IR 05000255/2004008
| ML041670106 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/10/2004 |
| From: | Lanksbury R Plant Support Branch II |
| To: | Domonique Malone Nuclear Management Co |
| References | |
| IR-04-008 | |
| Download: ML041670106 (22) | |
Text
une 10, 2004
SUBJECT:
PALISADES NUCLEAR PLANT NRC INSPECTION REPORT 05000255/2004008(DRS)
Dear Mr. Malone:
On April 12, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed a baseline inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings which were discussed on May 20, 2004, with members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
Within these areas, the inspection consisted of a review of selected examinations, procedures, and representative records, observation of licensed operator examination activities, and interviews with personnel.
Based on the results of this inspection, we identified one issue of very low safety significance (Green) that was determined to be a violation of NRC requirements. However, because of its very low safety significance and because the issue was entered into your corrective action program with appropriate compensatory actions, the NRC is treating this issue as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you deny this Non-Cited Violation, you should provide a response with a basis for your denial, within 30 days of the date of this inspection report, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Palisades facility. In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Roger D. Lanksbury, Chief Operations Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20 Enclosure: Inspection Report 05000255/2004008(DRS)
w/attachment: Supplemental Information cc w/encl: J. Cowan, Executive Vice President and Chief Nuclear Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division Michigan Department of Attorney General
SUMMARY OF FINDINGS
IR 05000255/2004008(DRS); 03/22/2004 - 03/26/2004 (on-site) and 03/18/2004 - 04/12/2004 (periodic in-office review); Palisades Nuclear Plant; Licensed Operator Requalification Program.
This report covers an approximate one-month period of on-site and in-office reviews in the area of licensed operator requalification training and examination. This was an announced, baseline inspection conducted by two regional specialist inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commission management review. The U.S. Nuclear Regulatory Commissions program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified Findings
Cornerstone: Reactor Safety/Mitigating Systems
- Green.
The inspectors identified that the licensee was not completing the requirements of 10 CFR 55.53(f) prior to allowing inactive licensed operators to resume control room watchstanding duties. Because the Shift Engineer position did not meet the definition of "actively performing the functions of an operator or senior operator" per 10 CFR 55.4,
"Definitions," operators inappropriately received credit for license proficiency when standing this watch station. For licensees that stood this watch station exclusively, their licenses became inactive at the end of the next calendar quarter. When these licensees subsequently stood Shift Manager or Control Room Supervisor watches prior to completing the requirements of 10 CFR 55.53(f), a violation of 10 CFR 55.53(e)requirements occurred.
The finding was more than minor because the failure to satisfy license proficiency requirement increased the likelihood of an operator error involving systems used to mitigate an event. The SDP Appendix I flowchart focused on general record deficiencies exceeding a specified threshold of 20 percent of the records reviewed. The sample review of 27 operators revealed that 7 operators had inactive senior operator licenses (26 percent). The inspectors determined from the SDP that this finding was of very low safety significance. (Section 1R11.7.b)
Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Mitigating Systems
1R11 Licensed Operator Requalification
.1 Facility Operating History
a. Inspection Scope
The inspectors reviewed the plants operating history from January 2002 through March 2004 to assess whether the Licensed Operator Requalification Training (LORT)program had identified and addressed operator performance deficiencies at the plant.
b. Findings
No findings of significance were identified.
.2 Licensee Requalification Examinations
a. Inspection Scope
The inspectors performed a biennial inspection of the licensees LORT program.
The inspectors reviewed the annual requalification operating test and biennial written examination material to evaluate general quality, construction, and difficulty level.
The operating examination material reviewed consisted of four operating tests, each containing three dynamic simulator scenarios and five job performance measures (JPMs). The annual operating tests were conducted in February and March 2004.
The four biennial written examinations reviewed were administered during calendar year 2003. Each examination consisted of approximately 30 open-reference, multiple choice questions and two questions involving calculations. The inspectors reviewed the methodology for developing the examinations, including the LORT program two-year sample plan, probabilistic risk assessment insights, previously identified operator performance deficiencies, and plant modifications. The inspectors also reviewed the licensees program and assessed the level of examination material duplication during the current year annual examinations as compared to the previous years annual examinations.
b. Findings
No findings of significance were identified.
.3 Licensee Administration of Requalification Examinations
a. Inspection Scope
The inspectors observed the administration of the requalification operating tests to assess the licensees effectiveness in conducting the tests and to assess the facility evaluators ability to determine adequate performance using objective, measurable performance standards. The inspectors evaluated the performance of one shift crew and several day-staff licensees in parallel with the facility evaluators during four dynamic simulator scenarios. In addition, the inspectors observed licensee evaluators administer several JPMs to various licensed individuals. The inspectors observed the training staff personnel administer the operating test, including pre-examination briefings, observations of operator performance, and individual and crew evaluations after dynamic scenarios. The inspectors evaluated the ability of the simulator to support the examinations. A specific evaluation of simulator performance was conducted and documented under Section 1R11.7, Conformance With Simulator Requirements Specified in 10 CFR 55.46, of this report. The inspectors also reviewed the licensees overall examination security program.
b. Findings
No findings of significance were identified.
.4 Written Examination and Operating Test Results
a. Inspection Scope
The inspectors reviewed the pass/fail results of individual written examinations, individual operating tests, and crew dynamic simulator operating tests (required to be given per 10 CFR 55.59(a)(2)) administered by the licensee during calender year 2004.
b. Findings
No findings of significance were identified.
.5 Licensee Training Feedback System
a. Inspection Scope
The inspectors assessed the methods and effectiveness of the licensees processes for revising and maintaining its LORT program up to date, including the use of feedback from plant events and industry experience information. The inspectors reviewed the licensees quality assurance oversight activities, including licensee training department self-assessment reports. The inspectors evaluated the licensees ability to assess the effectiveness of its LORT program and their ability to implement appropriate corrective actions.
b. Findings
No findings of significance were identified.
.6 Licensee Remedial Training Program
a. Inspection Scope
The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous annual requalification examinations. The inspectors assessed the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans.
b. Findings
No findings of significance were identified.
.7 Conformance With Operator License Conditions
a. Inspection Scope
The inspectors reviewed the facility and individual operator licensees conformance with the requirements of 10 CFR Part 50 and 10 CFR Part 55. Specifically, the inspectors reviewed the facility licensees program for shift manning and maintaining active operator licenses to assess compliance with 10 CFR 50.54(m), and 10 CFR 55.53(e)and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators and which control room positions were granted credit for maintaining active operator license proficiency. In addition, the inspectors reviewed the facility licensees LORT program to assess compliance with the requalification program requirements as described by 10 CFR 55.59(c).
b. Findings
Introduction:
The inspectors identified one finding of very low safety significance (Green) associated with a Non-Cited Violation of 10 CFR 55.53(e), Conditions of License, for the failure to complete specified requirements (10 CFR 55.53(f)) to restore an inactive operators license to active status prior to allowing the operator to resume control room watch standing activities.
Description:
The inspectors determined that Senior Reactor Operators (SROs) were receiving watchstanding proficiency credit for standing watches at the Shift Manager, Control Room Supervisor (CRS), and the Shift Engineer/Shift Technical Advisor (SE/STA) watchstations. Two SRO watchstations are required by 10 CFR 50.54(m) to be continuously manned by operators that maintain an active SRO license while the plant is operating. At the Palisades Nuclear Plant, these two watchstations are the Shift Manager and the CRS. The SE/STA position was required by the stations technical specifications, but was not required by the stations technical specifications to be filled by an individual holding an SRO license. The licensees Administrative Procedure No.
4.00, "Operations Organization, Responsibilities and Conduct," Section 4.2.3.d.4, "Shift Engineer/Shift Technical Advisor Qualifications," required the SE/STA to have an active SRO license. Procedure No. 4.00, Section 5.3.1, "Minimum Staffing," allowed an SE/STA with an inactive SRO license to fill the SE/STA position in the control room under certain conditions. The SE/STA responsibilities defined by Administrative Procedure 4.00 included:
- (1) duties normally assigned to a control room advisor in the areas of engineering;
- (2) predicting expected plant response for system operations;
- (3) evaluation of plant equipment and system operating conditions;
- (4) evaluation of compliance with technical specifications and other documents; and
- (5) other administrative duties in the control room. The procedure did not require the SE/STA to supervise or direct activities of control room operators nor did it require the watchstander to exercise any command/control functions of the SRO watchstation.
Section 55.53(e) of 10 CFR, "Conditions of Licenses," stated, in part, "To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter."
"Actively performing the functions of an operator or senior operator" (10 CFR 55.4), was defined as, "an individual has a position on the shift crew that requires the individual to be licensed as defined in the facilitys technical specifications, and that the individual carries out and is responsible for the duties covered by that position." The inspectors determined that since the SE/STA was not required to be licensed per the stations technical specifications and the command/control function of the SRO was not being exercised at the SE/STA watchstation, no credit should be granted for SRO watch proficiency at the SE/STA watchstation. When no credit was allowed for the SE/STA watchstation, several operator licenses became inactive at the end of the next calendar quarter. Section 55.53(e) of 10 CFR stated, in part, "If a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph
- (f) of this section." Operators whose licenses were inactive because credit was not warranted for the SE/STA watchstation performed duties in the control room at watchstations requiring an active operator license without completing the requirements of 10 CFR 55.53(f) to re-activate the license prior to resuming those duties. The licensee stated that they believed that NUREG-1262, "Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators Licenses," provided USNRC acceptance of proficiency credit for additional licensed operator watchstanders in the control room. The inspectors determined that station personnel had not applied all of the clarifying statements on this issue in NUREG-1262, and had a misunderstanding of the guidance provided in NUREG-1262.
The inspectors determined that the SE/STA was not a position of responsibility in the control room and did not satisfy the definition of "actively performing the functions of an operator." Because individuals performed duties requiring an active SRO license when their license was inactive, the inspectors concluded that a significance evaluation was warranted.
Analysis:
In accordance with Inspection Manual Chapter 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Disposition Screening," the inspectors determined that this performance deficiency was more than minor since the issue affected the Mitigating Systems Cornerstone, Human Performance Attribute, because licensed senior operators that are not current in watchstanding proficiency may commit operator errors that could cause mitigating systems to fail to respond properly, or the senior operator may issue incorrect directives to other operators that would cause mitigating systems to be mis-operated. Either of these errors would impact the cornerstone objective by increasing the likelihood of an undesirable consequence during an event.
The inspectors reviewed this issue in accordance with Manual Chapter 0609, Significance Determination Process (SDP), Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). The SDP Appendix I flowchart, decision box 27, focused on general record deficiencies exceeding a specified threshold of 20 percent of the records reviewed. The sample review of 27 operators revealed that seven operators had inactive senior operator licenses (26 percent). The inspectors determined from the SDP that this finding was of very low safety significance (Green).
Enforcement:
Section 55.53(e) of 10 CFR, Conditions of Licenses, required, in part, that "If a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph
- (f) of this section."
Contrary to the above, SROs with inactive licenses were performing license duties in the control room prior to completing the requirements of 10 CFR 55.53(f) to restore their licenses to active status.
The facility licensee stated that this had been their normal practice for the last 10 years (approximately). The licensee reviewed their watchstanding proficiency credits and determined that as many as nine SROs performed licensed duties with an inactive license in the previous four calendar quarters (April 2003 through March 2004). The licensee entered this issue into their corrective action program as CAP040816. The proficiency review conducted by the licensee determined which SRO licensed individuals were in active status without taking credit for standing control room watches in the SE/STA position. The active status list for SRO licensed individuals was revised to ensure that the individuals on the list were not taking credit for the SE/STA position to satisfy the requirement to be on active status. Because this violation was of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy. (NCV 05000255/2004008-01)
.8 Conformance With Simulator Requirements Specified in 10 CFR 55.46
a. Inspection Scope
The inspectors assessed the adequacy of the licensees simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements as prescribed in 10 CFR 55.46, Simulation Facilities. The inspectors also reviewed a sample of simulator performance test records (i.e., transient tests, scenario test and discrepancy resolution validation test), simulator discrepancy and modification records, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy process to ensure that simulator fidelity was maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions, as well as on nuclear and thermal hydraulic operating characteristics. The inspectors conducted interviews with members of the licensees simulator staff about the configuration control process and completed the IP 71111.11, Appendix C, checklist to evaluate whether or not the licensees plant-referenced simulator was operating adequately as required by 10 CFR 55.46(c) and (d).
b. Findings
No findings of significance were identified.
4OA2 Problem Identification and Resolution
.1 Biennial Sample Review
a. Inspection Scope
The inspectors reviewed a licensee training department self-assessment report. The licensees self-assessment reviewed the licensed operator training program two months prior to this inspection activity. The self-assessment was reviewed to ensure that any issues identified during the self-assessment were appropriately evaluated, prioritized, and controlled.
b. Findings
There were no findings of significance.
4OA6 Meeting(s)
.1 Exit Meeting
The inspectors presented the inspection results to Mr. G. Packard on May 20, 2004.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Malone, Site Vice President
- G. Baustian, Training Manager
- R. Bender, Requal Operator Training Supervisor
- M. Carlson, Engineering Director
- T. Davis, Operations Training Supervisor
- B. Dotson, Regulatory Compliance
- G. Hettel, Plant General Manager
- D. Malone, Regulatory Compliance Supervisor
- G. Packard, Operations Manager
- P. Schmidt, Simulator Training
- G. Sleeper, Operations Training Coordinator
- G. Smith, Initial Operator Training Supervisor
- A. Stover, Nuclear Oversight Manager
- D. VandeWalle, Assistant Operations Manager
- S. Wawro, Consumers Energy/Asset Manager
Nuclear Regulatory Commission
- R. Lanksbury, Chief, Operations Branch, RIII
- J. Lennartz, Senior Resident Inspector, Palisades
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000255/2004008-01 NCV Green. Licensed Operators Were Not Completing the Requirements of 10 CFR 55.53(f) to Reactivate Their Licenses Prior to Resuming Watchstation Activities after Their Licenses Became Inactive.
The Licenses Became Inactive Because Operators Were Taking Credit for Watchstanding at a Watchstation That Did Not Qualify as a Licensed Operator Required Watchstation. A Violation of CFR 55.53(e) Requirements Occurred When Operators Executed Licensed Operator Duties Prior to Completing 10 CFR 55.53(f) Reactivation Requirements.
Attachment