IR 05000219/1990005

Requalification Program Evaluation Rept 50-219/90-05OL on 900409-11 & 0416-18,0518-25,0601 & 0607-08.Audit Results: Three Reactor Operators Failed Written Exam & Two Reactor Operators Failed Operating Test

ML20058P084
Person / Time
Site:	Oyster Creek
Issue date:	08/09/1990
From:	Conicella N, Conte R, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058P083	List: IR 05000219/1990005 ML20058P080
References
50-219-90-05OL, 50-219-90-5OL, NUDOCS 9008160042
Download: ML20058P084 (68)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

l Report No.:

50-219/90-05. (OL)

j Facility' Docket No.:

50-219

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Facility-License No.:

OPR-16

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Licensee:

GPU Nuclear Corporation-Facility:

Oyster Creek _ Nuclear Generating Station-

Examination Dates:

April 9 -'ll and-16 - 18, 1990-May 18 and 25,.1990 June 1 and 7 - 8,;1990

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Examiners:

N. Conicella,' Senior Operations Engineer

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J. Williams, Senior Operations Engineer C. Sisco, Operations Engineer-

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T. Easlick,-Cperations Engineer i

R. Miller, Sonalysts M. Daniels, Sonalysts

'G Robinson, Penn-State University'

Chief Examiner:

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Nicola F. Conicella, Sr.._ Operations Engr; D~ ate

l Reviewed By:

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Richard U. Conte, f6fef I ' (late BWR Section; Opera 4 Tons Branch Approved By:

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0 Robert M. Gallo, Ch'ief_

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Operations Branch, DRS SUMMARY:

Written and operating requalification examinations were administered to four crews consisting of 12' Reactor Operators (R0s) and 9 Senior-Reactor Operators-(SR0s).

The examinations were graded concurrently by the NRC and the facility-training staff. As graded by the NRC, 3 R0s failed the written examination and 2 R0s failed the Job Performance Measures (JPM) portion of the operating test.

9008160042 900809 PDR ADOCK 03000219 V

PDC

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All 9 of the SR0s passed all portions of the examination and all 4 crews perfonned satisfactorily. As graded by the facility, 3 R0s failed the written examination and 2 R0s failed the JPM portion of the operating test. All 9 of the SR0s passed all portions of the examination and all 4 crews performed satisfactorily. Overall, The NRC failed 5 individual operators and the facil-

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ity failed 4 todividual~ operators.

The difference is due to the NRC failing one R0 in the JPM portion of the examination that the facility did not fail and the facility.failing one R0 in the JPM examination that the NRC did not fail.

The latter individual also failed the written examination which accounts for the difference in total number of individual failures.

The~ facility's licensed operator' requalification program was determined to be

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satisfactory based on the criteria established in ES-601 of NUREG-1021, Rev. 5.

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However, several significant weaknesses were identified: (1) failure to establish and implement appropriate standards of performance in the evaluation process (UNR 219/90-05-01, Section 2.6);.(2) failure to identify poor quality procedures and utilize the requalification program to improve the quality of the operating-procedures (UNR 219/90-05-02, Section 6.2); and, (3) failure to evaluate Reactor Operators (R0s) in all positions allowed by their licenses during the annual operating test (UNR 219/90-05-03, Section 5). All three of these items will-remain unresolved. This report provides the details of these weaknesses.

Attachment 5 contains the licensee's evaluation of the Oyster Creek licensed operator requalification program.

The evaluation also contains corrective actions for weaknesses noted by the training organization.

The NRC has reviewed the evaluation and has the following concerns: (1) a root-cause analysis that explains why the noted weaknesses occurred was not provided; (2) the evaluation did not address procedure quality; (3) the evaluation'did not address-the R0 rotation practices during the annual operating examination; and, (4) the corrective actions did not include provisions for upgrading the evaluator ability to conduct objective evaluations and critiques.

As of the exit interview conducted on June 26, 1990, all' operators who had failed the examination as determined by either the facility or the NRC had been.

remediated and-retested satisfactorily with the exception of one written exami-nation failure who also failed the facility retake examination. All operators who have been retested satisfactorily have been returned -to licensed. duties.

The individual who failed the retake examination was not-returned to-licensed duties.

He was placed in another remediation program and will not resume licensed duties until retested satisfactorily by. the facility.

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DETAILS

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1.

Introduction and Overview An entrance meeting was held with the licensee'on February 15, 1990', in the.

Regional Office.

The purpose of this meeting was to'brief the' licensee on the requalification program evaluation and to clarify any questions or concerns that the licensee-may have with the process. At-the-conclusion of this meet-ing, the facility members of the examination team' presented the NRC:with the facility's examination. ban _k and the facility's proposed requalificatfu examination.-

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The requalification program evaluation was divided into several phases due t'o y

the facility' not having-its own plant referenced simulator. LThe facility uses

the Nine Mile Point UnitL1 simulator, located in Oswego, NY, for annual oper-

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ator training'and evaluation.

Each crew spends one week at the simulator.

Training is conducted the first four days and the evaluations;are performed the fifth day of that training week. As a result of these -logistics, the requal -

o ification progran' extended f rom April 9,1990 to June. 8,1990 since-four, crews I

were being evaluated by NRC staff.

l During the examination period, the ' RCLadministered requalification examina-

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N tions to 21 licensed operators (12 R0s and 9 SR0s). -These operators were

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divided into four crews.

Three of the crews were regular on-shift crews.and'

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the fourth crew.was comprised of staff licensed operators.

The' examinations j

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were administered using the process and criteria described in NUREG 1021,-

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" Operator Licensing Examiner Standards," Revision 5, section ES-601,;" Admin-

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istration of NRC-Requalification Program Evaluations."~ Two additional-oper-I

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ators_ (1 SR0 and 1 RO) were administered the simulatot examinations since they_

j part of the normal shif t complement of the shifts.that were being examined,

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These individuals were not available during the' weeks of the written a'nd-walk-through examinations and will be administered the written!and JPM portions

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I of their NRC requalification examination later this year.

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The NRC visited the facility during the-week of March.26,1990, to validate the

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written and JPM examination materials with the members of the facility exami-a nation-team.

The written and JPM examinations were administered during the l

weeks of April 9 and April 16, 1990.

l The NRC visited the Nine Mile Point Unit 1 simulator during the week of April 30, 1990, to validate the simulator examinations with the members of.the faci-lity examination team. The dynamic simulator examinations were administered on l

May 18 and 25 and June 1, 7 and 8, 1990, at the'Nine Mile: Point Unit1 simu-i

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lator in Oswego, New York.

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Summary of Examin~ation Results 2.1 Licensed Operator Examination Results.

j The fol1' wing is a summary of the. individual licensed operator o

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examination results-I-l

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R0 l

SRO -

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GRADING-l.

Pass / Fail 1-Pass / Fail l

Pass / Fail l

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9/3 l

9/0 1.

18 / 3 l

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l Simulator l

12 / 0 l:

9 / 0'

l 21 / 0 l

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JPM l

10 / 2

9 / 0'

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7/5 l

9/0 l

16:/ 5 l

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FACILITY l

RO l-

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TOTAL

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Pass / Fail l

Pass / Fail l

Pass / Fail l

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Written l

9 /'3 l-9/0 l

18 / 3 1:

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Simulator l

12'/ 0 l

9/0 l

21 / 0 I

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l JPM l

10 / 2 l

9/0 l

19 / 2 l

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Overall l

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17 / 4 l-

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l An additional R0 and SR0 were administered only the simulator exami <

nation.

Due to circumstances beyond the control of the facility,

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i these two individuals were unable to participate in'the written and-

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JPM examinations.: _These two individuals-passed.the' simulator exami-nation, but they are not included in'the overall requalification _

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program evaluation: since they.haveinot been administered a complete NRC requalific,ation examination.-

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.l As graded by the NRC, 3 R0s failed thE written examination' and 2 R0s

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failed :N JPM examination.

Each RO who-failed was-a different-individvAt therefore, there were 5' total individual operator fail-

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ures. Au t.he:SR0s passed the written,and JPM examinations..As

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graded by che facility, 3 R0sLfailed the written examination'andJ2:

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t R0s failed the JPM examination.

However, the facility failed one-individual RO on both' the: written and the >JPM examinations, but did.

not fail 1 R0 on the JPM examination that the NRC did; All SR0s-passed the written and JPM examinations. Therefore, there'were 4-

-total individual operator failures; as graded by the facility with oneE individual. Pass / Fail. disagreement between the NRC and theLfacility.

As graded by both the NRC and.the facil.ity evaluators, all 12 R0s and-

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all 9 SR0s passed the simulator examinations and all 3 operatingL-i crews;and the 1 staff crew were found to be satisfactory.-

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I 2.2 Generic Operator Strengths

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Written Examination-

• All test items.not listed as a weakness were~ answered cgrrectly.

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by more than 75% of'the operators exposed to that test item.

JPM Examination I

• All tasks not listed as a weakness were performed: correctly by more.

than 75% of the operators exposedLto that task.

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Simulator Examination

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• Crew communications, specifically, ensuring the correct transfer of information has transpired.

• Control board manipulations

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2.3 Generic Operator Weaknesses'

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Written Examination

All test items listed below were answered incorrectly by at least.

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25% of the operators exposed to that test item, i

• Ability to calculate heatup rate

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• Ability to determine time allowed to secure injection to determine

RPV level af ter level instrumentation is restored e

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• Knowledge of how core cooling is assured given certain plant

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conditions

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- * Knowledge of why reactor power can decrease.following a shallow rod withdrawal

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• Ability to vent.the drywell given certain plant conditions

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• Knowledge of the length of time req ~ ired for xenon to reach u

equilibrium i

• Knowledge of the immediate operator actions if unable to restore

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a tripped circulating water pump

• Ability to determine sequence of steps to locate a leak'in the

RBCCW system

• Ability to determine applicable technical ' specification LCOs given the plant status

• Knowledge nf the E0Ps. required given the plant status

• Ability to determine technical specification actions given a faileti control rod collet' housing

• Knowledge cf the procedural requirements to continue a start up with the RWM inoperable

• Knowledge of the.EOP pressure control strategy given the plant status

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• Ability to determine technical specification actions'given a stuck open EMRV

• Ability to verify proper'IRM response given the-plant status

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• Ability to determine protective action ~recommendationsLgiven the plant status

• Ability to determine, technical specification' required action given a degraded recirculation = system-

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JPM Examination All tasks and test items listed below were performed incorrectly or

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were answered incorrectly by at least 25% of the operators exposed to that task or test item.

• Operating procedure usage during the first week of the ex mination

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• Ability to' transfer controlfof the emergency diesel to LSP-DG2 and

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. locally start the; diesel

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• Ability to purge the contro.l' room after a fire

• Knowledge of the' purpose ofi he-acceleration relay in the turbine t

control-system

• Knowledge of the' consequence'of placing a recirculation pump in t

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automatic with its I/P pressure lower than the other pumps

• Ability to determine technical specification actions for' bus 10 being deenergized-i

• Knowledge of what causes-fuel zone transfer to wide range l

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• Knowledge of the bases for init1ating containment spray when torus:

. pressure exceeds 17 psig

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• Knowledge of the. criteria for securing liquid poison.

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Simulator Examination i

• Crew communications with respect to feedback from members'of the crew when an individual demonstrates questionable intentions or actions j

• Ability to determine technical specification required; actions for various plant conditions.

• Ability to properly anticipate:RPV emergency depressurization

• Knowledge of the. actions required if the heat" capacity temperature limit of the torus is. exceeded 2.4 -Requalification Program Evaluation-Overall Rating:

SATISFACTORY

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The facility program for licensed operator requalification training

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was rated as SATISFACTORY in accordance with the criteria established in NUREG-1021, " Operator Licensing Examiner Standards," section ES-601, " Administration of NRC'Requalification Program Evaluations,"

j paragraphs C.3.b.(1)- C.3.b.(2), 0.1.C.(2)(c), 0.2.C.(2)(b) and

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0.3.C.(2)(b).

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At least 75% of all operators that are administered the exami-nation must pass all portions of the examination.

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-76% of the operators passed all: portions of.the examination, 86% passed the written examination-90% passed the JPM examination

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100% passed the simulator examination-

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b.

- A program may be judged; unsatisfactory if there is less than 90%

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agreement-between the NRC and facility.on the individual pass /--

fail determinations for the written. and operating examinations

with the facility evaluating fewer individuals es

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unsatisfactory.

100% agreement for.the written examination 95%: agreement for the:JPM examination-

. 100% agreement for the simulator examination A_ program may be judged'-' unsatisfactory if the NRC judges at

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least-one crew unsatisfactory and the facility evaluators judge

-.the same crew as satisfactory.

There was 100% agreement on crew pass / fail decisions.

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If more than 1/3 of the crews are determined to be unsatis-factory by the NRC, regardless of individual failures, the'

overall program shall be judged unsatisfactory.

- All four crews evaluated were determined to be satisfactory, The program meets the requirements of'10 'CFR 55.59(c)(2), (3)'

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and (4) or is based on a systems approach to training (SAT).

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As reported by the facility, the_requalification program.is based on a systems approach to training.

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Additionally, if 3 or more of the following-are app 1_icable to a

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requalification program, then that program SHALL be'determ1ned to be unsa ti s factory.

If 1 or 2 of the following are applicable, the program MAY be determined unsatisfactory.

The same common JPM is missed by at least 50% of< the. operators.

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The maximum percentage of operators missing any of the' common JPMs was 34%.

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The same question about the same common JPM is missed by at least 50% of the operators.

There were 3 common JPM questions that were missed by more than 50% of the operators.

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The facility failed to train and evaluate operators in all

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positions permitted by their individual licenses.

The facility _does_not evaluate 'all the R0s in the lead control

.I room: operator position during the simulator examinations ti

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(Section~5.0 of this_ report discusses this issue in detail).-

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Failure to train' operators for:"in plant" JPMs.

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As reported by the facility, the facility trained operators for

"in plant" JPMs.

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Less than 75% of the' operators correctly answered 80% of the common JPM questions,

,3 81% of the operators correctly, answered at least 80% of the-l common JPM questions.

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More than one facility evaluator is determined to be unsatis-factory in accordance with the guidance of ES-601.

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.All facility evaluators were found to be satisfactory.

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r Although the facility program did not successfully meet all the evaluation criteria listed in ES-601,-the NRC-has evaluated the

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results and the program has been rated overall as satisfactory 4 in accordance with the guidelines of ES-601, but several serious weak-nesses are evident as noted below.

2.5 Requalification Program Strengths

• Operations management involvement in the conduc~t of training

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• Use of a simulator, even though it-is non-referenced to the facility-L control room, for annual training l.

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• Video and audio recording capability for the simulator-2.6 Requalification Program Weaknesses

• Effectiveness of training conducted as evidenced by the number.of operator: knowledge:and ability weaknesses noted (see-section'2.3)

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• Quality of the evaluation. materials developed (see sections 3; 4 and 5)

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• Development of appropriate standards of performance for evaluation L

purposes (see sections 3,4 and 5)

• Quality of the simulator evaluator's post-scenario critiques (see i

section 5)

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• Adequate utilization of the requalification process to update plant-

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operating procedures-(see section 6.2)

• Reactor 0perator_ rotation for the dynamic simulator evaluations (see section 5)-

The facility has acknowledged these noted weaknesses in their licensed operator requalification program >and has committed to

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-actions designed to correct several: of these weaknesses. The details ~

of the facility commitments made~ to date are in section 7 of this report.

This area is. unresolved pending NRC review of the

completion of licensee corrective actions =(UNR-219/90-05-01),

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Written Examination l'

During the pre examination _ review, specific _ problems relat'ing to the written examination question bank and -the facility proposed: written _

requalification examination were:noted as follows:

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• no point-values assigned to questions in the examination bank i

• no partial credit assigned to short-answer type questions and the majority.of ' questions were of the short-answer type

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• many of the questions were not clearly written:and required clarific-ation to solicit the answer as stated in the answer key

• several of the' static scenario questions eith3r provided answers _to

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other questions or provide for " double-jeopardy" situations-

These problems were corrected by the-NRC examination team for the first d

week's examination.

The second week's examination was left to the facil-ity to correct using the same comments and suggestions that-were used for

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the first week's examination, The results of'the written examination l

indicate that the facility was not> effective at completely correcting the'

l second week's examination.

There were two individuals who failed theIfirst week's examination.

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was complete agreement between the NRC and the facility over:these two~

individuals failing the written examination.

The second week's results,

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however, initially provided for pass / fail disagreements between the NRC

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Af ter the preliminary gr' ding, the NRC failed 'three-a t

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individuals and the' facility failed none 7 The NRC results were based on j

strict adherence to the answer key as provided.

The NRC and the facility attempted to-resolve these disagreements. The facility was asked to provide formal' justification-to-the NRC on how they graded the examina-tions and how they obtained their results.

The following day, the-facility training staff presented to the NRC their revisions to several of the answers in the answer key.

However, two of

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tte'd by the. facility were t'echnically the answer key corrections !

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incorrect,.The NRC reviewed aiFand accepted several of the proposed

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changes to the answer key. As a~ result of regrading the examinatisns, the NRC failed one individual, However, even after-accepting the answer key.

modifications provided by the facility, the NRC~had to adjust'the answer key independent of the revisions that the facility requested.

The adjust-ments that the NRC made to the answer _ key were to designate partial credit

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and to annotate portions _ of the answer as written in the key as being voluntary information that was not required for full credit.

The adjust-r ments that the NRC made were consistent with the guidance 3rovided in-t NUREG/BR-0122,_-Examiner's Handbook for Developing Operator Licensing-Examinations, t

The preparation,~ administration and grading of the written examination indicates that the facility training department was ineffective at

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developing a bank of quality written examination questions, Also, the

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facility evaluators displayed subjective _ grading in awarding credit for answers that were not in accordance with_ the. answer key, The training'

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departmert was aggressive in attempting to justify to the NRC why pass /

fail disagreements should pass rather.than-critically evaluating the operator's responses and the validity of the answer,as written in the key, i

Additionally, management and QA oversight.-in this area was apparently

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l ineffective since many of the problems noted by the NRC were not discovered and corrected by the facility prior to the NRC arriving on site to conduct the requalification examination.

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JPM Examination L

During_the pre examination review, specific problems relating'_to the JPM examination bank and the facility proposed JPM requalification examination-were noted as follows:

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• the standards for satisfactory performance were not specific enough and I

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required the evaluator to make arbitrary on-the-spot decisions '

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Examples: (1) " refer to tech specs and-declare inop" (2) " calculate the correct answer"

• evaluator cues to the operator did not exist

• tools, keys and procedures required were not mentioned i

• JPMs were not properly validated as indicated by:

~ (1) times for completion were arbitrary (2) some JPM critical steps were not in accordance with the operating procedure (3) some nomenclature used in the JPMs we not as stated in the operating procedure g

(4) one JPM had the incorrect valves annotated 8 being locked

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The problems noted above were corrected by the NRC examination' team for all JPMs that were to be used during the examination in-order for these JPMs to be considered adequate evaluation tools.

The facility was not effective in properly developing and validating a bank of quality JPMs in

preparation for the NRC requalification examination.

The types and amount of deficiencies noted in the review of the JPMs indicate that the facil-ity's validation process was cursory.- Additionally, many of.the JPMs that.

were of' poor quality were used in the-past-by the faci _lity and not effectively updated after they were administered.

The results of the first week's JPM evaluation indicated a generic-weak-ness that the operators did not strictly follow the operating procedures-in order to satisfactorily complete a JPM. -The first week's JPM examina-tion results indicated that about 60*4 of the individual JPMs not puformed satisfactorily were due to not following or understanding the operating'

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procedure.

The remaining 40*4;were divided between knowledge deficiencies.

or procedural inadequacies. The results of the second week's JPM exami-nation were. markedly different. Only one individual.JoM was not performed satisfactorily during the second week.

Additionally, all the operators evaluated during the second. Week followed their operating procedures and were methodical in their performance of each JPM.

These observations were not made during the first week of JPM examinations.

It appears that facility management was aggressive _in their review-of the first week's JPM results and promptly took measures'to ensure that the second week's

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operators were better prepared for'the examination.

The preliminary.results of the first week's JPM examination showed pass /--

fail disagreements becween the NRC and the facility.

The NRC failed three individuals and the' facility failed one but not one of the three NRC failures. Af ter reviewing and discussing the facts'that occurred,-

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discussing the criteria for acceptable levels of' performance, and deleting-one JPM due to a procedural inadequacy, the NRC failed two individuals and the facility failed two individuals with one pass / fail disagreement t

remaining.

The final. disagreement was based on the_ facility evaluator not having observed the 'same facts that the NRC observed during the conduct of one JPM.

The facility evaluators displayed a lenient grading policy

and a loose interpretation of the acceptable standards of performance.

The NRC, however, graded strictly by the standards as established in the

JPM and as a result, the initial disagreements occurred.

The preparation, administration and grading of the JPM examination.showed that the facility training department had not developed a bank of quality JPMs.

Also, the facility evaluators were lenient in awarding credit for-

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oper 4 tor actions that were not in accordance with the JPM or the facil--

ity's operating procedures.

On several occasions, facility evaluators would credit the operator for proper performace of a task when the operator's actions displayed weaknesses that warranted further evaluation.

The facility evaluators were not as critical of the operators' performance as the NRC examiners.

This is also illustrated by the argument the facility made for their understanding of satisfactory JPM performance, i

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Thefacilitystatedthatthestandardforsatisfactorycompletionof:jPM i

was. satisfactory completion of all " critical steps" of the JPM and that:

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the operators were taught to this " critical step" criteria..The facility

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representatives stated that the NRC was using criteria other than this, specifically, that the NRC was usirig :trict procedural compliance'instead.

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of the." critical step" criteria. _ However, procedural Mherence is.an inherent part af-the JPM since the steps of the opere ng procedure-are the only authorized method of JPM performance.

Performance of'a critical step in a manner different than as specified by the operating procedure-cannot be accepted by either the NRC or the. facility as successful task completion.

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Dynamic Simulator E, amination During the pre-examination review, specific problems with the dynamic simulator scenario. bank and the facility proposed dynamic simulator examination were noted as follows:.

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• not all signifit. ant. required procedures and operator actions were-specified in ne scenario

• several performance standards were unacceptable Examples:

(1) notice ATWS~within 5 minutes (2) notice ATWS by 10" vacuum (setpoint is 23" vacuum)-

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• emergency operating procedures (EOPs) that must be entered were omitted from the scenario

• several of the malfunctions were incorrectly annotated in.the scenarios

• several expected operator actions were not in accordance with the operating. procedures

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These problems were corrected by the NRC examination team for all.scen-

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arios that were to be used for the examination. Although the facility stated that they performed a thorough validation of these scenarios, the:

quality of the scenarios as initially provided to the NRC was poor.

The-scenarios as submitted could not.in several cases.be used as adeouate.

evaluation tools.

The fact that E0P entrier were'omitted indicates that these scenarios were not validated properly.

As stated earlier, each crew was to spend four days i,rainkg on the simu-lator and was to be evaluated on the-last day of the w s k.

This schedule covered four consecutive weeks.

The facility's-dynamic simulator scenario bank consisted of 16 scenarios.

The minimum required is 15. The facility had intended, during the four days of training each week, to train on all 16 of the scenarios and then evaluate the operators on the last day of the J

l week with two or three of the same 16 scenarios..The-NRC found this l -

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Even.though examination security could be maintained since the operators did not know which of the scenarios they would be evaluated with, the facility's approach did not meet the intent of having a bank of scenarios. The NRC requested that the scenarios chosen for the examination not be used for training and that the facility replace these scenarios with other topics that could be trained on during the week.

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i The results from the aaministration of the simulator examination indicate that the.ftcility evaluators are not critical of questionable operator j

performance. The trainers and evaluators for the simulator examination

included the facility's operations division management.

The evaluators fur the written and JPM examinations were training personnel.

Even though there were no pass / fail disagreements between the NRC and the facility evaluators, there were a number of individual critical steps that the NRC evaluated as unsatisfactory that the facility evaluated as' acceptable.

i The. operator critiques provided by the facility evaluators to the NRC were

cursory and did not indicate the weaknesses that the NRC observed.

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though-the standards of performance were clearly annotated in each scen-j ario, (as a result of the NRC validating the scenarios), it appears that the facility was more lenient towards the interpretation'of these stand-

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ards than the NRC was.

Initially, the few follow-up questions-that.the facility asked the operators at the end of each scenario indicated that -

the facility evaluators included assumptions.in their evaluations instead of verifying that the operators truly understood their actions by directly

questioning them.

However, by the-last week of the-simulator evaluations, the facility evaluators began asking more follow-up questions of the I

operators.

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Another deficiency noted during the conduct of the simulator examination dealt witn the assignment of critical tasks.

There were se.veral. critical tasks that were not performed due to the course that the scenarios took c'uring its performance. 0n occasions the facility gave credit to individ-

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uai operators for having completed these critical tasks: satisfactorily, i

After the NRC questioned the facility on these instances, the facility'

retracted the credit that they had awarded.

j During the conduct of the simulator examinations, the.NRC questioned how 10 CFR 55.59(2)(i) was met.

The facility did.not rotate all R0s to all R0 j

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watch stations in the simulator.

The regulation states that the annual

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operating examination provides a comprehensive sample of various licensed.

operator tasks. The facility has'one-of the R0s designated as Lead CRO.

This is a position of seniority and not all R0s are qualified as Lead CRO.

Since the NMP-1 simulator is configured differently than the facility's control room, only the Lead CR0 can manipulate certain controls in the

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simulator since these controls are at his. watch station.

In the facility control room, the Lead CRO's watch station has no controls.

Therefore, in the facility's control room, the R0s not qualified as Lead CR0 actually manipulate all the controls.

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4 During the!first week of simulator examinations, the facility's, proposed schedule for RO rota ion involved the non-Lead CR0 operators to be tested only in the balance of plant (BOP) position.

The_ Lead CR0s were rotated j

between the Lead CR0 and the nuclear steam supply systems (NSSS)_ posi-tions.- This resulted in the most novice of the R0s receiving an annual operating examination that consisted of only one scenario and during;that scenario these R0s were in the BOP position. Once the NRC became aware of-the facility's rotation practice,- the NRC informed the facility tha,, the-j operators had_to receive an examination that encompassed a comprehensive j

sample of the required test items of 10 CFR 55. The facility pr_oposed.

schedules for the remaining crew evaluations that involved rotating the

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R0s who were not qualifi ed Lead CRO to both the 80P and NSSS positions ~ for

the examination.

-The facility presented their position on why they believed that-their rotation practice was not in violation of the 10 CFR 55.59 requirements for

an annual operating examination.

The facility trair.s all R0s during the four days of training that precedes the annual operating' examination in all-R0 positions. Additionally, the facility stated that an in-depth

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critique of their performance is done during each scenario performed j

during training.

The actual annual operating examination is conducted I

with personnel assignments as they would normally be in the plant. 'The

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question arises-over proper rotation due to the fact that the NMP1 simu-

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lator_ is configured differently from' the 0yster Creek control. room..Had i

the f acility been using a plant referenced simulator, this problem would.

-l not have occurred. The inforriation provided by. the facility to date has not assured the NRC staff that the facility adequately administered and

documented annual operating tests that comply with the 10 CFR 55.59 (2)(1)

I requirement for a comprehensive sample.

This item will remain unresolved pending the submittal' of the facility's justification of 'their compliance i

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with 10 CFR 55.59 (2)(1) and the NRC staff's review of this justification (UNR 50-219/90-05-03).

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The results of the preparation, NRC examination team validation'and admi-L

nistration of the dynamic simulator examination are consistent with the

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observations made of the written examination and the JPM examination.

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Specifically, the facility's training department and-the facility's oper-ations management did not develop and implement acceptable standards of

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performance for their requalification examination.

-6.

Additional Issues 6.1 LOR Training Program Procedure i

a Licensed Operator Requalification (LOR)' Training Program Procedure I

6231-PGD-2612 Revision 9 was reviewed by the NRC to verify that it

complied with the requirements of 10 CFR 55'.59.

The NRC review was

conducted prior to the start of the Requalification Program Evalu-ation.

To address the NRC's concerns, the licensee issued Revision 10 to '.his procedure.

Revision 10 became effective during the conduc'. of the Requalification Program Evaluation. The following deficiencies were noted with Procedure 6231-PGD-2612, Revision 9:

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• Paragraph 4.4.2.4 implies that a licensed operator _ who fails the biennial written examination may be returned to licensed duties prior to being remediated and retested.

This was corrected by the facility in Revision 10 to the procedure.

• Pat. graph 4.1.4.4 allowed a licensed operator who failed the biennial written examination to be retested only on the section'of the written examination that scored < 80*4 if the overall written exam'. nation score was < 80*4.

This practice is not in accordance with the NRC methodology for written examina. tion failure re-exami-nations.

In Revision 10 to this procedure, the facility changed their method of written reexamination to be consistent with the NRC methodology.

The facility now administers a complete written examination to individuals who are being retested.

Licensee corrective actions for these issues were acceptable.

6.2 _ Plant Operating Procedure Adequacy As stated in previous sections of this report, all three sections of the requalification examination clearly showed that the facility did a poor validation of the examination materials.

The facility assured the NRC that they had done thorough validation-of all tte material in their examination banks.

However, during the NRC validation of the avamination material, the NRC identified several procedures that

needed to be corrected.

The NRC's emphasis on the quality of the operating procedures also caused the facility to critically look at the operating procedures and generate changes.

It appeared that.the facility was not routinely correcting operating procedures based on examination activities.

The following is a list of concerns the NRC had with various procedures.

• Procedure # 310. " Containment Spray System Operation," sections 3.3.1.3 and 5.3.4 direct the operator to verify ESW pumps automatically start 45 +/- 6.75 seconds after pumps SIA (SIC)

start. This fractional time dclay is not approprlate for an operating procedure.

• Procedure # 337, "4160 Volt Electsical System," section 2.4 does not contain a step te turn "c,ri' the synchroscope.

• Procedure # 301, " Nuclear Steam Supply System," section 10.3.5 does not give clear direction that the speed of the recirculation pump should not be changing when repositioning the povitioner supply and bypass valves.

• Procedure # 301, " Nuclear Steam Supply System," section 10 does not contain a step to check for proper operation of the controller prior to transferring control of an MG set to remote-manual.

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• Procedure # 301, " Nuclear Steam Supply System," section 10 does not identify in which directions to adjust the control to achieve the required deviations.

• Procedure # 315.1, " Main Turbine Operation," section 4.3.4 does i

not direct the operator to turn "on" the EPR.

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• Procedure # 307, " Isolation Condenser System," section 5.4 does

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not direct the operator to manually start the backup condensate transfer pump. Operator feedback from the examination indicates that the backup pump is manually started as normal pra:tice. The procedure does not reflect the normal practice.

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• Procedure # 1001.6, " Core Heat Balance, Power Range," cannot be

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performed without the use of operator aid 15 but the procedure does not direct the operator to this aid.

• Procedure 106.9, " Emergency Operating Procedtra Supporting Calcu-

lations," section 4.2' has a note which may niislead the control room operators into dispatching an operator to obtain H2/02 readings f rom a local panel when this action is not needed if drywell to i

torus dP is < 15 psid.

• Procedure 312.1, " Bypassing Isolation Interlocks and Automatic Scrams Durirg Emergency Conditions," does not contain a list of specific required tools and equipment for each of the interlocks or scrams to be bypassed. Additionally, the procedure does not state where the tools and equipment that are dedicated for performance of this procedure are located.

• procedure EMG-3200.02, " Primary Containment Control-Torus water Temperature," Table 4 has guidance for containment spray system

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lineup for torus cooling that is not in accordance with the guid-ance in Procedure 310 section 5.3.

• Procedure EMG-3200.02, " Primary Containment Control-Torus Water Level," section TOR /L-4 contains core spray system lineup instruc-tions that: (1) do not indicate wHch valves are locked and (2) do not give sufficient operating details for opening V-20-27(26).

• Procedure EMG-3200.02, "Prwary Containment Control-Primary Contain-

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ment Pressure," section PC/P-3 does not; (1) reference Procedure 312.1 as being needed to bypass interlocks (2) reference proce-dure 106.9 as needed if torus water level cannot be determined and (3) give sufficient operating details for placing control room HVAC in full recirculation mode if torus water level is at s above 461 inches.

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• In general, the.EMGs do not associate noun-names with valve numbers.

The EMGs only state valve numbers. This could cause confusion when operators t'ry to locate valves in the plant.

• Procedure ABN-3200.02, " Recirculation Pump Trip," as written will not allow the performance of steps 3.1.9, 3.1.10, 3.1.11, 3.2.8, 3.2.9, 3.2.10 and 3.3.5.

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• Procedure ABN-3200.29, " Response to Fire " section 3.6.7 could not be performed as written. The last step of this procedure section had to be performed first in order for the equipment to operate as

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expected.

The following is a list of observations the NRC made regarding various

documents.

• Contro11 M copy # 213 of technical specifications was missing the latest amendment.

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• Procedure # 346, " Operation of the Remote and Local Shutdown Panels," located in the DG2 vault, is held together by a paperclip i

with pages falling out.

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• Procedure 1001.6, " Core Heat Balance, Power Range," had data sheets

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in the file cabinet by the STA's desk that were illegible.

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Most of the procedural concerns noted above have been addressed by the facility. Apparently, the 1989 requalification examination did not effectively identify and address the quality of procedures.

To a certain extent, the quality of procedures affected the JPM results in the 1990 requalification examination.

The lack of use of the requalification process to improve plant procedures will remain unresolved pending NRC staff review of the corrective actions performed by the licensee (UNR 50-219/90-05-02).

From the list of procedure changes that the facility generated as a rer. ult of their simulator training from May 14 through June 9, 1990, it appears that the facility is now placing appropriate emphasis on procedural adherence and procedural quality.

7.

Ex_it Meetings 7.1 Interim Exit Meeting An interim exit meeting was conducted April 24, 1990, at the Region I office.

Personnel in attendance at this meeting are noted on Attachment 1.

The NRC presented the final results of the written and JPM examinations and discussed deficiencies with the facility requal-ification noted up to that point.

The NRC also made the facility

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NUREG 1020, E5-601.

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The facility discussed their resul"s of the written and JPM examina-tions.

The facility committed to enhancing operator training and the evaluation process with respect to the JPMs.

The facility also displayed r.oncern over what they perceived to be rising standards by the NRC as applied to their facility.

The NRC i

explained to facility management that the requalification program i

evaluation being administered to their facility was being done using

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the same. general acceptance standards that other facilities had been subject to.

Attachment 3 to this report is the presentation made by facility management to the NRC at the interim exit meeting. -Commitments

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made by the facility are listed on pages 9 and 10 of Attachment 3.

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t 7.2 Final Exit Meeting The final exit meeting was conducted June 26, 1990, at the Region I office. Personnel in attendance at this meeting are notted on Attach-

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ment 1.

The NRC presented the final.results of the dynamic simulator (

evaluation and tha final.results of the overalll licensed operator requalification program evaluation.

The facility was informed that their program was being rated as satisfactory; however, several significant weaknesses needed to be addressed. The NRC discussed the

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weaknesses noted specifically with the dynamic simulator i

examinations.

• The facility's presentation at this ex'.t meeting is contained in f

Attachment 4 to this report. Basically, the facility answered several questions that the NRC had previously asked.

Included in t

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their presentation was an update of the commitments made at the interim exit meeting and the facility's position on why their method-ology of RO rotation during the simulator scenarios complied with the requirements of 10 CFR 55.59. Additionally, Attachment 4 contains a

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list of procedures that the facility revised as a result of this requalification program evaluation. The facility was in agreement

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with all of the noted NRC weaknesses with the exception that the facility did not believe that the quality of their post-scenario critiques was poor.

The facility stated that the critiques they

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presented to the NRC were cursory as understood from their reading of NUREG 1021 ES-601.

The licensee representatives stated that actual critiques given to the operators to evaluate their performance were in-depth and exhaustive. The facility committed in question 1 of Attachment 4 +.o enhance the dynamic simulator development process.

Attachments:

l '.

Per>onnel Contacted 2.

Requalification Examination Test Items 3.

Facility Presentation of Requalification Training Program Status of April 24, 1990 4.

Facility Presentation at Final Exit Meeting of June 26, 1990 5.

Facility Examination Report dated July 26, 1990

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t ATTACHMENT'l I

PERSONNEL CONTACTED

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.GPUN PERSONNEL t

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P. Fiedler'

Director, Nuclear. Assurance 01 vision'(2)(3)

R.'Long Director, Corporate. Services (2)

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E.-.Fitzpatrick -

. Director, Oyster Creek (1)(2)(3).

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R. Coel Director, Training and Education-(1)(2)(3)

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J. Kowalski Manager,' Plant. Training (1)(2)(3)-

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R. Barrett Plant Operations Director (1)(2)(3)

f G. Busch Licensing Manager (2)(3)

G. Cropper Operator Training Manager (1)(2)(3)

H. Tritt Supervisor, Operator Training (1)(4).

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r J. Boyle Operations Training Coordinator. (1)(4)

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"S.

Todd Communications (2) '

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M. Heller Licensing Engineer (3)

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NRC PERSONNEL i

T. Martin-Regional Administrator, RI (2)

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R. Burnett Deputy Regional Administrator, RI.(acting) (2)

i M. Hodges Director, Division of Reactor Safety (DRS) (2)(3)

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W. Johnston Deputy Director, DRS (3)

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D. Lange Section Chief, Operator Licensing Branch (3)

R. Gallo Chief, Operations Branch, DRS (1)(2)(3)-

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E. Wenzinger Chief, Projects Branch.No. 4. DRP_(3).

R. Conte Chief, BWR Section, DRS (1)(2)(3):

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W. Ruland Chief, Projects Section 4B, DRP (3)

F. Young Chief, Projects Section' 4B DRP (acting) (2)

E. Collins-Senior Resident Inspector-(2)

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N. Conicella SeniorOperationsEngineer(1)(2)(3)(4)

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J. Williams Senior Operations Engineer'(4)

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C. Sisco Operations. Engineer (1)(2)(3)(4)

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T. Eas11ck Operations Engineer (4)

P. Bonnett

' Operations Engineer (3)'

i D. Harris Reactor Engineer (3);

M. Daniels Consultant, Sonalyst (4).

R. Miller Consultant,Sonalyst(4)-

G. Robinson Consultant, Independent (4)

(1) Attended entrance meeting on February 15. 1990 l

(2) Attended interim exit meeting on April 24, 1990

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(3) Attended exit meeting on June 26, 1990

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(4) Member of the NRC/ Facility examination team

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ATTACHMENT 2

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REQUALIFICATION EXAMINATION TEST ITEMS

WRITTEN EXAMINATIONS

' EXAMINATION No.11-(Crew 0/E)

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1.) Plant Operations-Scenario 4A (R0 and SRO)

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-Scenario 2B (RO and SRO)

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2.) Limits and Controls

-Question No.-

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016 166 i

017 (R0 only)

176-(SRO only)

018 (SR0 only)

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019 257

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EXAMINATION No, 2-(Crew F/ Staff)

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1.) Plant Operations

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-Scenario IA (RO and SRO)

-Scenario 14B (R0 and SRO)

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2.) Limits and Controis-

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-Question No.

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008 168

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176 (SRO only)

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036 207 i

057 220 (SRO only)

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165 229

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166 255

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JOB PERFORMANCE MEASURES EXAMINATION No.1 (Crew 0/E)

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~1.) Common Control Room In-Plant I

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ATTACHMENT.2i(cont.)

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2;)-Non-Common

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EXAMINATION No._2'(Crew F/ Staff)

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2.) Non-Common

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Control Room-In-Plant 1:

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72 SIMULATOR SCENARIOS

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Examination No. 1 (Crew D)

0'iginal-. Number-Revised Number

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I Examination No. 2 (Crew E)

Original Number Revised Number

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Examination No.l3-(Crew F)

Orig'.nal Number Revised Number

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s Examination No. 4 (Staff)

Original Number Revised Number

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ATTACHMENT 3 GPU NUCLEAR REQUALIFICATION TRAINING PROGRAM STATUS APRIL 24, 1990 I

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I ATTACHMENT 4 GPU NUCLEAR EXIT MEETING PRESENTATION JUNE 26, 1990 t

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OVERVIEW OF FAILURES TO TilIS POINT EM.'.

%RITIEN MEEK 1: NRC

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• 1 DISAGREEMENT J1Lil WRl'ITEN WEEK 2 : NRC

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GPUN ANALYSIS OF JPMs

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'IDTAL GIVEN:

210 TOTAL PASSED:

191

'IDTAL FAILED:

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ANALYSIS OF FAILED JPMs.

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WEEK 1 : 18 WEEK 2 : _1

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'IN. PLANT" JPMs J.

CONTROL ROOM JPMs _11 i

i JPM Fall,URES HY CATWORY

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WEEK 1 WEEK 2

PROCEDURAL ADilERENCE:

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IlOARDSMANSillP:

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IlUMAN FACTORS:

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TRAINEE WEAKNESS /OTilER:

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GPUN ANALYSIS OFWRnTEN EXAMS STILL UNDERWAY i

2 OF 3 FAILURES WERE NEW OPERATORS WilO IIAD NEVER

ENCOUNTERED Tills STYLE OF EXAM (STATIC SIMULATOR

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AND OPEN REFERENCE) -

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1 SUMMARY OF JPM CHANGES

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JPMs CHANGEQ TECH CIARt1Y EDITORIAL

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SIGNIFICANT CHANGE SUMMARY

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TWO JPMs IIAD SIGNIFICANT CIIANGES WillCil FELL INTO Tile FOLLOWING AREAS:

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EXPANSION OF CRITICAL STEPS BY 1WO STEPS.

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ADDITIONAL EVALUATOR CUES FOR CIARI'lY.

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ADDITIONAL ITEMS TO TASK CONDITIONS.

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REWORDING OF TASK CONDITIONS.

5.

REWORDING AND CONSOLIDATING OF PERFORMANCE CilECKLIST/ STANDARD FOR CLARITY.

TOTAL JPMs SIGNIFICANTLY CilANGED 2

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SUMMARY OF OUESTION BANK CHANGES

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NUMBEROE NUMBER QUESTIONS CHANGED 'IECH CLARITY FORMAT J

WK1 3S

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20

WK2 26 + 10*

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. 10

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• 10 QUESTIONS CARRIED OVER FROM WEEK 1

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TOTAL SIGNIFICANT CilANGES 17 i

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SIGNIFICA1TfCilANGE SUMM AltY

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CllANGEI) TO MULTl CllOICE TO l'.NSUltE CORRECT ANSWER

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l IMPROPER FORMAT (YES/NO OR NOT PROPER MATClllNG)

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REPLACED QUESTION (ORIGINAL QUESTION DIFFERENT,ITUT SATISFACTORY)

s TECIINICALLY INCORRECI'

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CAUSFS/ DISCUSSION EXAM BANK DEFICIENCIES I

1)

SOME QUESTIONS SOLICIT MULTIPLE ANSWERS

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PARTIAL CREDIT ASSIGNMENT NOT EXPLICITLY DEFINED 3)

VALIDATION PROCESS NOT CLEARLY DEFINED 60M E OPER ATORS NOT ADF;il(MIfd3_1.liii;.i.3EEij 1)

NOT ENOUGli JPM PRACTICE AllSENCE OF A PIANT REFERENCED SIMULATOR

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UNFAMILI AR WITil WRITTEN EXAM FORMAT (NEW OPERATORS)

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CAUSES/ DISCUSSION (COImNUED)

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JPMRANK DEFICIENCIES l

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FORMAT OF,lPMs NOT CI OSF.I,Y TIED TO PROCED17RES i

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DID NOT FOCUS ON DE_M,ONSTRATION OF PROCEDURA!,

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JPM VALIDATION PROCESS NOT CLEARLY DEFINED

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CORRECTIVE ACTIONS 1)

A CLEARLY DEFINED PROCESS FOR TECHNICAL AND 'I1ME VALIDATION WILL BE ESTABLISHED (JUNE 1990).

.

2)

WR11 TEN EXAM BANK WILL RECEIVE AN INDEPENDENT REVIEW

-

TO IMPROVE QUESTION CLARITY (MARCH 1991).

l

'

3)

THE WRI1 TEN EXAM BANK WILL HE TECIINICALLY AND TIME REVALIDATED (MARCH 1991).

'

T}lE JPM FORN! AT AND EVALUATION PROCESS WILL I:t'

!

MODIFIED TO MORE TilOROUGillX STi(ESS DEMONSTilATION OF PROCEDURAL ADilERENCE ALONG WITil TIIE CRITICAL STEPS AS PASS / Fall CRITERIA (3RD QUARTER 1990).

!

!)

Tile.JPM ADMINISTRATION l'ROCESS WILL llE MODIFIED AS

FOLLOWS:

{

USE OF FLASI1LIG1IT TO CLEAR 1X PolNT OUT

'

SWITCilES (COMPI,ETE).

• EACil OPERATOR WILL I!E EXPOSED TO TIIE USE OF

.....,.. "., C L,.; ;.... i. i 1.1

• '

-

..

.

ACTLAL REQUAL EXAM (AS APPROPRIATE).

• REQUIRE OPERATORS TO WRITE DOWN TASK

'

INITIALLY TO MINIMIZE POTENTIAL MISCOMMUNICATION (COMPLETE).

• PLANT REFERENCE SIMULATOR WILL llE USED WHEN AVAllAllLE (PROJECTED. EARLY 1991).

6)

TIIE TRAINING PROCESS FOR JPM EVALUATORS WILL 11E r

.

EXPANDED TO INCLUDE THE IMPORTANCE OF IDENTIFICATION i

I AND RESOLUTION OF DIFFERENCES BETWEEN UTILITY AND NRC Q

EVALUATORS ON THE SPOTTO AVOID SUBSEQUENT FACTUAL

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DISAGREEMENTS LIUNE 1990h i

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i CORRECTIVE AcrIONS (CONTINUED)

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AN ENHANCED ON THE-JOB TRAINING PROGRAM IS BEING DEVEthPED BY THE OPERATIONS DEPARTMENT. IT WILL INCLUDE JPM WALKTHROUGHS. JPM REVALIDATION WILL BE AN ON CO!NG PART OF TIIIS EFFORT (IMPLEMENTED 4TII QUARTER 1990).

,

.

8)

INDIVIDUALJPM F ILURES WILL BE REVIEWED ONE-ON ONE

{

WITil EACil OPERATOR INVOLVED (JUNE 1990). -

!

9)

INDIVIDUALWRITTEN EXAMS WILL BE REVIEWED ONE ON ONE WITil OPERATORS INVOINED TO UPGRADE TIIEIR KNOWLEDGE (J UNE 1990).

10)

CU

.N AREAS OF QUESTION DIFFICULTY WILL IIL IIM

' FIED FOR INCLUSION IN Tills IllENNIAL REQUAL CiCLE AS APPROPRIATE (MAY 1990).

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SAFETY ASSESSMENT l

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TECHNICAL CORRECrNESS HAS ALWAYS BEEN 'IHE PASS / FAIL

-

!

CRITERIA.

!

COMPETENCY HAS BEEN DEMONSTRATED CONSISTENTLY BY OUR

i OPERATORS AND EFFECTIVELY EVALUATED BY TRAINING.

.

>

WHILE TiiE EVENTS OF TIIE LAST 'IWO WEEKS DO REVEAL

AREAS FOR IMPROVEMENT IN TIIE EXAM DEVELOPMENT AND ADMINISTRATION PROCESS, OUR ASSESSMENT IS TilAT TIIERE i

j IS NO CARRYOVER IMPACT ON PLLNT&tICI%--

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PROCEDURE j

REQUIREMENTS l

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REQUIREMENT TO ESTABLISH PROCEDURES. TECH SPEC SECTION 6.8.1

AND APPENDIX B TO 10 CFR 50 PROCEDURE COMPLIANCE REQUIREMENTS i

,

PROCEDURE 101,' ORGANIZATION AND RESPONSIBILITY * SECTION 4.10.1

.

.

PROCEDURE 106,' CONDUCT OF OPERATIONS * SECTION 4.10

-

PROCEDURE 107,' PROCEDURE CONTROL' SECTION 5.1.5

-

t STANDING ORDER #41 ' PROCEDURE IN llAND'

.

PROCEDURE liiERARCilY

PROCEDURE 106,'CONDUcr OF OPERATIONS * SECTION 4.14.2

.

EMERGENCY OPERATING PROCEDURES (EOPs)

ABNORMAL OPERATING EVENT PROCEDURES (AEOPs)

>

OPERATOR JUDGEMENT EVENTS

NORMAL STATION PROCEDURES

CORPORATE REQUIREMENTS

CORPORATE POLICY 1000 POL 1218.01

-

-

PRESIDENT, GPUN MEMO DATED JULY 15,1988

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i PROCEDURE

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Si1E IMPLEMENTATION OF PROCEDURE REQUIREMENTS

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COVERED IN1 RAINING PROGRAMS

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-

GENERAL EMPIhYEE TRAINING (INITIAL AND REQUAL)

'

.

NON LICENSED OPERATOR (INITIAL AND REQUAL)

-

RO/SRO (INITIAL AND REQUAL)

-

i

'

COVERED DURING MEETINGS WITil SITE DIRECTOR (MID 1988)

ALL OPERATIONS SIIIFT PERSONNEL

-

'

PERIODICALLY RE ADDRESSED REMINDER MEMOS

.

MEETINGS

-

.

ADDRESSED IN LESSONS LEARNED TRAINING

CRITIQUES OF STATION EVENTS

-

INDUSTRY EVENTS

.

SIMULATOR TRAINING

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PROCEDURE

-

VARIOUS ASSESSMENTS OF ADHERENCE

-

,.

1989/90 GPUN EMPLOYEE OPINION SURVEY RESULTS

'

lNSARLY ALL 6 PUN EMPI4YEES SAY THEY ARE ENCOU

' PROCEDURES, AND DVO THIRDS AGREE 'IEEY ARE ABLE M FOLIDW j

PROCEDURES ACCURATELY

,

l MOST SAY COMPLIANCE WITil' PROCEDURES IS HANDLED CONSISTENTLY

.

IN TilEIR DEPARTMEffr j

lt 1989/90 0.C. OPERATIONS SELF ASSESSMENT RESULTS

ALMOST EVERY EMPLOYEE SAYS TlIAT Tile OPERATORS ESTAllLISil

-

j SYSTEM CONFIGURATIONS SATISFACTORILY AND MOSTIIELIEVE Tills IS A

'

DEPA RTM ENTAL STR ENGTi!.

ALL EMPLOYEES P.:h.!EVF Tl!AT THE INDEPENDENT VERIFICATION PROCESS

-

IS PERFORMED SATISFACTORILY AND lilGli PERCENTAGE FEEL Tills IS A STRENGTil.

ALMOST ALL EMPLOYEES SAY TilAT OPERATOllS DO A SATISFACTORY JOli OF

-

COMPLYING WITil PROCEDURES AND MOST SEE Tills AS A DEPARTMENTAL STRENGTi!.

ALL EMPLOYEES SAY TilAT.TECil SPEC COMPLIANCE IS AN OPERATIONS

'

-

'

DEPARTMENT STRENGTil.

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PROCEDURE

!4 VARIOUS ASSESSMENTS OF ADHERENCE (CONTINUED)

i

j NRC INSPECTION REPORTS

'

ON BALANCE ARE POSITIVE j

'

.

SEE SUMMATION OF COMMENI'S IN APPENDIX A

.

!

LERs

'

(

-

'

TREND IS POSITIVE i9

.

SEE CllART IN APPENDIX C

'

.

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GPUN JPM RESULTS

SIX (6) PROCEDURAL ADilERENCE PROBLEMS OF 210 JPMs CONDUCI'ED,

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PROCEDURE

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&EQUACY

!

PROCEDURE IMPROVEMENTS l

HUMAN FACIDRS IMPROVEMENTS OPERATIONS PROCEDURE WRITERS' STANDARD UNDER DEVELOPMENT

,

MODEL PROCEDUREk COMPLETED 11/89

-

,

I FIRST DRAIT STANDARD 12/89

-

SECOND DRAIT STANDARD 02/90

-

F1NAL STANDARD 05/90

-

1MPLEMENTATION 06/90

.

-

!

I i i

PROCEDURE UPGRADE PROGRAM

[

PILOT SYSTEM'S PROCEDURES IW4Til QUARTER 1990 SCliEDL 1.E FOR

-

-

'

OTilER llANKS OF OPERATIONS PROCEDURES TO FOLl.OW ALL NEW PROCEDURES TO WRITERS' STANDARD l-

-

MAJOR (> 50%) REVISIONS TO WR!TERS' STANDARD

-

'

FUTURE ACI'lONS MAINTENANCE PROCEDURE WRITERS' STANDARD

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PROCEDURE

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ADEOUACY h

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i PROCEDURE IMPROVEME?i[H jl Il

• BIENNIALREVIEWPROGRAM i

OPERATING PROCEDURES NOW OWNED BY OPERATIONS DEPARThfENT (l

-

510ST OPERATING PROCEDURES NOW REVIEWED BY LICENSED

.

SillFT PERSONNEL

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OPERATIONS DEPARThfENT 4 PAGE REVIEW CIIECKLIST ESTAllLISilED J

-

CRITERIA 1:

LESSONS 1. EARNED INCORPORATED

.

i OVERDUE REVIEWS VIRTUALLY ELI.NilNATED

.

• D1 RECT OPERATOR INPUT

,.

.

,

Ui ER3.TUR CONCERN PROGR AM

.

' TOTAL NUh111ER RECEIVED 304.

• NUMIIER RELATED TO PROCEDURES

- 133

,

' NUMilER RESULTING IN PROCEDURt. CllANGES 111 r

• NUhtilER REQUIRING lhth1EDIATE PROCEDURE CilANGE 1 h

PIANT LMlELING PROGRAh!

-

' 79 CIIANGE DOCUh1EN'I'S INITIATED

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TRAINING PROGRAh!S

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ADEQUACY

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PROCEDURE IMPROVEMENTS (CONTINUED)

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• REQUALIFICATION EXAM TFAM

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,

NUMBER OF JPMs RESULTING IN PROCEDURE CHANGES: 8 OF 18 3,

-

EXTENT OF PROCEDURE CibtNGES (6 PROCEDURES INVOLVED)

.

,

,

l ADD STEP TO PLACE FLOW CONTROLLER TC ' MANUAL *

.

ADD STEP TO TURN EPR 'ON'

-

ADD STEP TO TURN C.R. EXilAUST FAN *OFF"

'

-

ADL) STEP TO TURN SYNCIIROSCOPE "ON"

'

.

.

ADD STEP TO 'RESE*I' F1RE AIARM PRIOR TO STARTING FA."

-

DELETE PREREQUlSITE TO VERIIT D/G OPERAllLE

-

'

DELETE IMPLICATION TO TIME ESW PUMP STARTTO

-

WITI11N 453. 6.75 SEC.

PROCEDURE STEP SEQUENCE

.

'

ADD NOUN NAMES OF VALVES

-

ADD REFERENCES, TABLES l

-

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IMPROVE READAlliLITY QUALITY OF A PAGE

-

-

REMAINING 57 JPMs REVIEWED

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4 PROCEDURE CHANGES NEEDED TO SUCCESSFULLY ACCOMPLISH 4 JPMs

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OTHER MINOR ENHAbiCEMENTS WILL BE MADE

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CONCLUSIONS

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PROCEDURE ADHERENCE ALWAYS AN ONGOING CONCERN OF GPUN I

-

WE HAVE ACTIVE PROGRAMS AS DISCUSSED

-

WILL CONTINUETO STRESS

.

OUR EFFORTS DEALING WITil ADEQUACY WILL ALSO HELP ADHERENCE

--

PROCEDURE ADEQUACY TECIINICALLY ADEQUATE

-

e, OUTECTIVES OF Tile PROCEDURES CAN DE PERFORMED

-

NEED TO ENilANCE ESPECIALLY Fh0M llUMAN FACTORS STANDPOINT

-

ACTIONS ONGOING

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plSCUSSION AND COMMENTS a

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' OUR FOCUS HAD STRESSED THE DEMONSTRATION OF

'

-

.

ACCOMPLISHMENT OF CRITICAL STEPS, CONSISTENT WITH k

PROCEDURAL COMPLIANCE, AS THE CRITERIA FOR SUCCESSFULl COMPLETION OF JPMs IN THIS CONTEXT THE 8 I'UDENT COULD

"

MAKE A Ra'OVERABLE ERROR YET SUCCESSFULLY AND SAFELY COMPLETE A TASK BASED ON '",UIDANCE OBTAINED FROM THE

-

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FOLLOWING:

NUMARC l

-

ES 601

-

REGIONAL TRAINING GROUPS

..

-

'

TRAINING MANAGERS MEETINGS J

- RECOGN17,1NG HOW DIFFICULT IT IS TO CONDUCT A VALID

'

(

j Silll'l' CREW EVALUATION ON A NON PLANT REFERENCED l

.A SIMULATOR IT IS EXTREMELY IMPORTANT THAT THERE BE CLEAR

_ j UNDERSTANDING BEDVEEN ALL PARTIES AS TO WilATTHE.

CRITERIA ARE FOR SIMULATOR PASS / FAIL. WE ARE d

.J a

PARTICULARLY SENSITIVE TO THIS BASED ON OUR RECENT JPM

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g-EXPERIENCE WITH RESPECT TO WHERE OUR FOCUS SHOULD HAVE f

BEEN AND WHERE ITWAS.

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DISCUSSION AND COMMENTS (CONTINUED):

I.

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j IN THIS REGARD WE, QUITE NATURALLY, ARE CONCERNED ABOUT j

i BEING INFORMED THATWE WILL BE HELD TO A HIGHER STANDARD 'IBAN OTHERS WITH REGARD TO COMMAND, CONTROL -

AND COMMUNICATIONS DURING OUR EXERCISES. IN THIS CONNECTION WE HAVE THE FOLLOWING CONCERNS / COMMENTS:

,

WE DO NOT BELIEVE THAT IT IS APPROPRIATE TO IlOLD

-

US TO HIGHER STANDARDS TIIAN THOSE BEING USED FOR l

TIIE REST OF TIIE INDUSTRY.

!

NEED TO CLEARLY DEFINE THE ROLE OF THE GENERAL

'

-

PHYSICS INSTRUCTOR WITH REGARD TO SYSTEM DIFFERENCES AND ASSISTANCE /IIELP.

'

.JSPONSIBILITIES OF CONTROL ROOM PERSONNEL

-

MAi' JEED TO BE REDEFINED / MODIFIED, SINCE THE NINE i

i 7tE Pr

'MULATOR LAYOUT IS DIFFERENT FROM OUR

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nkt n z QUIRED CHANGES TO SIMULATOR SCENARIOS ARE '

-

.I NEEDED BEFORE B IAY 1 IN ORDER TO SUPPORT REVA' IDATION.

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DISCUSSION AND COMMENTS (CONTINUED)

.

_

.

GPUN OPERATIONS AND TRAINING PERSONNELWILL CONDUCT-

.

'

ANOTHER SIMULATOR SCENARIO REVIEW COMMENCING ON APRIL -

,-

25TH DURING WHICH TIME H SHALL MAKE USE OF SIMULATOR'

i REQTUL E14M EXPERIENCED PERSONNEL FROM TMI TO HELP f

RVMi3 ATE OUR OC SCENARIOS.

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NRC PERSONNEL ARE SCIIEDULED TO REVIEW OUR SCENARIOS AT i

,

TIIE SIMULATOR ON MAY IST AND 2ND.

l

,

ARE STANDARDS AND CRITERIA GOING TO llE SET AT TilAT

-

TIME? IF SO, HOW WILL AGREEMENT BE DOCUMENTED?

ROLE OF GENERAL PIIYSICS INSTRUCTOR, ETC.?

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P lr APPENDIX A

,

!

NRC INSPECTION REPORTS

..

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!

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.

!

Inspection Report 89-07

[

Re Independent Valve Position Verification by NRC

"All valves were found to be' correctly positioned in accordance

!

with licensee's approved procedures."

t Re: Plant Startup (3/26/89)

,.

" overall, the startup was conducted in an orderly fashion and in accordance with facility procedures."

Re: control Room Observations

" Operators were using and adhering to procedures" (numerous)

.

i

.

.

i

" Operators were noted to be attentive and responsive to plant parameters and conditions" l

t'

"Several chift turnovers were observed. Operators were noted to be thorough in walking through the consolo and panels with their reliefs. Discussions of activities and plant status were thorough."

Re: Plant Operations

. a valve lineup problem was identified in the air supply

"

.

to the MSIVs. A contributing factor in identifying the. problem during the performance of the valve lineup verification was the method by which changes to drawings are issued.

this= type

..

of prompt action by management should be beneficial in

...

L both improving operator attitude and in preventing future errors."

'

Re Licensed Operator Training Program j

,

" Oyster Creek Licensee Event Reporte (LERs) were reviewed to determine if any of these events can be attributed to a lack of

.

.

training. There was no obvious correlation between the LERs-and the training the operators received."

-l

"The majority of the operators. indicated that the quality and the overall effectiveness of the requalification program has improved in the last two years. This trend was attributed to

-

the recent increase in training staff".

4

"The operators indicated that there was a communication path which exists between operations and the training department so

'

,

problems and events occurring on' shift can be incorporated into-the training program."'-

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APPENDIX B -

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LICENSED OPERATOJS!

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SHIFT STAFF '

REMEDIATION TOTAL SRO'S -

16*

'15

L31

'.1

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RO'S --

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28'

'

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• INCLUDES 2 UNAVAILABLE WHILE IN COLLEGE FULL TIME -

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SHIFT POSITION REOUIREMENTS TECil SPEC GPUN SRO'S 2 --

RO'S

3 MINIMUM -

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APPDDIX C

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LER STATISTICS

_

.

1987-- 1989

-

,

.

l TOT LERs EQUIP FAIL

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- PROC INADEQUACY E PERS ERROR

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1987 1988 1989 I

I TOT LERs 45-

22

'

EQUIP Fall-

2

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I PROCINADEQUACY

7 2-I PERS ERROR

15

6-

. _... _..

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ee:

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.

.

' Job Performance Measure Content

.

- A Job Performance Measure should have detailed information and specific

' '

l criteria-in order to provide objectivity an*J consistency to the evaluation process. A Job Performance Measure should contain the "ollowing information:

-/

1.

Administrative Information Plant-specific information necessary to meet _ individual utility record keeping commitments (e.g., task title, student name, instructions, evaluation method, evaluation location, approximate time for completion, revision number, etc.).

2.

Importance Ratings-K/A references and K/A importance ratings or plant-specific importance ratings should be included on JPM worksheets.

Importance ratings derived from plant specific job analysis must be based on: the direct and indirect

impact of task performance on safe plant operations, ensuring public

. health and safety.

3.

Task Conditions

!

'

Conditions.necessary for task performance (e.g., Rx critical.at IT.

power, ready to start up a main feed pump).

Task Standards

'

'

The predetermined outcome fqualitativt or quantitative) against which (

task performance is measured (e.g., HCP running within normal operating

,

limits).

Task standards should, when appropriate, include a time' standard if necessary for satisfactory task performance.

5.

Tools and Equipment

,

l Special items needed to perform 'the task (e.g., stop watch, manometer,

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breaker racking tool, etc.),

.

l 6.

References

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The procedure (s) that require task performance and the procedure (s)

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that provide guidance, directions, or standards for task performance (e.g., E-1, Loss of Reactor or Secondary Ccolant; E-2, Faulted Steam

,

Generator Isolation).

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7.

Initiating Cue The stimulus that should result in beginning task ' performance.

l 8.

Performance Checklist

,

Check points should be used to evaluate the successful completion of the task. All critical elements.must_be included and standards provided.

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Since most or tne in-piant tasks wii s oe simulateo, tne inoiviouai

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DRAFT

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u,i Ken set the groundwork for the discussion on exas bank size by citing the original requirements based on the new requalification program guidelines.

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The guidelines require:

350 Section A Written Questions 350 Section B Written Questions

'

i 75 - Job Performance measures 15 - Scenarios

..

Ken said he wanted a dynamic bank with question growth. He wanted to see the

.

subttitution of new, more relevant questions for old ones. He said he was not wedded to the number 1,000 in five years as a required goal. He suggested l

instead a floor value with some measure that would assure that a specific portion of the bank would be-reviewed and substitute questions added where

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appropriate.

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l The first strawman presented by Ken to address the-issue of bank growth called for 75 questions per-.section (A&B) to be reviewed, revised as needed,

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and substitutes made where appropriate each year. The working group members suggested instead of a fixed numoer to let the conditions at the plants drive the reviews and-revisions.

i Ken said he needed a number since there would be potential differences among aggressive and non-aggressive utilities.

Percentages were discussed.

The outcome of the discussion was a consensus statement:

A 25% sample of the entire written bank (parts A&B) with a minimum of 700 questions will'be reviewed, revised and/or

substituted where appropriate, over the two-year requalification cycle on a reoccurring basis.

!

On the topic of expanding Job Performance Measures, Ken suggested tbst the bank should be expanded to capture all tasks with a X/A rating of 3.0 and

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i

higher. After some discussion, Ken suggested the following:

Each JPM bank will be increased by 10 new JPMs per year until all plant specific JPMs have been addressed. The process will incorporate the review and revision convention from the written

'

lj bank above on.15 preexisting JPMs'per year.

,;

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On the topic of scenario bank expansion, Ken suggested the addition of

!

five per year up to a ceiling of 40. An alternate approach'was offered.to better address the ceiling. The alternate called for the. addition of five scenarios per year up to a total number that represents. virtually all plant

,

events that are significant. Ken suggested that the 40 ceiling be kept since the ES 601 revision cycle is programmed to be at 18 month intervals, allowing-

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for scenario ceiling adjustments to be made, if appropriate, in Revision VII.

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DRAFT on the subject of E5-601 and the industry request to develop a procedure to review revisions and present comments before ratification, Ken suggested that the existing convention of issuing errata when necessary between formal

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revisions had proved adequate. Xen said also that to reduce the impact of new

'

ES 601 requirements, there will be a 60-day period in the future between revision distribution and implementation.

Ken's suggestions were discussed at length. The major counter point being the strong request for a comment period before implementation. Ken was not receptive since he felt a comment period is too time consuming. He said the process of-getting comments, considering them and choosing which ones to incorporate was not acceptable given the 18 month revision cycle. As a potential alternative, Ken said that first he would have to talk with the i

legal department, but perhaps he could hold a meeting to verbally describe the changes that will be incorporated into futun ES-601 revisions.

'

Procesed Revisions to Initial License Examinationi

According to Ken Perkins, the initial examination will be based on facility-developec materials; however, the NRC will construct the test. As for the cc ponents, the JPMs will be emphasized using a substantial amount of

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facility material. The aynamic simulator portion will be similar to that in the recualification examination; however, the focus will be on individual behavior rather than crew perfomance.

The written portion may be divided into :hree section such that instant SRos, SRO upgrades, and RO candidates will receive all or a subset of the sections. The written examination administration will follow the closed book, open reference, and static simulator like the recualification examination.

-

l Ken said that the new initial license examination would be phased in after October 1990 with a pilot test (s).

He said that actual implementation will be 18 24 months away. He also suggested that facility participation during examinaf. ion preparation will be sought.

Stress:

On the topic of undue stress durino the conduct of the. operator reoud l

examination, the NRC was toio.wnat tne working group nad discussea relatou to i

croister1ng, waiting, ese.orting, etc.

It was suggested that the operators should be treated with professional regard, with the most importance issue being that of a security agnement. A security agreement would reduce much of

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the stress by reducing or eliminating the stressors. The NRC was not in favor of-signing security agreements. The reason given for this position was that the more people who sign a security agreement, the more potential breeches of

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I test security.

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ORAFT It was suggested that there were ways short of the security agreement that would reduce unnecessary stress.

For example, the minimization of caucus time after scenarios, allowing crews to talk after their scenarios, better

'

scheduling, assuring that the days are used for the exas only, and for sites to disregard the mandatory eight hour day on exam days would go a long yay toward reducing stress.

After general discussion, and just before the NRC members left the meeting, the Workin Group was told that emergency action level (EAL)

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'

classifications wou d no longer be a ISCT requirement in the dynamic simulator portion of the requalification examination for those SRO's who by duty title are not routinely responsible for EAL classifications.

>

Oav Two:.

'

t The first order of business on day two of the meeting was to explore ways to get reoual lessons learned and eremolaPY oractices nut to the industry.

Ine members cegan a I1vely discuss 1on on tne topic.

Ine discussion inclucec the following hign points:

The requalification program may not be stable enough yet to employ

-

INP0 good practice approach.

There r::ay not be enough consistency between and among regions

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We may not want to shoot for 100% consistency since what works well

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at one location '::ay not at another.

Ask the regional training organizations to get involved in compiling

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and distributing exemplary practices.

Identify things that work in their regions (qualify and quantify)

May also want to gather consensus on inconsistencies

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Consider sending a questionnaire out frate NUMARC to be filled out and

-

returned after each requal exami Data, and trend analyses c&n be maintained centrally at NUMARC with reports on exemplary practices and inconsistencias taken from data base. The member consensus was to revise original requal questionnaire and send several copies to each site for their use. The basic revision question ~is, what needs t

I to be changed to make the form useful as an on going document.

One suggestion was to request that INPO address requal exemplary

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practices at the next training managers workshop.

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Other issues discussed included the regional training omanizations and whether or not it would be beneficial to ask their chairmen to sit with the OperatorIssuesWorkingGroup(OPI). The subject will be included on the i

agenda for the next OP; meeting.

There was discussion of holding future workshops similar to the one held in Dallas, Texas.

After some discussion, it was recommended that a workshop

'

be planned for 1991 since the initial examination process will be a timely j

issue, as well as requal exams.

,

Bob Evans and Sob Whitesel briefed the members on the NRC research being conducted in the area of Human Factors. The briefing included an overview of I

the NAC RES program and an overview of the outcomes from the first NUMARC l

meeting of the Ad Hoc Advisory Committee on Human Factors / Human Performance.

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The meeting adjourned at 11:30 a.m.

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NRC OUESTIONS CONCERNING OPERATOR REOUALIFICATION PROGRAM -

1) HOW ARE SIMUIATOR SCENARLOS DEVELOPED AND VALIDATED?

EXISTING EXAM SCENARIOS WERE DEVELOPED UNDER CONTRACT WITH GENERAL PHYSICS, BASED ON THE JOB TASK ANALYSIS AND SUBJECTS ADDRESSED IN THE PREVIOUS BIENNIAL PERIOD. SCENARIOS WERE VALIDATED BY SHIFT CREWS, OPERATORS AND TRAINING MANAGEMENT.

FUTURE SCENARIOS WILL BE DEV 3 LOPED IN HOUSE UTILIZING THE SITE SIMULATOR WITH BASIS AND VAll 1 ATION AS STATED ABOVE.

2) HAVE THESE SCENARIOS BEEN USEI) BEFORE ATTHE SIMUIATOR?

YES,THEY WERE USED DURING PldVIOUS YEAR'S TRAINING AND -

)

EVALUATIONS.

3) UOW HAVE WE HANDLED SIMULATOR FAILURES IN THE PAST AND WHAT PROCESS IS IN PLACE TO RE-EXAMINE SIMULATOR FAII URES?

,

OYSTER CREEK HAS HAD NO LICENSED OPERATOR REQUAL SIMULATOR FAILURES. FAILURES WILL BE ADDRESSED ON A CASE-BY-CASE IIASIS WilEN NECESSARY. OPERATORS WilO FAIL ARE REMOVED FROM SIIIFI'

?

UNTIL REMEDIATED/RE EXAMINED. A FAILURE WOULD REQUIRE l

RETESTING ON THE SIMULATOR AS A MINIMUM.

4) PROVIDE STATUS OF COMMITMENTS MADE AT 4/24/90 MANAGEMENT M EETING.

I AS LISTED.

-'

5) WHAT IS GPUN'S POSITION ON HOW OPERATOR EVALUATIONS CONDUCTED AT THE NMP-1 SIMULATOR MEET 10CFR55.59 REOUIREMENTS?

GPUN BELIEVES THE EVALUATIONS WERE CONDUCTED IN ACCORDANCE l

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WITH 10CFR55.59 REQUIREMENTS BASED ON GUIDANCE PROVIDED IN EXAMINER STANDARD 601.

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LIST PROCEDURE CHANGES BROKEN DOWN AS FOLLOWS: (A) DUE TO GPUN VALIDATION. (ID DUE TO JOINT GPUN/NRC VALIDATION. (C) DUE

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TO SIMUIATOR EVALUATION PROCESS AND (D) DUE TO EXAM PROCESS.

AS LISTED.

7)

RESPOND TO CONCERN THAT OPERATOR FAILED TO IMMEDIATELY SCRAM ON LOW VACUUM CONDITION.

PROCEDURE 106 REQUIREMENTS WERE REVIEWED WITH INDIVIDUAL INVOLVED. MEMORANDUM WAS ISSUED TO ALL LICENSED OPERATORS TO -

EMPHASIZE REQUIREMENTS OF PROCEDURE 106, PARAGRAPH 4.2.2. TIIE

PARAGRAPH STATES IN PART, THAT THE CONTROL ROOM OPERATOR HAS TIIE DUTY AND AUTHORITY TO SHUT DOWN THE REACTOR 'WHEN VERIFIED OPERATING PARAMETERS SHOULD HAVE INITIATED A SCRAM AND NO SCRAM OCCURRED". NOTE THAT UNDER THESE CIRCUMSTANCES, APPROVAL FROM TIIE GSS IS NEITHER REQUIRED NOR WARRANTED. IT IS REQUIRED THAT THE CRO IMMEDIATELY INITIATE A MANUAL SCRAM UPON RECOGNITION OF A FAILURE TO AUTOMATICALLY SCRAM.

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L STATUS OF COMMITMENTS FROM APRIL 24.1990 MEETING i

COMMITMENT STATUS

.1 COMPLETE 2-TO BE COMPLETED BY MARCH,1991 l

TO BE COMPLETED BY MARCH,1991

'I

INTERIM GUIDANCE HAS BEEN ISSUED. TO BE COMPLETED llY END OF 3RD QUARTER,1990 t

5A COMPLETE 5B AS APPROPRIATE SC COMPLETE SD WilEN SITE SPECIFIC SIMUIATOR IS.

AVAlLABLE

COMPLETE a

"'O BE IMPLEMENTED llY END OF 4TH QUARTER, 1590

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IN PROGRESS TO BE COMPLETED BY END OF JT;NE,1990

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IN PROGRESS. TO BE COMPLETED BY END OF JUNE,1990 j

i-10 COMPLETE

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IN ADDITION, PROCEDURE WRITERS STANDARD IS COMPLETE.

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' CORRECTIVE ACTIONS.

1)

A CLEARLY DEFINED PROCESS FOR TECHNICAL AND TIME VALIDATION WILL BE ESTABLISHED (JUNE 1990).

2)

WPJITEN EXAM BANK WILL RECEIVE AN INDEPENDENT REVIEW TO IMPROVE QUESTION. CLARITY (MARCH L991).

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3)

THE WRTITEN EXAM BANK WIEL BE TECHNICALLY AND TIME REVALIDATED (MARCH 1991).

4)

THE JPM FORMAT AND EVALUATION PROCESS WILL BE

-

MODIFIED TO MORE THOROUGHLY STRESS DEMONSTRATION OF PROCEDURAL ADHERENCE ALONG WITH THE CRITICAL STEPS AS -

.

PASS / FAIL CRITERIA (3RD QUARTER 1990)._

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5)

THE JPM ADMINIS'IRATION PROCESS WILL BE MODIFIED AS

,

FOLLOWS:

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USE OF FLASHLIGHT TO CLEARLY POINT OUT i

SWITCHES (COMPLETE).

!

EACH OPERATOR WILL BE EXPOSED TO THE USE OF TWO GPUN EVALUATORS TO CLOSELY SIMULATE THE'

ACTUAL REQUAL EXAM (AS APPROPRIATE).

• REQUIRE OPERATORS TO WRITE DOWN TASKe

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INITIALLYTO MINIMIZE POTENTIAL

,

MISCOMMUNICATION (COMPLETE).

• PLANT REFERENCE SIMULATOR WILL BE USED WHEN i

AVAIIABLE (PROJECTED - EARLY 1991)..

i 6)

THE TRAINING PROCESS FOR JPM EVALUATORS WILL BE

EXPANDED TO INCLUDE THE IMPORTANCE OF IDENTIFICATION '

AND RESOLUTION OF DIFFERENCES BETWEEN UTILITY AND.NRC ~

EVALUATORS ON THE SPOT TO AVOID SUBSEQUENT FACTUAL '

DISAGREEMENTS (JUNE 1990).

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AN ENHANCED ON THE. JOB TRAINING PROGRAM IS BEING DEVELOPED BY THE OPERATIONS DEPARTMENT. ITWILL INCLUDE JPM WALKTHROUGHS. -JPM REVALIDATION WILL BE AN ON-GOING PART OF THIS EFFORT (IMPLEMENTED. 4TH l

QUARTER L990).

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INDIVIDUAL JPM FAILURES WILL BE REVIEWED ONE,-ON ONE

-:

WITH EACH OPERATOR INVOLVED (JUNE 1990).

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.

9)

INDIVIDUAL WRITTEN EXAMS WILL BE REVIEWED ONE-ON.ONE WTTH OPERATORS INVOLVED TO UPGRADE THEIR KNOWLEDGE

'

(JUNE 1990).

,

COMktON AREAS OF QUESTION DIFFICULTY WILL BE 10)

IDEh"17FIED FOR INCLUSION IN THIS BIENNIAL REQUAL CYCLE AS d?ROPRIATE (MAY 1990).-

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Procedure changes resulting from on-going Biennial Review Process.

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Proc. 107, Procedure control

.

- Replaces previous temp change to this procedure.

Requires that one of the RTRs signing a tamp change must hold an SRO if the change

'may affect the operational status of facility systems or equipment".

Proc. 201.1, Approach to criticality

- An item is added to the pre-critical check-off to ensure PASS is ready for operation.

Proc. 201.2, Plant Heatup to Hot Standby

- Gives directions for bypassing IRM channel whenever ranging between ranges 6 and 7 to prevent spurious half scrams, t

- Renewal of previous temp change to make value of condenser vacuum -

'j for removing mechanical vacuum pump-frem service consistent with

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other procedures.

Adds stop to manually reset condenser. vacuum

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switches if they don't automatically reset.

'

Proc. 253.2, Plant Cooldown from Hot Standby to Cold Shutdown

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- Deletes unnecessary surveillance requirements when removing low

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Condenser vacuum and MSIV :lesure fumpors.

'

Proc. 215.2, Turbine Lube oil System i

- Provide guidance on swapping the EPR final filters and roughing

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I Proc. 317.4, Feedwater Hydrogen Injection ll

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- Provides added isolation when placing hydrogen injection system into

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service, by closing manual isolation valves in addition to automatic valves.

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Proc. 330, Standby Gas Treatment System

.

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- Precaution added to remind operator to notify Chemistry -before securing Reactor Building exhaust fans.

- Moves material for system reset from Precautions and Limitations to

' Instructions, where it belongs.

)

- Step added to open Reactor Building isolation valves V-28-21 and i

V-28-22 before resetting push button interlock on Panel-11R.

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- Provides damper numbers for inlet dampers to SGTS f ans EF-1-8 and

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EF-1-9 and corrects the position of these dampers in'the lineup;to_

.j locked open.

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Procedure Changes 'resulting from Oyster Creeks simulator Training.

Proc. 201.1, Approach to criticality

.

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- Step added to allow for exiting procedure if a startup must be aborted.

• Proc. 315.1, Main Turbine operation

- Adds step to confirm EPR power switch is on.

~

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Proc. 2000-RAP-3024.01, NSSS Annunciator-Response Procedures

- Window H-7-e, G-1-b, G-2-b.and H-6-a revised to have the operators

>

perform actions in the associated ABN series procedures.

- Window E-1(2)-c, E-1(2)-e, F-1(2)-a, F-1(2)-c and F-1(2)-e revised to reflect that only one recirc~ loop must be open at most times.

- Adde initiating signal to window C-1(2)-a, -ISOL COND LOGIC TRAIN I(II) ACTUATED, V-14-34(35) manually opened.

I Clarifies and adds reference to Standing order 21 for windows

-

G-1(2)-d, REACTOR NUTRON NONITORS CHANNEL I(II).

'

- Adds reference to Procedure 2000-ABN-3200.07,.? Unexplained-Reactivity Change", to window G-7-d, SRM PERIOD SHORT.

Procedure Changes result $ng from Actual Requal Exam.

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. Proc. 315.1, (Upcoming Rev.)

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- Remove instructions for operating EPR, MPR and DVOJ from-turbine

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normal ops to own section.

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Proc. 2000-ABN-3200.29, Response to Fire.

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- Instructs operator to reset fire detection alarm and HVAC system before returning HVAC system to normal.

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Proc. 312, Reactor containment Integrity and Acnosphere Control

- Changes requirements for nitrogen. tank level for commencement of-j containment inerting.

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Proc.'610.4.007, Core Spray System Firewater Valve Test i

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- Corrects PIV number in System 1 valvo lineup.

Proc. 2000-ABN-3200.32, Response to Loss of Intake

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- Puts references to Emergency Plan procedures - at = beginning of low intake level sectio'n.

.

Proc. 2000-RAP-3024.03, BOP Annunciator Response Procedures

- Window Q-3-c' revised to correct condenser low vacuum scram setpoint

!

and to have operator take corrective action in accordance with Ops l

procedure.

!

- Window Q-6-b revised to clarify the points that will cause the alarm.

.

.

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II.

Procedure changes resulting from Oyster. Creek JPN and Exam Bank Validation.

Proc. 301, Nuclear Steam Supply System

.,

- Clarifies procedure for taking. remote manual co'ntrol of recire pump

after an air failure lockup.

-

Proc. 305, Shutdown Cooling System Operation

- Clarifies requirements for satisfying the shutdown cooling pump- -

start interlock.

r

- Proc. 308, (Upcoming Rev.)

- Move directions for taking manual control of Core Spray from Section 5.0 to 6.0.-

Proc. 308, Rev.~40, Emergency Core Cooling-System Operation

- Directions for verifying fire water injection and securing fire water injection enhanced to agree with emergency operating procedures.

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Proc.-310, containment spray System operation

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'- Has operators-enter emergency operating procedures anytime thau torus water temperature is greater that 90*F.

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Proc. 312.1, (Upcoming Rev.) ~

- Make various clarifications, corrections'and additions identified in' performance of operator JPMs.

Proc. 331.1, Rev. 1, Control Room and Old Cable Spreading. Room NVAC System-

- Adds a note to ensure that a path for contamination to enter the Control Room via EF-1-24 is eliminated when operating in partial or full recire-uodes.,

- Note added t'o confirm EF-1-24'is.off and'its damper' closed when operating control-Room HVAC in partial or full' recirculation' modes.

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Proc. 334, (Upcoming Rev.)

' l

- Change steps contained-in a " NOTE * to regular proceduralToteps.

Proc. 337, 4160 Volt Electrical System

- Clarifies procedure for energizing a dead emergency: bus.

Proc.'2000-RAP-3024.01, NSSS-Annunciator Response'Procedares

'

- corrects alarm setpoint for Cleanup' system area high radiation to 100mR/hr.

Proc. 2000-RAP-3024.02, Electrical Annunciator Response Procedures

,

- Window R-3-c reviaed to have operator, tak'e corrective actions in accordance with associated ABN-proceduro.

Proc. 2000-RAP-3024.O?, BOP Annunciator Response Precedures

- l l

- Corrects the references to Emergency Plan-procedures for window J-3-a, J-4-a, J-1-b, J-2-b,'J-3-b, K-5-e and K-5-f.

-

-WindowsJ-1-b,K-5-eandK-5-frevisedtoprovideguidancetot$e operators on the possible entrance into the EPIP's.

III.

Procedure Changes resulting from NRC and OC Exam Team ' review of JPMs-and simulator scenarios.

Proc. 309.2, Reactor Building closed Cooling Water System

- Corrects the Toch Spec section on radioactive releases referenced in the section on heat exchanger tube leak determination.

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' Proc. 310, Containment Spray System operation

- Deletes the i tolerances for pump start time delays.

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ATTACHMENT 5

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GPU'N_UCLEAR EXAMINATION RELATED FINDINGS AND CONCLUSIONS JULY'26, 1990

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GPU Nuclear Corporation-l Nuclear

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Forked River, New Jersey 08731 0388 i

609 971 4000 Writer's Direct Dial Number:

'

July 26,1990 Mr. Thomas T. Martin, Administrator

, Region I

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia,'PA 19406 t

. Dear Mr. Martins--

~

Subject Oyster Creek-Nuclear Generating Station Docket No. 50-219.

Operator Requalification Examinations Enclosed is the facil'ity evaluation report for the. licensed operator.

raqualification exams.adminstered to 21 individuals from April.9 to June 8, 1990.

This information is being provided'at the request of NRC Region 1 management.

>

Ovsrall, Oyster Creek has rated'its licensed operator-requalification program.as.

'

cctisfactory. All 12 Senior Reactor Operators passed.both the written and operating portions of the exam. Four out of 9' Reactor Operators failed the exam; thsre were 3 written exam failures and 2 operating exam failures (one operator i

fciled both sections).

If there are any questions, please call Mr. Michael Heller, Licensing: Engineer, at-(609)-971-4480.

Very truly yours, (

,

E.E.-Fitzpa. rick

,

Vice President and Director Oyster Creek EEF/MH/jc (OPERTRNG 38)

L Attachment I

cca Mr. R. Conte Region I

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U.S. Nuclear Regulatory Commission 475 Allendale Road

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' King of Prussia, PA19406 U.S. Nuclear Regulatory Commission Attna Document Control Desk

' Washington, DC 20555 NRC Resident Inspector t

Oyster Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary d General Pubhc Utihties Corporation i

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EIAMINATION RELATED FINDINGS AND CONCLUSIONS

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Written Examinations The following is a' summary of the generic strengths and weaknesses noted from the grading of the written examinations.

i Strenothe

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.1 Understanding the operation of the turbine control pressure regulating

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system.

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Understanding of the basis of. adequate core cooling due to steam flow

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through open EMRVs.

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.Use of Abnormal Procedures addressing high winds.

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Use of Alarm Responso Procedures addressing high drywell pressure.

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Interpreting Technical Specifications when control rod drive will not move

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due to failed collet.

Use of Emergency Plan to determine how transfer of communication i

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responsibility is accomplished during an emergency (RO ONLY).

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Weaknesses Understanding the basis for emergency depressurization in level

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restoration procedures.

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Knowledge of conditions that require entry into level control procedures.

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Understanding of xenon transients.

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Identifying applicable Technical Specifications, given Static' Simulator

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' Scenario.

Use of the protective action recommendations flow chart in the Emergency

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Plan (SRO ONLY).

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Use of Abnormal Operating Procedures concerning feedwater control problem-

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t Ooeratina Examinationg The following is a summary of generic' strengths and weaknesses as noted on the i

operating tests.

Job Performance Measures

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Strenoths Knowledge and use of the support procedures-for the SBEOPs (Procedure

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312.1, Procedure 106.9).

Weaknesses

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Locating procedure for purging the Control Room.

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Locating information required to perform a heat balance.

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The basis for initiating containment spray system when torus pressure

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reaches 17 pounds.

Identifying Technical Specification that applies when 4160V bus 1c is

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de-energized.

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consequences of placing the recirculation pump local controller in

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automatic with the I/P lower than other pumps.

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Interlocks associated with EC and ED breakers.

criteria for securing the liquid poison system.

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Page 2 of 3 Simulator Examination Strenothe-Communication and teamwork displayed by the shift complement.

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Use of Alarm Response Procedures and Abnormcs Procedures.

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Command cnd control expressed by the Group Operating Supervisor, when

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assuming the role of shift Supervisor.

Weaknesses i

Predicting the amount of lead time available prior to reaching a

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condition requiring emergency depressurization and taking appropriate anticipatory actions.

Effect of bypass valve operation on reactor vessel level while having

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feedwater control system in manual.

Crews did not provide feedback to GSS on wrong or questionable

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decisions.

GENERAL OBSERVATIONS Written Examination The.following deficiencies were noted in the examination bank during the i

examination process.

Questions which solicit multiple answers.

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Questions which do not solicit respective answer, as writtea

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Partial credit not explicitly defined.

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Validation process not clearly defined.'

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Job Performance Measures Format and Job Performance Measure not closely tied to procedures -

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relied too heavily on critical elements.

Standards need to.be more clearly defined'for acceptable operator

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actions.

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Validation process not clearly defined.

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Simulator Scenarios Insufficient detail-in the simulator scenario. Need to include more

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operational steps.

The standard did not delineate the expected operator actions to

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accomplish a task.

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Need to more clearly define what determines a critical task.

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Too many critical tasks, especially GSS, in several scenarios.

Several malfunctions were not properly noted on the scenario.

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Validation procesa not clearly defined.

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Procrammatic Deficiencies Insufficient training utilizing' walk-through of evolutio'ns (JPM's).

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Lack of static-simulator style examinations during Biennial Program.

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Corrective Actions Planned-A clearly defined process for technical and time validation will be

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established'(complete).

Written exam bank will receive an independent review to improve

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question. clarity-(March 1991).

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The written exam bank will be technically and time revalidated (March-

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1991).

The JPM format'and evaluation process will be modified to more

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throughly stress demonstration of procedural adherence along with the

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critical steps as pass / fail criteria (3rd quarter 1990)..

The JPM' format administration process will be modified as follows:

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Use of flashlight to clearly point out switches (complete).

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Each Operator will be exposed to the use of.two CPUN evaluators to

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I closely simulate the a:taal requal axamination (as appropriate).

Require Operators to write down task initially to' minimize

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potential m'.scommunication (complete).

Plant reference simulator will be used when available (projected -

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early 1991).

The. training process for JPM evaluators will be expanded to include the

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importance of identification and resolution of differences between utility and NRC evaluators on the spot to avoid subsequent factual disagreements (complete).

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An enhanced on-the-job training program.is being developed by the-

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Operations Department.

It will~ include JPM walkthroughs. JPM revalidation will be an on-going.part of this effort (implemented - 4th quarter 1990).

Individual JPM failures will be reviewed one-on-one with each Operator

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involved (complete).

Individual written exams. will be reviewed one-on-one with Operators

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involved to upgrade their knowledge (complete).

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common areas of question difficulty will be identifisd.for inclusion in-l

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this Biennial Requal Program as appropriate (complete).

Simulator scenarios will be enhanced to increase detail via the

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inclusion of more operational steps, clearly defined expected operator

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actions and to reduce the number of critical tasks.

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