IR 05000266/1997019

Insp Repts 50-266/97-19 & 50-301/97-19 on 970908-12.Noncited Violations Noted.Major Areas Inspected:Review of Licensee Licensed RO & SRO Requalification Training Programs

ML20199D939
Person / Time
Site:	Point Beach
Issue date:	11/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199D857	List: IR 05000266/1997019 ML20199D852
References
50-266-97-19, 50-301-97-19, NUDOCS 9711210057
Download: ML20199D939 (12)

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U.S. NUCLEAR REGULATORY' COMMISSION

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REGION lll

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Docket Nos: 50-266;50-301-License Nos: DPR-24; DPR 27- t

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Report Nos: - 50-266/97019(DRS); 50-301/97019(DRS)

Licensee: Wisconsin Electric Power Company ,

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Facility: Point Beach Nuclear Plant, Units 1 and 2

' Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates- September 8 - 12,1997

. Inspectors: R. Bailey, Reactor Engineer D. Muller, Reactor Engineer

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P. Louden, Resident inspector Approved by: M. Leach, Chief, Operator Licensing Branch Division of Reactor Safety

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9711210057 971114 *

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EXECUTIVE SUMMARY

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Point Beach Nuclear Plant Units 1 and 2 NRC Inspection Reports 50-266/97019; 50-301/97019 The inspectors used the guidance in inspection procedure (IP) 71001 to review the licensee's licensed reactor operator (RO) and senior reactor operator (SRO) requalification training programs. The inspection included a review of training administrative procedures, records, and examination material; observation of an operating r.rew during the evaluated dynamic examination; an assessment of simulator fidelity; and an evaluation of program controls to assure compliance with license condition Prior to examination administration, a potential compromise was identified by the licensee, This was in violation of NRC requirements as stated in 10 CFR 55.49, " Integrity of Examinations and Tests." However, as described in the enclosed examination report (Secdon 05.3), the violation is not being cited because the criteria specified in Section Vll.B.1 of the NRO Enforcement Eojicy was satisfie ORSialinds

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Facility control room operators demonstrated appropriate attentiveness to their assigned control panels and were knowledgeable of plant conditions (Section O1.1).

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All portions of the annual requalification examination w 3re judged to be effective for determining operator competency with some minor exceptions (Sections 05.2 and 05.3).

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Licensee controls to maintain the licensed operator requalification training program current and relative to operator needs was satisfactory (Section 05.4)

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Operator license conditions were being maintained in accordance with 10 CF3 Part 55 requirements (Sections 05.5 and 05.6).

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No validation and verification of operator actions assumed in design basis accident analyses was evident (Section 08.1).

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1. Operations

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01.1 - Control Room Observations a; Insoection Scoo (7170Z)

The inspectors observed routine control room activities while both ' units were in a '

shutdown condition, attended a licensed operator shift turnover and crew briefing, performed a dual unit panel walk-down, reviewed control room logs, and questioned operators on plant and equipment status, Observati9ns and Findings The licensed control room operators' conduct was professional and the operators were attentive to the control panels. During shift turnover, each operator performed a unit control panel walk dgam and discussed differences with their counterpart. Face-to-face and remote communications were consistent with management guidel;nes. The control room's background noise level was minimal and no annunciator alarms were left in a prolonged alarm state. The operators demonstrated satisfactory knowledge of plant conditions and equipment status upon questioning by the inspectors, Conclusions The inspr ctors concluded that an appropriate level of attention to detail existed in the

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control room and operator actions were consistent with licensee expectations as outlined in operations administrative guideline Operator Training and Qualification 0 Ooerating Histo]y InspfCtion Scoce (71001)

The inspectors reviewed the following to assess the licensed operator requalification trainirg program's effectiveness regarding operator performance:

e SALP report No. 50-236/301:96001

• . Resident inspector reports covering the time frame of May 1,1996 to presen * Licensee event reports covering the time frame of May 1,1996 to presen * Initial license examination report No. 50-266/301:97307

• - Licensed operator requalification training report No. 50-266/301:95012

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- Qbservations and Findings The inspectort noted that previous reports had indicated a rise in operator' performance concerns. in response to these NRC identified concernsi the licensee's senior management had implemented rigorous corrective actions to improve operator perform.nce and provide positive management oversight. These corrective actions.-

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included enhancements to the licensed operator requalification training program to em;;hasize management expectations and evaluate operator competencies, Qnclusjons

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The inspectors concluded that the licensed operator requalification training program was an integral part of the process to identify and correct operator performance issue .2 : Recualification Examination ContgD1 insrection Scoce (71001)

The inspectors reviewed the operating examination material which consisted of dynamic scenarios and JPMs to be administered during the inspection wee Additionally, the inspectors reviewed past operating and written examination material administered to licensed operators. The inspectors also compared the operating examination material with Appendix A check-lists contained in IP-71001, The checklists used were " Simulator Scenario Review Checklist, Job Performance Measure (JPM) Quality Checklist, and NRC Checklist for Written Examination Questions." Observations and Findinas The dynamic scenarios were challenging and provided ample opportunity to evaluate the crew and individuals based upon safety significant critical tasks and performance based competencies. However, scenario event descriptions did not cross reference any

. specific task accomplishment to an operator position (unit CO or DOS / DSS) as outlined in NUREG 1021," Operator Licensing Examination Standards for Power Reactors." This deviation was not consistent with training implementation procedure (TIP) 8.8,

" Simulator Training and Examination," Revision 8, section 2.8, which stated that simulator scenarios used for examination purposes should meet the expectations of NUREG 102 The JPMs contained appropriate action steps with certain vital steps identified as critica The JPMs clearly identified and incorporated PRA elements in the selection proces However, a number of " Task Standards" were not consistent with guidance found in TIP-8.1, " Job Performance Measures," Revision 12, section 5.4.3 in that expected operator or plant response was not performance based. For example, one JPM element standard stated " Steam generator level checked." However, the expectation was that the operator would recognize a high level condition based upon an increasing trend.-

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Additionally, a few task elements were identified as critical which was not cor.dstent with section 5.4.8.a. of TIP 8.1. For example, one JPM element required ti.e operator to verify a valve select switch in the AUTO position. Since the switch had been placed in the AUTO position for the JPA _ etup, no operator action was required to satisfy the task -

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element and unsatisfactory completion of the element would have had no impact on completion of the tas The written examination questions were of good quality and written to the appropriate difficulty level. A majority of the open reference questions were higher cognitive knowledge level questions. Tha static examination questions made good use of the simulator as a reference. Less than ten percent of the questions were repeated from week to week, and one hundred percent of the questions were new or significantly modified from the previous examination cycl Conclusions The inspectors concluded that the requalification examination materiai contained the necessary quantitative and qualitative attributes to ensure the appropriate level of competency was metained by cil licensed operators, with minor exceptions. However, the administered operating examinations did not always reflect the program's guidance for examination development and validatio .3 Reaualification Examination Administration Practices Insoection Scone f71001)

The inspectors performed the following to assess the licensee's policies and practices regarding requalification examination administration, and simulator fidelity:

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• Observed and evaluated one operating crew during the performaace of dynamic siinulator scenarios and job performance measures. This observation also included an assessment of the evaluation team's performanc * Reviewed Training Administrative Procedures and interviewed selected personnelinvolved in the requalification examination proces * Reviewed ;he simulator fidality lo * Reviewed the examination security measure Observations and Findinas The licensee identified no unsatisfactory crew or individual performance during the dynamic scenario sets. One individual was evaluated as unsatisfactory during the performance of JPMs. Previous to the inspection week, the licensee had identified an unsatisfactory dynamic scenario set performance by one cre'n and one individual. The inspectors reviewed and concurred with the licensee's assessment of operator (s)

performance (See Section 05.6 for a discussion of the remediation process).

During the dynamic scenarios, the lead evaluator was distracted during an abnormal transient and a major event while discussing plant parameters with another evaluator in the simulator control booth. The two evaluators had their attention diverted from one to three minutes in both ;nstances. While no adverse operator actions were overlooked,

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the inspectors expressed a concern that any distraction during an evaluation setting could be a missed o'pportunity for observing an operator deficienc During the dynamic scenarios, an extra instructor was assigned as " communicator" in the simulator control booth. The communicator's role was to portray se'octed plant operators and respond accordingly. The instructor's communication with the control room operators was not always consistent with operations manual OM-1.1, " Conduct of Plant Operations," Revision 0, Attachment 7, section 2.0 in that clear and complete three-way communications did not occur and information transfer was incomplete. The instructor communicated a number of technical errors which were corrected. The inspectors were informed that this instructor was a new employee with previous commercial experience at another facility. These errors were attributed to the instructor's inexperience at the Point Beach facihty. The inspectors determined that the instructor's poor communication skills had no adverse impact on operator performance but a potential for introducing error had existe The inspectors observed the licensee's examination security practice throughout the administration process. No security concems were identified. However, the licensee did issue a Condition Report on August 11,1997, that described a potentici examination compromise. An operations representative assigned to the licensee's examination security agreement was observed instructing a crew of licensed ope ators. Some of the licended operators in attendance had not taken the annual operational examination but were scheduled to participate in the near future. This action was contrary to Training Procedure TRPR 33.0, " Licensed Operator Requclification Training Prograrr.,"

Revision 6, Se: tion 8.4.4.1, which stated in part that exam team members signed on to the security agreeraent would not participate in any instruction or tutoring of examinees until those examinees had completed their examinatio The failure to prevent unauthorized instruction of licensed eperators by an individual on the iicensee's examination security agreement was a violation of Criterion V of Appendix B to 10 CFR Part 50 which states in part that licensees shall accomplish activities that affect quality in accordance with prescribed instructions. This licensee-identified and corrected violation is being treated a Non Cited Violation consistent with Section Vll. of the NRC Ersforcement Poliev (50-266/301:97019-01).

No new simulator fidelity concems were identified during the operating examination process. The licensee's simulator deficiency or condition reports were properly prioritized and addressed in a timely manner. (See Enclosure 2 Simulator Fidelity Report)

c. Conclusions The inspectors concluded that for the most part the licensee was implementing the licensed operator requalification program in accordance with program guidance and regulatory requirements stated in 10 CFR Part 55.59. However, the inspectors were concemed that the administration portion of the dynamic scenarios sets contained weaknesses, such as instructor communications and evaluato s being distracted, which

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could contribute to Eass than effective evaluation result .

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0 lhaual(1 cation Training Feedback System f i

. insge.qtion Scooe (71001)

ThJ inspectors performed the following to assess the licensee's training progrom feedback system effectiver.ess:

• Reviewed revisions to the requalification program based upon operator  :

performance and industry event .

• Revi;wed operator feedback process and comment,s QbWYallops and Findings

The inspectors noted that training material had been revised basea upon past i

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performance prior to use in a future training cycle. - The licensee conducted periodic Training Advisory Committee (TAC) reviews of the licensed operator training program  :

and recommended changes la incorporate emerging operations issues. In addition, the i licensee maintained a tracking program to incorporated revisions based upon recent procedure changes or plant modifications, CDDClullQas The inspectors concluded that the training feedback process was effective in providing licensed operatom with updated information affecting plant operations or operator +

i performanc .5 Conformance with Ooerator License Conditions ,

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The inspectors reviewed the following documents to assess the licensee's compliance  ;

with 10 CFR Part 55.53, " License condition requirements," and 10 CFR Part 55.21,

" Medical examination."

-*- Active license tracking record * Requalification training records, e- Licensed operator medical rec ~ds, b .- Observations ar!d Findings The inspectors determined that the active license and medical exam tracking systems contained sufficient controls to maintain license condition. Recent revisions to the medical program were consistent with regulatory requirements and no concems were identified.' Alllicensed operators maintaining an active license condition had performed their duties consistent with program guidelines and regulatory requirements '

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The inspectors concluded that the operator license conditions were being maintained in i accordance with licensee's program guidance and regulatory requirements stated in 10  ;

CFR Part 55.53 and 10 CFR Part 55.2 :

05.6 Remedial Training Procram InspfIlion Scone (71001) I The inspectors performed the following to assess the licensee's remedial training j

program effectiveness:

i o Reviewed individual operator and crew performance evaluations for the previously completed examination week * Reviewed the remediation training plans for unsatisfactory operator performanc * Interviewed licensed operators, instructors / evaluators, and supervisors, Qbietyailons and Findings .

The inspectors determin6d that the remedial training program contained sufficient I

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controls to address individual operator performance concerns. This was especially true when an operator failed the annual requalification examination or had an adverse trend  ;

in performance during successive training cycles as indicated by poor quiz grades or '

aynamic simulator performance. The development of remediation training plans  ;

included a comprehensive root cause analysis of past individual or crew performance j and possible programmatic breakdown. Retake exam; nations for individual operators  !

and/or crews were comprehensive and ensured that individual operators or a crew had achieved the required skills to retum to licensed dulle Conclutl0ns The inspectors concluded that the remediation training program contained the necessary attributes to address individual and crew performance weaknesses prior to allowing either to assume licensed dutie i 08.1 Missellaneous Ooerations issues ADettion Scone (71707)

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The inspectors reviewed a copy of the 'icensee's design basis documents in regards to -

operator actions required to mitigate specific design basis accidents. The inspectors identified two design basis accidents (Steam Generator Tube Rupture - SGTR and Large Break Loss of Coolant Accident - LOCA) for which operator action was required to mitigate the accident. The following documents were reviewed: training lesson plans on

. SGTR and LOCA events covered in fiscJ year 1996 and 1997; the updated final safety analysis report (UFSAR) section 14.2.4, " Steam Generator Tube Rupture," and section 14.3.2, * Loss of Coolant Accident *; and the individual plant examination (IPE) summa'y

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i report section 3.1.2.13, ' Steam Generator Tube Rupture Event Tree," and section

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3,1.2.10, *Large LOCA Event Tree."

t Observations and Findinas ~

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The licensee's analysis for a LOCA event noted that, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after an event, the l operator would have to realign the safety injection system to permit simultaneous I injection of borated water into both the cold legs and the reactor vessel to prevent or !

minimize the potential of boron precipitation. Boron precipitation was a concem

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because it reduced tne heat transfer capability across the fuel cladding surface. The inspectors determined that early intervention by the operators was addressed in the emergency operating procedure, EOP 1.2. The licensee's continuing training program ,

had incorporated classroom and simuistor training on the implementation and use of :

EOP 1,2 to address this concer i

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The licensee's analysis for a SGTR event noted that, within 30 minutes of the event, the ,

safety injection system would have re!.i:ed the reactor coolant system and the operator l would have had time to determine which steam generator was faulty. The radiological consequences section made an assumption that 30 minutes after the postulated tube !

rupture accident the pressure between the faulted stearn generator and the primary system would be equa'ited.1 This assumption was palt of the licensee's evaluation to !

support the statement that the radiological release from a design basis SGTR would not be significant and would be less than permissible limits of 10 CFR Part 10 ;

Additionally, the licensee's IPE document made an assumption that the SGTR recovery actions would be successfulif most of the EOP 3 acti~o~ns were completed within approximately 30 minute Upon questioning, the inspectors were informed that validation of tho above design i basis accidents involving an operator timed response was not part of the continuing i training program. The inspectors identified a concern that operator respons6 dunng a design basis SGTR accident may exceed the assumed con.pletion time to perform the

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major actions contained in EOP 3 and equalize reactor coolant pressure with steam generator pressure to stop tha radioactive releas ' Conclusions .. t The inspectors concluded that, while the licensee's continuing training program was i being implemented in accordance with prescribed program ruldance, no process was in place to ensure continued validation of expected operator response times during a design basis accident. This matter will be reviewed during a future inspection (50 266/301:97019 02).

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E Mattagement.Mputings X1 Evat f,1ccijng3ummmy The inspectors presented the preliminary inspection results to members of licensee rnanagement on September 12,1997. The licensee acknovoledged the findings oresente The inspectors asked the licensee whether any materials reviewed during the inspection could be considered proprietary. No information or documents reviewed were considered proprietary by the license ,

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee

'R. Amundson, Senior Training Specialist

• A. Cayla, Plant Manager

'M. Koudelka, Regulatory Speclatist

• T. Staskat, Assistant Operations Manager

'W. Walker, Manager - Training 88C

'P. Louden, Resicient inspector

'T. McMurtray, Sen!or Resident inspector

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• Denotes those present at the ex t on September 12,199 lNSPECTION PROCEDURES USED t IP 71001: Licensed Operator Requalification Program Evaluatior IP 71707: Plant Operations ITEMS OPENED, CLOSED, AND DISCUSSED

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f Damned 50-266/301:97019 01 NCV Failure to maintain proper security level during examination preparatio /301:97019 02 IFl No operator timed response evaluation for design basis SGTR accident analysis Cloitd 50 266/301:97010-01 NCV Failure to maintain proper security level during examination preparatio .

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Enclosure 2 r, SIMULATOR FIDELITY REPORT l: Facility Licensee: Point Beach Nuclear Plant, Units 1 and 2 Facility Licensee Dockets No: 50 266, 50 301

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' Operatinh Tests Administered: September 8 9,1997 s 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 Part 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 items were observed (if none, so state):

IIEM DESCRIPTION NONE OBSERVED

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