ML20196F438
| ML20196F438 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/06/1988 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8812130084 | |
| Download: ML20196F438 (7) | |
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PHILADELPHIA ELECTRIC COMPANY tdh>
PEACil IKMTOM ATOMIC POWER STATION R. D. l. cas 208 Ltgf Delu, Pennsylvania 17314 pixse sonme.assa nma oe e u nusv s (717) 4 $6 7014 D M Smith vue President Docket Nos. 50-277 50-278 Mr. Thomas T. Martin, Director Division of Reactor Safety Region !
U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Powar Station Response to Combined Inspection Report Nos. 50-277/88-32; 50-278/88-32
Dear Mr. Martin:
This is in response to your letter dated November 8, 1988 which transmitted Peach Bottom Inspection Report Nos. 50-277/88-32; 50-278/88-32.
This report concerned the routine safety inspection conducted at the Peach Bottom plant specific simulator during the period August 31 - September 29, 1988. Appendix A of your letter described concerns regarding Licensed Operator Performance and Requalification Program. The attachment to this letter provides a restatement of these items, and provides Philadelphia Electric Company's response.
If you have any questions or require additional information, please do not hesitate to contact us.
Very trul yours, hs Attachment cc: Addressee J. T. Boettger, Public Service Electric I. Gas T. P. Johnson, USNRC Senior Resident Inspector T. E. Magette, State of Maryland W. T. Russell, Administrator, Region 1. USNRC H. C. Schwe m. Atlantic Electric J. Urban, Delmarva Power I
SS12130084 881206
{DR ADOCK 03000277 i
FDC
T0: Mr. Thomas T. Martin Page 2 bec:
C. A. McNeill, Jr. - S26-1 S. J. Kowalski - 525-1 J. W. Gallagher - S25-1 E. P. Fogarty - S7-1 E. J. Bradley - 523-1 D. R. Helwig - S7-1 J. F. Franz - PB C. J. McDermott - S13-1 G. F. Daebeler - PB T. E. Cribbe - PB A. J. Marie - N2-1 G. A. HJnger 1 J. T. Robb/ISED - S7-1 J. A. Basilio/FDL - 510-1 Commitment Coordinator DAC i
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o Attachment Page 1 of 5 Docket Nos. 50-277 50-278 Response to Concerns CONCERN 1 - Licensed Operator Requalification Program The inspector identified four areas of concern within the Licensed Operator Requalification Program.
Each area will be addressed individually.
CONCERN la - The lack of attention to training scenario preparation and revision as discussed in Paragraph 2.1 of the inspection report.
RESPONSE -
The Training Division is currently making a concerted effort with Operations to improve the training scenarios.
Performance objectives and evaluation criteria have been developed for each scenario. Operations management is requiring their concurrence of specific scenarios and is developing performance expectation criteria for those attributes which apply to Operations personnel and are generic to all scenarios, such as connunications.
Evaluation scenarios will include pass / fail criteria. Simulator ExerciseGuides(SEG's)willbevalidatedandidentified discrepancies corrected in succeeding revisions.
CONCERN lb - The effect of limited time available fd the crew to operate the l
simulator during training sessions on training effectiveness as discussed in Paragraph 2.2 of the inspection report.
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RESPONSE -
Additional simulator time has been allocated for shift operator training.
Since the inspector performed this evaluation, each creu has received an additional four days simulator time between 10/3/88 and 11/3/88. This included two days of detailed training on operation of specific equipment, such as HPCI, RCIC, RHR valves, Diesel Generators and other evolutions and operations identified as requiring additional training.
The third day was spent responding to operational transient scenarios.
Each crew was evaluated on the i
fourth day while responding to events requiring extensive use of Operation Transient (OT) and TRIP procedures.
Between 11/7/88 and 12/2/88 cach crew spent three days additional at the simulator correcting weaknesses identif.ea 1.ing p'evious simulator performances. Each period concluded with a one day evaluation performed by VP - PBAPS, Plant Manager, Superintendent of Operations and the Training Division.
During January / February 1989 each crew will receive two days refresher training to help maintain their operaticnal skills.
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o Attachment Page 2 of 5 Docket Nos. 50-277 50-278 CONCERN Ic - The unclear definition of rcsponsibility between the training department and the Shift Manager for correction of identified performance deficiencies as discussed in Paragraph 2.2 of the inspection report.
RESPONSE -
Standards have been developed by Operations management to be utilized by the Training Division and Shift Managers in order to insure consistent assessment of crew and individual performance on the simulator.
It has been re-affirmed that it is a Shift Marager and Operations management responsibility to ensure operator performance deficiencies are corrected. The Training Department is responsible for training, monitoring performance and identifying areas of weakness or inadequacy. The Training Department, Shift Manager and Operations Management are jointly responsible for determining the appropriate corrective actions necessary to resolve any problems noted.
CONCERN Id-Simulation performance deficiencies are being identified but are i
not being corrected as discussed in Paragraph 3.1 of the inspection report.
RESPONSE -
The Peach Bottom Simuletor has remained at the Singer facility in Columbia, MD so that modification updates can be incorporated into its' design to more closely reflect the present day plant. Since the needs of training could be served simultaneous to the development of the modification updates, an agreement was made between PECO and Singer that training would take priority and mod development would be done in background.
No unauthorized work was performed on the simulator by Singer personnel. Due to needed access by Singer personnel, :.ome problems develooed with the use of this access in the beginning and again when a new Singer modeler incorrectly accessed the "Training Load" software. To eliminate this problem, an "Engineering Load" was built and isolated from the master and slave computers. Access to the "Training Load" requires a password that is controlled by PECO.
i As with any new complex system, the ability to utilize the system to its fullest potential require', time and experience. With the time restraints of the training being performed on the simulator, the simulators capabilities have not yet been fully used.
The Training Division will be able to develop and use these capabilities when they are required on site.
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e Attachment Page 3 of 5 Docket Nos. 50-277 50-278 A comprehensiva configuration control system is in place.
The mechanism used for identifying problems with the simulator is to file a discrepancy report (DR). These reports are logged by the Singer Project Enginee. and assigned to an appropriate party for reulution. OR's that have a direct impact on training are handled immediately. DR's that do not severely impact training are resolved on the Engineering Load and placed in the "ready for recheck" category. Resolved DR's are selectively transferred into the Training Load. Becausa of the extensive amount of modifications being developed on the Engineering Losd. and the need l
to maintain the Training program, the approach has been taken that if a discrepancy can be bypassed, it is better to leave the Training Load as is for now, and fix it when the modification upgrade is installed.
The NRC observed weakness of Simulator Configuration Management Control is not considered to be a concern. Tracking and corrections of identified simulator problems is performed as j
described in the preceding paragraph. The DR's are kept in log books by Singer at the simulator.
In addition, a sumary of the DR's and their status is maintained by PECO personnel in a report a
j kept at the Instructor Station. The list groups the DR's by system J
for easy referral. Discrepancies that nave been corrected hue i
been approved by knowledgeable PECO or General Physics (PECO's i
simulator consultant) personnel. The example of the deficiency of j
torus temperature and drywell pressure not responding to an i
addition of heat to the torus is detailed in DR #W4583 written l
9/15/88.
The discrepancy was observed in an "Initial Condition" listed as IC-42. Since this IC is an unprotected IC, and the discrepancy does not occur in the protected IC's, training will not use this IC until the discrepancy can be further analyzed.
I Instructors will provide suffit.ient detail for engineers to analyze identified problems. Although this is a burden on the instructors.
the basis of the discrepancy needs to be known to alther modify or l
update the existing data base of the simulator.
j CONCERN 2 - Licensed Operator Performance l
The inspector identified five areas of concern regarding Licensed j
Operator Performance.
Each area will be addresstd individually.
CONCERN 2a - Numerous deficiencies in performance of control board manipulations as discussed in Paragraph 2.3 of the inspection report.
l RESPONSE -
As prcviously noted in the response to Concern Ib, an additional l
two days training wcs allocated to procide instruction on specific manipulations.
This training has proven to be effective as demonstrated t'y improved system operation proficiency during subsequent evaluation scenarios, i
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o Attachment i
Page 4 of 5 Docket Nos. f;0-277 50-278 Special emphasis has been placed on maintaining level control between 0 and 45 inches. Training and evaluation has demonstrated improved dater level control and oparator recognition that levels greator than 45 inches are undesirable.
Emphasis was placed during training to properly verify isolations and scrams b/ observing actual position as opposed to the previous practice of using 4
annunciaturs.
CONCERN 2b - Shift Supervisc
- difficulties with using multipic TRIP procedures simultanem sly as discussed in Paragraph 2.3 of the inspection
- report, a
RESPONSE -
Detailed training performed in October and November reviewed TRIP procedures on a step by step basis with Shift Supervisors, RO's, and C0's.
This review included BASES, Cautions, Notes and proper flowchart marking.
Instructors have demonstrated proper usage on more than one TRIP procedure to the Shift Supervisors during multiple malfunction scenarios. As a result of this training Shift Supervisors demonstrated proficiency in the use of multiplo TRIP
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procedures in subsequent evaluation scenarios.
CONCERN 2c - Weaknesses in the comand and control ability of one Shift j
Supervisor as discussed in Paragraph 2.3 of the inspection report.
RESPONSE -
Upgraded / additional training in the use of TRIP procedures has had a positive effect on Shif t Supervisor command and control ability.
Superintendent and Assistant Superintendent - Operations have counseled the Shift Supervisors to clearly define and emphasize PECO's expectations of them as Operations Management.
l Superintendent - Operations is worki.)g daily at the simulator with the Shift Supervisors clearly relating his expectations of their comand and control performance during TRIP procedure usage.
Evaluations during subsequent training sessions have shown marked I
improvement in this area with Shift Supervisor performance being j
rated satisfactory.
l CONCERN 2d - The unclear definition cf responsibilities and interface between the Shift Managers and Shift Supervisors as discussed in Paragraph 1
2.3 of the inspection report.
RESPONSE -
The roles of Shift Manager and Shift Supervisor have been clearly re-emphasized durirg training sessions subsequent to the inspection 1
period.
The thift Supervisor has the responsibility to direct operator actions, l
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Attachment Page 5 of 5 Docket Nos. 50-277 50-278 The Shift Mcnager has the responsibility to ensure overall crew prrformance is proper for the scenario in progress.
The Shift Manager accomplishes this by determining plant status through observation, review of TRIP procedures and consulting the Snift J
Supervisor. Shift Managers, through additional training, have become more efficient in dealing with Emergency Plan requirements, allowing more time to be cognizant of olant conditions. The Shift Managers should perform manipulations on the control boards when dire ded by the Shift Supervisor and then only under conditions of limited operator availability.
It is expected these manipulations will occur on a very infrequent basis and then only during a high level of crew activity or when a particular action must be performed in a expeditious manner.
CONCERN Pe - Weaknesses in comunicat ons between R0's and Shift Supervisors as discussed in Paragraph 2.3 of the inspection report.
4 RESPONSE -
Since the inspection, improved communications has been strongly emphasized during all training and in-plant activities.
It has been stressed by Operations Management and during training critiques that communications shall be in accordance with the guidance given in Section 4 of the Operators Manual. During i
command and control training use of repeat backs was stressed.
Evaluations recently performed indicate communications are now at a satisfactory level.
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