ML18153C516

Discusses Requalification Exam Rept 50-280/OL-90-02 Review. Program Satisfactory,Based Upon Licensed Operator Performance During Comprehensive Battery of Test Administered by NRC

ML18153C516
Person / Time
Site:	Surry
Issue date:	02/01/1991
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
91-004, 91-4, NUDOCS 9102070143
Download: ML18153C516 (8)

Text

• VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 1, 1991 U. S. Nuclear Regulatory Commission Attention:

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

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.: 91-004 SPS/RCB R3 Docket Nos.: 50-280 50-281 License Nos.: DPR-32 DPR-37 REQUALIFICATION EXAMINATION REPORT 50-280/0L-90-02 We have reviewed your letter of January 2, 1991, which provided the requalification examination report for our Surry Nuclear Power Station. The report found that Surry's requalification program remained satisfactory based upon licensed operator performance (92% pass rate) during the comprehensive battery of tests administered by the NRC. Your letter also directed our attention to observations made concerning the facility and its training program and requested that we provide our plans for addressing these observations within thirty days. We note that the observations generally fall into three categories:

training, procedures and facility labeling.

In the training area, we plan to continue to apply significant efforts to the preparation and conduct of requalification examinations.

Our goal is to maintain or improve our performance in this area. Written examination question time validation and job performance measure task scope are under evaluation and will be upgraded as necessary.

An Operations Department Standard for emergency event classification is under preparation.

This standard will be used for training during licensed operator retraining.

In the procedures area, applicable procedures will be changed to require monitoring of Critical Safety Function status trees as directed by the Westinghouse Owners Group Emergency Response Guideline User's Guide. Concerns about clarity of certain steps are being evaluated and will be remedied as appropriate with the issuance of Revision 4 to th,e Emergency Operating Procedures.

The concern over "subjective guidance" in Fire Contingency Action Procedures (FCAs) will be resolved as part of the planned upgrade of these procedures.

With regard to labeling, a comprehensive station-wide project is underway.

This program includes systematic walkdowns, component identification, and relabeling.

Temporary labels may be installed when a label is discovered missing or incorrect.

The labeling concerns identified in the observations will be addressed under this program. -------=--:-::-:~~~"'!~-~, ( 910207014,3 91020 *1 PDR ADOCK 05000280 l V PDR Moo.3 ,,,

• Numerous actions have already been taken as a result of the comments made at the exit meeting held following the site visit. The remaining actions to be taken have been assigned and are scheduled for implementation.

If you have any further questions, please contact us. Very truly yours, \j~ W. L. Stewart Senior Vice President-Nuclear pc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station lt. ACTION PLAN 1990 REQUALIFICATION EXAMINATION REPORT Enclosure 1 Paragraph

1. Responsible Department 3a. Exam administration went very well. It was evident Training 3b. 3c. that the Training Dept. personnel had spent signifi-cant time and effort in putting together this exam; and they were rewarded with a smooth running examination.

An aggressive schedule was developed and adhered to for the most part. When changes needed to be made, the training staff exhibited creativity and flexibility in promptly proposing resolutions to the NRC exam team. Some areas* of examination development have room for improvement particularly with regard to written examination question time validation and Job Performance Measure (JPM) task scope. During a large break Loss of Coolant Accident (LOCA) simulator scenario, the three SROs examined in the . Shift Supervisor (SS) position exhibited a wide range of interpretations for evaluating the Emergency Action Levels (EALs) in this situation.

Such cation diversity for the same transient was expected and may be indicative of a procedural or training weakness.

3d. It was noted that monitoring of Critical Safety Function (CSF) status trees is not initiated at the same time at Surry as it is at her sister plant ,. North Anna. The Training Dept. acknowledged that the Westinghouse Owners Group (WOG) Emergency Training Operations/

Training Action None Evaluate & implement appropriate actions to address concerns. N/A Prepare a conservative Standard for event fication so that Training may be completed during 2nd 1991 LORP training session. N/A

• 3/31 /91 (Eval. only) 5/24/91 (FIRM)

• Response Guideline (ERG) User's Guide (66898:1, p. 16) directs monitoring of the status trees whenever Enclosure 1 Responsible Paragraph

1. Text Department Action CTS Due (3d continued) a transition from one ERG to another occurs Procedures PAR ODAP to provide 2/28/91 or when directed to monitor the status trees by documented guidance for (FIRM) E-0. However, Surry modifies these rules of usage monitoring CSFs during

• depending on the situation which may or may procedure transitions or not include monitoring of the status trees when as directed.

specified by the User's Guide. This "conditionally preferable application" of the various rules of usage related to monitoring of the CSF status trees is not documented in station procedures and could lead to operator confusion during an emergency.

3e. The hole for the locking pin to the cover of 1-CW-Maintenance Investigate

& elimi-2/28/91 117, "Discharge Tunnel Vacuum Breaker" is very nate mechanical tight. Most operators were unable to remove the locking pin without some form of mechanical bindin_g.

assistance.

This valve must be available for opening in an emergency and should be easily accessible to the operators.

• 31. Labels on valves in the plant ("dog tags" were Configuration Evaluate & implement 2/28/91 very difficult to read, in general, and pre-Management actions consistent (eval. sented a burn hazard when attached to with labeling project only) bonnets of high temperature.

systems such objectives.

as the Main Steam System. 3g. Labeling for the Semi-Vital Bus feeder Configuration Evaluate & implement 2/28/91 breaker 2H1-2A1 is not consistent with Management actions consistent (eval. that given in AP-10.05, "Loss of Semi-Vital with labeling project only)

Enclosure 1 Paragraph

1. 3h. 3i. 3j. Bus and AC Distribution Panel" which calls it 2H1-121 A. This led to confusion among the operators during the JPM exams. Emergency Contingency Action (ECA) pro-cedure 1-ECA-0.0, "Loss of All AC Power", Attachment 1, Part 1, Step 4, directs the operator to "Locally open or verify open ALL breakers on MCC 2J1-1." Subsequently, in Part 3, Step 4, the procedure directs the operator to "Locally close ALL breakers on MCC 2J1-1." Since there are several breakers that are tagged open or have "open" as their normal position, the pro-cedure is unclear as to how the operator should handle these breakers.

Some operators closed ALL the breakers per procedure, others read i_ntent into the pro-cedure and "closed in" only those breakers originally shut. Procedure 1-ECA-0.1, Attachment 1, Part 1, Step 1, says to put 1-VS-F-18 in pull-to-lock (PTL). The label on the Main Control Room (MCA) switch only reads "1 B" objectives.

Procedure 1-ECA-0.1, Attachment 1, Part 1, Step 2, directs the operator to "Locally verify MCC 1J1-I supply breaker 14J-16 is open". The label on the panel reads "14J1-6" and is not labeled as Responsible Department Procedures Configuration Management Procedures objectives Action Evaluate & include appropriate changes in Revision 4 to EOPs. Evaluate & implement actions consistent with labeling project Evalute & include appropriate changes in Revision 4 to EOPs. 3/31 /91

• 2/28/91. (eval. only) 3/31 /91 *j "MCC 1J1-1 supply breaker".

As a result, one operator was unable to find this breaker to properly perform the step. * *

• • -, Enclosure 1 Paragraph

1. 3k. 31. -3m. ,, Labeling for Instrument Air Compressor C-1) breaker 1J1-221 on the 1J1-2 bus is not consistent with that given in 1-ECA-0.1, "Loss of All AC Power Recovery Without SI Required", Attachment 1, Part 2, Step 1 (1J1-2E 2A). The qperators relied upon the title of the component to perform the step, but were uncomfortable in doing so without having the breaker designations match as a second check. Responsible Department Configuration Management Fire Contingency Action (FCA) procedure FCA-1.01, Procedures "Limiting MCR Fi re", Steps 1 Ob and 1 Oc on page 4 of 17 direct the operator to "disable" (emphasis added) the Main Steam Trip Valves (MSTVs). These switches have an "Emerg. Close" position which accomplishes this goal. While no operators missed this step, it may be better if the procedure directed the operator to perform the positive action of placing the appropriate switches to the "Emerg. Close" position rather than the subjective guidance of "disabling" the valves. Functional Restoration (FR) procedure 1-FR-H.1, "Response to Loss of Secondary Heat Sink", Attachment 1, Part 3, provides for lining up Fire Main water to the suction of the Auxiliary water (AFW) pumps. This procedure involves opening two isolation valves (2-FW-120 and 2-FW-185) from the Fire Main System, closing a tell-tale drain valve (2-FW-119) and then lining up the remainder of the AFW system to accept Fire Main water to the AFW pump suction lines. The Action Evaluate & implement actions consistent with labeling project jectives.

Include as part of FCA upgrades.

~,-2/28/91 1992/ 1993 * *

-I Enclosure 1 Paragraph

1. (3m continued) facility evaluator indicated that the expected operator action in this situation was to close the tell-tale valve PRIOR to opening the two isolation valves to prevent flooding in the Unit 2 guards Building (despite the valve manipulation sequence given in the procedure).

None of the six SROs examined on this task closed the tale valve first. They followed strict procedural compliance.

Operator performance was judged to be satisfactory despite not meeting desired sequencing (non-critical) criteria.

Responsible Department Procedures Action Complete.

N/A N/A * *