IR 05000324/1993035
| ML20059A354 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/14/1993 |
| From: | Lawyer L, Payne D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059A324 | List: |
| References | |
| 50-324-93-35, 50-325-93-35, NUDOCS 9310260309 | |
| Download: ML20059A354 (11) | |
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UMTED STATES o
NUCLEAR REGULATORY COMMISSION 8%
REGION ll 7,
101 MARIETTA STREET, N.W., SUITE 2900
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- j ATLANTA, GEORGIA 303234199 a
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Report Nos.:
50-325/93-35 and 50-324/93-35 Licensee:
Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.:
50-325 and 50-324 License Nos.:
DPR-71 and DPR-62 Facility Name:
Brunswick 1 and 2 Inspection Conducted:
September 13-17, 1993 Inspector:
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A D. Charles Payne Date Signed Approved by:
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Lawrence L. Lawyer, Ch'ief, s/
Date Signed Operator Licensing Sections Operation Branch Division of Reactor Safety SUMMARY Scope:
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An NRC inspector conducted a special, announced inspection of the Brunswick licensed operator requalification program during the period September 13-17, 1993. 'The inspector reviewed and observed annual requalification examinations conducted by the facility licensee and conducted inspection activities as specified in Temporary Instruction 2515/117.
Nine Senior Reactor Operators and four Reactor Operators received facility administered written'and operating examinations. Activities reviewed included examination development, examination administration, training staff qualifications and training, and -
simulator fidelity. Also during the course of this visit, the inspector reviewed the licensed operator medical records for compliance with 10 CFR 55.
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9310260309 931015
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PDR ADOCK 05000324
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Results:
i Operator Pass / Fail:
(As determined by facility results)
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i SR0 R0 Total Percent Pass
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92.3%
Fail
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7.7%
i The inspector identified the documentation of the Brunswick requalification program and its administrative guidelines as a strength (paragraph 2.b.(2)).
The inspector identified an inspector follow-up item regarding dynamic simulator competency grading methodology, IFI' 50-325,324/93-35-01 (paragraph 2.b.(4)).
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The inspector identified the area of operator performance standards as a strength (paragraph 2.c.(1)).
t The inspector identified the tracking of training staff qualifications and
retraining as a weakness (paragraph 2.e).
The inspector identified and reviewed one violation with regards to reporting changes in licensed operator medical status in accordance with 10 CFR 55.25, VIO 50-325, 324/93-35-02 (paragraph 2.f).
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REPORT DETAILS t
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1.
Persons Contacted Licensee Employees
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- G. Barnes, Manager, Unit-1 Operations
- M. Bradley, Manager, Nuclear Assurance Department
- J. Brown, Plant Manager, Unit 1 e
++W. Geise, Unit Manager-Simulator
- R. Godley, Manager, Regulatory Programs
- E. Harkcom, Nuclear Assurance Department
+*D. Hicks, Manager-Training l
- C. Hinnant, Director, Site Operations
- W. Levis, Manager, Regulatory Affairs
- J. Lyash, Manager, Operations Support
- J. McGowan, Regulatory Affairs Specialist
+ G. Thearling, Regulatory Affairs Senior Specialist
- J. Titrington, Manager, Unit-2 Operations
+ C. Warren, Plant Manager, Unit-2
++M. Williams, Manager, Operator Training (Acting)
Other licensee employees contacted included instructors, engineers, technicians, operators, and office personnel.
NRC Personnel
- P. Byron, Resident Inspector - Brunswick
+ Attended entrance interview
- Attended exit interview Acronyms and initialisms used in this report are listed in the last paragraph.
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Discussion a.
Scope An NRC inspector conducted a special, announced inspection of the Brunswick licensed operator requalification program during the period September 13-17, 1993.
The inspector reviewed ~and observed annual
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requalification examinations conducted by the facility licensee and conducted inspection activities as specified in Temporary Instruction 2515/117.
Nine Senior Reactor Operators and four Reactor Operators received written and operating examinations. Activities reviewed
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included examination development, examination administration, training
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staff qualifications and training, and simulator fidelity. Also during the course of this visit, the inspector reviewed the licensed operator medical records for compliance with 10 CFR 55.
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Report Details
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b.
Examination Development t
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(1) Sample Plan The facility developed a sample plan indicative of the training
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received and material covered during the requalification cycle.
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Examination items were selected based on the sample plan.. The
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sample plan followed the process documented in Brunswick training procedures.
Lesson plans and learning objectives from subject areas taught during the requalification cycle were used in the construction of the examination.
The inspector verified that examination items selected for testing were based on appropriate job tasks from the respective operator task analyses.
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(2)
Reference Materials The Brunswick requalification program was fully defined in Training Department procedures, and these procedures were complied with in the development of the examination. A list of i
procedures reviewed during the inspection is provided in Enclosure 4.
The inspector found that these procedures closely followed the guidelines given in the Examiner Standards with the exception of the simulator competency grading criteria (see paragraph 2.b.(4) below). Also, the inspector determined that a feedback process was in place to incorporate lessons learned,
changing industry standards and events, as well as operator and r
management comments. The thorough documentation of the Brunswick requalification program and its administrative guidelines was considered a strength by the inspector.
Lesson plans and
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learning objectives were complete and accurate. The training department has been updating these training materials and i
improving the format. Those lesson plans 'not yet updated were marked with the new information, or special augmented lesson plans were used. This method was used to train operators on recent plant modifications. Recent procedure modifications were
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covered via the " required reading" program.
(3) Written Examinations The written examinations adequately tested the operators on procedural and systems knowledge.
Some questions from the static l
examinations were determined to be too simplistic. The correct response was self-evident. Questions such as "What system is
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injecting to the RPV?", when only one system of four possible i
choices (multiple choice question) was operating, does not test the appropriate level of operator understanding of ESF equipment operation.
The inspector verified that the R0 and SRO questions on the written examination adequately sampled the items stated in i
10 CFR 55.41 and 10 CFR 55.43.
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Report Details
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f (4) Operating Examinations The inspector determined the dynamic simulator scenarios to be well written, comprehensive, and representative of an operationally challenging series of events. They were designed to exercise the Brunswick E0Ps and the operators' understanding of integrated plant operations.
Each scenario contained complete information on simulator setup, simulator operator cues, performance objectives, grading criteria, and expected operator actions.
Crew critical tasks were well defined and consistent with Examiner Standard (NUREG-1021) guidelines.
However, the inspector found that individual and crew competency evaluation criteria as specified in Procedure TM-4.06 differed from those given in the Examiner Standards. The training department had expanded and clarified the competency areas defined in ES-604. While the inspector evaluated this initiative positively, the actual grading method appeared to be subjective in nature and could not be compared objectively to the Examiner Standard grading criteria. No weighting criteria was applied to the sub-items of each competency.
Thus, the more important sub-
competencies were evaluated equally with the less important subcompetencies. Also, each subcompetency was graded strictly as PASS / FAIL with no numerical score assigned. The facility i
evaluators were comfortable in their use and application of this unique grading technique.
Following examination administration, grading among evaluators appeared to be consistent with the performance demonstrated by the operators. The grading technique needs further evaluation through observation of its use in future examinations before any conclusion can be made on its validity.
The NRC inspector identified this item for follow-up as IFI 50-325,324/93-35-02, " Evaluate Brunswick Requalification Dynamic Simulator Examination Competency Grading Methodology As Compared To Examiner Standard Guidelines."
The training department validated eight JPMs for each cycle of examinations.
The inspector determined that each JPM consisted of a high level task selected from the facility Job Task Analysis.
The inspector also found that each JPM completely defined the task to be performed and contained prompts and cues where appropriate. The JPM tasks that could be performed on the simulator, contained simulator setup information. Steps critical to the correct performance of the task, were appropriately identified and marked in the JPM.
The inspector verified that the operating examination adequately sampled the items stated in 10 CFR 55.4,
Report Details
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Examination Administration The inspector observed that examination security was maintained by segregating and controlling the crews until they had completed their portion of the examination.
The facility licensee's examination schedule was well planned and coordinated thus minimizing undue operator stress.
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(1) Dynamic Simulator Examinations The inspector observed all crews during the conduct of this portion of the examination. Two operating crews and one staff crew were administered dynamic simulator examinations in accordance with the facility's requalification program and Procedure TM-4.06.
Each crew consisted of two SR0s, two R0s and an STA.
Each crew was evaluated by four training department instructors, and each scenario was observed by an Operations
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management representative.
Each scenario was conducted as planned, and no examination administration difficulties were encountered.
Deficiencies in scenario performance were noted by the lead facility evaluator for incorporation into a future
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revision of the scenario.
Crew and individual evaluation criteria (critical tasks) were predefined and specified in each simulator guide. Additionally, each crew and individual was evaluated against performance competency ratings as specified in Procedure TM-4.06.
Weaknesses identified during the scenarios were noted and discussed among the evaluators and then documented in crew and individual writeups.
The Operations management representative participated fully in the evaluation process. The performance standards for satisfactory completion of'the simulator examination were co-developed and concurred in by Operations. Operators and managers interviewed by the inspector indicated that performance expectations, both in the plant and on the simulator, were well defined and communicated to the staff.
The area of performance standards was considered a strength by the inspector.
One RO failed this part of the examination during the observed cycle of requal while three individuals and one crew failed during previous cycles. An adequate remediation program for these operators was defined and implemented.
(2) Walkthroughs/JPMs Each operator was administered five JPMs as part of their operating test. Two JPMs were performed on the simulator and
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three were walked through on either Unit 1 or Unit 2.
The inspector did not identify any weaknesses in this are '
a Report Details
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(3) Written Examination
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The inspector observed portions of the static and open reference written examination administration. The inspector did not
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identify any weaknesses in this area.
d.
Simulator Facility Simulator fidelity and performance was good. The inspector did not
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identify any fidelity deficiencies with the simulator.
Backlog items were being tracked, and the number of items was low.
Few of the backlog items were more than one year old.
Simulator maintenance personnel have completed 122 SSRs and 41 SMRs this year. Of the 17 outstanding SSRs and 8 SMRs, only 4 were greater than 1 year old. The simulator staff and training staff appeared to work well together thus ensuring that significant deficiencies were quickly identified and corrected.
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The inspector reviewed simulator usage and confirmed that operator
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training and retraining was a priority for simulater availability.
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Only about three percent of simulator availability'in 1993 had been utilized for non-operator related training. Of the 5832 simulator training hours available through August 1993, about 1750 hours0.0203 days <br />0.486 hours <br />0.00289 weeks <br />6.65875e-4 months <br /> (30 percent) were not required to meet training commitments and'
demonstrate the capacity for expanded training, as needed.
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Staff Training and Qualifications The inspector reviewed t'he process for certification and requalifica-tion of Training Department instructors. This process was fully documented in the NTS AI procedures listed in Enclosure 4.
The Training Manager indicated that these procedures were in the process of being upgraded and rewritten. The inspector found that the
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Brunswick instructors were trained, certified and retrained in accordance with CP&L instructions, but that the documentation and tracking of this process was incomplete and spread among several members of the training staff. The Training Manager acknowledged this observation as a recognized weakness and indicated that corrective action was in progress. The inspector considered the poor tracking of training staff qualifications and retraining as a weakness, f.
Licensed Operator Medical Records Review During this inspection, the inspector reviewed the medical records of s
Brunswick's licensed operators.' The inspector compared these records
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to the requirements of 10 CFR 55.21, 10 CFR 55.23, 10 CFR 55.25, and 10 CFR 55.33. The inspector found that biennial medical examinations were certified as being performed by a licensed physician in accordance with the guidelines given in ANSI /ANS-3.4-1983. The physician's examination determined that the eyesight of four licensed
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Report Details
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operators no longer met the minimum standards required by 10 CFR 55.33(a)(1) as measured by the standards of ANSI /ANS-3.4-1983.
However, no notification was made to the NRC of the change in licensed operator medical status.
In April 1989, the facility's physician identified one operator as needing eyeglasses to perform licensed duties while the other three operators were identified in November 1990, April 1991, and June 1992. Additionally, in April 1991, the facility licensee's physician determined that an operator's medical condition would not permit solo operation, again as measured by.the
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standards of ANSI /ANS-3.4-1983.
This is a violation of the reporting requirements of 10 CFR 55.25 and
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10 CFR 50.74 in that the facility licensee must notify the Commission within 30 days of the determination that an operator does not meet the minimum standards specified in 10 CFR 55.33(a)(1). The inspector identified the first example of the violation when the facility licensee submitted one of the operator's license renewal application.
During the inspection, the inspector found four other examples of
untimely notification to the NRC of changes in licensed operator medical status.
Inspection by the inspector determined that no other deficiencies were present in the medical records in this regard.
The inspector interviewed plant personnel to determine the cause for failure to notify the NRC upon a change in a licensed operator's medical status. He determined that corporate procedure, "CP&L.
Corporate Medical Procedure for NRC License Applications and Renewals," dated January 15, 1990, was in place for managing the
conduct and reporting of biennial medical examinations for licensed operators and applicants.
In this case, the facility's consulting physician had identified the change in the operators' medical condition following their regular biennial physical examinations and i
reported this result to the facility. However, the facility staff apparently overlooked this change in medical status and failed to
report to the NRC within the 30 day time requirement.
The inspectors found examples of previous changes in licensed operator medical status that had properly been reported to the NRC within 30 days. The NRC inspector identified this violation as VIO 50-325,324/93-35-02,
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" Licensee Failure To Report Changes In Licensed Operator Medical Status Within 30-Days As Required By 10 CFR 55.25."
The inspector also determined that two active and one inactive
licensed operators were not medically qualified in respirator usage as
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measured by the standards of ANSI /ANS-3.4-1983 and thus were i
conditionally licensed for "No Solo" operation.
Recent NRC
Headquarters' guidance has determined that this approach is not
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appropriate for handling this situation. The facility licensee plans
either to qualify medically each affected operator for respirator usage or terminate the individual's license.
i One example of one violation was identified.
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Report Details
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Exit Interview
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At the conclusion of the site visit, the inspectors met with representa-tives of the plant staff listed in paragraph I to discuss the results of
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the inspection.
The licensee did not identify as proprietary any material provided to, or reviewed by the inspectors. The inspectors further i
discussed in detail the inspection findings listed below. Dissenting
comments were not received from the licensee.
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Item Number Description and Reference
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IFI 50-325,324/93-35-01 Inspector follow-up item regarding dynamic simulator competency grading methodology (paragraph 2.b.(4)).
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i VIO 50-325,324/93-35-01 Licensee failure to report changes
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in licensed operator medical status I
within 30 days as required by 10 CFR 55.25 (paragraph 2.f).
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4.
List of Acronyms and Initialisms CFR Code of Federal Regulations
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E0P Emergency Operating Procedure ES Examiner Standards
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ESF Engineered Safety Feature IFI Inspector Follow-up Item
JPN Job Performance Measure NRC Nuclear Regulatory Commission NTS AI Nuclear Training Section Administrative Instruction
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R0 Reactor Operator RPV Reactor Pressure Vessel
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SMR Simulator Modification Request i
SRO Senior Reactor Operator SSR Simulator Service Request STA Shift Technical Advisor l
TM Training Memorandum
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VIO Violation
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ENCLOSURE 3
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SIMULATOR FACILITY REPORT
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Facility Licensee: Brunswick I and 2
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Facility Docket Nos.:
50-325 and 50-324
Operating Tests Administered on:
September 13 - 14, 1993
This form is to be used only to report observations. These observations do not constitute, in and of themselves, audit or inspection findings and are
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not, without further verification and review, indicative of noncompliance with 10 CFR 55.45(b). These observations do not affect NRC certification or
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approval of the simulation facility other than to provide information that may be used in future evaluations.
No licensee action is required solely in y
response to these observations.
'j While conducting the simulator portion of the operating tests, the following items were observed.
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ITEM DESCRIPTION
No simulator fidelity weaknesses were identified.
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ENCLOSURE 4 l
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00CUMENTS REVIEWED t
Document-Revision Number Number /Date Title
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01/15/90 CP&L Corporate Medical Procedure for NRC
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License Applications and Renewals NTS AI-11C
Evaluation of Instruction and Instructional Materials NTS AI-18A
Instructor Certification Program I
NTS AI-18B
Instructor Continuing Training Program i
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NTS AI-25
CP&L-Certified Senior Reactor Operator (SRO) Instructor Certification and i
Training Program
I TI-200
Brunswick Plant Operator Retraining Program TM-1.02
Maintenance of Accredited Training
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Programs
TM-1.04
Training Material Development and
Maintenance i
TM-1.05
Student Counseling and Remedial Training
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TM-1.06
Receipt, Evaluation, Disposition, and Documentation of Information Affecting Training Programs TM-1.07
Training Examination Policy
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TM-4.01
Licensed Operator Retraining Program
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TM-4.04
Guidelines for Simulator Training l
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TM-4.06
Development / Administration / Evaluation of i
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Licensed Operator Requalification (LOR)
Exams
i TM-4.09
Operator On-the-Job Training (0JT)
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