ML20215L556

Responds to NRC Re Deficiencies & Weaknessess Identified in Requalification Program Evaluation Rept 50-352/87-07(OL).Corrective Actions:Six Shifts of Senior Reactor Operators Retrained on re-entry of Trip Procedures

ML20215L556
Person / Time
Site:	Limerick
Issue date:	06/19/1987
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Gallo R NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CON-#387-3900, RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, OL, NUDOCS 8706260099
Download: ML20215L556 (6)

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• PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET

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P.O. BOX 8699 PHILADELPHIA. PA.19101 (215) 841 5001 JOSEPH W. G ALL AGHER ucl*.Il"."'.*I"/. . June 19, 1987 Docket No. 50-352 Evaluation Report: 50-352/87-07 Mr. Robert M. Gallo, Chief Projects Branch No. 2 Division of Reactor Projects Region I U.S. Nuclear Regulatory Commission  :

ATTN: Document Control Desk Washington, D.C. 20555

Dear Mr. Gallo:

Your letter dated May 22, 1987 forwarded Requalification Program Evaluation Report 50-352/87-07 (OL) conducted during the period of March 9, 1987 through March 25, 1987 for Limerick i Generating Station. The report addresses deficiencies and i weaknesses identified by the NRC in the operators requalification  !

program. A summary of such deficiencies and weaknesses is stated 4 below, followed by our response.  !

) Deficiency:

87-07-01 Senior Reactor Operators have not been trained to re-enter the Emergency Operating Procedures (TRIPS) following subsequent re-entry conditions. This deficiency was observed during several transient evaluation scenarios conducted on the Limerick Simulator.

Generic Letter 82-33, (NUREG-0737), Supplement 1 requires that operators be trained in accordance with Emergency Procedure Guidelines for upgraded EOP procedures.

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PDR ADOCK 05000352' V PDR.

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a Mr. R. M. Gallo June 19, 1987 Page 2

Response

87-07-01 Between the period 03/16/87 and 04/16/87, all six (6) shifts of Senior Reactor Operators were re-trained, in the classroom and the control room simulator, on re-entry of TRIP procedures following subsequent entry conditions. Situations were discussed in the classroom and several different scenarios were run in the

} simulator which reinforced use and application of TRIP procedure  ;

J (specifically T-101, RPV Control) entry conditions for initial l and subsequent re-entry occurrences. This emphasis on TRIP procedure re-entry will be added to applicable future License Operator Requalification (LOR) training in both classroom and simulator instruction. In each of the first two years (1985 and 1986) of LOR training at LGS Unit 1, TRIP procedures were covered extensively in the classroom and simulator. Cycle 6 of 1987 LOR training will include 8-10 hours of scheduled TRIP training and will be held in January-March 1988.

Deficiency:

87-07-02 Senior Reactor Operators have not been adequately trained to enter the RC (RPV Control) T-101 Trip Procedure. Discussions between the Limerick training department personnel, the Operations Staff Personnel, and the NRC, resulted in a difference of opinion on when to enter T-101 given a scram condition with power above 4% or unknown. Continuity must exist between the Limerick Training Department and Operations personnel to provide appropriate upgrade training to licensed candidates on this issue. The basis for this deficiency is the same as deficiency 87-07-01 above.

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Response

87-07-02 Specific re-training on TRIP entry into T-101 (RPV Control) was provided to all Senior Reactor Operators between 03/16 and 04/16/87 as mentioned in response above. Any difference of opinion which may have resulted between Operations and Training has been resolved by establishment of LGS Operational Transient (OT) Procedure OT-117 RPS Failures. The entry condition to this

Mr. R. M. Gallo June 19, 1987 Page 3 y

procedure is stated as " Failure to SCRAM, Failure to Half-SCRAM or any RPS Instrument / logic malfunction". Training on this procedure was provided to all RO and SRO personnel during Cycle 1 of 1987 LOR, 04/20-05/28/87. OT-ll7 leads the operator directly to T-101 as far as immediate operator rctions. Training given to LOR personnel stressed use of both OT-117 and T-101 in an integrated, logical manner.

Deficiency:

87-07-03 A training deficiency was noted, during the Simulator l examinations, on the proper implementation of Procedure A-7, Conduct of Operations.

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Specifically, the communication, authority and responsibility of the Shift Supervisor and Shift Superintendent was demonstrated as unsatisfactory. This performance deficiency contributed to the i failure of four (4) SRO candidates. I 1

Response

i 87-07-03 Communications re-training for all RO/SRO personnel was specifically stressed during the period 03/16/87 through l 04/16/87. The LGS Operations staff provided the Training Staff with Shift Operations Communications Guidelines, which are now part of the LGS Operations Manual Section 6.2. These guidelines were discussed in the classroom and applied in the simulator to promote greater operator familiarity with standardized techniques of shift communications. Additionally, all LOR simulator training sessions periodically use one SRO to monitor all shift communications during simulator instruction. This SRO will then critique his group and offer suggestions for shift improvement.

During Cycle 2 of 1987 LOR training June 1 through July 9, 1987, a memo from the Vice-President-Nuclear Operations to the Manager, Nuclear Generation Department dated April 2, 1987, is being discussed with all Licensed Operators. This memo reinforces the specific responsibilities of Shift Supervisory Personnel. The memo has been added to LO/ SLO Monthly Required Reading material for May, 1987.

Mr. R. M. Gallo June 19, 1987 Page 4 Deficiency:

87-07-04 A training deficiency was noted, during the Simulator examinations, on the proper implementation of Procedure GP-8, Containment Isolation Reset. Both RO and SRO candidates demonstrated unsatisfactory performance using this procedure. It was noted, by NRC examiners, that discrepancies existed between the actual plant and the simulator for control switch identification.

Response

87-07-04 A thorough review of NSSSS Isolations and GP-8 usage was provided to all Licensed Operators between 03/16-04/16/87. This training refamiliarized each LO/ SLO with GP-8 sections, and proper implementation of containment isolation reset features. The classroom instruction presented was reinforced with actual use of GP-8 during various simulator training scenarios as well. All pertinent control switches utilized to reset or provide containment isolations were discussed in the simulator and differences between the actual control room and the simulator were reiterated. GP-8 and NSSSS Isolation instruction now has a permanent spot in every 2 year cycle of LOR training to periodically reinforce LO/ SLO level of knowledge concerning the many aspects of Containment Isolations.

As for the discrepancies which exist between the actual control room and the simulator, modifications of the simulator to maintain it plant-specific are in progress. Each Simulator Training Scenario has a section which provides that simulator ,

instructors discuss plant vs. simulator differences expected to j be encountered by LO/ SLO personnel before each scenario. This method ensures that any confusion which may result because of different switch position or identification in the simulator does j not hamper the performance of the LO/ SLO in handling simulator l and ultimately plant transients.

Program Weakness:

As a result of the Pilot Program evaluation the following weaknesses were noted in the effectiveness of the Limerick Licensed Operator Requalification Program. j

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Mr. R. M. Gallo June 19, 1987 Page 5 (a) The requalification program, as outlined, does not address what action is to be taken for candidates who perform unsatisfactorily on the simulator examination.

Response

(a) Prior to the next set of LOR Exams, scheduled for November 2, l November 9, and November 16, 1987, the LGS LOR program will be changed to indicate what action will be taken for those ,

LO/ SLO /STA candidates who perform unsatisfactorily on their  !

annual simulator examination. The plan of action will be to remove the LO/ SLO from shift until appropriate remedial 1 training and re-exam can be given. Upon satisfactory re-exam, which will include deficiencies which caused previous failures, LO/ SLO will be released to stand licensed duties j again. Any repeated simulator exam performance deficiencies will, of course, be added to the LOR program as needed for the following year.

Program Weakness (b) The examiners who conducted the simulator exams were different from those who conducted the oral walk-thru exams for the same candidates. This lack of continuity contributed q to no follow-up questioning during the oral examinations for {

deficiencies identified during the simulator examinations. '

Response

(b) For future LGS LOR Annual Operating exams, every effort will be made to utilize the same examiner for specific candidates in both the simulator and in plant oral walk around exams.

If due to instructor / examiner unavailability, the same examiner is not available, then an appropriate turnover of information from the one examiner to another will ensure proper follow-up questioning in the simulator or oral exam.

This requirement will also be added to the LGS LOR program prior to the November, 1987 Annual Simulator exams.

Program Weakness:

(c) Simulator training scenarios and evaluation scenarios were extremely similar. Simulator examination scenarios should differ sufficiently from training scenarios to conduct an effective performance evaluation.

Mr. R. M. Gallo June 19, 1987 Page 6

Response

(c) The new format of LGS Simulator Training Scenarios (STS),

resolves the concern about similarity between training scenarios and evaluation scenarios will be resolved.

Specifically, any evaluation scenario now utilized for LOR Annual Exams will differ from STS's in several ways:

o Initial Conditions (Section II of STS) will be changed.

o The Sequence of Events (Section III of STS) will be modified to add different malfunctions as well as different Simulator Exercise Guides.

o All STS's used for evaluation will also be reviewed and approved by LGS Operations Staff and Training Coordinator to ensure training scenarios used in LOR manipulation training differ sufficiently from evaluations required for annual operating exams.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours, cc: Addressee W. T. Russell, Administrator, Region I, USNRC E. M. Kelly, Senior Resident Site Inspector See Attached Service List