IR 05000302/1993020

Insp Rept 50-302/93-20 on 931101-19.Violations Noted.Major Areas Inspected:Licensed Operator Requalification Training

ML20058P680
Person / Time
Site:	Crystal River
Issue date:	12/03/1993
From:	Hopper G, Lawyer L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058P672	List: IR 05000302/1993020 ML20058P671 ML20058P678
References
50-302-93-20, NUDOCS 9312270230
Download: ML20058P680 (11)

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LNITED STATES'

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Report No.: 50-302/93-20

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Licensee: Florida Power Corporation 3201 -34th Street, South St. Petersburg, FL 33733 [

a Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: November 1-5, and November 15-19, 1993 +

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Inspector: du @

George T. Hopper "

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Accompanying Personnel: J. H. Bartley '!

R. F. Aiello Approved by: - .

Lawrence L. Lawyer, Chief Date Signed .

Operator Licensing'Section Operations Branch Division of Reactor Safet i Scope:

This was a routine, announced inspection in the' area of licensed operator ,

requalification trainin Its purpose was to ensure that the licensee's- '

requalification program for licensed operators incorporated requirements for both evaluating operator mastery of training objectives and to assess the-licensee's effectiveness in evaluating and revising the requalificatio ,

program for. licensed operators based on the operational performance of licensed operators. The program assessment included a review of training administrative procedures, requalification training records, and examination ,

material. The inspectors conducted an evaluation of operator performance and *

~ the ability of licensee evaluators to administer and objectively evaluate 1 operators during requalification examination Results:

Inspectors identified a violation with regards to failing to notify the NRC within 30 ' days of the change in the medical stati!s of a . licensed operator (paragraph 2.e.(1)). VIO 50-302/93-20-01 Inspectors identified a violation concerning the failure to provide safeguards against tampering with official records (paragraph 2.e.(2)). -

VIO 50-302/93-20-02  ;

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9312270230 931203 PDR ADOCK 05000302 O PDR

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Inspectors . identified an inspector follow-up item regarding a licensed ;

operator having three unnecessary medical restrictions on his license '

(paragraph 2.e.(3)). IFI 50-302/93-20-03 ,

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Inspectors identified a violation with regards to failure to provide adequate details in documentation supporting TDP-113, Remedial Training Program -

(paragraph 2.f.(1)). VIO 50-302/93-20 04

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REPORT DETAILS Persons Contacted Licensee Employees

• J. Alberdi, Manager, Nuclear Plant Operations

• D. Bates, Supervisor, Quality Systems

• G. Boldt, Vice President, Nuclear Production L. Kelly, Training Manager J. Kessler, M.D., Florida Power Corporation

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• J. Lind, Manager, Nuclear Operator Training

• Marshall, Manager, Nuclear Plant Operations

• J. Smith, Nuclear Licensed Operator Training Supervisor

• J. Springer, Nuclear Simulator Training Supervisor

• R. Yost, Supervisor, Quality Audits ,

Other licensee employees contacted included instructors, engineers, technicians, operators, and office personne '

NRC Personnel

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• R. Butcher, Senior Resident Inspector

• T. Cooper, Resident Inspector '

• K. Landis, Chief, Reactor Projects Section 2B

• L. Lawyer, Chief, Operator Licensing Section

• Attended exit interview Licensed Operator Requalification Program Evaluation (TI 2515/117) Examination Development The inspectors reviewed the Job Performance Measure (JPM) and simulator examination development activities for conformance with 10 CFR 55 and the guidelines of NUREG-1021, Operator Licensing Standards, Revision 7. The inspectors concluded that the facility-developed examinations for this cycle met the requirements of 10 CFR 55. However, the inspectors noted several departures from the guidelines of NUREG-102 '

(1) Attachment 2 to ES-601, Examination Sample Plan, lists 11-elements that are expected to be contained within the sample _:

plan. Six out of eleven of these elements were missing from the

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licensee's sample plan. These items are described in Appendix ,

(2) NUREG-1021-guidelines state that at least 80 percent of the test outline should reflect the training curriculum of the most recent requalification cycle in a manner consistent with the j distribution of emphasis in the curriculum. The proposed test i outline was generated to reflect the sum of 10 individual crew

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Report Details 2

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examinations to be administered independently over a period of several weeks. 'Each crew member had five JPMs to perform. A total of 25 JPMs were selected as test items, and the test outline used this number to calculate distribution of emphasi The. inspector calculated the distribution for each independent examination using the five JPMs that were to be evaluated and found two crews whose examinations were skewed and not in accordance with the sample plan. The licensee corrected this problem prior to examination administratio (3) NUREG-1021 guidelines state that the use of a test outline and sample plan provides a systematic approach to selecting and developing test items. The inspectors found that the sample plan did not include criteria for selecting dynamic simulator scenarios. The licensee had selected the scenarios at random with no consideration given to the sample plan and distribution of emphasis over the past yea .

(4) The inspectors reviewed the simulator scenarios administered during the inspection to determine their quality and conten The scope and complexity of the scenarios were satisfactory and challenged the operator Violations or deviations were not identifie , Operator Training The inspectors reviewed operating and training records'for the period January 1, 1993 through November 1, 1993. These were compared to the requirements of Systems Approach to Training (SAT), element 5 of 10 CFR 55.4, and the guidance contained in NUREG-1220, " Training Review Criteria and Procedures, Revision 1." _The inspectors determined that there were no significant operator errors caused by ineffective '

training. The inspectors also determined that the facility had adequately incorporated corrective actions for operator deficiencies identified during training into the requalification training progra Violations or deviations were not identifie Examination Administration The inspectors observed the licensee administer operating examinations to verify conformance to the guidelines of NUREG-1021. Additionally, the-inspectors reviewed training department procedures and the supporting documentation to determine if the requirements were being i followed. The inspectors concluded that the examinations were !

administered in accordance with the guidelines.except for a problem noted with cuing during the walkthrough examinations. Additionally, the inspectors identified a poor practice which could result in compromising the proposed examinations and deficiencies in Training Department Procedures (TDP) 106 and 20 j

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Report Details 3 l 4 I (1) -The examiners monitored the administration of JPMs in the plant 1 and in the simulator. They observed four licensee evaluators. .  !

One. licensee evaluator displayed a. weakness.in that.he provided l inappropriate feedback to an' operator while ^ administering in-

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plant JPMs. . The inappropriate feedback consisted of the evaluator repeating back the valve nomenclature of the valve; being operated. This could inappropriately cue the operator if he had selected the wrong valve..' i

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(2) TDP-106, " Examination Preparation, Administration and Grading," j section.5.2.6.5, discussed shredding of unnecessary master copies i during test reproduction. The procedure did not address the shredding of draft copies' of test items used for validation and verification during test development. This.was a concern sinc the inspector learned that some items had been placed in the . .i paper recycle bin just prior to an examination. This practice- .;

could' result in a possible compromise of the examinations.- j i

(3) TDP-106, section 5.5.4.12, defined the " Satisfactory Performance  !

- Remediation Required" criteria for an individual or crew.that a demonstrated significant weaknesses during a requalification i examination but did not meet the. failure criteria. The -!

e subsequent paragraphs did not-describe'the specific. criteria.to :!

be used when a " Satisfactory with Remediation" individual or crew - .

should be removed from licensed duties, nor did it list the_  !

person (s) responsible for making that decision. This indicates a lack of mana;ement oversight in that'a' consistent standard cannot be. implemented without application of defined criteria and ,

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(4) TDP-203, " Licensed Operator Requalification Training Program,.

section 5.8.1.1, contained a statement that.a Reactor Operator (RO) was considered Senior Reactor Operatori(SRO) certified by'  ;

virtue of having his.R0 license (without additional training).

The licensee recognized that this was in' error;and intends to "!

cor.ect the procedur Violations or deviations were not identified

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The inspectors observed simulator performance and reviewed simulato ,

usage documentation and trouble reports for-the period January 1, 1993  !

through November 1, 1993. -The simulator 'exhibitesi no anomalies or t fidelity problems during the conduct of the examinations. The -

examiners concluded that simulator availability and the program for tracking simulator. problems,were satisfactor !

(1) The inspectors reviewed the licensee's record of simulator usage 1 over the past year to obtain a breakdown of simulator d availability for operator training versus other categories ofL .;

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simulator utilization such as engineer training, modification testing, maintenance, etc The inspectors found that priority was given to operator training. The inspectors concluded that -

the simulator availability was satisfactory for present operator training need '

(2) The inspectors reviewed simulator trouble reports and interviewed the Simulator Maintenance and Engineering Supervisor regarding I simulator fidelity, modification tracking, and trouble report resolution. The trouble report summary contained a'large number

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of entries (103) due, in part, to the large scope of the capabilities of this simulator. The inspector noted that work requests that affected simulator availability or- fidelity received highest priorit The licensee recently added trouble report 911 to the list due to an event in'which a Reactor Coolant Pump tripping from 100 percent power resulted in a Flux / Flow reactor trip. This event could not be duplicated in the simulator and was under investigation. This was the most- ,

significant of all the discrepancies on the report and the licensee intends to benchmark actual plant data on the simulato Violations or deviations were not identifie Licensed Operator Medical Review

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The inspectors reviewed the medical records of licensed operators on November 5, 1993, to determine whether the facility met'the i requirements of 10 CFR 55. The inspectors identified violations in '

the areas of required notifications and inadequate record keepin The inspectors identified an Inspector Follow-up Item (IFI) concerning *

an operator with apparent unnecessary restrictions on his licens (1) The inspectors determined that required notifications were not ;

made for a change in the medical status of two operators as required by 10 CFR 55.2 The inspectors found that on June 30, 1993, and August 25, 1993, conditions were identified by the facility medical examiner which required notification to the NRC on form NRC 396 within 30 days of learning of the diagnosis. In both cases the facility medical examiner determined that the ,

operators visual acuity required a restriction to their individual licenses. As of the date of the inspection, November 5, 1993, the notification to the NRC had not been mad ,

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Subsequently, the licensee took corrective action and submitted the Form 396 for both individuals to the NRC. The inspectors ,

determined that the process used to satisfy the 10 CFR 55.25 notifications was flawed. No procedures or' directives existed which defined the process or delegated responsibility. The ,

failure to notify the NRC within 30 days of the change in the .

medical status of an operator is an example of Violation (VIO) l 50-302/93-20-0 l

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(2) The inspectors noted during the medical records review that 22 out of 47 records had been modified or corrected with the use of-correction fluid. The inspectors were particularly concerned with the use of this material on the Periodic Physiological and >

Lab Data Report. This document was used to summarize an operator's medical data to verify that the ~ operator meets the ANSI 3.4-1983 medical qualification requireeents. The licensee was required by 10 CFR 50.71(d)(1) to maintain adequate ,

safeguards against tampering with and loss of records. The use

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of correction fluid on these records removed any safeguards against tampering. In addition, this practice was not in accordance with N00-04 Rev 8 (Records Management Program) which ,

requires in part that under no conditions may white-out,'

correction tape, or cutting and pasting methods be used to correct information. This failure to provide safeguards against tampering with official records is considered an example of VIO 50-302/93-20-0 (3) The inspectors reviewed the medical record of an operator who had three restrictions placed on his license. One of these restrictions stated "no use of respiratory equipment". The inspectors found an NRC Form 396 in his medical file which certified him to have no restrictions as of October 29, 199 However, the NRC had not received an application for an amendment ,

to his license. The operator was assigned to the Fire Brigade as team leader and maintains an active license. An interview with !

the licensee's medical examiner on November 16, 1993, confirmed .

the fact that all three restrictions were unnecessary. These restrictions currently remain on his license and are not medically required. This item is identified as IFI N /93-20-0 a f. Remedial Training Program ,

The inspectors reviewed the Remedial Training Program as implemented by TDP-113, " Remedial Training Programs, Revision E." The inspectors determined that the documentation supporting TDP-113 was inadequate, ,

that some remedial programs were implemented prior to being developed and approved or were implemented without being approved, and that some retesting was not adequat (1) The team reviewed Remedial Training Program Descriptions (Form 113.1) and Training Class Attendance Records. 10 CFR Part 50, Appendix B, Criterion V,-required that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. The inspectors found that the documentation was inadequate in that it did not '

contain enough details to demonstrate that the remedial training ,

had been adequately designed, properly reviewed,'and  !

satisfactorily accomplished. The Remedial Training Program

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Descriptions typically-did not specify the weaknesses identified ;

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during the evaluation other than which portion of. the examination was failed. The Remedial Training Program Descriptions also failed to provide idequate details of specific tasks or knowledge weaknesses to be covered during the remedial training. This lack of detailed documentation was also noted on the Training Class Attendance Records. An audit of the records failed to show that weaknusses identified during evaluatior.s were adequately i remediated because the records did not list the weaknesses :

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identified during the evaluation or the detailed training conducted to correct the weaknesses. The inspectors interviewed f several instructors and supervisors to determine whether .

effective remedial training was being conducted but not being documented properly. Based on the interviews and reviews of non-quality controlled documents, the inspectors concluded that ,

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effective remedial training had been conducted in most case The failure to provide adequate details in documentation supporting TDP-113, " Remedial Training Programs," is an exampic of VIO -

50-302/93-20-0 .

(2) The inspectors found that in some instances, remedial training-was implemented prior to a remedial training program being developed and approved. An example of this was an individual who started a remedial training program on November 23, 1992, which was not developed and approved until November 24, 1992. The inspectors found two examples of remedial training programs being ;

developed, implemented, and completed without being approved and signed by the Nuclear Training Superviso '

(3) The inspectors determined that some retesting under the remedial training program was inadequate. NUREG-1220, " Training Review Criteria and Procedures," stated one characteristic of Element four was that retesting should include all aspects where weak performance was originally identified. The inspectors determine ,

that some retests did not include all aspects where weak

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performance was originally identified during the evaluation. An example of this was the retest for a failed requalification >

walkthrough examination. The operator failed two JPMs and demonstrated a significant weakness on a third JPM. The retest consisted of a set of five JPMs. None of the JPMs tested the tasks in which the weak performance was originally identified nor were they even remotely relate ,

3. Exit Interview '

The inspection scope and findings were summarized on November 19, 1993, ,

with those persons indicated in paragraph 1. The NRC described the areas inspected and discussed in detail the inspection findings. No proprietary material is contained in this report. No dissenting comments were received from the license . .

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Item N Description 50-302/93-20-01 VIO - Failure to notify the NRC within 30 days of the change in the medical status of a licensed i

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operator (paragraph 2.e.(1)).

50-302/93-20-02 VIO - Failure to provide safeguards against l tampering with official records (paragraph .

2.e.(2)).  ;

50-302/93-20-03 IFI - Licensed operator has three unnecessary i medical restrictions on his license (paragraph 2.e.(3)). ,

50-302/93-20-04 VIO - Failure to provide adequate' details in ,

documentation supporting TDP-ll3 Remedial .

Training Program (paragraph 2.f.(1)). .

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4 APPENDIX A The inspectors reviewed the licensee's sample plan that was developed and used to construct the test outline for the annual operating examination. The licensee selected categories to be included.in the exam on the basis of time spent in training on that category. The inspectors had difficulty auditing the test outline because several key elements were missing. The sample plan contained no reference to the preferred testing media for each subject or category, nor did it contain the identification code for previously developert i test items that evaluate the subject. Without these elements, it is impossible to construct an examination directly from the sample plan. Th test outline contained the facility's reference to the Job Task Analysis (JTA)

associated with each test item. However, neither the sample plan nor the test outline contained the associated K/As or importar.ce factors. The inspectors could not verify that all test items used in the examination had a K/A value of three or greater from the test outline. No subjects had been identified.as safety-related in the facility JTA. Recent safety-related events or modifications were not specifically identified in either the sample plan or the test outlin !

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i APPENDIX B *

DOCUMENTS REVIEWED i Number Title Re N0D-02 Training Development and Documentation Program 7 N00-05 Document Control Program 9 N0D-19 Licensed Operator Exams -1-TDP-106 Examination Preparation, Administration and Grading 15 TDP-113 Remedial Training Programs 8 TDP-203 Licensed Operator Requalification Training Program 17 TDP-210 NRC License Application Process 9

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