ML20249B484
| ML20249B484 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/17/1998 |
| From: | Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-277-98-04, 50-277-98-4, 50-278-98-04, 50-278-98-4, NUDOCS 9806230205 | |
| Download: ML20249B484 (8) | |
Text
J John Doering. Jr.
j Vice President Peach Bottom Atomic Power Station v
PECO NUCLEAR
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A nit of PECO Energy gpa P 7
032 Fax 717 456 4243 E maiidoenng@peco-energycom June 17,1998 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn.: DocumentControlDesk
-Washington,DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violations (Combined Inspection Report No. 50-277/98-04 & 50-278/98-04)
Gentlemen:
In response to your letter dated May 14,1998 which transmitted the Notice of Violations concerning the referenced inspection report, we submit the attached respon se. The subject report focused on the licensed operator re-qualification training (LOF T) program and maintenance rule baseline inspection open items inspections that were conducted from March 9 through April 3,1998.
If you hav an questions or desire additionalinformation,do not hesitate to contact us.
/
l John Doering, Jr.
Vice President, Peach Bottom Atomic Power Station Attachments 9806230205 990617 r
MT/mt PDR ADOCK 05000277.
G POR cc:
N.J. Sproul, Public Service Electric & Gas h
R. R. Janati, Commonwealth of Pennsylvania e
H. J. Miller, US NRC, Administrator, Region I A. C. McMurtray, US NRC, Senior Resident inspector R. l. McLean, State of Maryland A. F. Kirby ill, DelMarVa Power CCN 98-14039
- bec:
OEAP Coordinator -
. 62A-1, Chester' brook
-. Correspondence Cont,ol Program 61B-3, Chesterbrook
- NCB Secretary (11)
. 62A-1, Chesterbrook G. R.- Rainey '
63C-3, Chesterbrook J. Doering.
SMB4-9, Peach Bottom 4
- J. B. Cotton.
62C-3, Chesterbrook j
T. J. Niessen.
53A-1, Chesterbrook l
E. J. Cullen -
S23-1, Main Office
{
T.A.'Shea
- SMB4-6, Peach Bottom G. D. Edwards
. 62A-1, Chesterbrook J.' G. Hufnagel 62A-1, Chesterbrook C. J. McDermott S13-1, Main Office i
M. E. Warner
. A4-1S, Peach Bottom q
G. L. Johnston -
SMB3-5, Peach Bottom R. L. Gambone
. A4-1S, Peach Bottom
.R.A.Kankus 61C-1, Chesterbrook G.J.Lengyel A4-4S, Peach Bottom M.J. Taylor -
A4-5S, Peach Bottom
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RESPONSE TO NOTICE OF VIOLATION 98-04 Restatement of Violation Violation 1 10 CFR 50.54(i-1) requires that the facility licensee shall have in effect an operator re-qualification program which must as a minimum, meet the requirements of 55.59(c).10 CFR l
55.59(c) requires, in part, that in lieu of paragraph (c)(4) of this section, the Commission may approve a program developed by using a systems approach to training (SAT).10 CFR 55.59 (c)(4) requires, in part, that the facility licensee re-qualification program shall include comprehensive written examinations and annual operating tests which determine areas in which retraining is needed to upgrade reactor operator and senior reacto~r operator knowledge.
Peach Bottom's SAT-based re-qualification program procedure POC-2.4, " Licensed Operator Re-qualification Training", requires in part, that subsequent examinations shall be designed to be greater than 40% different than previous examinations developed for the same annual operating test.
Contrary to the above, from January 1998 to March 13,1998, the facility licensee administered the annual operating test to operators in a manner such that examination test item sample selection was not sufficiently comprehensive. Specifically, there was a pattern of overlap in that every JPM set was used at least twice on two different crews on different examination weeks.
This resulted in 0% difference when comparing any two particular crews which got the overlapping JPM sets.
This is a Severity Level IV violation (Supplement 1).
Violation 2 10 CFR 55.59(a)(2)(ii) ;equires, in part, that the operating test will require the licensed senior operator to demonstrate the ability to perform the actions necessary to accomplish a comprehensive sample of items specified in part 55.45(a)(2) through (13) inclusive to the extent applicable to the fac;lity 10 CFR 55.45(a)(11) requires, in part, the licensed senior operator to demonstrate the ability to execute the emergency plan.
Contrary to the above, operating tests administered from January to March 1997 and from January through March 13,1998, did not require licensed senior reactor operators fulfilling the role of the Control Room Supervisor to demonstrate on a sampling basis their ability to execute the emergency plan.
This is a Severity Level IV violation (Supplement 1).
Violation 3 10 CFR 50.65(b) established the scope of the monitoring program for selection of safety-related and non-safety related structures, systems or components (SSCs) to be included within the maintenance rule program.
The monitoring program shall include, in part, non-safety related SSCs that are used in the plant emergency operating procedures.
Contrary to the above, as of April 1,1998, the licensee failed to include the area radiation monitoring system
- within the scope of the maintenance rute program. The area radiation monitoring system is a nonsafety,
r; lated system used in the plant emergency operating procedures.
This is a Severity Level IV violation (Supplement 1).
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i Backaround information 4
Violation 1 The Peach Bottom Job Performance Measures (JPM) portion of the annual and biennial operating exam was defined as those JPMs that were developed and administered during a given week. A subset of this exam w:s reused to prepare an exam to be administered later in the exam cycle that was greater than 40 percent -
i different. The JPM exam should have been defined as those JPMs administered to an individual. Based upon this when JPMs were reused to develop additional exams a zero percent difference between two administered exams existed.
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Violation 2 LORT exam development is performed using the skills, knowledge and on-the-job experience of the Nuclear Licensed Operations training instructors and the NRC examiner standards as a guideline 10 CFR 55.45 provides a listing of the information that is to be included in the operating tests administered to holders of re ctor operator and senior operator licenses. This section requires the individual to demonstrate an understanding of and the ability to perform the actions necessary to accomplish a representative sample from 3
cmong the list of 12 items, one of which deals with the emergency plan. LORT course plan POC-2.4 is the j
guidance document for development and administration of the exams to the licensed operator. There is no section in this course plan that specifically states the information to be considered as pad of the sample plan th;t would include the evaluation items from 10 CFR 55.45. It is from this document that the required LORT cxams are generated. This led to the development of the exam which excluded the evaluation of the Control Room Supervisors in their ability to properly implement the Emergency Plan in the operating portion of the cxam. Implementation of the emergency plan by the CRS did not have a rating that would require inclusion in the Biennial Operating exam.
l Violation 3
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While closing open items generated during the Maintenance Rule Baseline inspection, the NRC identified that Ar;a Radiation Monitors (ARMS) used in Emergency Operating Procedures (EOPs) were not included in the scope of the Maintenance Rule contrary to 10 CFR 50.65.10 CFR 50.65 requires that non-safety related l
equipment that is used in EOPs be within the scope of the Maintenance '.ule. Additional guidance in r
interpreting this requirement is given in NUMARC 93-01. NUMARC 93-01 states that for non-safety related Systems, Structures and Components (SSC) to be considered important, the SSC must add significant value t3 the mitigation function of an EOP by providing the total or a significant fraction of the total functional ability required to mitigate core damage or radioactive release. PECON has defined significant mitigation as the cbility of the SSC to successfully fulfill the necessary function during an event at the point in the EOP when it b directed to be placed in service. The significance of the mitigation function should be based on the actions j
required and the impact the particular SSC will have on the event. This PECON definition focuses on the j
capability of the device to directly mitigate the event. However, the NRC has interpreted this requirement to be the equipment's ability to perform a significant mitigation function by allowing performance of the EOP. In this particular situation, if ARMS were not available then the secondary containment radiation control leg of T-l 103, " Secondary Containment Control" could not be completed.
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Reason (s) For The Violation Violation 1 One apparent cause for this violation was identified in that, the methodology to meet the forty percent difference of the Job Performance Measures exam was not clearly defined in the present Licensed Operator Requalification course plan. The lack of guidance resulted in, as seen by the inspector, a 100 p:rcent duplication of a JPM exam in the 5'" administration of the exam. This duplication raised the issue of potential compromis'e of the exam. The event investigation indicates that the exam was not compromised for the following reasons.
Individuals are briefed, prior to administration of the exam, that no aspects of the exam are to be o
discussed with other trainees until the conclusion of the exam period.
By the time a set of five JPMs were reused, 32 operators had been tested with various combinations o
of 53 JPMs. Until the first repetition of the five JPMs, each set of two operators received a new set of JPMs. Knowledge of a specific JPM set in the 5'" administration of the exam would have required the individual to interview 32 previous trainees.
No anomalies in exam performance were observed during the 5'" administration of the exam or o
subsequent administration of the exam.
Violation 2 The event investigation identified that the Control Room Supervisors ability to properly implement the Emergency Plan had not been captured in LORT Course Plan 2.4..The requirements of 10 CFR 55.45 wtre not captured in any documented formal process for the development of the Licensed Operator cxam. This omission prevented the identification of any potential weaknesses in the skills and knowledge of the Control Room Supervisor SROs regarding the implementation of the Emergency Plan.
Violation 3
/wo apparent causes were identified in the event investigation. One being personnel predispostioned to to meaning of mitigator as PECO has used in MR determinations and the other the inadequate i
incorporation of operating experience into the Maintenance Rule, in both accident and probabilistic safety
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assessment analysis a mitigator or something that mitigates, had been defined as something that performs an active finiction to reduce the effects of the event in progress. This is well beyond s:mething thei simply performed a notification or indication function. When NUREG-1526 was issued cnd discussed at an information conference, the example of how another plant interpreted the meaning of NUREG 93-01 guidance was thought by PECON to be one of several ways to meet the requirement. Due to this predisposition, the PECON defined way was thought to be an acceptable way to comply with the r:quirements of the regulation. In addition, during the NRC baseline inspection, scoping of the M intenance Rule was found to be satisfactory and therefore did not trigger a re-examination of the PECON interpretation of significant mitigator.
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Corrective Steps That Will Be Taken To Avoid Further Violations
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Violation 1 A well defined process will be developed to ensure compliance with the 40 percent JPM exam difference are met for annual and biennial exams. This process will be captured in the LORT course plan POC-2.4.
Violation 2 Immediate corrective actions were to examine a representative sample of Control Room Supervisor (CRS)
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SROs to determine their ability to.mplement the Emergency Plan. This was done satisfactorily by all 12 CRS
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SROs sampled. This sample, in addition to the Shift Managers sampled, represents greater than 50 percent I
of the population of all SROs. Licensed Operator Requalification Course Plan POC-2.4 will be revised to include a process to ensure that the requirements of 10 CFR 55.45(a)(2)-(13) are satisfied.
Violation 3 Area radiation monitors were included in the Maintenance Rule scope for the plant and other lessons learned that are documented in NUREG-1526 have been evaluated for incorporation under the Rule. All Off Normal (ON), Operational Transient (OT), Special Event (SE), and Trip (T-200 and T-100 series) procedures were cl:o reviewed to identify SSCs that are used as significant mitigators in EOPs that may be covered by the M:intenance Rule.
Shift Mr.naaement Oversiaht In the Notice (,* Violation letter dated May 14,1998, you requested that we address the weakness of the Shift
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Mrnagers in their oversight of the Control Room Supervisor (CRS), and any corrective actions planned or taken. Expectations regarding Shift Manager oversight of Control Room Supervisors is clearly defined in the Operations Manual. Specifically, section 2.2.3. of OM-P-3.2, " Senior Licensed Operators", requires that the shift manager continually evaluate Operations Shift Team personnel performance, alertness and attentiveness cnd provide instructions, guidance, or counsel as required. Contrary to the requirements of the Operations Manual, Management's expectations were not carried out or reinforced by the Shift Managers. During Licensed Operator Requalification training, instances where Control Room Supervisors performance does not meet expectations and the Shift Manager fails to address the performance are identified and discussed during the post-training critique. In a similar manner, evaluation of Control Room Supervisor performance during the operating portion of the biennial exam identified instances where three-part communication, Emergency Operating Procedure flow chart mark-up and crew briefings did not meet expectations. In some instances, the Shift Manager did not address the Control Room Supervisor performance during the dynamL portion of the cxam. The post-exam critique identified these performance issues and assessed their impact on exam grade.
It was determined that these incidents represented an area for improvemer.t, since the Control Room Supervisor performance and Shift Manager oversight did not meet expectations but that the overall evaluation was satisfactory.
The Senior Manager of Operations met with the Shift Managers to ensure a clear understanding of expectations. The Senior Manager Operations also issued a letter to all licensed holdert explaining recent performance issues, reinforcing expectations and immediate corrective actions. Thes'.s areas for improvement h ve been communicated with the individuals involved. These performance issues will continue to be cssessed and critiqued during 1998 LOR year program.
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Drte When Full Compliance Will Be Achieved Violation 1 The process for exam development to ensure required minimum overlap will be completed and incorporated into the LORT course plan POC-2.4 prior to the development of the next Annual LOR Operating Exam in January 1999.
l Violation 2 The examination of a representative sample of Control Room Supervisor SROs to determim their ability to implement the Emergency Plan was completed by April 30,1998. Licensed Operator Requalification Course Plan POC-2.4 revisions will be completed prior to the development of the next Annual' LOR Operating Exam in January 1999. This revision willinclude a method to ensure the requirements of 10 CFR 55.45 are captured.
Violation 3 Area radiation monitors were incorporated into the scope of the Maintenance Rule on April 3,1998. A review of SSCs identified in procedures that may need to be included under the Maintenance Rule was completed on June 5,1998. Ten SSCs were identified as needing further review for possible inclusion. This review will be completed by July 31,1998.