IR 05000331/1998020
| ML20198N861 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/29/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20196K226 | List: |
| References | |
| 50-331-98-20, NUDOCS 9901060237 | |
| Download: ML20198N861 (22) | |
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. U. S. NUCLEAR REGULATORY COMMISSION REGIONlil Docket No: 50-331 License No: DPR-49 Report No: 50-331/98020(DRS)
Licensee: Alliant, IES Utilities In Facility: Duane Arnold Energy Center Location: Palo, Iowa
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Dates: November 30 through December 4,1998 Inspectors: H. Peterson, Lead Inspector '
D. Calhoun, Reactor inspector j Approved by: M. Leach, Chief, Operator Licensing Branch j I
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9901060237 981229 '
> PDR ADOCK 05000331-G
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EXECUTIVE SUMMARY Duane Amold Energy Center NRC Inspection Report 50-331/98020 i This inspection report contains the findings and conclusions from the inspection of the Licensed
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Operetor Requalification Training (LORT) program. The inspection included a review of training l procedures and operating examination material, observation and evaluation of operator performance and licensee evaluators during a requalification operating examination, an ;
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L : assessment of simulator fidelity, an evaluation of program controls to assure a systems
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approach to training, and a review of requalification training records. The inspectors used the
' guidance in inspection procedures (IP) 71001 and 7170 l
. Operations 1
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The inspector considered the implementation of an end of shift $ -iefing as a positive practice. The inspectors concluded that the control room activities were conducted in a i professional manner; however, the inspectors noted that operators were not aware of two abnormal plant indications until identified by the inspectors. (Section 01.1)
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Overall, the two operating crews passed the operating portion of the requalification l
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examination; however, one SRO and two ROs failed the written examination. During the dynamic simulator examination, the inspectors concluded that the operators adequately ,
executed their duties in a safe manner during abnormal and emergency conditions in l accordance with station procedures and management expectations. Also, the inspectors determined that the licensee's evaluators effectively assessed the operators
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by properly observing the operators' performance and documenting all identified operator weaknesses. Although some weaknesses were noted pertaining to command j and control, and crew communications, the aggregated individual performance i deficiencies did not adversely impact the crew's ability to implement necessary I mitigating actions to safely control the pirt during emergencies. (Section 04.1) l I
Trainina Proaram
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The inspectors concluded that licensed operators, in the past, had demonstrated performance deficiencies pertaining to procedure adherence, attention to detail, and questioning attitude. However, the licensee effectively re-enforced these attributes in the licensed operator continuing training program. Subsequently, these corrective actions have resulted in recent safety conscious operations by the operators. (Section 05.1)
. The inspectors concluded that the requalification examination material generally contained the necessary quantitative and qualitative attributes to provide an effective evaluation of operator skills. However, two job performance measures were not l sufficiently challenging to discriminate between a competent and less than competent operator. In addition, the licensee satisfactorily incorporated current industry events applicable to the facility into the licensed operator requalification training and testin (Section 05.2)
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The inspectors concluded that the annual requalification examinations were generally administered according to program guidance and were consistent with regulatory guidelines. However, the inspectors identified minor program deficiencies pertaining to
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the requalification examination. The inspectors concluded that the licensee had l
adequately maintained examination security, even though some minor program deficiencies were noted. Therefore, these minor programs deficiencies constituted a violation of minor significance and were not subject to formal enforcement actio (Section 05.3)
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The inspectors determined that the licensee's feedback process was satisfactorily implemented. Good, self-critical audits were conducted by the licensee which provided i constructive feedback into both the initial license operator training and licensed operator requalification training programs. (Section 05.4)
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The inspectors concluded, in general, that the remediation program contained adequate l measures to ensure individual and crew performance weaknesses were identified, l
assigned, remediated, and properly addressed prior to resumption of licensed dutie However, the inspectors identified that the program had previously failed to adequately I administer comprehensive remedial retake written examinations to operators who had failed the licensed operator requalification training written examination. The licensee !
had implemented satisfactory corrective actions and was now administering proper l comprehensive retake examinations. The failure to conduct and pass a comprehensive written requalification examination constituted a violation of minor significance and was not subject to formal enforcement action. (Section 05.5)
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The inspectors concluded that the operators' license conditions were in conformance with program guidance and regulatory requirements. (Section 05.6)
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The inspectors concluded that the licensee had satisfactorily addressed and corrected previously identified Licensed Operator Requalification Training program weaknesse l (Section O5.7) l
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The plant specific control room simulator provided consistent and realistic plant response under normal, abnormal, and emergency conditions. (Section 05.8)
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The inspectors concluded that the licensee had a satisfactory program for identifying !
and tracking licensed operators who require corrective lens for use with respirators, j (Section 08.1)
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. Report Details 1. Operations
01 Conduct of Operations 1 j
01.1 General Comments l Inspection Scope (71707; Using the guidance of Inspection Procedure 71707, " Plant Operations," inspectors observed routine control room activities during full power operations. The inspectors performed a panel walk-down, reviewed control room logs and documents, questioned ;
operators about plant and equipment status, and attended a shift turnover and two shift briefings (two 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift operating crews, morning and evening). The following procedure was reviewed:
. Administrative Control Procedure (ACP)-1410.1, " Conduct of Operations," !
Revision 18, October 24,199 l l Observations and Findinas The inspectors found that the shift briefings were conducted by the Shift Manager and held in the control room panel area. All operators, including outside non-licensed operators, attended the shift briefing. The inspectors observed that the Station Manager attended the moming shift briefing. In general, 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 implemented, on a trial basis, an end of shift crew briefing. The inspectors found that this end of shift briefing allowed the operators to discuss and update the day's activities prior to the shift turnover to assure that the most recent and correct information was turned over to the on-coming ;
crew. In general, this activity appeared to be a good practice in crew communication During the control room observations, the inspectors noted that the operators properly l acknowledged and responded to alarms. The operators rarely left an annunciator 1 alarming. When asked by the inspectors, the control room operators promptly answered questions and were knowledgeable of plant conditions. However, following the control room panel walk-down and log review, the inspectors identified two minor discrepancie A breaker status light was not illuminated, therefore, the inspectors could not determine if the condition indicated a burned out light condition or an apparent abnormal breaker configuration. Also, an incorrect pressure indication was logged in the outside operator's logs. The operators were informed and both items were quickly correcte l l
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? Conclusions The inspector considered the implementation of an end of shift briefing as a positive practice. The inspectors concluded that the control room activitias were conducted in a professional manner; however, the inspectors noted that operators were not aware of I two abnormal plant indications until identified by the inspector !
-04 . Operator Knowledge and Performance - l 04.1 Annual Evaluation Performance Review ~ Inspection Scope (71001)
The inspectors reviewed the performance of two operating crews during the annual licensed operator requalification operating examination. The crew consisted of a shift manager and a shift supervisor who were licensed senior reactor operators (SRO), three control room operators who were licensed reactor operators (RO), and a shift technica! l advisor (STA). Each crew was evaluated on two simulator scenarios on the plant I specific simulation facility and on five job performance measures (JPM). The evaluation referenced the following procedure . NUREG-1021, " Operator Licensing Examination Standards for Power Reactors," i interim Revision 8, June 199 .- Training Department A'dministrative Procedure (TDAP)-1830.4, " Licensed Operator Requalification Program Description," Revision 2, May 18,199 . Operations Training Instructions (OTl)-105, " Licensed Operator Requalification ,
Examination Administration," Revision 6, November 24,199 j l
' Observations and Findina Both operating crews successfully completed each critical task as identified in the dynamic simulator scenarios. In addition, all ten licensed operators successfully passed the JPM portion of the operating examination. The licensee's evaluation team assigned a passing grade for each licensed operator's performance during the operating portion of the annual requalification examination. Although alllicensed operators passed the l operating examination, three licensed operators (two ROs, and one SRO) and two STAS failed the written portion of the annual requalification examinatio During the dynamic simulator examination, the inspectors noted that both crews i conducted frequent and generally well coordinated crew briefs. Communications were, I
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in general, good with one crew displaying good three-way communications. One crew also demonstrated good peer checks during the performance of a surveillance test, but the other crew did not perform any peer checks. Peer checks were encouraged, but were not required per procedures. In general, both crews performed satisfactoril _ _ _
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However, the inspectors observed individual performance weaknesses by a few operators during the dynamic simulator examination. The shift supervisors demonstrated weaknesses in command and control, communications pertaining to the exchange of plant parameter information, and appropriateness of crew brief The inspectors found that periodic crew briefings conducted by the shift supervisor were, in general, clear. The shift supervisor presented appropriate information and directions to the crew. However, several of the briefs were held at inopportune times when operators were involved in performing mitigating actions per the emergency procedure Crew communications, at times, were informal and fragmented. Several communications between operators were made without completing the third leg of the three way communications. However, the messages were generally relayed and understood to complete the tasks at hand. Also, some informal communications were I made without clear and specific directions. For example, while the primary plant i conditions were degrading, rather than specifying the need for specific parameters, the i shift suprisor requested plant parameters by stating, "How's the containment doing?"
l The inspectors identified two shift supervisors that demonstrated some weaknesses in 1 command and control. During the simulator scenario examination, the expectation was I that the shift supervisor was responsible to implement the emergency procedures and direct mitigating actions of the reactor operators. However, one shift manager was constantly overseeing the shift supervisor's command and control of the crew and the implementation of the emergency procedures. On a few occasions this shift manager coached the shift supervisor on the use of the emergency procedures. For example, during a reactor coolant system leak on the reactor water cleanup system that prompted a high temperature condition and entry into the secondary containment control emergency procedure, the shift manager interjected to direct the monitoring of temperatures and directed the shift supervisor to scram the reactor. Although the shift supervisor appeared to be adequately following the emergency procedures, he lacked assertiveness and displayed weak command and control over his crew. This led the shift manager to interject to assure that timely mitigating actions were taken by the operator These findings were all adequately identified by the licensee's evaluators. Individual operator performance weaknesses for two of the ten licensed operators were appropriately identified and documented during the dynamic simulation evaluation. The licensee also indicated that additional actions would be taken to enhance the performance of the two shift supervisors. Although some weak performances were noted, in general, the operators as a team were able to safely control the plant during the emergencie In general, the licensee's findings and conclusions on the crew's performance during the dynamic simulation evaluation agreed with the inspectors' overall assessmen Conclusions Overall, the two operating crews passed the operating portion of the requalification examination; however, one SRO and two ROs failed the written examination. During the
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- dynamic simulator examination, the inspectors concluded that the operators executed
~ thelr duties in a safe manner during abnormal and emergency conditions in accordance with station procedures and management expectations. Also, the inspectors determined
' that the licensee's evaluators effectively assessed the operators by properly observing <
' the operators' performance and documenting all identified operator weaknesse Although some weaknesses were noted pertaining to command and control 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 emergencies.-
05 Operator Training and Qualification 05.1. Operatina History Inspection Smoe (71001)
i The inspectors reviewed the plant's operating history from December 1996 to November i 1998 to determine if any operator errors occurred that could be attributed to ineffective or inadequate training. The inspectors reviewed the following documents to assess the licensed operator requalification training program's effectiveness regarding operator performance:
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Requalification inspection Report No. 50-331/9601 .
Systematic Assessment of Licensee Performance (SALP) Report No. 50 -
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Licensee Event Reports (LERs) for the 1998 calendar yea .
Duane Arnold Plant Performance Review covering the period of April through September 199 .
Duane Amold Plant issues Matrix covering the period of December 1996 through November 199 .
Operator performance during the October 12,1998, Emergency Preparedness Exercis Observations and Findinas As a result of the inspectors' review of the above documents, the inspectors determined that the operators had demonstrated deficiencies in the area of procedure adherence, attention to detail, and questioning attitude. The inspectors noted that the licensee had generally addressed these deficiencies in the licer sed operator continuing training program. The training program appropriately addressed these previously identified weaknesses. The licensee provided appropriate training to enhance operator awareness of problems and on lessons leamed from significant industry event _ _ _
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i$ c.' Conclusions The inspectors concluded that licensed operators, based on the review of past documents, had. demonstrated performance' deficiencies pertaining to procedure ,
adherence, attention to detail, and questioning attitude. However, the licensee i effectively re-enforced these attributes in th'e licensed operator continuing training program. Subsequently, these corrective actions have resulted in recent safety conscious operations by the operator !
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05.2 Reaualdication Examination Material ,
a.' inspection Scoos (71001) !
The inspectors reviewed the written and operating examination material with Appendix A !
checklists in Inspection Procedure 71001. This review included a comparison of written )
questions, dynamic scenarios, and job performance measures (JPM) with previously administered examinations. The inspectors also reviewed the licensee's program to
assess and incorporate current industry events applicable to the facility into training and testing. The following procedures were reviewed:
. . OTI-104, " Licensed Operator Requalification Exam Preparation and Development," Revision 4, July 18,199 . .TDAP No.1830.4," Licensed Operator Requalification Program Description," i Revision 2, May 18,199 I 1 Observations and Findinas The inspectors identified that the licensee, as part of the requalification program description, developed separate examination material for each of the five weeks of the i annual requalification examination cycle. The inspectors also found that the licensee developed a separate examination sample plan for each examination. The inspectors determined that the examination sample plan, at a minimum, included the learning objectives referenced in the licensed operator requalification training two-year plan. The I sample plan also required that all test items have an NRC knowledge and abilities (K/A)
value of 3 or greater, and that the examination included recent safety-related issues and events. For this examination week, the licensee had developed two scenarios and five JPMs (four common and one specifically for the SRO and RO) for the requalification annual examinatio The two dynamic simulator scenarios were comprehensive and provided sufficient quantitative attributes to evaluate the crew and individual members on safety significant tasks and competencies. The inspectors determined that the scenarios were generally challenging. Also, the scenario objectives incorporated probabilistic risk assessment significant events in the examination proces '
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The five JPMs contained adequately stated critical steps and termination criteria required for successful completion. However, the inspectors noted that two of the JPMs were very short and very simple to perform. As a result, the inspectors determined that the )
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JPMs were not adequately challenging. For example, the JPM to bypass a failed local power range monitor (LPRM) only had one critical step which was to place the mode selector switch for the failed LPRM in the bypass positio The written examination questions were operationally orientated and contained the appropriate level of difficulty. The static examination questions made good use of the simulator as a reference; however, a few of the questions were less challenging. Also, the inspectors noted that some question distractors required enhancements. For example, a few questions had distractors with multiple items, whereby knowing one part of the answer eliminated two of the four distractors. Subsequently, this left the operator with a 50% chance to guess the correct answer. But, in general, the open reference questions were of a higher cognitive knowledge leve The inspectors identified that the licensee's training program required that each exam shall be at least 75% different from the previous weeks' exams. The inspectors determined that the written examination administered during the inspection period adequately met the material repetition requirement. Also, the inspectors found that no simulator scenarios and only two JPMs were repeated during the five weeks of the requalification examination cycl The inspectors reviewed several lesson plan outlines for the requalification examination cycle and determined that the licensee had been incorporating industry events into the lesson plans. The events included NRC issued daily reports, significant operating event reports (SOER), and site specific problems and events which addressed some previously identified operator deficiencie Conclusions The inspectors concluded that the requalification examination material generally contained the necessary quantitative and qualitative attributes to provide an effective evaluation of operator skills. However, two job performance measures were not sufficiently challenging to discriminate between a competent and less than competent operator. In addition, the licensee satisfactorily incorporated current industry events applicable to the facility into the licensed operator requalification training and testin .3 Reoualification Examination Administration Practices Inspection Scope (71001)
The inspectors interviewed operations and training staff personnel, and reviewed the licensee's examinction practices, including proper conshtion to examination administration, evaluation, and security. The inspectors observed the licensee's evaluators during the dynamic simulator scenarios and JPMs. The crews consisted of five licensed operators (two SROs and three ROs) and one STA. Each crew was
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I required to perform two' dynamic scenarios and a set of five JPMs. The inspectors I attended both the crew evaluation critiques and crew debriefs. The inspectors also observed the licensee administer and proctor the written requalification examinatio The following procedures were reviewed:
. TDAP-1830.4, " Licensed Operator Requalification Program Description,"
- Revision 2, May 18,199 . OTI-104," Licensed Operator Requalification Exam Preparation and
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Development," Revision 4, July 18,199 i
. OTI-105," Licensed Operator Requalification Examination Administration,"
Revision 6, November 24,199 Observations and Findinos i The inspectors determined that both crews performed satisfactorily during the dynamic simulation examination; however, the second crew appeared to demonstrate minor deficiencies in some areas. The inspectors determined that the individuals'
performance, as the shift supervisor, in the area of command and control was acceptable; however, the inspectors noted several deficiencies by the shift supervisor which indicated some improvement was needed in this area. In general, the licensee's evaluation team identified no unsatisfactory crew performance. However, the licensee's evaluators appropriately documented that two operators were identified as having demonstrated weak performance during the dynamic simulator scenarios. (See Section
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' During the JPM portion of the operating examination, the inspectors observed that the ;
- licensee's evaluators performed the examination administration in a professional manner j and properly documented operator performance. No evaluator m!scuing or prompting
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was identified. All operators satisfactorily passed the JPM examinatio j
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During the written examination, the inspectors determined that the licensee's proctors ensured appropriate examination security was maintained. For example, the proctors initiated actions to prevent operators from potentially compromising the exam material by prohibiting two operators from being in the back of the control panels at the same tim The proctors ensured that operators covered their respective exam material when leaving their assigned test area to review references or verify control panel indication Additionally, the proctors ensured that the operators maintained adequate distance between applicants as they concurrently reviewed similar reference material and control room board indication The inspectors found that appropriate security measures were taken throughout the examination process. Individual operators were sequestered and separated into test groups during each portion of the examination process. No examination compromise was identified. In general, the licensee's conduct of examination security during development and administration of the requalification examination was satisfactory;
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I however, the inspectors identified examples where the licensee's practice was not in compliance with OTI-104, OTI-105, and did not meet the Intent of 10 CFR Part 55.49 and
.NUREG 1021, Section ES-601. The inspectors determined that the following examples for failure to meet the requalification training program requirements were considered a minor violatio (1) The inspectors determined that the licensee was allowing individuals (instructors)
to develop exam material without requiring them to be on the exam security agreement. The licensee informed the inspectors that the individuals did not know exactly which week their developed exam material would be use Therefore, the licensee did not consider that the exam material could be compromised. However, the inspectors informed the licensee that once individuals were knowledgeable of the specific examination material to be used for the examination, they needed to be on the security agreement. The .
inspectors recognized that continued maintenance of the examination bank to develop new or revise existing questions was an integral and expected part of the licensed operator training progra (2) The inspectors identified that one of the simulator evaluators had not signed onto the examination security agreement as required by OTI-105. The examination coordinator had the responsibility to ensure all individuals who have knowledge of '
what was on the examination are documented as being on examination securit However, during the inspectors' review of the " Exam Security Record," that was in effect for the simulator evaluation, the inspectors identified that the operations ,
manager had not signed the security agreement. The operations manager should have signed the security agreement because he was involved in the evaluation of both crews. After his assessment of the first crew, prior to the second crew being sequestered, he was privy to exam material which necessitated the implementation of exam security measure ,
(3) The inspectors identified that certain precautions required by OTI-104 for validating simulator scenarios and actual administration of the requalification i examination were not consistently being performed. The inspectors identified the
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following deficiencies:
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. The licensee had three ingress / egress doors to the simulator which were maintained locked during exam validation and administration; however, the licensee routinely only posted two of the doors because the licensee considered these two doors as the normal access points to the simulato The operations training manager did not post the third door because he did not consider the door as a normal access point. He stated that the
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door was only utilized during construction of the simulator to allow an entry point for large pieces of equipment. Also, the operations training i
manager had initially informed the inspectors that only one individual had access to the key for that door which also supported the need to not post
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the door. However, after further questioning by the inspectors, the licensee subsequently identified that control of the key had not been
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maintained. The licensee identified that an additional five keys had been issued to various site personnel and several of them were unaware that they had the key for this simulator doo .
The licensee was not routinely deleting the computer backtrack files and logging an entry of the file deletions for the simulator scenario examination material during exam validation. The licensee informed the inspectors that these actions were not necessary to maintain exam security because it was not known when the validated simulator evaluations would be used in the exam requalification cycle. Again, the inspectors informed the licensee that tne lack of exam security requirements in this case was inappropriat Conclusions The inspectors concluded that the cnnual requalification examinations were generally administered according to program guidance and were consistent with regulatory '
guidelines. However, the inspectors identified minor program deficiencies pertaining to the requalitication examination. The inspectors concluded that the licensee had adequately maintained examination security, even though some minor program deficiencies were noted. Therefore, these minor programs deficiencies constituted a violation of minor significance and were not subject to formal enforcement actio .4 Reaualification Trainina Proaram Feedback System Inspection Scope (71001)
The inspectors interp , d operations, training, and quality assurance personnel, and reviewed the ic!!owin, 9er'Jments to assess the licensee's training program feedback system effectivenes .
Operator Training Comprehensive Self-Evaluation Team Report, January 8-16, 199 .
Quality Assurance Audit, Operations & Emergency Planning Assessment Team -
Third Quarter Rsport, Training and Qualifications, Subject: Conduct of Operations Trainin Quality Assurance Audit, Operations Assessment Report Module - Fourth Quarter 1998, Subject: Licensed Operator Requal - Examination Proces Observations and Findinas The licensee performed self-assessment activities by assessing identified individual operator and crew weaknesses, operator training requests, and plant and industry events. Additional self-assessment processes included course evaluations, instructor evaluations, cassroom feedback, simulator evalua' ions and critiques, and on-the-job
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training evaluations. Also, the licensee's Quality Assurance group performed periodic audits of the Operations and Training programs. Subsequently, the training department 1 gathered, evaluated, and assigned priorities to the results of all the self-evaluations, l including those conducted by the Quality Assurance group. One significant theme identified through the self-assessment audits was the lack of adequate management oversight of operator training. The audits recommended that shift managers should be in l attendance at follow-up meetings and in discussions as to the corrective actions for I remediation of weak or unsatisfactory individuals in their respective crew. The training self-assessment indicated that there was a lack of adequate training management :
oversight for ensuring completion of RO and SRO training program requirement l The inspectors received self-critical inputs from licensed operators, instructors, and Quality Assurance staff members interviewed on the feedback process. The inspectors determined that licensee's self-assessment program was up to date and flexible enough to incorporate emerging training issue l Conclusions The inspectors determined that the licensee's feedback process was satisfactorily implemented. Good, self-critical audits were conducted by the licensee which provided constructive feedback into both the initial license operator training and licensed operator requalification training program .5 Remedial Trainina Proaram Insoection Scope (71001)
The inspectors reviewed the licensee's remedial training program and selected records to assess corrective actions for identified weaknesses in operator and crew performance. This review included an interview with selected personnel involved with the remedial training process. The following documents were reviewed:
. TDAP 1801.2," Conduct of Training," Revision 4, August 25,199 . TDAP 1830.4, " Licensed Operator Requalification Program Description," Revision 2, May 18,199 . Simulator Crew Evaluation Form, OTI 105, Attachment 1 . Operator Dynamic Grading Worksheet, OTl 105, Attachment j
. Completed Remediation Packages for Five Licensed Operator Observations and Findinas During this annual requalification examination cycle a total of six (5 ROs 6nd 1 SRO) out of 48 licensed operators examined failed the wntten examination. Three RO failures had I i
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occurred during the previous examination weeks, and 2 ROs and 1 SRO failed during l the inspection period. The last week of the examination cycle had no operator failure l The inspectors determined that selected remedial training plans had incorporated a comprehensive retraining and evaluation process, and were consistent with the licensee's assessment of operator's poor performance. The licensee acknowledged that the written examination failures were potentially attributed to a recent revision in
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examination question difficulty which made each one more operationally discriminatin ,
! The inspectors noted that the licensee had developed remedial training plans for ,
individuCs who demonstrated weaknesses and required successful completion of the I remedial vaining prior to resuming license duties. The remedial training program
! properly Mentified and corrected licensed operator performance deficiencies.
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Regarding written examination failures,10 CFR 55.59(a)(2) required each operator to !
pass a comprehensive written examination associated with the requalification progra )
l The inspectors identified that in the past, circa 1996, remedial retake examinations for i l operators who had failed the written examination only covered the minimal areas of l
! demonstrated individual weaknesses. Operators who failed the comprehensive written l requalification examination (approximately 25 to 40 questions), consisting of both Part A, '
" Plant and Control Systems," static simulator examination, and Part B, "Adrninistrative Controls / Procedural Limits," examination, were administered only a 15 question classroom examination for their remedial retake. The inspectors determined that the l partial remedial retake examinations were ineffective tools for evaluating the overall competency of an operator. The inspectors concluded that the licensee's partial retake examination did not meet the requirement of 10 CFR 55.59(a)(2) to pass a comprehensive written examination, when the operators were only required to complete a shorter, less comprehensive retake examination. This issue was considered a minor violation of NRC requirement The inspectors identified, through reviews of recent remediation documentation, that the licensee had changed the remedial re-examination process. The licensee was adequately remediating the operators who failed the comprehensive written examinatio The remediation included training and retest of the demonstrated weaknesses over the objectives missed. The licensed operator who failed the written examination was then given an overall comprehensive retake examination consisting of both Parts A and B with j
a comparable number of question Subsequent to the review of the licensee's remedial re-examination changes, the inspectors identified that the licensee's procedure TDAP 1830.4 was recently revised on ;
l May 18,1998. This new procedure revision incorrectly noted that individual failures of l- either the Part A or Part B of the comprehensive written examination, could be l remediated and re-examined only on the specific area of the failed examination (i.e., Part l' A or Part B only). This discrepancy between the correct implementation of the j comprehensive retake examination compared to the incorrect program description was
- relayed to the licensee. The licensee acknowledged the differences and noted that the procedure would be revised to reflect actual practice, i
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The inspectors concluded, in general, that the remediation program contained adequate !
measures to ensure individual and crew performance weaknesses were identified, !
L assigned, remediated, and properly addressed prior to resumption of licensed dutie l l However, the inspectors identified that the program had previously failed to adequately I administer comprehensive remedial retake written examinations to operators who had l l failed the Licensed Operator Requalification training written examination. The licensee 1 had implemented satisfactory corrective actions and was now administering proper [
comprehensive retake examinations. The failure to conduct and pass a comprehensive written requalification examination constituted a violation of minor significance and was i not subject to formal enforcement actio .6 Conformance with Ooerator License Conditions
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( Inspection Scooe (71001)
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i The inspectors reviewed the licensee's medical and operator q liification programs, and l selected records to assess licensed operator compliance with regulatory requirements.
l This review included a small sampling (two operators) of the available medical records and schedules of the past and pending operator medical examinations. The following procedures and documents were reviewed: i
. Operations Department Instruction (ODI)-009, " Reactor Operator, Senior Reactor l Operator, and Shift Technical Advisor Qualification Requirement," Revision 9, dated March 17,1998.
! . 001-009, Attachment 1,"RO/SRO Reactivation Record."
. ODI-009, Attachment 7, " Quarterly Watchstanding Record." ! Observations and Findinas - ,
i The inspectors determined that the licensee maintained proper control of the operators to ensure that only active ROs, SROs, and STAS stood watch stations. Through review of procedures and interview with the operations shift manning coordinator, the inspectors I determined that the ROs could only obtain credit for maintaining an RO license by l standing watch in one of three RO positions (the Nuclear Station Operating Engineer, and the two Assistant Nuclear Station Operating Engineer. The SROs were credited for j standing watch in two positions (Shift Manager or Shift Supervisor). The inspectors also reviewed a sample of RO and SRO quarterly watch standing records, that recorded the number of hours the operator stood watch, and did not identify any problems. Also, the inspectors sampled a number of medical reports and determined that the licensee was effectively ensuring that operators were physically fit to stand watc ,
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' c. - Conclusions The inspectors concluded that the operator's license conditions weru in conformance with program guidance and regulatory requirement .7 Follow-uo of Previousiv identified Weaknesses
, Inspection Scope C1001)
-The inspectors reviewed the identified weaknesses from the last LORT program inspection (NRC Inspection Report 50-331-96012) to ascertain the licensee's actions to
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. resolve the weaknesse Observations and Findinas During the previous LORT program inspection, one significant weakness was identifie <
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The weakness was associated with the remedial training program. The inupection repost noted that the weaknesses associated with the remedial training program included informal remedial training with the same generic material for all operators who failed. The most significant example was related to the remedial retake of the comprehensive written examination. (See Section 05.5 for additional details.)
The above weaknesses were effectively reviewed by the licensee. Corrective actions were implemented to address the weaknesses, including formalized remedial training ;
program. The licensee had appropriately addressed individual performance weaknesses by developing remediation packages based on specific examination j objectives misse . Conclusions
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The inspectors concluded that the licensee had satisfactorily addressed and corrected the previously identified licensed operator requalification training program weaknesse .8 Simulator Fidelity l - Inspection Scooe (71001)
..The inspectors reviewed the effectiveness of the licensee to identify and correct j- simulator discrepancies, and noted any simulator fidelity issues identified during the
- - operating examination, <
i; , Observations and Findinas L
The inspectors observed that the simulator performed the required component
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malfunctions and provided realistic plant response to changing conditions during normal and emergency events. No simulator fidelity concerns were identified. (See Attachment 1," Simulation Facility Report.") j i
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l Conclusions The plant specific control room simulator provided consistent and realistic plant response I under normal, abnormal, and emergency condition Miscellaneous Operations issues 1 08.1 Resoirator Fit Proaram Insoection Scope (71001)
The inspectors interviewed operations and training staff personnel and reviewed the i I
licensee's procedure describing the control methods used to maintain the operators'
need for corrective lens for use with respirator . Operating Order 98-133-1," Operator License Restrictions," November 17,199 Observations and Findinas
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The inspectors interviewed the operations shift manning coordinator regarding the j station's methods for identifying and tracking licensed operators who require corrective '
lens for use with respirators. The operations shift manning coordinator informed the l Inspectors that she maintained the list of licensed operators requiring corrective len She further stated that Operating Order 98-133-1 was issued identifying and tracking those current corrective lens users. The inspectors verified that corrective lens were available for the required licensed operators. No concerns were identified by the inspector Conclusions The inspectors concluded that the licensee had a satisfactory program for identifying and tracking licensed operators who require corrective lens for use with respirator .2 Followuo on Past insoection items (1) (Closed) Unresplved item 50-331/96012-01: Inadeauate comorehensive remedial written reaualification examination. The inspectors determined that the partial remedial retake examinations were ineffective tools for ovaluating the overall competency o' an operator. The inspectors concluded that the licensee's partial retake examina: ion did not meet the requirement of 10 CFR 55.59(a)(2) to i pass a comprehensive written examination, when the operators were only required to complete a shorter, less comprehensive retake examination. This issue was considered a minor violation of NRC requirements. This item was l closed. (See Section 05.6 for additional details.)
(2) (Closed) Unresolved item 50-331/98006-03: Inadeauate 50.59 screenina for takino RMCS out-of-service durina oower ooerations. A 50.59 screening l
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! correctly identified that a safety evaluation for the Rod Manual Control System (RMCS) modifications was not required. However, no 50.59 screening j addressed removal of the RMCS from service during plant power operation. The inspectors concluded that further inspection was required to determine if a violation of 10 CFR requirements had occurred. After further review, it was concluded that a 50.59 screening was not required. This item was close (3) (Closed) Inspection Followuo item 50-331/98301-01: Potential orocedural weaknesses for Emeraency related orocedures. The inspectors observed operator performance during the annual licensed operator requalification dynamic simulator examinations. The shift managers satisfactorily performed the emergency classification and protective action recommendation. The operators were familiar with the procedural requirements for noting the higher level classifications on the notification forms even though the plant conditions were i mitigated which no longer supported the higher classifications. Additionally, the inspectors reviewed the licensee's updated operator requalification in-plant j exercise guide (98C5) pertaining to Rod insertion Procedure (RIP) 103.4, " Vent !
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Individual CRD Exhaust Lines." This guide specifically addressed the use of the 1
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special venting connection device to the radwaste drain. The licensee informed i the inspector of the planned implementation of the procedural update to RIP
' 103.4. This item was closed, i l
- (4) (Closed) Insoection Followuo item 50-331/98301-02: Licensed operator l oerformance weaknesses durina dynamic simulator scenario verification were considered safety sianificant. During the July 1998 initial license examination, the ,
licensed operators who supported the dynamic simulator scenario validation !
demonstrated severa performance weaknesses. The most significant of these )
{ weaknesses: (1) failure to communicate critical instrument readings to the SRO,
(2) failure to detect an ATWS, and (3) the SRO's inability to correctly implement
- the EOPs. Subsequently, the licensee performed remedial training prior to retuming the three licensed operators to duty. The inspectors reviewed the
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remedial training documentation and found it adequate. During the annual i licensed operator requalification examination, the inspectors were able to
} observe and evaluate the performance of the same three operators. The three
- - operators performed adequately; however, deficiencies were still noted for the two SROs. The deficiencies included weak command and control, and j communications. Although deficiencies still existed, the crews' overall
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performance was satisfactory to pass the requalification examination. The i licensee's evaluators noted the same deficiencies and indicated that the training department would focus additional attention on these deficiencies to determine i the necessary action to t ince the operators' performance. This item was
! closed. (See Section 04 ? / additional details.)
i (5)- (Ocen) Inspection Followuo item 50-331/98301-03: Operational adeauacy of licensee's operators and trainina staff to oroperly recoanize and acolv th_g j Imoroved Technical Soecification LCOs. During the July 1998 initial license examination, the ability of applicants to properly recognize and apply the
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improved technical specification (ITS) limiting condition for operation (LCO),
4 during both the dynamic simulator and JPM examinations, was considered a notable weakness. This demonstrated weakness in ITS interpretation and application appeared to affect both the applicants and the training staff. The j issue on ITS use and understanding was considered an inspection follow-up item t
pending the upcoming operator license requalification program inspectio I During the requalification inspection, the inspectors noted that the licensed l
l operators performed satisfactorily pertaining to the use and understanding of IT However, the inspectors did not identify any changes in the initial license training l program to assure that new applicants for operator license were adequately I
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being trained on ITS. This item was considered still open pending further review l of initial training and applicant performance on the next initial operator license examinatio V. Manaaement Meetinas l l
X1 Exit Meeting Summary l
The inspectors presented the inspection results to members of licensee management at the !'
conclusion of the inspection on December 4,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie ;
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PARTIAL LIST OF PERSONS CONTACTED :
Licensee J. Franz, Vice President Nuclear D. Wilson, Assistant Vice President Nuclear l G. Van Middlesworth, Plant Manager l K. Young, Manager, Nuclear Training
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D. Curtland, Operations Manager M. Davis, Operations Training Supervisor ,
K. Peveler, Manager, Regulatory Performance I K. Morgan, Quality Assurance ,
T. Allen, Operations Shift Manager G. Thullen, instructor, Exam Developer M. Pettengill, Lead Instructor l
NRC P. Prescott, Senior Resident inspector M. Kurth, Resident inspeator i
INSPECTION PROCEDURES USED IP 71707: Plant Operations IP 71001: Licensed Operator Requiification Program Evaluation IP 92901: Followup - Operations ITEMS CLOSED AND DISCUSSED Closed Unresolved item 50-331/96012-01: Inadequate comprehensive remedial written requalification examinatio . Unresolved item 50-331/98006-03: Inadequate 50.59 screening for taking RMCS out-of-service during power operatio . Inspection Followup Item 50-331/98301-01: Potential procedural weaknesses for Emergency related procedure . Inspection Followup item 50-331/983G1-02: Licensed operator performance 1 weaknesses during dynamic simulator scenario verification were considered safety significan Discussed Inspection Followt; Item 50-331/98301-03: Operational adequacy of licensee's operators and training staff to properly recognize and apply the improved Technical Specification LCO I
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LIST OF ACRONYMS USED
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ACP- ' Administrative Control Procedure
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ATWS - . Anticipated Transient Without Scram CFR Code of Federal Regulations CRD Control Rod Drive DAEC Duane Arnold Energy Center DRS- Division of Reactor Safety EO.P- Emergency Operating Procedure IFl : Inspection Followup Item IP' . Inspection Procedure
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IR : Inspection Report ITS ' Improved Technical Specification -
l 'JPM Job Performance Measure I
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K/A . Knowledge and Abilities LC Limiting Condition for Operation LE Licensee Event Report l-LORT . Licensed Operator Requalification Training -
LPRM Local Power Range Monitor NRC Nuclear Regulatory Commission
.NRR Nuclear Reactor Regulation .
ODi~ Operations Department Instruction
! OTI Operations Training Instruction ,
PRA Probabilistic Risk Assessment j RI Rod Insertion Procedure 1 I RMCS Rod Manual Control System !
RO Reactor Operator l SALP Systematic Appraisal of Licensee Performance '
SOER Significant Operating Event Report-SRO- Senior Reactor Operator L STA Shift Technical Advisor ,
TDAP Training Department Administrative Procedure URI Unresolved item L
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I Attachment 1 SIMULATION FACILITY REPOR1 Facility Licensee: Duane Amold Energy Center Facility Licensee Dockets No: 50-331 l Operating Tests Administered: November 30 - December 4,1998 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 items were observed (if none, so state):
ITEM DESCRIPTION NONE OBSERVED e
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