IR 05000255/1995006
| ML18064A695 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/14/1995 |
| From: | Burdick T, Hansen J, Lennartz J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18064A694 | List: |
| References | |
| 50-255-95-06, 50-255-95-6, NUDOCS 9504180214 | |
| Download: ML18064A695 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION II I Report No. 50-255/95006(DRS)
Docket Nos. 50-255
'Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:* Palisades Nuclear Plant
./
Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
March 27 - 31, 1995 Inspector:
Lead Inspector:
Approved By:. ~
T:BUriCJCie Operator L1censing Section Inspection Summary Licenses No. DPR-20 Date
Inspection conducted on March 27 - 31.* 1995 {Report No. 50-255/95006CDRS))**
Areas Inspected: Announced inspection of the. licensed operator requalification
~rogram to include a revie~ 6f training administrative procedures, requalification training records and examination material; observation and evaluation of operator performance and of licensee evaluators during requalification exa~ination admiriistration; an evaluation of the program controls to assure a systems approach to training; and an assessment of simulator fid~lity. The inspectors used the guidance in NRC Inspection Procedure 2515/7100 Results: Within.the areas inspected, no violations, deviations, or inspection followup items were identified. The inspectors concluded that the licensee was implementing the licensed operator requalification trafning program in accordance with 10 CFR Part 55 requirement Operator performance was satisfactor ~8R41ao214 950414 a
ADOCK 05000255 PDR
Strengths:
The scope of questions used in the annual written examination and the minimal overlap of examination materials from prior examinations (Sections 3.1 and 3.2).
- Operations management regularly monitored requalification training for content and participated in examination development and administration (Section 3.2).
- Operations Curriculum Committee and Training Improvement Program (TIPs}
input to the SAT based training program (Sections 3.3 and 3.5}.
Weaknesses:
The control ~d rev1s1on of job performance measures and the absence of low power and shutdown scenarios in the evaluation scenario bank (Section 3.1).
Control of the crew, crew communications, and rotation of operctors during evaluations (Section 3.2).
- Documentation of individual operator performance during dynamic simulator evaluations (Section 3.2).
- Proceduraliz~tion and management oversight of the program used to track operator proficiency (Section 3.7}.
Training personnel qualification card completion and the auditing of evaluators (Section 4.0).
- REPORT DETAIL Persons Contacted Licensee Representatives D. W. Rogers, Operations Manager S. C. Cote, Acting Administration Manager R. J. Frigo, Training - Ops. Staff Support Supervisor E. Feury, Training Administrator R. Scudder, Training - Simulator Support Supervisor D. Fitzgibbon, NPAD, Operations Specialist L. Todd, Operations - Sr. Instructional Technical Specialist W. L. Roberts, Plant Licensing M. A. Hobe, Nuclear Liaison Administrator Nuclear Regulatory Commission M. E. Parker, Senior Resident Inspector Other*persons were contacted as a matter of course during th~
inspectio.0
- Inspection Scope and Objectives The licensed operator requalification program evaluation included a review of training administrative procedures, written and operational examination material, systems approach to training (SAT) controls, written and operational examination administration practices, training feedback system, remedial training program, and conformance. with
- *
operator license conditions. Additionally, the inspectors observed and co-evaluated operator performance during administration of the operational examinatio Further, the inspectors assessed simulator fidelit The inspection's primary objectives were to: verify the licensee's requalification program for licensed operators ensures safe plant operation by adequately evaluating operators ski 11 s;.
- assess the licensee's effectiveness in evaluating and revising the licensed operator requalification program based on operational performance, including requalification examinations;
- ~ssess the licensee's effectiveness in ensuring that the individuals licensed to operate the facility satisfy the conditions of their licenses as specified in 10 CFR 55.5.0 Licensed Operator Regualification Program Assessment Regualification Examination Material The inspectors reviewed the examination administered during the week of March 27, 1995 and compared it to the sample plan. Additionally, the inspectors reviewed the previously administered examinatio These were evaluated against content and overlap among the evaluation period *
The inspettots concl~d~d that the lit~nse~*s requalifica~on examinations were developed in accordance with their training administrative procedures and met the intent of 10 CFR Part 5 The inspectors identified the following strengths and weaknesses*
regarding requalification examination materials:
Strengths
..
A good variety of questions were used in the written examination.
This included questions that weren't specific to the sample plan and questions with Knowledge and Ability (K/A} importance rating of less than The examiners standard normally requires questions to have an importance rating of greater than 3.0 but the questions used were appropriate for the subject material and adequate justific.ations were given for their inclusion in the examinatio The us~ of a "performance time limit" during JPM ad~inistration increased the objectivity of the evaluation criteria.
. The simulator scen~rio bank used for operator evaluation was not made available to the students for review or normal training.
Weaknesses
The written examination did not have all review signa~ures on the coversheet as required by PNT 2.0, Preparation of Training Materials arid Examiriations, Re~. 0, section..
The Job Performance Measures (JPMs} are made available to operators for training purposes but are only re~ised prior to ~s This could caus~ negative training if the JPM is not upd~ted to*
the current re~ision of ~ procedur *
PNT 7.0, Simulator Training, Rev. 0, Section 6.4.3, indicates that,.
"only approved Simulator Performance Exams (SPEs} will be ~tilized for the p~rformance evaluations." No_approval cover sheet exists on SPEs indicating training or operations management approva PNT 2.0, Preparation of Training Materials and Examinations, Rev. 0, Section 6.3.4, conimits to using NUREG 1021 for exam developmen The following weaknesses relate to meeting the guidance given in NUREG 1021, Operator Licensing Examiner Standard *
No time critical Job Performance Measures (JPMs) as discussed in ES-603 C.l.e were available in the examination ban *
The Simulator Performance Exams (SPEs) were a collection of unrelated events and malfunctions that did not flow easily from event to event. ES-604, Attachment 3, Sections B.l.a and discuss credibility, realism and event selectiti SPEs that had been recently developed showed indication of greater attention being applied to ensuring the events/malfunctions were relate *
No low power and shutdown scenar'i os have been develope ES 601, Form 601-2 indicates that low power and shutdown scenarios will be develope.2 Requalification Examination Administration The inspectors concluded that the licensee's requalification examinations were administered in accordance with their procedures and allowed for an effective evaluation of the licensed operator skill The inspectors observed administration of the annual operational examinations. Additionally, the inspectors co-evaluated the operators'
perfor~ance and were in agreement with the licensee's evaluation *
proces The inspector~ identified.the following strengths and weakness~s regarding requalification examination administration:
Strengths
Operations management has given training a high priority as evidenced by the Operations Manager observing and being involved
. with.the team eva 1 uat ion of a crew's dynamic scenario. performance..
The operations management involvement allowed direct*comrm,mication of expectations to operations personne Interviews with operations and training personnel indicated.that operations management routinely observed* and participated in the crew evaluation *
Examination security appeared adequate to prevent compromise of the examination and was not overly restrictive or stressful for the operators. *Measures were taken to ensure exam security wa5 maintained incliJding a security agreement for those involved.in exam developmen Also, appropriate measures were taken during administration to ensure crews and individuals that had received the exam did not come in contact with those yet awaiting the* exa A PLOR EXAM DEVELOPMENT JOB AID had been developed to assist the exam developer in determining overlap. This resulted in minimal exam overlap from the previous year and between weeks in the
.. current cycl Weaknesses
The Shift Supervisor (SS) often gave direction to the board operators without going through the Control Room Supervisor (CRS).
Additionally, separate directives were given to the Control Operators by the SS and CRS at about the same time which precluded timely task completio These made it difficult to determine who
on the crew was in charge during the scenario Crew communications were weak during the scenarios as indicated by a lack of repeatbacks by both Control Operators (COs)* and CRSs.
Crew members did not ensure other crew members received specific directions and the cos performed board operations without informing the CR These communication weaknesses resulted in
untimely task c011pletio Crew communication seemed to improve once the EOPs were entere *
The COs were not rotated between the RO positions for evaluation during the operational examination. This resulted in one CO not being evaluated in the primary reactor operator position. A records review indicated that these two cos were evaluated in both CO positions during the last annual exam and that the previous weeks COs were rotate In discussions with training and operation management the inspectors determined that the operators are normally rotated with the decision being left to the Shift Supervisor. This practice tould result in weaknesses in the COs abilities to conduct board operations not being identifie *
10 CFR 55.59(a)(2)(ii) states, "The operating test will require the opeyator 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 *55.45 *~***" 10 CfR 55.59 refers to *each licensee" with licensee defined as individual operator or senior operato ES-604, Section B, states, "The facility evaluators will eval~ate the performance of the licensees during the dynamic simulator examination." During the dynamic simulator examination it is conceivable that a crew member could "do nothing" and be.
compensated for by the other crew member If only a crew evaluation is performed individual weaknesses may not be identified. Therefore, the individuals as well as the crews should be eva~uated by the facilit *
. Currently, the facility only completes crew-evaluation forms for the dynamic simulator examination Identified crew comp~tency weaknesses were i dent ifi ed in the comment section on. these form However, the current documentation did not always relate*an
'*identified weakness to a specific individual. This method of documenting weaknesses was evident on crew ~valuatio.n forms.
completed this week as well as past crew evaluation forms that were reviewed by the inspectors. Therefore, an evaluation of the individual's competencies could not necessarily ~e performed..
While training records indicated that individual remediation had been performed when weaknesses were identified, the specific competency weaknesses for that individual were not documente This lack of individual documentation precluded trending individual performance weaknesses during simulator examination This resulted in eliminating a potential tool for root cause determination regarding individual performance deficiencie.3 Systems Approach to Training Controls The inspectors reviewed the licensee's operator requalification program against a systems approach to training {SAT) and concluded that the program had controls in place which effectively monitored and revised the training program as needed based on operational performance issues, ind.ustry events (LERs), plant modification packages and similar item *
The inspector's review of the Operat*ions Curriculum Co11111ittee minutes indicated that the co11111ittee had developed operator requalification traini~~ checking for appropriate content and relevancy. Also, they revised training during the cycle to be responsive to operation's need This was considered a strengt.4 Remedial Training The inspectors reviewed the licensee's remediation training program administered during the previous training yea The remediation training was appropriate for the weaknesses identified and resulted in successful completion of the assigned remediatio During the observed annual examination, remediation training was required for identified w~aknesses that did not result in crew failure. This additional remediation was considered a strength by the inspector The inspectors concluded tha:t the remediation program was appr.opriate and met the*
intent of 10 tFR Part 5.5 Training Feedback Syste~
The inspectors reviewed the licensee's training procedures and evaluation forms used during requalification training. The inspectors concluded that the training feedback system was a strength in addressing traini.ng issues identified by. plant personne The TIP (Training Improvement Program) was used to track and resolve training issue The program was comprehensive and accurate in the tracking of conunents and reconunendations concerning trainin The program also encouraged continued participafion by plant.personnel by ensuring resolutions were forwarded to the comment initiators. The TIPS presentation during each training cycle included TIP comments and resolutions, Course Evaluations, and Management Observation Interviews with operations and training personnel indicat~d the program was successfu * Quality Verification Audit Review The inspectors reviewed QA audit PA-94-27, Palisades - Training and Qualif1cation, performed October.3/94-November 4/9 The inspectors concluded that the licensee's quality verification program was operationally oriented and adequately audited and addressed the licensed requalification program performanc.7 Conformance with Operator License Conditions The inspectors concluded that the licensee's programs to ensure that individuals licensed to operate the Palisades Plant would satisfy the conditions of their license as specified in 10 CFR Part 55.53 are adequate with a weakness in the tracking of operator license statu licensed Operator Medical Examinations Medical records reviewed were satisfactory with one minor exception. A followup pulmonary test was scheduled on one individual who had originally failed the respirator certification then was determined to
pass by a-pulmonary specialist. Documentation of the followup examination was not in the individuals medical file. Upon further investigation the inspector determined that the followup examination had never been performe Subsequently, the facility scheduled a followup examination for the individual with the pulmonary specialist. The inspector concluded that the individuals respirator certification was currently vali Maintenance of Ooerators License Status The mechanism used to track proficiency watches was not proceduralized and was dependent on the abilities of one individual in operation The facility tracked each active license's watch standing performance on the Operations Proficiency Watch Record which is maintained in a log book in or near the main control roo Prior to the end of each quarter, the Plant Suppor~/rSupervisor in charge of shift scheduling reviewed this data and nottfied the licensed operators that were not in complianc The Plant Support Supervisor would not schedule operators to stand shift whose proficiency had lapsed but no list of active and inactive licenses was published for management revie The inspectors requested the names of those operators whose licenses were currently inactiv The Plant Support Supervisor provided the names of three senior reactor operator During a review of the Operations Licensee Record supplied by the Training Administrator and the Operations Proficiency Watch Record, two additional inactive licenses were identified. The Plant Support Supervisor indicated that these were personnel holding RO licenses that had been promoted to non-union positions and could not be scheduled for the CO positio The inspectors determined that the management's oversight role in verifying the data was limite The individual licensee was expected to meet the requirements of his license in accordance with 10 CFR 55.53, Conditions of Licenses~ prior to standing shift. However, 10 CFR 50.54, Conditions of Licenses, requires the facility to ensure that licensed operators are at the control No program guidance existed for management verification of the documented data. After a review of shift records, the inspectors concluded that the licensee's program met the intent of 10 CFR Part 55 with a weakness in the management oversight of the tracking of operator license statu Regualification Attendance Licensed individual requalification training attendance was reviewe The inspectors concluded that attendance at requalification training was adequate with one observatio No attendance records were required or kept for operations meeting While no formal lesson plans were developed for the meetings, management expectations were discussed. Also, the meetings were listed on the sample plan as part of the training conducted within the cycl.8 Simulator Fidelity No plant specific simulator deficiencies were identified. Differences between the simulator and actual plant performance were documented and
- identified to the licensed operators prior to scheduled training and evaluation session Identified fidelity issues were appropriately tracked for resol~tion. Plant modifications scheduled to be completed during the next refueling outage (May - September 95) were reviewed for incorporation into the simulator modeling as appropriate. The examiners concluded that plant modifications are being actively tracked* by the simulator group. Additionally, simulator modeling was scheduled to be revised for significant plant modifications which would allow training on these modifications prior to plant operation The inspectors concluded that the simulator performance did not result in any negative training that could cause a safety concer.0 Evaluation of Licensee Evaluators The inspectors observed and co-evaluated inplant and simulator JPMs and a dynamic sc~ario evaluation., The inspectors agreed with the licensee evaluators on the overall assessment of operator performance and concluded that the licensee evaluators/instructors could adequately administer the requalification training and evaluation while objectively determining the performance of the operator However, the inspectors identified two weaknesses in the training program admir.istratio Weaknesses
Some examination evaluators were observed using improper evaluation techniques during the exa These improper techniques included not keeping notes and upcoming scenario events hidden from the candidate and inappropriate cuing during JPM performanc While plant administrative procedures did address the NRC concern that a mechanism exists to train evaluators (PAP 4.05, Rev. 10, 5.2.c.2), being audited as an evaluator is not procedurally addressed or routinely performe PNT 1.0, Personnel Traini.ng and Qualification, Rev. 0, Section 6.9, indicates the evaluation of instructional skills should be performed at least once per calendar year in an appropriate setting. Section 6.9.4 further indicates that the annual instructional skills evaluation should be the basis for requalification of an instructor in the appropriate setting. The setting of auditing the evaluator' skills is n6t addre~se *
PNT 1.0, Section 6.4 provides direction on Initial Instructional Skills Qualification and indicates that Instructor on the Job Training (IOJT) cards should be completed within the first year of assuming a job and prior to performing a task independentl However, instructor qualification cards had not been completed by some instructors in areas where they were providing unsupervised instruction even though they had been assigned to the job for greater than one yea In some instances, the instructors had been assigned to the job for several year.0 Exit Meeting The inspectors conducted an exit meeting on March 31, 1995, with the training staff and with plant management at the Palisades Nuclear Plant to discuss the major areas reviewed during the inspection, the strengths
and weaknesses observed, and the inspection results. License~
representatives in attendance at the exit meeting are documented in Section I of this repor The inspectors also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspectors during the inspection. The licensee did not identify any documents or processes as proprietary.
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