ML20206D312

Insp Repts 50-277/88-32 & 50-278/88-32 on 880831-0929.No Violations or Deviations Noted.Major Areas Inspected: Licensed Operator Requalification Training Program. Weaknesses in Requalification Program Identified

ML20206D312
Person / Time
Site:	Peach Bottom
Issue date:	10/27/1988
From:	Johnson T, Lange D, Walker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206D291	List: ML20206D287 ML20206D312
References
50-277-88-32, 50-278-88-32, NUDOCS 8811170042
Download: ML20206D312 (13)

See also: IR 05000277/1988032

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U.S. NUCLEAR REGULATORY COMMISSION

Report Nos. 50-277/88 "

50-278/88 _.

License Nos. DPR-44

OPR-56

Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, PA 19101

Facility Name: Peach Bottom Unit 2 and Unit 3

Inspection at: Columbia, Maryland

Inspection conducted: August 31 - September 29, 1988

Inspectors: ~

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7."Wa1kert'Seni~or Operations Engineer date

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T. JoVson, Senior Rekdent' Inspe6t'or

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Date

Approved by: <. zd' -#7-8f'

O. Lange, Offief, _ perations Section Date

Summary: Inspection on August 31 - September 29, 1988 (Report Nos.

50-277/88-32 and 30-278/88-32)

Areas Inspected: A routine, announced safety inspection was conducted to

review the Peach Bottom Licensed Operator Requalification Program in order to

evaluate the effectiveness of the licensce's simulator training program. The

inspection consisted of observation of requalification training on the plant

specific simulator, NRC/ facility parallel evaluation of operator performance,

and discussions with training personnel.

Results: No violations or deviations were identified, The following strengths

were identified: self evaluation during post-scenario critiques, knowledgable,

experienced instructors, Operations and Training department interface, and

plans to share requalification program experience and resources with Limerick

Generating Station. Weaknesses in the requalification program were observed in

the following areas: training effectiveness with respect to real time training

on the simulator, instructor /Shif t Manager interface, training scenario

preparation and revision, and simulator configuration management control.

Weaknesses related to licensed operator performance were observed in the

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following areas: control board manipulations, use of multiple TRIP procedures

(Emergency Operating Procedures), Shift Manager / Shift Supervisor interface,

command and control ability of one Shift Supervisor, and communications between

reactor operators and Shift Supervisors.

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DETAILS

1.0 PERSONS CONTACTED

1.1 Philadelphia Electric Company

D. M. Smith, Vice President - Peach Bottom

R. G. Andrews, Operations Training Supervisor

D. McClellan, Senior Requalification Instructor

R. Watkins, Requalification Instructor

R. Artus, Requalification Instructor

F. Polaski, Assistant Superintendent of Operations

R. Helt, Corporate Training

The inspector also interviewed other licensed operators during

the inspection period.

1.2 Other

S. Maingi, Commonwealth of Pennsylvania

R. R. Reichel, Delmarva Power

T. E. Magette, State of Maryland

M. A. Phillips, Public Sarvice Electric and Gas

H. R. Abendroth, Atlantic Electric

1.3 U.S. Nuclear Regulatory Commission

W. F. Kane, Director, Division of Reactor Projects

E. C. Wenzinger, Chief, Reactor Projects Branch 2

J. Linville, Chief, Reactor Projects Section 2A

J. H. Williams, Project Engineer

R. Gallo, Chief, Operations Branch

D. J. Lange, Chief. BWR Section

R. E. Martin, NRR Project Manager

Denotes those present at the exit meeting conducted on 9/29/88

2.0 Simulator Training Observation

Four shif t crews were observed during requalification training sessions on

the Peach Bottom plant specific simulator located in the vendor's facility

in Columbia, MD. The training sessions included normal power operations,

transients and control manipulations expected during the power ascension

program and transients requiring TRIP procedure usage and Emergency Plan

implementation. A list of the shift crews that were observed and the

scenarios that they participated in is included as Attachment 1. The

inspectors did not alter the training department prepared scenarios or

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schedule. The lesson plans used during the training sessions were re-

viewed and discussed with the training instructors. Pirallel evaluations

of the crews were performed by the inspectors and compared with the

evaluations made by the training instructors. Operations and training

department interface was observed during the training sessions. The focus

of the observations was on operator actions taken to mitigate transients

and actions taken to place the plant in a safe shutdown t.ondition follow-

ing a transient.

2.1 Simulator Exercise Guide Preparation and Revision

The simulator exercise guides (SEGS) used during the observed

training sessions were prepared just prior to the start of the

requalification training cycle. Twenty-eight (28) of the twenty-nine

(29) SEGS were signed by the preparer on 8/1/88 and reviewed by the

Senior Requalification Instructor and the Operations Training

Supervisor between 8/2/88 and 8/4/83. In several cases, the Senior

Instructor both prepared and reviewed the SEG. The remaining SEG was

used in hand-written, unreviewed form during the training sessions.

None of the SEGS had been reviewed by the Operations Department or

approved for use by the Training Superintendent.

In many cases the prepared simulator exercise guides (scenarios) did

not completely define the expected plant response and required

operator actions. For example the SEG for plant startup testing did

not discuss the expected response of reactor water level for a

specified level transmitter failure and did not describe the actior.,

required for single loop operations following a recirc pump trip.

Also, this SEG referred to a sample Maintenance Request Form (MRF)

that was not included in the SEG. None of the observed scenarios

included any references to Technical Specifications when plant

conditions warranted that they be addressed.

Numerous deficiencies that were not identified during reviews or

previous training sessions were identified while running the

scenarios with the operating crews. These problems interrupted the

real time scenarios and distracted the operators from concentrating

on operating the simulator as if it was the plant. During one

crew training session, the plant startup testing scenario had to be

interrupted and run again due to a combinatine cf f; Mures that

caused a reactor scram that the operato , could not reasonably have

been expected to prevent. This problem was not identified during

two previous crew training sessions or during the review of the

scenario by training personnel. The objectives of the SEG for a main

turbine load reject were changed during the third session of crew

training because the power level would be below the level at which

a scram occurs on a load reject. This discrepancy was also not

identified during previous training sessions or SEG review.

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When problems with the scenarios were identified, the senior

requalification instructor noted them. Changes were not rade to

the SEGS until the requalification cycle was completed, therefore,

the instructors had to depend on their personal knowledge and

experience to keep track of the expected plant response and required

operator actions. A discrepancy was identified in the procedure for

response to an earthquake during a training session on 9/8/88. The

same discrepancy caused confusion during the training session on

9/22/88. This indicates that items identified during training are

l not being adequately tracked and passed on to the following crews.

The weaknesses noted with the preparation and revision of the

scenarios indicate a lack of attention to the preparation and

decumentation of the training. Due to the level of knowledge and

experience of the instructors, the training that was administered

was adequate, but the weaknesses in the scenario documentation were

of concern.

2.2 Training Effectiveness

Following each training scenario, the operators and training

instructors held a critique to discuss and evaluate crew performance.

The performance evaluations done by the crew members and the training

instructors during the post-scenario critiques were a strength in

the training sessions. Most of the deficiencies noted by the

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inspectors were recognized by both the crew members and the

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instructors. The parallel evaluations performed by the instructors

were comparable to the evaluations performed by the inspectors.

The knowledge and experience of the instructors was noted as a

strength in the licensee's training program. When questions arose,

they we. e able to resolve the issue w'th accurate and clear answers.

During the training sessions, the instructors demonstrated a high

level of understanding of integrated plant operations and familiarity

with the plant systems and components. In spite of the weaknesses in

the simulator exercise guides (see section 2.1), the instructors

provided technically accurate training and were able to adequately

evaluatr, the performance of the operators.

Interastion between the Operations Department and Training Department

was noted as a strength in the licensee's program. Operations

Supervision participated in the training sessions in both evaluating

and providing insight and clarification when questions arose. During

the scenarios numerous procedural and simulator fidelity deficiencies

were identified by the operators and actions were taken to correct

the deficiencies.

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The effectiveness of the training was limited by the amount of

time the crews spent operating the simulator. The amount of

time available for the operators to perform manipulations on the

simulator was considered a weakness in the training program.

Numerous situations arose where the crew and the instructors

identified areas that required more training on the simulator, but

the training schedule did not allow for the additional training.

! Post-scram water level control was identified several times as an

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area that required additional training, but was not provided for in

the schedule. Several times the instructors stopped scenarios to

discuss appropriate actions, but the effectiveness of the training

was limited because the scenario was not run again to allow the

operators to utilize the scenario ',pecific training they had received.

The tight training schedule did not always ensure that all members

i of the crew benefitted from the objectives of the scenarios. Post

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scenario discussions were used to summarize the scenarios and inform

all crew members of the results, but there was no opportunity for

operators to swap positions and perform the operations they were

trained on.

Another weakness was the interface between the instructors and the

! Shift Manager. In many cases the instructors were not specific as to

what the appropriate actions should have been and left the

determination to the Shift Manager. Individual deficiencies were

identified and tracked by the training personnel, but left to the

Shift Manager to present to the rest of the crew. The Shift Manager

is responsible for crew performance, but it was not clear to the

inspectors whether the training department or the Shift Managers

would ensure that the identified performance deficiencies are

corrected.

In summary, the training that was provided was technically

accurate due to the knowledgeable, experienced instructors, but the

effectiveness of the training was limited by the time available on

the simulator. The instructors and operators were able to identify

performance deficiencies and weaknesses. The training department is

tracking the identified items, but the responsibility for correction

of the deficiencies was not clearly defined,

2.3 Licensed Operator Performance

, The crew for each training scenario consisted of the Shift Manager,

l an Inside Shift Supervisor, an Outside Shift Supervisor (acted as an

evaluator in some cases), a Chief Operator (R0 licensed), a Unit 2

Reactor Operator, and a Shift Technical Assistant. The other RO on

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the shift acted as either the Unit 3 Reactor Operator or as an extra

operator. Several of the operators received their licenses af ter

Peach Bottom was shutdown and have not operated the plant during

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power operations. These individuals hold "cold" conditional

licenses and will have to participate in reactor and plant operation

at power levels of at least 20% power for one month and performance

of five significant control manipulations which affect reactivity

or power level under the direction of a licensed operator prior to

assuming full licensed duties.

During the training scenarios a number of deficiencies were observed

ir the performance of control board manipulations by both cold

licensed and experienced operators. In one instance, an incorrect

breaker was opened causing a trip of the plant. A cold licensed

cperator, while attempting to secure HPCI, did not recognize that the

turbine was already tripped. Several operators had difficulty with

abnormal RHR system lineups and understanding of RHR interlocks.

Post-scram water level control was a recurring problem among all the

crews observed. The operators were unable to maintain water level

below 45 inches following the restoration of level after a reactor

scram. Several instantes of failure to verify automatic actions were

observed along with some difficulties with manual initiation when the

automatic actions did not occur.

Two Shift Supervisors (SSs) had difficulty using multiple TRIP

procedures (E0Ps) simultaneously. The deficiencies noted appeared to

be a lack of ability to step through the multiple flow charts during

real time scenarios rather than a lack of understanding of the

procedures. These deficiencies were identified by both the

instructors and the inspectors and were acknowledged by the senior

reactor operators. In most cases the appropriate actions were per-

formed by the crew with or without direction from the SS. The one

action that was not performed in a timely manner was depressurization

via the safety relief valves to allow low pressure injection. In

discussions af terward, the Shif t Supervisors recognized that depres-

surization should have been performed, but had not reached the

applicable step in the procedures due to difficulty in following

multiple flowcharts in a real time situation.

A weakness was observed in the command and control ability of one

Shift Supervisor. In many instances, the SS did not direct the

actions of the reactor operators during transients and recovery from

the transients. He allowed the operators to take the required

actions, but provided very little guidance or direction, especially

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in use of the TRIP procedures. Additionally he often checked

parameters and plant status himself rather than requesting the

information from the reactor operators at the control boards. This

action caused him to remove himself temporarily from the procedures

and did not allow all members of the crew to be informed of plant

status.

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The interface between the Shift Manager and the Shift Supervisor was

determined to be weak, especially during TRIP procedure usage and

Emergency Plan implementation. In one case the Shift Manager was

involved in the Emergency Plan to the extent that he was untware of

plant conditions and would not have been able to assist the Shift

Supervisor if required. In other cases the Shif t Manager and Shif t

Supervisor were both directing the actions of the R0s, causing

confusion among the crew members. In one case the chain of command

was not followed in that the Shift Manager performed a manipulation

on the control boards. Defined responsibilities for the Shif t

Manager and the Shif t Supervisors are necessary to ensure that shif t

supervision is fully aware of plant conditions but does not cause

confusion among the crew by providing contradictory direction.

Communicativns between the R0s and Shift Supervisors were weak during

several of the observed training sessions. The weaknesses in

communications that were observed were minor and in most cases did

not hinder the operators in safely operating the plant. The Shift

Supervisors did not always give specific directions to the R0s (i.e.,

did not provide limits or preferred method of level control) and

phrased some directions in question form. In several ceses the SS

did not give a direction to a specific person, sometimes causing

confusion about responsibilities among the R0s. Both R0s and SSs did

not always acknowledge communications, which occasionally resulted in

Shift Supervisors directing actions that were not performed and R0s

reporting plant conditions that the SS did not hear and had to

request again. Acknowledging the communications wculd have prevented

the confusion. In several cases the R0s were deficient in supplying

plant conditions, specifically not informing th? SS of degrading

plant conditions. The R0s did not always inform the SS of actions

that were performed or completed, therefore the SS was not always

aware of plant status.

The deficiencies noted in operator performance indicate that

additional training on the simulator is necessary in two particular

areas. The first is in performing control manipulations because the

number of deficiencies observed indicated a lack of proficiency in

this area. The second area is in use of TRIP procedures because of

the difficulties the Shift Supervisors experienced in using multiple

TRIP procedures during transients. In almost all cases the crews

successfully worked together to mitigate the transients and place the

plant in a safe shutdown condition. The scenarios were run for

training and all of the performance deficiencies were identified by

the operators and instructors. The deficiencies were discussed with

the entire crew during the scenarios or during the post-scenario

critiques.

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3.0 Discussions with Training Department Personnel

The inspectrrs discussed the capabilities and fidelity of the plant

specific si.nulator with the instructors. Requalification program documen-

tation wa< also discussed with the senior requalification instructor.

Preparat'.on for NRC administered requalification examinations was discussed

with t6.e requalification instructors and corporate representative.

3.1 Simulator Use and Configuration Management Control

The simulator is located in Columbia, MD at the Singer Link fe:ility

where it was constructed. The licensee is presently operating !t for

licensed operator requalification training. The simulator will ta

turned back over to Singer Link for modifications prior to delivery

to the site. During the observed requalification cycle, some

simulator usage time was lost due to Singer Link personnel performing

unauthorized work on simulator, but the problem was corrected after

the second occurrence.

The simulator is not being used to its full potential at this time.

The simulator has extensive capabilities for scenario development and

training documentation that are not being utilized at this time. The

instructors are preparing the scenarios and operating the simulator

to provide training to the operators, but do not have enough time to

utilize the machine to its full capabilities. For example, the

simulator can be used to keep a training record for each individual i

operator, but the instructors have not had the opportunity to learn

how to use this capability. The simulator has extensive instructor

override (IO) capabilities that are not often used due to lack of

time to test the more complex functions. To provide training to the

operators, the instructors are limited to using the basic functions

that will accomplish the objectives.

Numerous simulator performance deficiencies have been identified by

the instructors and the operators, but have not been corrected. The

number of deficiencies is not considered unusual for a new simulator,

but the tracking and correction of the deficiencies was observed to

be a weakness. Many of the deficiencies impact the training of the

operators. For example, torus temperature and drywell pressure do

not respond to an addition of heat to the torus. This deficiency had

been identified and documented by the instructors, but did not appear

on the simulator discrepancy report. In many cases, the instructors

are required to provide references to the engineers to justify

problems with simulator fidelity, which is an additional demand on

the limited time available to the instructors.

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Simulator configuration management control was considered a weakness

due to the problems identified with correcting identified simulator

deficiencies and simulator utilization. These problems appear to be

due to limited training department resources. Simulator fidelity

is needed to provide valid training to licensed operators.

3.2 Requalification Examination Preparation

The licensee intends to utilize personnel in addition to the

requalification instructors to prepare for NRC administered [

requalification examinations. The additional personnel will develop  :

the open reference test items and job performance measures that will

be necessary for administration of requalification examinations. The l

licensee intends to sh. ire experience and resources with Limerick in  ;

preparation for the requalification examinations. This was observed  !

to be a strength in the licensee's program. l

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The training department is familiarizing the licensed operators with '

the new format for the examinations during requalification training. 1

Static simulator scenarios were utilized during the observed training

sessions to acquaint the operators with the open reference written

examination format.

4.0 Exit Interview

All observations and findings were discussed with lic9nsee representatives g

during interim exit meetings held following observation of each operating  ;

crew. The inspection scope and findings as detailed in this report were  ;

summarized on September 29, 1988 during an exit interview with licensee

personnel (see paragraph 1.0 for attendees). The inspector determined -

that no proprietary information was utilized during the inspection.

At the exit meeting on September 29, 1988, the licensee committed to

providing an additional four (4) days of simulator training to each of I

th6 operating crews prior to release of the simulator to Singer Link l

for correction of deficiencies and delivery to the site. This training l

will consist of two days of training on control manipulations and TRIP (

procedure usage and two days of transient scenarios for each operating -

crew. Each crew will be evaluated by the licensee during real time  :

scenarios at tht, completion of the training.

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5.0 Telephone Conversation

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The licensee's corrective action to be taken for the weakness in Shift  !

Supervisor use of TRIP procedures and for the individual weakness in  !

command and control ability were discussed in a telephone conversation j

on 10/4/88 between Mr. R. Gallo, Chief, Operations Branch, Division of  ;

Reactor Safety and Mr. D. Smith, Vice President - Peach Bottom. The

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licensee stated that the weakness in TRIP procedure usage would be

addressed by the additional simulator training provided to each crew.

The individual weakness in command and control ability would be addressed

by licensee management and the NRC would be notified of the corrective

action. The effectiveness of the additional training will be evaluated  !

during a followup inspection after the training has been completed. '

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ATTACHMENT 1

Shift Crews Observed:

8/31/88 - Warfel, Shift Manager - SEG 101R, SEG 309R

9/7/88 - Mannix, Shift Manager - SEG 101R, SEG 309R

9/8/88 - Mannix, Shift Manager - SEG 404R, SEG 402R, SEG 310R

9/14/88 - Wasong, Shift Manager - SEG 101R, SEG 309R

9/21/88 - Niessen, Shif t Manager - SEG 101R, SEG 309R

9/22/88 - Niessen, Shift Manager - SEG 404R, SEG 402R

Scenarios:

SEG 101R: Plant Startup Testing -

Full power operation, power decrease with recire, level instrument

failure, RFPT trip, Recirc Pump trip, sinle loop operations

SEG 309R: Main Turbine Load Reject -

Operation at 30*4 power, power increase with control rods, trip of #1

breaker (loss of 1/2 of plant auxiliary loads), load reject (no

scram)

SEG 404R: Of f site Release /RWCU Line Break -

Full power operations, loss of condenser vacuum due to break in

condensate pump suction line, fuel failure, break in RWCU suction

line with failure of RWCU to isolate (leads to offsite release), fire

in SBGT maximizes release rate, failure of SRVs to manually open

SEG 402R: Loss of Conowingo Pond -

Full power operations, earthquake causes dam break (loss of Conowingo

Pond) and loss of offsite power, steam leak in MSL Tunnel

SEG 310R: Loss of Grid / Steam Leak in Drywell -

Full power operations, grid oscillations lead to a load reject and

loss of one offsite power source, steam leak in drywell