IR 05000155/1993018
| ML20059G199 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/28/1993 |
| From: | Jordan M, Mcneil D, Shembarger K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059G173 | List: |
| References | |
| 50-155-93-18, NUDOCS 9311080034 | |
| Download: ML20059G199 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-155/93018(DRS)
Docket No. 50-155 License No. DPR-6 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Big Rock Point Nuclear Plant Inspection At:
Charlevoix, Michigan Inspection Conducted: October 18 - 22, 1993 Inspectors:,l'Thenw0bc A lo/ap/g2, D. McNeil 0 V Date
$ D N M Qs DIOh{Q.>
K. Shemba ger" Ifa'te Approved:
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M. J.; Jordan, Chief Date Operator Licensing Section 1 Inspection Sumary:
Inspection conducted durina the week of October 18. 1993 (Report No. 50-155/93018(DRS))
Area Inspected:
Licensed Operator Requalification Training Program in accordance with NRC Temporary Instruction 2515/117.
Results: One violation of 10 CFR 50 requirements and one open item were identified.
In addition, several program strengths and weaknesses were identified, and other observations were made.
Apparent Violation:
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Failure to provide all required requalification training to all licensed'-
operators during the 1991/1992 requalification training program in accordance with 10 CFR 50.54(i-1) and 10 CFR 55.59(c).
(Section 2.10)
Open Item:
Lack of minimum requalification program requirements pertaining to
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program content.
(Section 2.10)
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9311080034 931101 PDR ADOCK 05000155 G
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Program Strenaths:
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Quality of requalification training program task matrix.
(Section 2.1)
Formation of a Curriculum Committee.
(Section 2.10)
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Establishment of Alignment Meetings.
(Section 2.10)
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Control of medical examination requirements.
(Section 2.10)
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Procram Weaknesses:
Requalification program feedback process was not closed-looped.
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(Section 2.6)
Lack of training and evaluation to ensure instructor proficiency.
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(Section 2.7)
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Implementation of the process for providing waivers from requalification training.
(Section 2.10)
Examination security.
(Section 2.12)
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Other Observations:
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Evaluator control of simulator examination administration.
(Section 2.4)
Lack of a root cause analysis for a simulator crew failure.
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(Section 2.9)
Requalification training makeup cycle.
(Section 2.10)
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Improvement in simulator development and usage.
(Section 2.11)
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REPORT DETAILS 1.0 Persons Contacted Consumers Power Company
- G. Withrow, Plant Safety & Licensing Director
- M. Bourassa, Senior Licensing Engineer
- T. Hagan, Director Nuclear Training
- D. Lacroix, Training Administrator
- W. Merwin, Operating Experience Coordinator
- G. Rowell, Instructional Technology Specialist
- D. Staton, Senior Nuclear Instructor
- W. Trubilowicz, Operations Manager t
U. S. Nuclear Reculatory Commission
- R. Leemon, Senior Resident Inspector, Big Rock Point Nuclear Plant
- Denotes-those present at the exit meeting on October 22, 1993.
Other persons were contacted as a matter of course during the inspection.
2.0 Introduction The purpose of this inspection was to perform a review of your licensed operator requalification training program in accordance with NRC Temporary Instruction 2515/117. The inspection focused on the content and effectiveness of your licensed operator requalification training program, which included a
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review of the following areas:
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Adequacy of selected facility licensee developed written and operating examinations.
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Significant operator errors that have occurred that may have been a result of ineffective training.
Facility licensee's process for identifying operator performance
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deficiencies and incorporating them into the evaluation portion of-the training program.
Facility licensee's effectiveness in conducting written
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examinations and operating tests to ensure operator mastery of program content.
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Facility licensee's use of objective performance standards when conducting evaluations and critiques of operators and crews to
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determine whether pass / fail decisions were made objectively.
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Effectiveness of the licensee's process for revising its
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continuing training program to maintain it up-to-date, including the use of student feedback.
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Adequacy of the licensee's process to train and evaluate the licensed operator training staff.
Training conducted as a result of operator errors that have
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occurred over the past two years to determine the effectiveness of the training.
Previously administered remedial training to ensure it adequately
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addressed licensed operator crew performance weaknesses.
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Facility's process for managing the requalification training program to ensure compliance with 10 CFR 55.
Simulator performance and its fidelity to the reference plant to
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determine if it was adequate to support the requalification program, and the safety impact of any negative training caused by simulator inadequacies.
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Adequacy of administrative procedures that were in place that ensure the integrity of examinations and tests, and observation of exam activities during the inspection week and review of the associated exam results for any indications of examination compromise.
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Quality Assurance involvement in the area of licensed operator requalification training.
2.1 Adeauacy of selected facility licensee developed written and oDeratinQ examinations.
A review of the current module operating examinations developed by the facility was performed using the associated exam review checklists in Appendix A of TI 2515/117, NUREG/BR-0122 and NUREG-1021. The following observations were made during the review:
The comprehension level tested on the current module examinations was
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comparable to the comprehension level tested on the two previously administered NRC examinations.
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The examinations were constructed in accordance with the facility's sample plan.
The requalification program task matrix contained significant detail,
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providing a quick means for cross-referencing learning objectives to the associated training material. The task matrix was considered a program strength.
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The facility licensee used lesson plans and learning objectives for the requalification program under review to construct the examinations, as denoted in the facility's sample plan.
Objective performance standards were utilized for the operating
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examinations administered during the current module.
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The written examinations administered in 1991 and 1992 were developed to discriminate at the appropriate level.
(Written examinations were not administered in 1993.)
In addition, the examinations adequately sampled the items stated in 10 CFR 55.41 and 10 CFR 55.43.
l The dynamic simulator scenarios administered in 1993 adequately sampled
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the items stated in 10 CFR 55.45.
In addition, the scenarios clearly noted the objectives of the individual malfunctions and the success paths expected to be taken by the operators.
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The JPMs administered in 1993 were found to be acceptable and challenging to the operators. The JPMs had clear performance standards for evaluator use. Critical tasks were clearly marked to assist the evaluator administering the examination.
2.2 Sionificant oDerator errors that have occurred over the past two
years that may have been a result of ineffective trainino.
A review of Big Rock Point Station Licensee Event Reports (LER) was performed to determine if significant operator errors may have been a result of ineffective training. Results of the review did not identify significant operator errors during the past year. However, it was determined that the i
licensee has a process for reviewing events for operator errors that may have
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resulted from ineffective training.
2.3 Facility licensee's process for identifyino qperator performance deficiencies and incorporating them into the evaluation portion of the trainina procram.
The inspectors reviewed the licensee's process for identifying operator performance deficiencies and incorporating them into the evaluation portion of the training program, and found the process to be adequate.
It was identified that the facility licensee had identified operator performance deficiencies during their review of various event reports at the station, and incorporated them into the training and evaluation portion of the train _ing program.
2.4 Facility licensee's effectiveness in conductina written examinations and operatina tests to ensure oDerator mastery o_(
Drocram content.
The inspectors interviewed licensed operators and training instructors and observed.the administration of the operating examinations administered during the inspection week to determine the facility licensee's effectiveness in conducting operating tests to ensure operator mastery of program content. The following observations were made during the review:
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Overall, the exams were conducted as planned. However, during the i
administration of the dynamic simulator examination, weaknesses were identified in evaluator control.
For example, when reactor pressure did
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not increase following an ATWS condition as planned, the evaluators input a rapid pressure increase into the simulator, to drive the
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operators to take actions as planned in the scenario.
By adjusting reactor pressure, the evaluators placed the simulator in a condition that did not accurately reflect the conditions that would occur in the plant.
Overall, the facility licensee's examination schedule facilitated
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reducing undue operator stress.
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Overall, critiques of operators and crews after the simulator examination were effective in denoting both strengths and weaknesses.
However, it was noted that usage of post exam questioning to followup on observed deficiencies was minimal, which led to speculation of why
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certain actions were taken.
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Management guidance parallelled the actual conduct of testing as it was
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observed.
2.5 Facility licensee's use of objective performance standards when conductina evaluations and critiaues of operators and crews to determine whether pass / fail decisions were made objectively.
The inspectors interviewed training instructors and a training supervisor, reviewed written performance standards, and parallel graded selected operating examinations to determine if the facility licensee used objective performance standards when conducting evaluations and critiques of operators and crews to
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determine whether pass / fail decisions were made objectively. The performance standards were found to be clear and relevant, and used consistently and objectively by facility evaluators.
2.6 Effectiveness of the licensee's process for revisina its clntinuina trainina program to maintain it up-to-date. includina lhe use of student feedback.
i The inspectors interviewed licensed operators and training personnel to determine the effectiveness of the licensee's process for revising its continuing training program to maintain it up-to-date, including the use of student feedback. The following observations were made:
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The instructor assigned to administer training on a given topic was required to other develop a new lesson plan or revise an associated lesson plan prior to its use to include changes in plant design and applicable procedures, and to include appropriate industry and plant specific events. Review of associated documentation revealed that the method used to upgrade training material appeared to be adequate.
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Although student feedback was solicited on requalification training, the
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feedback process was not closed looped, in that the licensee providing comments on training did not always get feedback on the resolution of the issue. Without resolution feedback, the student may not believe his/her recommendations were acted upon. Student participation may then decrease.
Lack of a program requirement to provide resolution on
program feedback to students was considered a program weakness.
2.7 Adeauacy of the licensee's process to train and evaluate the licensed operator trainino staff.
The inspectors interviewed training instructors and a training supervisor, reviewed station procedure NT-004, " Personnel Certification and Training,"
Rev. 2, and Instructor Training Program procedure "NT Program 25," Rev. 4, and reviewed qualification evaluations for three instructors. The inspectors identified that although a continuing training program for the licensed operator training staff existed, the program did not include continuous training on proper instruction in the simulator or in the plant.
In addition, the training program did not include evaluation of the instructor's ability to administer exams to licensed operators in the simulator or in the plant.
Lack of a training and evaluation process to ensure instructors remain proficient in these areas is considered a program weakness.
2.8 Trainina conducted as a result of operator errors that have occurred over the past two years to determine the effectiveness of the trainino.
A review of the process for including training on operator errors was performed.
It was determined that training on LERs, Deviation Reports, and other identified deficiencies was provided in the form of classroom training on a continuing basis.
Overall, the process for including training on operator errors appeared to be adequate.
2.9 Previous 1v administered remedial trainino to ensure it adeauately addressed licensed operator crew performance weaknesses.
A review of remedial training for a crew that failed the 1992 dynamic simulator examination was performed to ensure it adequately addressed licensed operator crew performance weaknesses. During the review, the inspectors identified that the documentation for the crew failures did not identify. the root causes for the failures.
For example, the evaluation for one of the operators only indicated that the operator failed to recognize and take action required in E0P 02. Without an indepth review to determine why the operator failed to recognize and take the required action, appropriate remedial training and re-evaluation cannot be assured, thus operator weaknesses may not
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be improved upon.
2.10 Facility's process fcr manacina the reaualification trainino I
procram to ensure compliance with 10 CFR 55.
Through interviews with training personnel, review of Administrative Procedure 1.7.2, " Operator Training," Rev. 3, and review of Nuclear Training I
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Program procedure NT PROG. NO. 4.1, "BRP Nuclear Operator Training," Rev. 3, the inspectors identified one apparent violation of 10 CFR 55 requirements, one open item, and several program strengths and weaknesses.
In addition, other observations were made.
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10 CFR 50.54(1-1) requires the licensee to have in effect, within three gnonths after issuance of an operating license, an operator requalification program which must as a minimum meet the requirements of 10 CFR 55.59(c).
10 CFR 55.59(c) requires in part, a requalification program that is conducted for a continuous period not to exceed two years.
During a review of the attendance records for the 1991/1992 requalification training program, it was identified that several licensed operators did not receive continuous training on all required requalification training during the two year training program.
Discussions with the training administer revealed that weaknesses in control of attendance records and a miscommunication between himself and his training staff on providing makeup training contributed to the failure of the training department to provide all required training to all licensees.
Failure to conduct the 1991/1992 requalification training program within the two year requirement is an apparent violation of NRC requirements (50-155/93018-01(DRS)).
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During the inspection, it was identified that minimum requalification
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program requirements pertaining to program content had not been
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established. Without identifying e minimum set of knowledge and abilities that licensed operators mest be trained on to remain proficient in their ability to resporfi to a range of events, and without i
establishing a predefined periodicity in which the operators would receive the training, the ability of the licensed operators to effectively respond to the events could decrease. The lack of minimum requalification program requirements is considered an open item (50-155/93018-02(DRS)).
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Formation of the Curriculum Committee to develop, review and revise the Licensed Operator Requalification Program appeared to be an effective and efficient means of soliciting feedback ; rom licensed operators on their training needs, and was considered 6 srogram strength.
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Recent establishment of the Shift Supervisor / Training Instructor alignment meetings appeared to provide for an opportunity to improve the working relationship between the operations and training departments to reach common goals. The implementation of the alignment meetings was
considered a program strength.
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Facility control of ensuring medical requirements were satisfied was
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considered a program strength.
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Implementation of the process for providing waivers from requalification training was considered a program weakness.
Specifically, it was revealed that instructors that develop and present simulator training receive a waiver from attending simulator training.
In addition, it was identified that a licensee who was involved in the revision of the E0Ps i
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was waived from the E0? simulator training. Although waivers from classroom training for the development of training material and revision of procedures is appropriate, it does not replace the training and experience gained from full participation in a simulator training course, which allows licensees to exercise their abilities in areas such as responding to control room indications, command and control, communications, and team work.
Review of the annual training schedule revealed that a makeup training
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cycle is provided at the end of each year, after annual exam administration. The purpce of this training cycle was to allow time for licensees to make up missed training.
Providing makeup training before the annual exam would provide the licensees with a more effective approach to training and evaluation.
In addition, establishing a five week cycle each year for makeup training could lead to the perception that attending scheduled training is not of high importance.
2.11 Simulator performance and its fidelity to the_rpference plant to determine if it was adeauate to sVQDort the reaunlification procram, and the safety impact of acv n;aative trainino caused by simulator inadeauacies.
During review of simulator performance and its fidelity to the plant, the
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inspectors found that overall, the simulator was adequate to support the requalification training program.
In addition, the inspectors made the following observations:
Improvement in the area of simulator development and usage was observed.
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In addition, during interviews with operations and training personnel, it was noted that the simulator was viewed as a significant asset to the training effort.
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The inspectors reviewed the Simulator Physical Fidelity Analysis and the Simulator Deficiency Report Log. During the review, it was identified that an active program was in place to discover and correct simulator errors.
In addition, operators were invited to participate in ficding
and correcting simulator errors to improve simulator performance.
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During administration of the dynamic simulator exam, simulator fidelity
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issues were identified and are described in Enclasure 3 of this report.
2.12 Adecuacy of administrative procedures that were in place that -
ensure the integrity of examinations and tests. and observation of i
exam activities durina the inspection week and review of the associated exam results for any indications of examination compromise.
The inspectors interviewed training instructors, observed exam administration during the inspection week and reviewed exam results for any indications of j
examination compromise. Although no concerns related to exam compromise for the observed exams were identified, a concern relating to question duplication was identified.
Specifically, it was identified that controls do not exist to
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year-to-year, and (2) annual exams from week-to-week. Without program controls, an excessive amount of duplication could occur, which could affect the validity of the exam.
In addition, it was identified that an instructor, after. signing a security agreement associated with development of the annual examination, provided training to licensees in the requalification program. Although this was identified by the facility licensee, the inspectors concluded that the
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violation of the security agreement, in conjunction with the lack of controis-to limit exam duplication, constituted a program weakness in the area of examination security.
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2.13 Quality Assurance involvement in the area of licensed operator recualification trainina.
Quality assurance involvement in she area of licensed operator requalification training was reviewed. The inspectors determined that routine and special audits of the training program were performed, one which was requested to identify the root causes of the examination failures that occurred during the April, 1992, NRC administered exams. The inspectors found that although the special audit was indepth, the routine audits focused primarily on documentation review. A more performance based approach to program review
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should be incorporated into the quality assurance function.
3.0 Exit Meetinc
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An exit meeting was conducted on October 22, 1993, at the Big Rock Point Nuclear Plant to discuss the major areas reviewed during the inspection, the apparent violation of NRC requirements, the open item, the strengths and weaknesses identified, and the other observations made during the' inspection.
Licensee representatives and NRC personnel in attendance at this exit meeting are documented in Section 1.0 of this report. The inspectors also discussed
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the likely informational content of the inspection report with respect to documents reviewed by the team during the inspection. The licensee did not identify any documents or processes as proprietary.
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Enclosure 3 SIMULATION FACILITY REPORT Facility Licensee:
Big Rock Point Nuclear Plant Facility Docket No.: 50-155 Inspection conducted: October 18 - 22, 1993 This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of noncompliance with 10 CFR 55.45(b).
These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluations. No licensee action is required in response to these observations.
While conducting the simulator portion of the operating tests, the following items were observed:
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i ITEM DESCRIPTION Event Repeatability The simulator may have a problem with repeatability of events. This was demonstrated on Friday during dynamic simulator scenario G1. The scenario was
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designed to cause a high reactor pressure and have the operators respond to the high pressure. The initiating conditions were tested and responded as anticipated during the scenario dry run. However, during the actual examination, rcactor pressure steadied out at a value that roquired no further
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action on the part of the operstors.
This is significant and requires. attention.
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simulator is not accurately repeating events, there is a flaw in its software. Negative training is the
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result of training with a simulator with flawed software.
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