IR 05000237/1994004
| ML17180A626 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/04/1994 |
| From: | Bielby M, Jordan M, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17180A625 | List: |
| References | |
| 50-237-94-04, 50-237-94-4, 50-249-94-04, 50-249-94-4, NUDOCS 9403160068 | |
| Download: ML17180A626 (13) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-237/94004(DRS)
Docket Nos. 50-237; 50-249 Licenses Nos. DPR-29; DPR-27 Licensee: * Commonwealth Edison Company Opus West II I 1400 Opus Place Downers Grove, IL 60515 Faci l ity Name:
Inspection At:
Inspection Inspector:
Inspector:
Approved By:
Dresden Nuclear Power Station Dresden Nuclear Power Station Morris, IL Operator Licensing Section 1 Inspection Summary 1994 Date 3/i/Jr Date 3/;)1[
Date Inspection Conducted January 31 - February 8, 1994 (Report No. *
50-237/94004(DRS)).
Areas Inspected: Special, announced inspection of the licensed operator requalification program to include a review of training administrative procedures, requalification training records and operating examination material; observation and evaluation of operator performance and licensee evaluators during requalification operating examination and remediation training administration; an evaluation of program controls to assure a systems approach to training; and an assessment of simulator fidelity. The inspectors used the guidance in Temporary Instruction (Tl) 2515/11 One senior reactor operator (SRO) was administered a requalification retake examination (job performance measures portion only).
Requalification Retake Examination Results:
'
The SRO satisfactorily completed the job performance measures (JPM)
requalification retake examinatio PDR ADOCK 05000237 G
Requalification Inspection Results:
The inspectors concluded that the licensee's overall implemention of the licensed operator requalification training program was in accordance with 10 CFR Part 55 requirements, and that operations and training management involvement with the process was a strengt Strengths:
Operations management observation and participation in crew evaluations during dynamic scenario examinations (Section 2.1.1).
- Operations management actively provided input regarding required training (Section 2.5).
Weaknesses:
Written examination questions (Section 2.1.3).
- Operator communications (Section 2.2).
- Lack of objective individual operator evaluations during dynamic simulator scenarios (Section 2.2).
- Lack of simulator backpanels (Section 2.6).
- REPORT DETAILS Persons Contacted The Commonwealth Edison Company
+M. Lyster, Site Vice President
+R. Wroblewski, Regulatory Assurance
- +M.*Korchynsky, Shift Operations Supervisor
- +D. Schavey, Operations Training Supervisor
+R. Sitts, Operations Training Requal Administrator
+J. Cox, Simulator Fidelity Coordinator
+A. D'Antonio, Site Quality Verification Superintendent
+R. Weidner, Training Supervisor
- J. Heck, Operations Training
- D. Zehrung, Operations Training
- K. Rach, BWR Operations Training Supervisor NRC Representatives
- +M. Bielby, Region III NRC Inspector
+E. Plettner, Region III NRC Inspector
+M. Leach, Dresden Senior Resident Inspector
- Denotes those present at the entrance meeting on January 31, 199 + Denotes those present at the exit meeting on February 8, 1994. Introduction. The purpose of this inspection was to assess the licensee's requalification program for licensed operators in order to determine whether the program incorporated 10 CFR Part 55 requirements for evaluating operator mastery of training objectives and revising the progra The licensed operator requalification program assessment included a review of training administrative procedures, requalification training records, and operating examination material. The inspectors conducted an evaluation of operator performance and the ability of licensee evaluators to administer and objectively evaluate during requalification operating examination An evaluation of the effectiveness of the program controls to assure a systems approach to training and remediation training was conducte The inspectors also assessed simulator fidelit Licensed Operator Regualification Program Assessment Program Administration The inspectors identified the following strengths regarding requalification program administration:
2.. *
Operations and training management observed crew evaluations during dynamic simulator examinations as verified by inspector observation and interviews with plant personne *
Operations management participated in crew evaluations during dynamic simulator examinations as verified by inspector observation and interviews with plant personne *
Attendance at requalification training had an appropriately high pri ori-t During review of the administrative procedures, the inspectors noted that the method of assigning credit for plant control manipulations did not require the operators to manipulate the controls. All crew members are given credit for manipulation of controls that occur during an evaluatio However, discussions with requalification training personnel indicated that all members of a crew are required to directly observe and otherwise be involved in discussions of the manipulations, which is acceptabl The inspectors concluded that the licensee was implementing the licensed operator requalification training program in accordance with the licensee's administrative procedures and 10 CFR 55 requirement Regualification Training Records Review The inspectors reviewed requalification training and attendance records for 1993 and 1994 training cycles and concluded that licensed operators had attended or made up all scheduled requalification training as required by their progra The inspectors also noted an adequate continuing training program for Nuclear Operator Instructors as evidenced by attendance at scheduled trainin Regualification Examination Material Review The inspectors reviewed the operating and written examinations administered during the inspection.wee The examination material followed guidelines contained in Revision 7 of the Examiner Standards, NUREG 102 The inspectors noted that adequate overlap existed for the JPM and dynamic simulator examinations for the duration of the examination cycle. The licensee had a tracking program to incorporate changes to the examination bank material when procedure changes or modifications were implemented by the plant. If a question is incorrectly answered on an examination a specified criteria number of times, the licensee has an evaluation program in place to review the question for clarity and correctness. Although the licensee's examination bank contains 1300 questions, there were areas which contained an insufficient number of questions to prevent repeating the questions on several written examinations throughout the annual examination cycl * *
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The inspectors made the following observations regarding the examination material:
Dynamic scenarios were very goo The number of malfunctions, complexity and run times were appropriat They also exercised various legs of the EOPs sufficiently. There were no significant weaknesses identifie *
The job performance measures (JPMs) were of good quality. They involved tasks important to safety, and appropriate steps were designated as critical for the successful completion of the tas At least 20% of the selected JPMs were not included in the most recent training cycle topic One JPM, "Mispositioned Control Rod
, was used as a common JPM to follow-up on a previous weakness identified by the NRC during the previous initial license examinatio Although the JPM examination bank contained alternate path JPMs, none were used for this evaluatio *
The Part A (static) and Part B written examinations were adequat The static examination questions were operationally oriented and took advantage of the simulator control room setting. Although the written examination contained a total of 40 questions, two or more of the following occurrences were identified during a comparison of the questions to the guidelines contained in NUREG/BR-0122, Revision 5, Examiners' Handbook For Developing Operator Licensing Written Examinations:
double-jeopardy questions
questions with stem information that eliminated two of the distractors
lack of clarity and preciseness in the question stem to illicit the identified correct answer
memory-level knowledge questions
direct look-up questions The inspectors concluded that the overall examination was adequat Operator Performance Evaluation The inspectors observed the performance of one operating crew (two groups) during dynamic scenarios and JPM examination The inspectors identified the following concerns:
The inspectors noted that the communication technique used during the dynamic simulator examination was inconsisten One of the groups was generally consistent with the use of three-peat communication The other group did not always acknowledge orders or information; when orders or information was not acknowledged, there was often no attempt to pursue it; and sometimes orders were not acknowledged, but still executed.
4 The inspectors also noted that the licensee failed to conduct an objective individual evaluation after administering annual dynamic scenarios examination CFR Part 55.59(a)(2) states that operators must pass an annual operating examination, and that the operating test will require the operator or senior operator to demonstrate an understanding of and the ability to perform the actions necessary to accomplish a comprehensive sample of items specified in Paragraph 55.45(a)(2) through (13) to the extent applicable. These items include identifying the significance of facility instrument readings, safely operating the facility's emergency systems, and demonstrating knowledge of the facility emergency plan. Attachment 3, Section C.1, of ES-604 states, 11The annual operating test should sample from all the operating skills and abilities required of an operator and the operating crew.
Although the licensee evaluators recorded individual performance weaknesses noted during crew evaluations, they did not have established standards nor objective grading criteria to determine if an individual demonstrated an understanding of, or ability, to do operational task The inspectors noted that immediately after dynamic scenarios, the licensee performed a crew evaluation using crew competency forms which had a rating system with a brief description of the rating factor The licensee then recorded identified individual performance weaknesses noted during the crew evaluation on a form entitled 11Dynamic Evaluation
/ Individual Performance Summary" as required by their training department instruction, TDI-523, Revision 0, November 1993, 11 Licensed Operator Annual Requalification Examinations".
TDI-523, section B.4.c, does not direct what criteria is to be used for the individual evaluation. It was not clear to the inspectors what objective criteria was being used to evaluate the individual Further discussions with requalification training personnel indicated that the crew competency factors, and operations standards for procedural adherence and communications contained in administrative procedures OAP 09-13, revision 1, "Procedural Adherence"; and OAP 07-02, revision 18, 11Conduct of Shift Operations
, section E.9 and Figure 2, were use The crew competency factors are not designed to evaluate individuals, and the lack of objective grading criteria or established standards made it uncertain that the individuals were evaluated as described in 10 CFR Part 55.59(a)(2). This item is corisidered unresolved (237/94004-01 (DRS)).
Evaluation of Licensee Evaluators The licensee determined one SRO to be unsatisfactory as a result of competencies during the dynamic scenario evaluation The SRO was immediately removed from shift and could not return until satisfactory completion of a remediation progra The inspectors' and licensees'
overall assessment of operator performance during the dynamic scenarios and JPMs was in agreemen Parallel grading of the written examinations was identica The NRC inspectors and the licensee evaluators overall assessment of operator performance was in agreemen The inspectors concluded that the licensee evaluators could adequately administer the requalification
- examinations and objectively evaluate the performance of the operator.4 Systems Approach to Training Controls The inspectors reviewed the previous two years Safety Assessment and Quality Verification (SAQV) audits, 12-92-01 and 12-93-01 for requalification trainin Items identified by 12-92-01 appear to have been adequately addressed by the licensee based on a comparison of audit results in the area of licensed operator required reading package also indicated a new data base to identify plant modifications and incorporate them into training to address the issue for lack of depth and timely implementation of plant modifications into trainin Inspectors verified this based on audit documentation and through interviews of training and operations personne The inspectors concluded that the licensee's program had controls in place to revise the training program as needed based on audits, industry and plant events, system and procedure modifications, and operator feedbac.5 Personnel Interviews The inspectors conducted interviews with a cross section of management and staff from both operations and requalification training group Results indicated that: plant, training and operations management periodically observed and participated in requalification evaluations of licensed personnel in dynamic simulator scenarios; operations management exhibited ownership of the requalification training program; and, training management and staff were responsive to operations request Interviews also verified the SAQV audit findings and corrective actions identified in Section 2.4 of this repor.6 Simulator Fidelity The simulator model handled all phases of the dynamic scenarios and appeared to reflect how the plant respond No discrepancies were noted during performance of the operating examinatio The inspectors review of the simulator fidelity log indicated that a continuous review and upgrade program is in place and continues to effectively address immediate and long range repair and improvement of the simulato The inspectors noted a lack of backpanels during the operating examinatio Discussions with the simulator fidelity group indicated the licensee plans to obtain or simulate backpanels to reduce the amount of face to face communications between the crew and simulator operators in order to obtain status of equipment from the backpanel.0 Licensee Actions on Previous Operator Licensing Examination Findings (92701)
(Closed) Mispositioned Control Rod Followup Item (50-237/0L-93-0l(DRSll:
The inspectors reviewed the licensee's revised training material, and observed operator performance during the requalification examination dealing with the subject of a mispositioned control ro The inspectors concluded that adequate corrective action has been taken to address the concer This item is close Licensee Actions on Previous Inspection Findings (92702)
(Open) Violation (50-237/93024-0l(DRS); 50-249/93024-0l(DRS)l:
Licensed operators failed to receive a medical examination by a physician every two year The inspectors reviewed the licensee's training department instruction, TDI-502, Revision 0, for control and administration of licensed operator physical examination The inspectors also reviewed the licensee's current schedule for licensed operator physicals and discussed the licensee's most recent response, dated December 15, 199 TDI-502 clearly does not ensure that operators will receive physicals every two year The licensee stated that they are reluctant to revise TDI-502 because it is still not clear that licensed operators are to receive physical examinations every two years from the date of their last physical. Discussions with the training department, and review of their scheduling of operator physical examinations, indicates the licensee's current intent is to ensure operators receive their physicals within the required two year period of their last physical. The NRC has subsequently issued Information Notice 94-14, which states that NRC-licensed reactor operators and senior reactor operators (licensees) are to be examined by a physician every 2 years. Although the licensee's intent is to ensure their licensed operators receive required physicals every two years, their procedural guidance does not. This item remains ope.0 Violations, Open Items, Unresolved Items Unresolved Items Unresolved items are matters which require additional information to determine whether they are acceptable, violations, or deviations. The unresolved item identified during this inspection documented in Section 2.2, is the NRC's determination of whether Dresden's crew evaluations constitute the required individual evaluations during dynamic simulator test.0 Exit Meeting The inspectors conducted the exit meeting on February 8, 1994.
Present were the plant management, training staff, and other staff listed in Section 1.0 of this repor The inspectors discussed the major areas reviewed during the inspection, the strengths and weaknesses observed, and the inspection results. The inspectors also discussed the likely informational content of the inspection repor The licensee did not identify any documents or processes as proprietar *
SIMULATION FACILITY FIDELITY REPORT Facility Licensee:
Dresden Nuclear Power Station Facility Licensee Docket No.: 50-237, -249 Operating Tests Administered: February 3 - 4, 1994 Attachment This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further.
verification and review, indicative of noncompliance with 10 CFR 55.45(b).
These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluation No licensee action is required in response to these observation While conducting the simulator portion of the operating tests, the following items were observed (if none, so state):
DESCRIPTION NONE OBSERVED
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