectors. This report
investigated the causes of the event in substantially more detail
, than was found in the LER. In it, several areas were identified that
j needed to be addressed by plant operations and training. The
' corporate OER Review System included HPES Reoorts, so this important
information should receive formal management review for implementa-
tion of needed changes.
There is a provision for an annual review of OER program ef fective-
ness. This is accomplished by a corporate entity known as the
Program Evaluation Staff. A yearly review is conducted on the TIR
status reports and their resolution. The status reports are produced
and circulated monthly to the appropriate individuals and updated by
the appropriate supervision / management. The number of closed TIR's
is reported monthly at the training center; TIR's are completed in
accordance with management goals; resolution of TIR's is incorporated
into the training program. These procedures and their implementa-
tion under the evaluation schedule appear adequate, however,
processing times for screening OERs prior to sending them to the site
training department should be reduced.
No violations or deviations were identified in this area.
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b. Entry Level Training
The Non-Licensed Operator Training program utilizes the Nuclear
Foundations Training Program to prepare entry level personnel for
admission into the Nuclear Control Room Operator Development Program.
A common track is employed for those seekirg to be health physics
technicians or control room operators. This consists of orientation,
mathematics, classical physics, chemistry, electricity (DC), and
Nuclear Physics. This is a four month program and is followed by a
two month program designed specifically for operators that consists
of thermodynamics, heat transfer, fluid flow, reactor theory,
electricity (AC), instrumentation and control, and engineering
mechanics.
No violations or deviations were identified in this area,
c. Requalification Training
Requalification training was reviewed by the inspector and found to
be adequate. The inspector reviewed the licensee's schedule for
non-licensed operator continuing training and found it to be
comprehensive and well organized. The curriculum was divided into
cycles that listed morning and afternoon sessions for each week, the
method of instruction, instructor designation where applicable, and a
listing of when each shift was to attend class. The curriculum
covered such topics as advanced radiation worker training, E0P's,
steam traps, fire protection, fuel handling, emergency response
organization, simulator training, nuclear instrumentation, secondary
plant equipment, and modifications. Most of the cycles contained
quizzes and the final cycle spent one day of self-study followed by
an annual examination. Training records reviewed during an audit of
the qualift:ations of NLO's were complete and well organized.
No violations or deviations were identified in this area.
8. Maintenance Training
Overall, training records reviewed during an audit of the training of
maintenance personnel were complete and well organized.
a. Operational Event Feedback
Thirteen OERs (seven LERs and six I&E Notices) were selected for
inspector review for feedback into the training programs. Of these,
seven had been entered into the TIR system, two had just been
received by the PCC through the corporate OER process, two had not
yet been received through corporate OER process, and two I&E Notices
from 1985 were found to have no record of being received at the site.
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These I&E Notices were received prior to the computerized tracking
system currently used by the PCC. At the time there was no site
system for monitoring the records of all the OERs received by the
PCC. The PCC stated that old INPO issued OERs were backfitted into
the computer TIR system by using annual indexes supplied by INP0.
The PCC receives no annual index of NRC issued OERs. However, each
I&E Notice contains an index of recent I&E Notices, so that an annual
index could be constructed by the licensee.
The OERs that were in the computerized tracking ;ystem appeared to be
adequately tracked and implemented. Lesson plan revisions were
checked for selected OERs and were found to be adequate.
The primary methods used for Operational Event Feedback for
maintenance personnel is required reading. The required reading
system was reviewed for electrical, mechanical and I&C technicians.
In each case, monthly packages of required reading are assembled with
a routing cover sheet. Each package may contain about ten different
items. Inspection of several completed required reading routing
cover sheets revealed that they had all been signed, and that the
routings had been completed within six months. The licensee
indicated that the routing process was being revised to cover each
shift separately instead of the whole department. This should
greatly improvr the timeliness of the feedback process.
No violations or deviations were identified in this area.
b. On the Job Training (0JT)
Inspectors reviewed the DJT program for maintenance personnel. The
licensee uses Job Performance Measures (JPMs) to assess the training
of maintenance personnel to qualify them for each successive step
that they achieve. The inspector interviewed maintenance foremen and
reviewed records for specific technicians' JPMs which the foremen
maintain. The review demonstrated consistency between the training
records and the jobs for which the maintenance personnel had
qualified. The JPMs are used by the foremen to verify, when there is
a question, the qualifications of personnel to perform assigned
tasks.
No violations or deviations were identified in this area.
c. Laboratory Mockups
The inspectors toured the licensee's mockup training facilities. The
facilities were comprehensive and contained equipment for instrumen-
tation and control, electrical, and maintenance training. The
licensee is still expanding the use of mockups and plans to implement
more training aids. The most extensive use of mockups was for the
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! practical factors portion of the General Employee Training (GET)
program. The licensee has a full scale mockup of the dress-out
rooms, health physics checkpoint, radiation controlled area access
point, maintenance jobs, and radiation controlled area egress point.
The licensee utilized a small hidden source under a frisking table
pad to simulate contamination and reinforce the trainees attention to
contamination precautions. The inspectors consider the mockups an
excellent training method.
As an aside to the GET training mockup, the inspectors discussed a
recent incident at the site where an employee received an overexpo-
sure due to a "hot" particle embedded within protective clothing. As
an example of the licensee's response to an operational event, they
immediately implemented more stringent surveys of all protective
clothing and subsequently purchased stand up portal monitors to
survey employees, in their protective clothing, prior to entering the
radiation controlled area.
Inspectors interviewed several maintenance personnel regarding their
opinions of the training program. Personnel were chosen to represent
a diverse cross-section of experience so that feedback could be
obtained from veterans with a great deal of experience as well as new
empicyees with a fresh outlook. The veteran employees expressed a
satisfaction with the direction of the training program and its
attention to their training needs. The newer employees also had no
problems with the amount or adequacy of their training and its
relation to the work they performed.
No violations or deviations were identified in this area.
d. Contract Personnel
The qualification of contract personnel were discussed with the
licensee. The licensee writes their contracts specifically
addressing ANSI 3.1 and Regulatory Guide 1.8. Nondestructive
examination personnel were used as an example of a typical contract
that was reviewed and audited. All contracts are reviewed on an
annual basis unless there is no activity. When an audit is postponed
due to insufficient activity, the responsible supervisor must approve
the reduction of audit scope. Vendor programs are evaluated based on
the month of contract approval. For example, a contract approved in
August would be audited annually or tri-annually based on the nature
of the work and the duration of the qualifications.
No violations or deviations were identified in this area.
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9. Natural Circulation Cooldown (41701)
a. Procedures
The inspectors reviewed the following emergency procedures for
natural circulation cooldown:
- 1-ES-0.2A, Natural Circulation Cooldown With Shroud Cooling
Fans, Rev. 1;
- 1-ES-0.2B, Natural Circulation Cooldown Without Shroud Cooling
Fans, Rev. 1;
- 1-ES-0.3, Natural Circulation Cooldown With Steam Void in Vessel
(with RVLIS), Rev. 1.
The licensee committed to write the E0Ps in accordance with an NRC
approved Procedure Generation Package (PGP) and incorporate the
Westinghouse Owners Group (WOG) Emergency Response Guidelines (ERC),
Rev. 1, into the E0Ps. The PGP requires the justification of any
setpoint or significant deviatten from an ERG step. The licensee
uses a Step Deviation Document (S00) for the identification of step
deviations and the documentation of step deviation justifications.
The licensee also uses an E0P Setpoints document for detailed
setpoint justifications.
Two of these procedures,1-ES-0.2A and 1-ES-0.3, appeared to contain
all of the prevention and mitigation measures for reactor vessel head
bubble as set forth in the WOG guideline procedures. These measures
include the use of core exit thermocouples for monitoring vessel head
temperature, checks for unexpected large variations in pressurizer
level, instructions on the mitigation of void formation, and limits
on cooldown rate and subcooling margin,
1-ES-0.2B deviated from the WOG guideline in two aspects:
(1) The cooldown and depressurization to a hold point is done
differently:
WOG North Anna
Starting Pressure 31950 psig 31950 psig
Subcooling at core exit 3200*F 1180*F
thermocouples
Cooldown Rate $25'F/ hour $15'F/ hour
Reduce Pressure (while
maintaining subcooling)
to hold point of 1200 psig 1025 psig
Soak Period 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
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The licensee has no justification for these procedural step
deviations in their Step Deviation Document (SDD). The
licensee's 500 should identify each step deviation, and ,
reference applicable E0P Setpoint documents for any needed
further justification. The lack of 500 documentation is an
example of deviation 338, 339/87-39-02.
,
The intent of this WOG guideline procedure is to cooldown and
depressurize the primary coolant system while maintaining
assurance of no voiding (boiling) in the reactor vessel upper
head. The inspector reviewed the licensee's data from the North
Anna E0P Setpoint document to determine whether this portion of
the North Anna procedure met the intent of the WOG guidelines.
Upper head subcooling was calculated by the inspector, using
licensee's data for upper head temperatures in comparison to
allowable primary pressures. This was done for both the North
Anna procedure and the WOG procedure. The inspector found that
the North Anna procedure maintains subcooling in the upper head
greater than the corresponding WOG procedure for this portion of
the cooldown. Therefore, the inspector concluded that this
portion of the North Anna procedure appears to meet the intent
of the WOG guideline.
(2) Af ter the hold period above, further cooldown and depressuriza-
tion is done differently in step 20 of ES-0.28. The WOG
guidelines indicates that pressure should be reduced to 350-400
psig while maintaining subcooling at >200'F. ES-0.2B has no
specific subcooling requirement.
l In the licensee's procedure, following the eight hour soak ,
I
period, isothermal depressurization is performed with the intent
of bringing RHR on line as soon as possible. This results in a ,
situation where subcooling of the upper head could be reduced to
as little as 2'F. The comparable WOG procedure maintains upper .
head subcooling greater than about 39'F. The licensee makes no
mention of this procedural step deviation in their 500. This
i
lack of documentation or justification is an example of
deviation 338, 339/87-39-02.
l
The PGP also requires that controls and displays to be used are
identified in their procedures to assist the operator in accurate
and quick identification. However, ES 0.28, Attachmant 1,
Pressure / Temperature Limits for Cooldown, fails to indicate which
temperature instruments are to be used in complying with the curve.
The same inadequately labelled curve appears in ES-0.2A and ES-0.3.
l This is an example of deviation 338, 339/87-39-02.
The licensee's procedures for natural circulation cooldown
(1-ES-0.2A, 1-ES-0.2B, and 1-ES-0.3) contain a cooldown minimum
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temperature / pressure limit curve that is different than the
corresponding technical specification cooldown curve. Further,
the licensee's natural circulation cooldown curve allows
operation in the "Unacceptable Operation" region of the
Technical Specification cooldown limit curve. The licensee's
procedures are thus inadequate in that the procedures do not
reflect technical specification requirements. This is violation
338, 339/87-39-01.
The fact that the licensee's natural circulation cooldown curve
was different from the corresponding Technical Specification curve
was not mentioned in the 500. This failure to properly identify and
justify the use of a different setpoint is an example of deviation
338, 339/87-39-02.
b. Training
Natural circulation cooldown training was reviewed, and the
inspectors found this area to be insufficient for the following
reasons:
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0ER's, including the St. Lucie event, were not formally
integrated into the lesson plan on natural circulation;
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Training was not sufficiently in-depth. It was noted that there
was no discussion of complications during natural circulation,
reasons for complications, detection of upper head voiding,
indication of upper head voiding, and mitigation / corrective
actions for upper head voiding;
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Natural circulation cooldown is addressed in four separate areas
of training (theory, systems, mitigation of core damage, and
emergency operating procedures) without adequate ties to each
area.
The upgrade of natural circulation cooldown training will be
inspector followup item 338, 339/87-39-08.
No violations or deviations were identified in this area.
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