IR 05000263/1999010
| ML20205N490 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/09/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205N484 | List: |
| References | |
| 50-263-99-10, NUDOCS 9904160293 | |
| Download: ML20205N490 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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' REGION 111~- .
't Docket No: 50-263 License No: DPR-22 .,
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Report No:
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50-263/99010(DRS)
Licensee: Northern States Power Company Facility: Monticello Nuclear Generating Station Location: 2807 West Highway 75 Monticello, MN 55362 Dates: March 8 - 12,1999'
inspectors: H. Peterson, Lead Inspector, Region lil D. Pelton, Resident inspector, Braidwood S. Burton, Senior Resident inspector, Monticello Approved by: D. Hills, Chief Operations Branch
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a EXECUTIVE SUMMARY
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Monticello Nuclear Generating Station NRC inspection Report 50-263/99010 This inspection report contains the findings and conclusions regarding the licensed reactor operator (RO) and senior reactor operator (SRO) requalification training program inspectio The inspection included a review of training administrative procedures and operating examination material; observation and evaluation of licensed operators and licensee evaluators during a requalification operating examination; an assessment of simulator fidelity; an evaluation of program controls to assure a systems approach to training; and a review of requalification training records. Additionally, observations of control room activities, including a shift turnover and briefing, were conducted. The inspectors used the guidance in inspection procedures (IPs)
71001 and 7170 Operations
- Control Room operators demonstrated an appropriate level of attentiveness to the operating panels and were knowledgeable of plant conditions. The inspectors considered the implementation of an end-of-shift briefing (post-shift briefing) as a positive practice. In general, operators conducted control room activities in a professional manner. (Section 01.1)
- The operating shift crew observed by the inspectors passed the operating portion of the requalification examination. The licensee evaluators' findings and conclusions on the crew's performance during the dynamic simulator evaluation generally agreed with the inspectors' overall assessment. Although the inspectors identified some weaknesses pertaining to procedure use and crew communications, the aggregate individual performance deficiencies did not adversely impact the crew's ability to implement necessary mitigating actions to safely control the plant during emergencie (Section 04.1)
- The inspectors, through observations and review of simulator scenario requalification examinations and discussions with licensee personnel, noted difficulties in the shift manager's (SM) ability to simultaneously implement the duties of the SM, emergency director (ED), and shift technical advisor (STA) roles during plant emergency condition In addition, during a plant fire casualty, the SM would also assume the duties of the shift supervisor. The licensee indicated that they were reviewing further actions to streamline the functions of the SM. (Section 04.2)
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- Based on the review of past documents, licensed operators had demonstrated some past performance deficiencies pertaining to procedure adherence, communications, and command and control. Consequently, during this requalification inspection, the inspectors noted several instances in which operators demonstrated similar deficiencies in procedure use and communications. The licensee's operator continuing training
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.s program and the operations department were continuing to address these issues at the
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conclusion of the inspection. (Section 05.1)
- . he requalification examination material contained the necessary quantitative and qualitative attributes to provide an effective evaluation of operator skills. However, the inspectors noted some opportunities to enhance the material to better probe and evaluate operator responsibilities and performance. In particular, dynamic simulator scenarios and JPMs could have been more challenging. (Section 05.2)
- The licensee administered the annual requalification examinations according to program guidance and the examinations were consistent with regulatory guidelines. The licensee satisfactorily maintained examination security throughout the evamination period; however, the inspectors noted that an added security posting on the outer door leading into the simulation facility room was needed. Also, no significant simulator performance or fidelity issues were identified. (Section 05.3)
- The licensee's feedback process, that included training department self-assessment and Quality Assurance group audits, was satisfactorily implemented. The licensee conducted good, self-critical audits which provided constructive feedback into both the initial license operator training and licensed operator requalification training program However, the licensee's operations department had not yet implemented a formal self-assessment program. (Section O5.4)
- The remediation program contained adequate measures to ensure individual and crew performance weaknesses were identified, assigned, and remediated prior to resumption of licensed duties. (Section 05.5)
- The operators' license conditions were in conformance with program guidance and regulatory requirements of 10 CFR 55.21 for biennial physical examination (Section 05.6)
- The licensee's program for maintaining operator licenses active, in accordance with 10 CFR 55.53(e) and (f), was generally effective. The licensee had identified problems j with the program that contributed to two individuals not maintaining their SRO licenses active; however, the problems were of low safety significance due to the fact that involved individuals had not been assigned to duties requiring an active SRO license. In addition, the inspectors were concerned that the licensee's nuclear lead plant equipment and reactor operator (NLPE&RO) position in the control room shift organization may not have been assigned to duties commensurate with maintaining either an active RO or an SRO license in accordance with 10 CFR 55.53(e). This issue is an unresolved item ,
pending further review. (Section 05.7) {
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- The licensee appropriately maintained self contained breathing apparatus (SCBA) for licensed operators as required by 10 CFR 50, Appendix R and station procedural requirements. Alllicensed operators had current SCBA medical examinations, SCBA i training, and SCBA fit testing. (Section 08.1)
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ReDort Details
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1&perations 01 Conduct of Operations a. Inspection Scope (IP 71707)
The inspectors observed routine control room activities during full power plant operation, attended control room shift tumover, a pre and post-shift crew briefings, performed panel walk-downs, reviewed the control room log, and questioned operators about plant and equipment status, b. Observations and Findinas During the shift turnover, the inspectors observed that each operator performed front and backpanel walk-downs with their relief. Subsequent to the shift turnover, the Shift Manager (SM) and the Shift Supervisor (SS) conducted the shift briefings in the control room panel area. All operators, including outside non-licensed operators, attended the shift briefing. In gencral, the inspectors observed that all operators were attentive to the shift briefing and actively participated with good exchange of informatio The inspectors also observed that the licensee had recently (circa January 1999)
implemented a new end-of-shift briefing (a post-shift crew briefing). During the control room observations, the inspectors observed the new post-shift crew briefing. The inspectors found that the post-shift briefing allowed the operators to discuss and update the day's activities prior to the shift tumover to assure that the most recent and correct information was tumed over to the on-coming crew. In general, this activity appeared to be a good practice in crew communication The inspectors reviewed a week's worth of control room log entries and noted the entries were thorough and clear. The inspectors also noticed good attentiveness to control room panels and indications. Face-to-face and phone communications were also satisfactory. The control room noise level was minimized and no annunciators were left in a prolonged alarm state. The operators were knowledgeable of tags on control room panels, plant conditions, and equipment status when questioned by the inspectors. The inspectors further noted consistent use of annunciator response procedures by the control room reactor operators when addressing alarm Conclusions Control Room operators demonstrated an appropriate level of attentiveness to the operating par.els and were knowledgeable of plant conditions. The inspectors considere j the implementation of an end-of-shift briefing (post-shift briefing) as a positive practice. In genesi, operators conducted control room activities in a professional manne J ul - - _
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04 Operator Knowledge and Performance 04.1 ' Annual Evaluation Performance Review (Operator Reaualification) I Inspection Scope (IP 71001)
The inspectors reviewed the performance of one operating shift crew during the annual licensed operator requalification operating examination. The control room cre positions consisted of a SM, SS, and three control room operators.' The three control-room operators included two licensed reactor operators (RO) and an additional licensed
- individual in the control room, referred to as a nuclear lead plant equipment and reactor operator (NLPE&RO). The licensee evaluated the crew on two simulator scenarios on -
the plant specific simulation facility and on five job performance measures (JPM). The inspectors' evaluation referenced the following procedures:
- NUREG-1021, " Operator Licensing Examination Standards for Power Reactors,"
Interim Revision 8, June 199 * Monticello Training Center Procedure (MTCP)- 03.32, "Requalification Examination Control," Revision . MTCP - 01.03.17, * Evaluation," Revision 8, November 30,199 Observations and Findinas The operating crew successfully completed each critical task as originally identified in the dynamic simulator scenarios. In addition, all licensed operators who took the JPM walkthrough examination successfully passed. The licensee's evaluation team assigned a passing grade for each licensed operators' performance during the operating portion of the annual requalification examinatio Although all licensed operators passed the operating examination, the inspectors identified some individual and crew parformance weaknesses. These weaknesses were in the areas of procedure use, crew communications, and operator use of peer checks, as discussed belo Communications The inspectors found that periodic crew briefings conducted by the SS, during both simulator scenarios, were frequent. The SS presented appropriate information and directions to the cre However, crew communications, at times, were informal and fragmented. The inspectors noted various examples of 2-way verses 3-way communications during both scenarios. In accordance with station procedures for communications,3-way communications were required when an order was given in the control room. However, the messages were generally relayed and sufficiently understood to complete the tasks at han h
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(miscommunications). For example, the inspectors noted a generallack of reports from operators to the SS concerning the completion of numerous ordered operations, such as the initiation of drywell sprays and torus sprays. Also, an unexpected reactivity change was performed by one of the control room operators due to a slight power fluctuatio The RO adjusted the reactor recirculation pump flow without SS permission or subsequently informing the SS of the slight reactivity manipulation. During one scenario where the core spray (CS) system experienced a component problem, one RO and the NLPE&RO had conflicting operating status of the CS system. The lack of relaying or exchanging pertinent information to appropriate operators resulted in the miscommunication to the SS and delayed actions by the operator responsible for the status and operation of the CS syste Procedure Use:
During an anticipated transient without scram (ATWS) event, the SS implemeting the emergency operating procedures (EOP) did not perform Step 8 of the 'leve.. .g of the ATWS EOP that required maintaining the reactor water level within specified band by using only specified injection sources. The SS gave no orders for maintaining a level band. However, as plant conditions escalated, torus water temperature exceeding 110'F, the SS appropriately entered the ATWS power level control of the EOPs satisfactorily mitigating the ATWS condition. In addition, durin0 the same scenario, the inspectors identified that the SS appeared to be singularly focused on the ATWS EOP and did not implement the Primary Containment EOPs (the initiation of torus and drywell sprays) in a timely manner. Subsequently, the drywell temperature exceeded 281 -F that required emergency depressurization of the reactor pressure vessel (RPV). The emergency depressurization of the RPV was an unanticipated event contrary to the licensee's validation and verification of the simulator scenario. However, the inspectors found, subsequent to the scenario, that the simulator operator had entered the expected drywell leak malfunction at a leakrate higher than what was validated. This error resulted in the higher rate of temperature increase and the subsequent need for emergency depressurization. Once emergency depressurization was required, the SS and the crew satisfactorily performed the EOPs to adequately place the plant in a sa% conditio During both dynamic simulator scenarios, the inspectors also observed inconsistent use of annunciator response procedures. During a continuous rod withdrawal malfunciion, the control room operators did not initially use the annunciator response procedure for the rod malfunction. Also, when the NLPE&RO used the abnormal response section of the control rod hydraulic system procedure, the NLPE&RO read and attempted to direct non-applicable and incorrect steps of the procedure. However, the SS and the SM immediately corrected the NLPE&RO of the mistake. In general, the continuous rod withdrawal event was adequately mitigated with no observed adverse effects to the plan ;
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Peer Checks: l
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The inspectors identified one instance of a lack of performing self-checking and peer checks that resulted in the mis-manipulation of a control rod. During one scenario, a control room operator performing the rod insertion as part of a power reduction did not use peer checks prior to rod manipulation. Subsequently, the operator incorrectly witt drew the control rod rather than inserting the control rod. The problem was immediately recognized by the operator and rod motion was stopped after the rod moved only one step. The licensee attributed the fault to a lack of self-checking. The inspectors ;
noted that the lack of peer checks, especially for a reactivity manipulation, also attributed j to the rod mis-manipulation. However, the inspectors identified that although peer checks were encouraged by the licensee, peer checks were not formalized nor required by procedure In general, the above performance weaknesses were adequately identified and documented by the licensee evaluators during the dynamic simulation evaluatio However, the unanticipated emergency depressurization was not identified by the licensee evaluators as an emergent critical task during the post-examination evaluation until the inspectors noted the problem. Although some weaknesses were noted, the operators as a team were able to safely control the plant during the emergencie Conclusions The operating shift crew observed by the inspe * ors passed the operating portion of the requalification examination. The licensee evaluators' findings and conclusions on the crew's performance during the dynamic simulator evaluation generally agreed with the inspectors' overall assessment. Although the inspectors identified some weaknesses pertaining to procedure use and crew communications, the aggregate individual performance deficiencies did not adversely impact the crew's ability to implement necessary mitigating actions to safely control the plant during emergencie .2 Dual-Role Shift Manaaer/ Shift Technical Advisor (SM/STA) Inspection Scope (IPs 7170L 71001)
The inspectors reviewed the licenses and industry documents associated with licensed shift personnel duties and responsibilities, shift organization, onsite emergency organization, and operating experience and events. Specifically, the inspectors reviewed the licensee's program and practice of the " dual-role" Shift Technical Advisor (STA)
position, the SM/STA. The inspectors reviewed the following documents to assess operator roles and responsibilities:
- Technical Specification Administrative Section 6.1," Organization," Amendment 104, December 24,199 * Technical Specification Table 6.1-1, " Minimum Shift Crew Composition,"
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- MNGP M-9300, "SM/STA Program Description," Revision 12, October 24,1997.-
. M NGP M-9312, "SM/STA' Continuing Training Course Outline,' Revision 3, January 22,199 * Shift Manager / Shift Technical Advisor On-The-Job Training Guide, Revision 4,:
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+' Emergency Plan implementing Procedure, A.2-001, " Emergency Organization,"
Revision 44, December 15,199 NUREG-1275, " Operating Experience Feedback Report - Human Performance in Operating Even's," Volume 8, December 199 . .
- Information Notice (IN) 93-81, " Implementation of Engineering Expertise on Shift," October 12,199 b. Observations and Findinas The licensee's Technical Specification Table 6.1-1, " Minimum Shift Crew Composition,"
noted that one of the two licensed senior operators, the two SRO position of SM and SS, performs the functions'of the STA. ' in practice, the'SM takes on the duties of the STA during plant emergencies. The licensee's action to use a " dual-role" SRO/STA was allowed per an October 28,1985, Federal Register notice 50 FR 43621, "NRC Policy Statement on Engineering Expertise on Shift." The licensee integrated the STA '
function into the SM position circa 1989, and maintained a continuing training program combining both aspects of SM and STA training curriculums. The inspectors did not perform a detailed review of the lesson plans or the overall effectiveness of the STA training progra The overall SM duties and responsibilities are as follows:
Within the licensee's organization, the SM, as the senior licensed shift personnel, has the responsibility for supervising the activities of the SS, the activities affecting operation of the plant as a whole, and has the ultimate authority and responsibility during routine, abnormal, and emergency situation Also, in accordance with emergency plan implementing procedure A.2-001, the SM has the initial responsibility to assume the duties of the Emergency Director (ED) during emergencies. The responsibilities were very significant and l included the following: (1) on-site emergency response activities, (2) evaluation '
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of in-plant and on-site radiological conditions, (3) emergency classification and classification changes, (4) recommendation of off-site protective actions, (5)
decisions regarding on-site emergency response center habitability and on-site protective actions, (6) decisions regarding on-site evacuation and selection of
' Assembly Point, (7) approval of emergency radiation exposures, (8) authorizing suspension of specific security measures to support off-site emergency response personnel, (9) emergency response organization (ERO) augmentation and maintaining 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ERO coverage, and (10) conduct Technical Support Center information briefings and public address announcements. Also, in conjunction with classifying an emergency, the ED was responsible to assure timely notification to offsite authoritie l q
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Furthermore, the SM must provide the STA function on shift. The licensee informed the inspectors that the SM position was the only position on shift that
' received the STA training, as part of the SM/STA program; and according to the licensee's technical specifications, the STA qualifications includei (a) possession of a bachelor's degree or equivalent in a scientific or engineering discipline, and (b) training in plant design, and response and analysis of the plant for transients and accidents. The inspectors also determined, as referenced in Appendix A of NUREG-1275, that the function of an STA was to objectively evaluate the plant condition during abnormal and accident conditions and recommend action. The STA's bachelor's degree ici engineering or equivalent was required to render engineering technical advise during an accident. Furthermore, the STAS perform the important safety function as independent eyes during an accident to review and trend plant parameters. The STAS would perform the function of reviewing the curves, cautions, and tables associated with the EOPs, while the SS implemented concurrent performance of multiple emergency procedure During the dynamic simulator scenario annual requalification examination, the inspectors observed that the duties of SM, ED, and STA were performed apart from each other. Subsequently, while the duties of one position was being performed the other two were not. Furthermore, the inspectors noted that the root cause of a previous week's requalification failure of a SM during a dynamic simulator examination was direct involvement in a task which resulted in the loss of the SM overview role or the oversight functio In addition, the inspectors also noted that if a plant fire casualty occurred, the SS performs the duties of the fire brigade leader and may exit the control room. Therefore, if the fire leads to or was in parallel to an emergency condition, the SM would take the additional role of the SS to implement the EOPs, along with the cumulative responsibilities of SM, ED, and the STA. Subsequently, the inspector further questioned the effectiveness of performing all of these duties concurrently. The ,
licensee's training department personnel informed the inspectors that further actions to streamline the functions of the SM, particularly the functions of the ED for event i classification and notification, was under consideratio After further review of NRC documents (IN 93-81 and NUREG-1275, Volume 8) l pertaining to industry operating experience conceming the " dual-role" SRO/ STAS, the
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inspectors found that related problems have occurred at several facilities which resulted
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in overburdening the SRO/STA while fulfilling duties involving EOP reading, event i classification, fire protection concerns, and implementation of the emergency plan. The t " observation" section of NUREG-1275, Volume 8, Section 3.2.2, " Shift Technical Advisor," page 15, stated:
"The use of the " dual-role" 3TA impaired crew performance because the ether SRO(s) were overioaded when one SRO assumed the STA rol The " dual-rele" STAS sometimes lacked independent " fresh eyes" because of the involvement in shift activities. Assignment of other tasks during events sometimes detracted from the STA's safety function."
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, Conclusions The inspectors, through observations and review of simulator scenario requalification examinations and discussions with licensee personnel, noted difficulties in the SM's ability to simultaneously implement the duties of the SM, ED, and STA roles during plant emergency conditions. In addition, during a plant fire casualty, the SM would also assume the duties of the shift supervisor. The licensee indicated that they were reviewing further actions to streamline the functions of the S Operator Training and Qualification 05.1 Operatina History Inspection Scope (IP 71001)
The inspectors reviewed the following documents to assess the licensed operator requalification training program's effectiveness regarding operator perform .-se:
- Systematic Assessment of Licensee's Performance (SALP) Report Nos. 50-263/96001 and 9809 Initial license operator examination report (50-263/OL-96-01) and licensed operator requalification training report (50-263/97004).
- Select resident inspector observations and report Select licensee event report Observations and Finainas As a result of the inspectors' review 0; the above documents, the inspectors determined that the operators had previously demonstrated deficiencies in the area of procedure adherence, poor command and control, weak communications, and lack of operations department self assessment activities. In particular, the last SALP report (IR ;
98099) also noted concerns with control room panel attentiveness and communication i of annunciator alarms. The inspectors noted that the licensee had generally addressed J these deficiencies in the licensed operator continuing training progra i During this inspection, the inspectors noted some weaknesses in procedure use and '
communications while evaluating the dynamic simulator scenario examinatio However, considering that only one operating shift crew was observed, the inspectors j found it difficult to conclude that these weaknesses were prevalent But, the inspectors also noted that a previous week's requalification failure also resulted from weak procedure use and command and contro The inspectors found that the operations department personnel continued to note that i procedure adherence, adequacy of procedures, and operations department self-assessment were still areas of concern and were tracked as items for continued improvement. The licensee also informed the inspectors that actions were being taken to implement a fomialized operations self-assessment and a program to improve i
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, procedures and procedure adherence. However, the noted activities were not yet completed to ellow for a detailed assessmen Conclusions Based on the review of past documents, licensed operators had demonstrated some past performance deficiencies pertaining to procedure adherence, communications, and command and control. Consequently, during this requalification inspection, the inspectors noted several instances in which operators demonstrated similar deficiencies in procedure use and communications. The licensee's operator continuing training program and the operations department were continuing to address these issues at the conclusion of the inspectio O5.2 Recualification Examinations Insoection Scope (IP 71001)
The inspectors reviewed the following using IP 71001. Appendix A checklists, to assess the licensee's examination material quality and content. No biennial written examination was reviewed during this inspection period because the licensee's written examination was scheduled for the year 200 Sample plan prepared for the current annual requalification operating examination Current annual requalification operating examination Observations and Findinas The inspectors reviewed the sample plan of the operating examination material administered during the current annual requalification examination. The inspectors noted that during this year's requalification examination, the licensee was not required to administer the biennial written examinatio The operating examination material contained the necessary quantitative and qualitative attributes to provide a satisfactory evaluation of operator skills. The dynamic scenarios were appropriate and provided ample opportu,1ity to evaluate the crew and individuals based on critical tasks and competencies. The inspectors noted that shift supervisory personnel initially started the scenario outside the simulator until called in for assistance during a plant transient, which resembles actual operating conditions in the plant. Both the JPMs and dynamic scenarios had appropriate steps identified as critical based on the initial verification of expected operator actions. The operating examinations administered each week during this requalification cycle were prepared such that each examination item appeared to be only used onc Although the operating examination material was considered satisfactory, the inspectors identified items that needed some enhancements. These items included more challenging dynamic simulrJor scenarios and JPMs to allow for improved operator evaluations. The following observations we' noted during the operating examinatio . _ . . -
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Dynamic Simulator Scenarios:
- The inspectors noted that one of the simulator scenarios was torminated too soon. The scenario pertaining to an ATWS condition should have allowed the operators to continue until all rods were inserted and the crew exited out of the )
ATWS EOP. Added evaluation si ;artunity was available to allow the crew to stabilize the reactor following an ATWS conditio * Technical specification events were simple in nature. The added challenge in determining multiple and complex technical specification applicability would be beneficia During both simulator scenarios, the inspectors noted that the lead-reactor operator position (NLPE&RO) was required to demonstrate minimal control board manipulation. Rotating positions of the control room reactor operators would facilitate a better evaluatio The identification of critical tasks could be improved._ The initially noted and validated critical tasks as documented in the scenarios were satisfactor However, that unanticipated occurrences during the scenarios could result in critical tasks that were not previously identified. During one scenario, the inspectors identified that the licensee evaluators failed to identify and document an emergent critical task at the conclusion of the scenario. After the inspectors noted the emergent critical task of the un-anticipated emergency depressurization, the licensee evaluators subsequently concurred and documented the critical tas Job Performance Measures: -
. The licensee gave each operator five JPMs to perform. The ROs performed two altemate path JPMs. Of the two SROs, only one SRO performed an attemate path JPM. The other SRO did not have any attemate path JPM.. (Altemate path JPM is defined in NUREG-1021, " Operator Licensing Examination Standards for Power Reactors," Interim Revision 8, Appendix C, Section C, page 6 of 15.)
- The administrative JPMs pertaining to a temporary change review, independent verification, and emergency plan each had only one critical step. These JPMs could be enhanced to be more challenging. For example, the emergency plan JPM should require additional task;; of identifying protective action recommendations and filling out or verifying the notification documents. The i temporary change review JPM could have been expanded to include the SRO's operability assessment as a critical ste * The independent verification JPM included a note for the evaluator to ensure the candidate ensured the verification was performed separately from the actions of the initial positioner and that this was a critical task. This action was not verified by the evaluato l
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they would obtain tools and keys needed to perform the JPM The inspectors noted that numerous breaker and switch position noun names that didn't match the required positions listed in the JPM Conclusions The requalification examination material contained the necessary quantitative and qualitative attributes to provide an effective evaluation of operator skills. However, the inspectors noted some opportunities to enhance the material to better probe and
~ evaluate operator responsibilities and performance. In particular, dynamic simulator scenarios and JPMs could have been more challengin .3 Recualification Examination Administration Practices > Inspection ScopeJIP 71001)
The inspectors performed the following to assess the licensee's policies and practices regarding requalification examination administration, simulator fidelity, and examination security:
- Observed the performance of, and evaluated, one shift operating crew during week two of the current annual requalification operating examinatio Observed simulator performanc Reviewed the licensee's examination security practice Observations and Findinas The inspectors observed the licensee evaluate the performance of one operating crew during two dynamic simulator scenarios. The licensee identified weaknesses and generally matched the inspectors' assessments with regards to the assessment of operator performance. The licensee also identified an unsatisfactory performance by an individual on one JPM. The inspectors noted no undue prompting by the evaluators during the performance of the JPM walkthrough examination. Overall, the licensee's evaluators appropriately evaluated the operating crew and passed all operators. In addition, the inspectors identified that the licensee appropriately evaluated and failed the crew and two individuals on a dynamic scenario during the previous examination wee No significant new simulator performance or fidelity issues were identified during the inspectors' observation of the operating examination. (See enclosed Attachment 1,
" Simulation Facility Report.") In addition, the licensee informed the inspectors that a -
new core model was anticipated to be installed into the simulator; however, no definite installation date was identifie In general, examination security was observed to be satisfactory throughout the examination administration. However, the inspectors identified that the first of the two
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doors leading into the simulation facility room was left open and not posted with an -
examination security sign. The area in between the two doors housed a small staging area that mimicked the actual SM/SS office at the plant, which included video monitors that monitored the simulation facility. Although the second (inner) door was properly posted for examination security, the inspectors informed the licensee that the first
- (outer) door should also be posted as a security door, Conclusions The licensee administered the annual requalification examinations according to program guidance and the examinations were consistent with regulatory guideline The licensee satisfactorily maintained examination security throughout the examination period; however, the inspectors noted that an added security posting on the outer door leading into the simulation facility room was needed. Also, no significant simulator performance or fidelity issues were identifie .4 Reaualification Trainina Proaram Feedback System Inspection Scope (IP 71001)
The inspectors performed the following to assess the licensee's training program feedback system effectiveness:
- Interviewed licensee personnel (operators, instructors, training management, and quality assurance).
- Reviewed licensee conducted training department self evaluation reports for the year 199 Reviewed the licensee's Quality Assurance audits for operations and training departments, (AG 1998-O-1, AG 1998-O-2, AG 1998-0-3, and AG 99-O-1).
- Reviewed licensee procedure MTCP-01.03.17, * Evaluation," Revision Observations and Findinas The inspectors determined that the feedback process was effectively implemente The licensee had adequate controls in place to revise the licensed operator
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requalification training program based on licensee audits, industry and plant events, system and procedure modifications, and operator feedbac The licensee's training department performed self-assessment activities by cssessing identified individual operator and crew weaknesses, operator training requests, and plant and industry events. Additional self-assessment processes included course evaluations, instr:Ator evaluations, classroom feedback, simulator evaluations and entiquc., and a Ethe-job training evaluations. Also, the licensee's Quality Assurance group performed periodic audits of the Operations and Training program Subsequently, the training department personnel gathered, evaluated, and assigned priorities to the results of all the self-evaluations, including those conducted by the Quality Assurance grou ' '
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The Quality Assurance audits appeared to t e self-critical and effective. During a past audit, the Quality Assurance group identified issucs pertaining to inaccurate medical examination checklists for licensed operators, and one operator was found with expired SCBA qualifications. Also, the training self-assessments incorporated non-licensea personnel to perform an independent evaluation. However, the inspectors identified that there were no formalized self-assessments being conducted by the operations department. The licensee informed the inspectors that recent actions were being processed to implement a formal operations department self-assessment progra The inspectors also received self-critical inputs from licensed operators, instructors, Quality Assurance staff members, and management personnelinterviewed on the feedback process. The inspectors determined that licensee's self-assessment program was up to date and flexible anough to incorporate emerging training issue Conclusions The licensee's feedback process, that included training department self-assessment and Quality Assurance group audits, was satisfactorily implemented. The licensee conducted good, self-critical audits which provided constructive feedback into both the initial license operator training and licensed operator requalification training program Hewever, the 1:censee's operations department had not yet implemented a formal self-assessment progra .5 Remedial Trainino Proaram Inspection Scope UP 71001)
The inspectors performed the following to assess the licensee's remedial training program effectiveness:
- Reviewed three individual operator and one crew unsatisfactory performance evaluations for the previous completed examination wee Reviewed the remediation training plans for the unsatisfactory performance for the previous completed examination wee Reviewed the one individual operator and one crew performance evaluations along with the associated remediation packages for the 1996 requalification failure * Interviewed licensee personnel (licensed operators, instructors / evaluators, and supervisors).
- Reviewed MTCP-03.32, "Requalification Examination Control," Revision * Reviewed MNGP M-8100, " Licensed Operator Training Program Description,"
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Revision 1 Observations and Findinas The inspectors determined that the licensee's training procedure MTCP-03.32,
- Requalification Examination Control," appropriately contained the requirements for the remediation program. Based on review of the 1996 and the previous week's individual
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and crew failures, the inspectors noted that the licensee had developed remedial training plans for individuals who demonstrated weaknesses and required successful completion of the remedial training prior to resuming license duties. The licensee's administration of the remedial training program and subsequent reexamination of operators was sufficient. The licensee properly identified and corrected licensed operator performance deficiencie Conclusions The remediation program contained adequate measures to ensure individual and crew performance weaknesses were identified, assigned, and remediated prior to resumption of licensed dutie .6 Conformance With Operator License Conditions: Biennial Medical Examinations Inspection Scope (71001)
The inspectors reviewed the following documents to assess the facility and operator licensees' compliance with 10 CFR 55.53 license condition requirements:
- Licensed operator requalification training record A sample of the biennial Medical History for individuals maintaining RO and SRO licenses in accordance with 10 CFR 55.2 Observations and Findinas The inspectors determined that the licensed operator biennial medical history included both the NRC required physical examination as well as the examination required by the licensee for individuals assigned to fire brigade duties. The inspectors also noted that the history file maintained by the licensee listed all licensed individuals (including those with inactive licenses), provided the due date of the next medical examination, the date the last exam was given, and the dates of previous examinations given back thru 199 Furthermore, the inspectors determined that all licensed individuals had current / valid medical examinations with the exception of a single individual with a potential adverse medical condition that had been reported to management and to the NRC. The licensee removed the individual from licensed duties. As of the date of this inspection, the licensee was still awaiting the outcome of the NRC's review of the individual's medical conditio Conclusions The operators' license conditions were in conformance with program guidance and regulatory requirements of 10 CFR 55.21 for biennial physical examination .
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O5.7 Conformance With Operator License Conditions: Maintenance of Active Operator Licenses Inspection Scope (IP 71001)
The inspectors interviewed operations and training departmer pa sonnel and reviewed the following documents to assess the f acility and operator licc~ ees' compliance with 10 CFR Part 55.53 license condition requirements:
- MNGP Operations Work Instruction (OWI) 01.06, " Duty Operat:ons Personnel Requirements and Responsibilities," Revision MNGP Procedure 1440, "NRC License Active Status Maintenance," Revision Monticello Active NRC SRO/RO Qualification Checklis . MNGP Condition Report 98003124," TRENDS: Arkansas Nuclear One Inspection Report 98-06 Violation."
- Technical Specification Administrative Section 0.1, " Organization," Amendment 104, December 24,199 Technical Specification Table 6.1-1, " Minimum Shift Crew Composition,"
Amendment 73, May 1,199 Observations and Findinas The inspectors reviewed the licensee's program for maintaining RO and SRO licenses active in accordancr., with 10 CFR 55.53(e) and (f). The inspectors determined that the licensee's program accounted for licensed individuals assigned to control roorn duties as well as those assigned to duties outside the control room (e.g., individuals assigned to support work control activities).
The inspectors compared the licensee's control room manning discussed in OWI 01.06 to the technical specification required control room licensed positions. The inspectors i
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identified that the licensee maintained an additional licerssed individual in the control room, referred to as a nuclear lead plant equipment and reactor operator (NLPE&RO).
While reviewing the responsibilities of the NLPE&RO, the inspectors identified that this individual may not have been assigned to duties commensurate with maintaining either an active RO or an SRO license. The NLPE&RO position was manned by two RO licensed and four SRO licensed operator In accordance with 10 CFR 55.53(e), to maintain active operator liccase status, the licensed operator 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. If a licensed operator has not been actively performing the functions of a licensed operator commensurate with the license, the operator may not resume licensed activities unless performing the reactivation watch standing under instruction per 10 CFR 55.53(f).
According to 10 CFR 55.4, " Definitions," actively performing the functions of an operator or senior operator means that an individual has a position on the shift crew that requires the individual to be licensed as defined in the facility's technical specifications, and that the individual carries out and is responsible for the duties covered by that positio ,
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, The inspectors identified that the licensee's Technical Specifications Table 6.1.1,
" Minimum Shift Crew Composition," only specified four licensed operators (two licensed operators (RO) and two licensed senior operators (SRO)). The rule does not preclude or discourage having additional licensed operators on shift beyond the minimum technical specification staffing requirements; however, to take credit for license proficiency (active status) based on 10 CFR 55.53 these individuals must manipulate the controls in the case of an operator, or direct the licensed activities in the case of a senior operator, commensurate to the positions defined in the technical specification The inspectors also identified that the NLPE&ROs were appropriately trained and '
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evaluated in accordance with their respective license during licensed operator '
requal$ cation training. However, the inspectors were concerned that these six licensed operators may not be appropriately maintaining their operator licenses in accordance with NRC regulations. This lssue of maintaining active license status for the additional licensed operator within the control room shift organization was considered an unresolved item (URI) pending further review and assessment by NRC Headquarters Operator Licensing Branch (URI - 50-263/99010-01(DRS)).
The inspectors also reviewed condition report (CR) 98003124 in which the licensee identified that two SRO licensed individuals had failed to maintain their SRO licenses active. The CR 98003124 stated that the individual was not normally assigned to main control room duties and was being monitored in accordance with MNGP Procedure 1440, Table 1. Because the procedure did not differentiate between RO or SRO when logging licensed activities time, the individual's SRO specific license activities could not be verified. The other individual, although normally assigned to main control room duties, was assigned to RO duties and had not performed a sufficient amount of SRO license activities to maintain the individual's SRO license active. The inspectors determined that these individuals had not been assigned any duties requiring an SRO license during the time period that their SRO licenses had become inactive. Therefore, the problem had no impact on the safe operation of the reactor plant. Corrective actions listed in CR 98003124 were not scheduled to have been completed as of the date of this inspectio The inspectors reviewed completed MNGP Procedure 1440, Table 1's for the fourth quarter of 1998 and the first quarter 1999 and with the exception of the NLPE&RO position discussed above, did not identify any additional examples o,' individuals who had not maintained their SRO or RO licenses active in accordance with 10 CFR 55.53(e).
c. Conclusions The licensee's program for maintaining operator licenses active, in accordance with 10 CFR 55.53(e) aiid (f), was generally effective. The licensee had identified problems with the program that contributed to two individuals not maintaining their SRO licenses active; however, the problems were of low safety significance due to the fact that involved individuals had not been assigned to duties requiring an active SRO licens in addition, the inspectors were concerned that the licensee's NLPE&RO position in the control room shift organization may not have been assigned to duties commensurat .
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. with mainta'ning either an active RO or an SRO license in accordance with 10 CFR 55.53(e). This issue is an unresolved item pending further revie Miscellaneous Operations issues 08.1 Self Contained Breathina Apparatus (SCBA) Use and Maintenance Inspection Scope (IP 71001)
The inspectors interviewed operations and training staff personnel and reviewed the following documents and procedures describing the control methods used to maintain the operators' respirator fit and r,eed for corrective lens for use with respirator MNGP OW101.06, " Duty Operations Pe.sonnel Requirements and Responsibilities," Revision MNGP R.05.07, "SCBA Inspection und Functional Test," Revision MNGP Administrative Work Instruction (AWI) 08.04.04, " Respiratory Protection,"
Revision Respiratory protection records for iicensed operator Observations and Findinas The inspectors determined that all individuals with active RO and SRO licenses had current SCBA medical examinations, SCBA training, and SCBA fit testing in accordance with AWi 08.04.0 The inspectors verified that SCBA equipment was maintained in the main control roo The inspectors also determined that the licensee maintained six sets of SCBA equipment in the main control room as required by MNGP R.05.0 '
The inspectors noted that, in accordance with OWI 01.06, the licensee required licensed operators who's license requires the use of corrective lenses to have prescription SCBA glasses or contact lenses readily available. The inspectors reviewed 1 the restrictions on RO and SRO licenses to determine those individuals requiring corrective lenses. The inspectors determined that of 17 licensed operators requiring j corrective lenses,15 operators maintained SCBA compatible glasses in the control j roo Title 10 CFR 50, Appendix R, Criterion Ill.H, " Fire brigade," stated, in part, that SCBA using full-face positive-pressure masks shall be provided for control room personne Licensee's procedure OWI 01.06, Paragraph 4.1.6 stated, in part, that licensed i operators requiring eyewear [ prescription lenses) must have prescription SCBA glasses j or contact lenses readily available. Contrary to the above, on March 12,1999, the !
inspectors identified two control room licensed operators who required corrective lenses I that were not maintaining either SCBA glasses or contact lenses readily availabl The licensee initiated a condition report, CR 99000695, and found that the two individuals had corrective lense endorsements on the.ir NRC licenses for reading
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h - purposes only. The licensee noted that through training and practice the individrals can operate and perform necessary manipulations while holding their reading gasses up to the outside of the SCBA face piece. However, as a precaution and to clarity any concerns, the licensee ordered SCBA glasses, for reading purposes at the conclusion of
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the inspection. The failure to maintain SCBA glasses for control room operators constituted a violation; however, due to the circumstances as describe above, the violation was of minor significance and was not subject to formal enforcement action, consistent with Appendix C of the Enforcement Polic In addition, the inspectors attended a session of the licensee's SCBA training, SCBA fit testing, and training on a new control room toxic gas air supply system. The inspectors noted that the instructors presented the training material in a thorough manner and observed good participation by all the operators.
' Conclusions The licensee appropriately maintained SCBA equipment for licensed operators as required by 10 CFR 50, Appendix R and station procedural requirements. Alllicensed operators had current SCBA medical examinations, SCBA training, and SCBA fit testing. However, the inspectors identified two licensed individuals who required corrective lenses were not maintaining SCBA glasses readily available as required by station procedure. This issue was a violation of minor significance not subject to formal enforcement actio V. Manaaement Meetinog X1 Exit Meetina Summary The inspectors presented the preliminary inspection results to members of licensee management at the conclusion of the inspection on March 12,1999. The licensee acknowledged the findings presented. No proprietary information was identifie Attachment: Simulation Facility Report t
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,. PARTIAL LIST OF PERSONS CONTACTED Licensee W. Bickford, Generation Quality Services D. Cox, Shift Manager, Operations B. Day, Plant Manager M. Fish, Business Support Supervisor- Monticello Training Center -
D. Fousek, Superintendent Simulator Services M. Hammer, Site General Manager M. Lechner, Acting General Superintendent of Operations K. Peterson, Senior Operations instructor 4 E. Sopkin, Training Manager -
A. Ward, Manager, Quality Services T. Witschen, Superintendent Operations Training NRC ,
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S. Burton, Monticello Senior Resident inspector INSPECTION PROCEDURES USED iP 71001: Licensed Operator Requalification Program Evaluation IP 71707: Plant Operations ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-263/99010-01 URI License 3's NLPE&RO position in the control room shift organization may not have been assigned to duties commensurate with maintaining either an active RO or an SRO license in accordance with 10 CFR 55.53(e).
Closed None Discussed None -
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LIST OF ACRONYMS USED ATWS Anticipated Transient Without Scram AWI ' Administrative Work Instruction CFR Code of Federal Regulations
~CR Condition Report CS ' Core Spray DRS- Division of Reactor Safety
~ED Emergency Director EOP Emergency Operating Procedure ERO Emergency Response Organization . ,
HOLB Headquarters Operator Licensing Branch IN Information Notice IP inspection Procedure IR inspection Report JPM Job Performance Measure LCO Limiting Condition for Operation LER Licensee Event Report MNG Monticello Nuclear Generating Plant MTCP Monticello Training Center Procedure NLPE&RO Nuclear Lead Plant Equipment and Reactor Operator NRC Nuclear Regulatory Commission NRR' Nuclear Reactor Regulation OWI Operations Work Instruction PA Public Address RO Reactor Operator RPV Reactor Pressure Vessel SALP Systematic Appraisal of Licensee Performance '
SCBA Self Contained Breathing Apparatus SM Shift Manager SRO Senior Reactor Operator SS Shift Supervisor STA Shift Technical Advisor TSC Technical Support Center URI Unresolved item y 22
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. Page 1 of 1 SIMULATION FACILITY REPORT Facility Licensee: Monticello Facility Licensee Docket No.: 50-263 Operating Tests Administered: March 9 - 10,1999 ,
This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of noncompliance with 10 CFR 55.45(b). These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future
- evaluations. No licensee action is required in response to these observation While conducting the simulator portion of the operating tests, the following item was observed:
ITEM DESCRIPTION Non .
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