IR 05000269/1992020
| ML16148A691 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/08/1992 |
| From: | Lawyer L, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A692 | List: |
| References | |
| 50-269-92-20, 50-270-92-20, 50-287-92-20, NUDOCS 9210270022 | |
| Download: ML16148A691 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/92-20, 50-270/92-20 and 50-287/92-20 Licensee:
Duke Power Company P. 0. Box 1007 Charlotte, NC 28202-1007
.
Docket Nos.:
50-269, 50-270 and License Nos.:
DPR-38, DPR-47 and DPR-55 50-287 Facility Name:
Oconee 1, 2 and 3 Inspection Conducted:
August 24 - 27, 1992 Inspector:
_
L__
_
_
'L. Lawyer, Chief Date Signed Operator Licensing Section 1 Division of Reactor Saftey Accompanying Personnel: B. Holbrook, License Examiner L. Vick, License Examiner Approved by:
/4
<fi T. A. Peebles, Chief Date'Signed Operations Branch Division of Reactor Safety SUMMARY Scope:
This routine announced inspection was conducted to review the development, implementation, evaluation, documentation, and maintenance of the licensed operator requalification program and to relate whether recent events were related to potential program weaknesse Results:
Tracking and closeout of training action items were identified a strengths (paragraphs 3 & 9).
Two weaknesses were identified: 1) lower tier procedures were not available to implement the provisions of the Empl.oyee Training and Qualifications System Manual resulting in many inconsistencies i program administration (paragraphs 4, 6 & 7); 2) it was not clear that requalification examinations administered after each training segment (week) met the requirement of 10 CFR 55.59 (a)(2)
(paragraph 4).
In the areas inspected, no violations or deviations were identifie PDR ADOCK 05000269 G
REPORT DETAILS 1. Persons Contacted Licensee Employees B. Ayers, Instructor J. Byko, Nuclear Station Instructor D. Covar, Nuclear Station Instructor
- 0. Kohler, Compliance Engineer T. Lee, Nuclear Station Instructor
- G. Ridgeway, Shift Operations Manager
- K. Saunders, Administrative Supervisor
- P. Stovall, Director, Operator Training J. Whitener, Nuclear Station Instructor Other licensee employees contacted included engineers and office personne Other NRC Personnel
- B. Holbrook, License Examiner
- L. Vick, License Examiner
- Attended the exit interview on August 27, 199. Licensed Operator Training Staff The inspectors reviewed selected training records and determined that licensed operator instructors were qualified and were being continually trained to accomplish present job assignment. Operator Error Analysis The inspectors reviewed Licensee Event Reports (LERs) 269/92-01, 92-04, and 92-05. The LERs' root causes were determined to be either inappro priate action, management deficiency, lack of task specific procedures or less than adequate training. The inspectors determined that corrective actions, which consisted of additional operator training and operating procedure revisions, were consistently completed. The corrective actions were thoroughly and promptly performe The inspectors reviewed the licensee's response to training weaknesses identified in the last Systemic.Assessment of Licensee Performance (SALP). In every case the licensee's response was appropriate and promptly executed. Tracking and closeout of training action items were identified as a strengt. Comprehensive and Topic Specific Examinations Oconee's 24 month Operator Requalification Program, required by 10 CFR 55.59 and in place at the time of this inspection, was implemented on September 24, 199 Each of the five operating crews received
a
approximately ten weekly segments of instruction during each 12 month perio Each of the five licensed operator crews attended training for one week, on. a rotating basis. Training generally consisted of weekly segments of simulator training covering abilities alternated with a week of classroom lectures covering knowledge item Eac h weekly segment consisted of four days. The maximum number of contact hours (time actually teaching lesson plan material) in a week was 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. A Section B, "Administrative Controls/Procedural Limits", style examination (Examiner Standard ES-602, part B) was conducted following each weekly segment of classroom instruction to evaluate the operators comprehension of knowledge material taught during that week. The weekly segment examinations were averaged together to obtain a final score which the licensee considered to be the score for the comprehensive examination as required by 10 CFR 55.59 (a)(2). At the end of the first 12 month period the operators were evaluated by means of a static examination (Examiner Standard ES-602, part A) and an operating test. At the end of the second 12 month period the operators were evaluated by means of an operating test and job performance measures (JPMs).
The licensed operators were not administered a comprehensive written examination to evaluate a representative sampling of the classroo materials taught during the 24 month licensed operator requalification period. The inspectors found and the licensee concurred that knowledge type lesson plan material was not evaluated except in the-week that the material was taugh The inspectors reviewed the ETQS manual. Some important requalificatio definitions and specifications were found to be absent. There was no specification of cycle duration or how to combine scores to determine written examination comprehensive pass or fail criteria and no local implementing procedures provided this informatio From the review of the Oconee requalification training and examination cycle the inspectors concluded:
(a) It is not clear that requalification examinations administered after each training segment (week), that address only material covered during that week, accomplish the following three objectives:
(1) Meet the requirement of 10 CFR 55.59 (a)(2) that licensed operators or senior operators pass a comprehensive requalifica tion written examination (2) Serve as a means of measuring comprehensive training effective ness as required by ETQS standard 2306.0, Rev. 6, section 5. (3) Ensure a satisfactory level of operator proficiency at all times as advised in NUREG-1262, question 31 (b) The inspectors found that each segment examination tested only the material presented during that segment (a maximum of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of lecture time over a three day period)
In a subsequent telephone conversation, Mr. Paul Stovall informed the NRC regional office that Duke Power Company was changing their requalifi cation written examinations from the segmented examiantions described above to annual written comprehensive examinations. These latter examinations will be-both Part A and Part B.. Approximately 80 percent of each examination will be devoted to material in theipreceeding 12,months with the balance of the examinations on material covered during the time period of 12.to 24 months prior to the examination. The inspectors found the proposed program change to-be adequate to resolve the "comprehensive examination" weaknes. Remedial Training A review of the remedial training employed in the two most recently completed requalification or continuing training programs was conducte The inspectors found no cases of non-compliance with the requirements of 10 CFR 55.49 In accordance with the ETQS manual Standard 2306.0 (Rev 6), licensed individuals who obtained less than 80 percent on any segmented requalifi cation written examination were assigned to a remedial requalifi-cation session. A complete review of three remedial sessions found full compliance with the standar The inspectors interviewed licensee personnel who had previously failed or had required remedial training. In each case individuals were adequately remediated and reexamined. The quality of remedial training was acceptabl. Training Program Monitoring The ETQS manual broadly specified the content and administration of training and qualification of employees. However, lower tier implement ing procedures have not been prepared or do not adequately specify content and administration of operating and written examination While the licensee training group had oral understandings and some informal documents, such as an undated memo controlling some aspects of the 1992 annual requalification.examinations, there are no controlled directives or guidelines providing implementing instructions for requalification operatidng and written examinations. This has led to inconsistencies in program implementation. Grading of simulator scenarios and documentation of evaluation results were inconsistently applied by facility evaluators. The inspectors learned that lower tier implementing procedures were once utilized but were canceled with licensee management approva The attendance records for several licensed operators, who participated in the segmented requalification lectures and subsequent examinations, were not clearly traceable. For example, some required attendance records contained initials to denote an individuals attendance at a lecture or examination for that segment while others contained a signa ture or initials by a third party and some were left blank. Where the
attendance records were inadequate to verify attendance, a review of the actual examination grading sheet was utilized to verify licensed opera tors received training and examination for the segment of interes In summary, the inconsistencies in requalification administration a applied to classroom training were: 1) Classroom attendance was not readily auditable, some attendances were indicated by personal initials or signatures, some by printed initials by other persons and in some cases the attendance form was left blank, 2) some examinations were graded with the same color ink as the original examination response. Instructor use of standards in evaluations and critiques Additional examples of inconsistencies in administration of the requalif ication program were found in the area of Active Simulator Exercises (ASEs). The inconsistancies included:
1).specification of the type of retraining and reexamination necessary in the event of a failure, 2) a final grade for one competency was not specified, 3) during a "pilot type" ASE, which resulted in a crew failure, a Senior Reactor Operator (SRO) was individually designated a "pass (sat)" without completing any critical tasks, 4) some summary sheets and competency evaluation check sheets were documented in pencil, and 5) some evaluators designated passing scores on.Individual Simulator Critical Tasks (ISCTs) with "S",
some with check marks and others had no marking. Instructional Settings The inspectors found classroom training instructor to student ratios ranged from 12-16 students per instructor and a ratio of 3-4 students per instructor for simulator training. The classroom area used for student instruction was generous and modern with plenty of space and lightin Simulator instructional hours per licensed operator averaged 3-4 hou per student per da All training aids and reference materials were available to the operators.. The operators that were interviewed general ly regarded instruction quality good to excellen. Simulator fidelity report review A review of simulator problems and fidelity issues from past examination reports was conducted. * Only one issue, regarding the reactor building response to heat addition by water or steam leaks, remained to be resolved. The simulator support group acknowledged that the limited scope of the simulator was the cause for the observed simulator respons Currently, outstanding Discrepancy Reports (DRs) do not adversely impact the training of licensed operators. The licensee s corrective action program for DRs was adequat.
Examination Qualit The inspectors reviewed six weekly written (segment) examinations to determine content, style and scope. The inspectors determined the examinations adequately examined the learning objectives that had been
- II5 taught during the week and parallel grading of specific topics did not indicate any grading discrepancy. Most segmented examinations consisted of four or five topics with five to six questions per topic. The instructor who taught a topic in the classroom was the one who selected the questions for that topic that were to be included on the weekly segmented examination. This method of examination development did not provide an evaluation of the effectiveness of the instructor or the instructio These six segmented examinations were compared to the guidelines as presented in NUREG-1021, Examiner Standard, ES-602. The following differences were noted:
1) Many of the questions were short answer or essay rather than multiple choic NRC's current policy is to not use short answer and essay style questions for operator requalification examinations. Essay style makes consistent grading more difficult. This style of question is not generally developed for open reference examination ) Many questions were low level knowledge (mere recall of facts and specifics) vice high level cognitive skill (analysis or synthesis).
Low level knowledge questions did not necessarily test for the complete understanding of the underlying concepts or issues in comparison to higher level cognitive skill style question Additionally, the operator's ability to utilize or apply knowl edge to a particular job situation was not evaluate ) Most questions were selected from the generic question bank rather than from the requalification examination ban The licensee submits proposed examinations developed from the requalification examination bank for examinations that are administered by the NRC. The NRC reviews the proposed examina tions and recommends the necessary changes to assure that the requirements of NUREG-1021 are met. The questions contained in the generic examination bank are not reviewed by the NR The inspectors determined the questions utilized on the weekly segmented examinations were not of the same quality as the questions utilized on the NRC administered examinatio ) Many of the questions, especially short answer and essay questions, were not time validate Training management stated that some of the individual ques tions and the completed examinations were not time validate However, the operators were allowed the normal time as recom mended by the Examiner Standard This may not discriminate
between competent and less than competent operators. Low level knowledge questions would allow less than competent operators the opportunity to utilize reference material and locate the answer without prior familiarization of the topic. ES-602 suggests licensee management incorporate their expectations into the response time (to evaluate operator response and performance).
This would also allow training management the opportunity to evaluate the instructor's ability to develop questions and to assemble a complete examination necessary to adequately evaluate competent operator.5) Many of the questions were not of a style best suited for open reference type examination Enhanced examination validity and elevation of the level of knowledge being tested by the test items are two important reasons why open reference examinations are utilized. Many questions did not utilize reference material which is normally available to the operator in the Control Room. Realisti settings-and context were not always incorporated in the question The open reference test did not require the opera tors to demonstrate that they could apply, analyze, evaluate or otherwise USE knowledge to handle problems. Therefore, the examination validity was not enhanced and the level of knowl edge required to answer the questions was not elevate ) Some learning objectives were not directly tied to identified operator tasks, skills or abilitie A review of one selected lesson plan indicated eight objectives that.were not directly tied to identified tasks, job skills or abilities. Training management stated that the learning objec tives had not yet been assigned to a task. The inspectors further determined that the results of the segmented examinations had not been utilized to identify specific weaknesses to be included in the subsequent requalification progra In summary, based on inspector review of several segmented examinations in conjunction with the above identified differences the inspectors determined that the weekly segmented examinations had not met the requirements of NUREG-1021 and would not, without substantial revisions, have been given as an NRC administered operator requalification examinatio.
Exit interview The inspection scope and results were summarized on August 27,.1992, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results noted abov Proprietary information is not contained in this repor Dissenting comments were not received from the licensee.