IR 05000341/1997017
| ML20198T518 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/21/1998 |
| From: | Leach M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198T505 | List: |
| References | |
| 50-341-97-17, NUDOCS 9801270080 | |
| Download: ML20198T518 (20) | |
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t U.S. NUCLEAR REGULATORY COMMISSION
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REGION ll1 Docket No:
50-341
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License No, NPF-43
- Report No:
50 341/97017(DRS)
Licensee:
The Detroit Edison Company
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Facility:
Fermi 2 Location:
6400 North Dixie Highway Newport, MI 48166 Dates:
December 1 - 5,1997 Inspectors:
H. Peterson, Reactor Engineer, Laad Inspector G. Larizza, Reactor Engineer
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Approved by:
M. Leach, Chief, Operator Licensing Branch Division el Reactor Safety
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-POR-A K 05000341
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EXECUTIVE SUMMARY Fermi 2 Nuclear Power Plant NRC Inspection Report 60-341/97017
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This inspection report contains the finding: and conclusions from the inspection of the licensed reactor operator (RO) and senior reactor operator (SRO) requalification training programs. The inspectic.. included a review of training administrative procedures; review of written and operating examination material; observation and evaluation of operator performance and licensee evaluators during a requalification operating examination; an assessment o! simulator fidelity; an evaluation of program controls to assure a systems approach to training; and a review of requalification training records. In addition, the inspectors observed routine activities in the actual control room. The inspectors used the guidance in inspection procedures 71001 and 71707.
Licensed operator requalification programs were generally implemented in accordance with 10 CFR Part 55 requirements.
In general, all portions of the annual requalification examination met the minimum
criteria in accordance with the guidance given in NUREG 1021, " Operator Licensing Examination Standards for Power Reactors," Interim Revision 8. (Sections 05.2,05.3)
Control Room operators demonstrated an appropriate level of attentiveness to the
operating panels and were knowledgeable of plant conditions. (Section 01.1)
The licensee's controls to revise the licensed operator requalification training program
were satisfactory. (Section 05.4)
The licensee's incorporation of current industry events into the operator training program was good. (Section 05.2.2)
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The licensee's continued implementation of the Operational Excellence Plan have shown improvements in the conduct of operations as noted in recent resident inspection reports. (Section 05.1)
However, concerns were identified with regard to the following:
Communications were at times !nformal and did not alws/s meet management
expectations for three way communication. Also, some lapse in formal controls to restrict personnel access to vital control areas in the control room was observed.
(Section 01.1)
In general, the requalification examination material bank contained the minimum
qualitative attributes to provide an adequate evaluation of operator skills; however, the quantity of examination materialin the bank was marginal. (Section 05.2.1)
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e The simulator scenarios lacked sufficient complexity. Some scenarios had no
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component or instrument failures following the major malfunction, and the scenarios did
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not readily incorporate equipment out-of-service or have existing technical specification
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limiting conditions for operation as part of the initial conditions. (Section 05.2.1)
Some knowledge and operating weaknesses were observed during the requalification e
examination (wrliten and operating). The operating weaknesses included erroneous emergency classification and weak command and control (Sections 01.2,05.3.1)
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The excessive repetition of examination material from week to week and during
remediation re-evaluation generated questions pertaining to examination integrity. This issue was considered an inspection follow up item (IFl 50/341-97017-01(DRS)).
'(Sections 05.3.2,05.5)
The differences between assessments and formal evaluations posed potential problems e
for meeting the requirements of an annual evaluation of licensed operators, The licensee's procedure allowed the use of the same failed simulator scenario for the
. remedial re-evaluation following an unsatisfactory assessment. (Section 05.5)
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Reports Details
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1. Operadons
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- 01- ; Conduct of C;1=&n.
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Of f Control Room Observations
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Inspection Scoos (71707)
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l The inspectors observed routine control room activities during full power operations',.
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- performed a panel walk-down, reviewed control room logs, and questioned operators
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Observations and Findings In_' general, the control room operstors conducted themselves in a professional manner 1 and wore attentive to their_ respective panel indications. However, access control to the
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main control room area and verbal communication practices wera not always consistent _--
with management expectation and guidelines.; The inspectors observed an individual -
performing janitorial service who was not part of the shift crew enter the control panel
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- area without asking permission on two occasions. Also, conversations, at times,L contained informal and incomplete three-way communication phrases.
The control room noise level was minimal and no annunciator alarms were left
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unattended or in a preonged alarm state. Upon questioning by the inspectors, the
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operators demonstrated satisfactory knowledge of plant conditions and equipment.
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- status.-' The inspectors observed a shift tumover and a shift briet, The inspectors found ;
that control room shift briefings were informative and were conducted in a professional mamner. -
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Conclusions
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The inspectors concluded that an appropriate level of awareness existed in the control.
room. - However, the inspectors noted an occasional lapse in formal controls to restrict
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. personnel access to vital control areas in the control room and to ensure proper three.
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HO'1'.2 J Operator Performance - Control Room Simulator
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L saMind Lw= (71001. 71707) =
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L Theinspectars observed one operating crew's performance during the requalification;
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[ examination.(The ' examination consisted of routine and emergency activities evaluated
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on two dynamic simula%r scenarios on the plant specific simulation facility. :The crew
- consisted of seven licensed operators and one non-licensed shift technical advisor.
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Qhservations and Findinos The crew performed well during routine activities, including the performance of surveillance testing and normal reactor power changes. Shift briefs were numerous and conducted professionally; however, some briefs were held at inopportune times during the mitigation of emergency conditions. Communications between the operators were satisfactory to ensure that appropriate mitigating actions were performed; however, the third leg of the three way communications were at times missed. In general, the crew satisfactorily performed the associated critical tasks identified in the simulator scenarios.
However, the inspectors noted several weaknesses in operator performance. During one of the scenarios, the Nuclear Shift Supervisor (NSS), a licensed senior reactor operator (SRO) responsible for the emergency plan as the Emergency Director, made errors in classifying the emergency condition. The major malfunction for the simulator scenario was a large break loss of coolant accident (LOCA). The emergency condition resulted in the loss or potential loss of two fission product barriers. The first barrier, the fuel cladding, was potentially lost due to reactor water level dropping below the top of active fuel. The second barrier, the reactor coolant system, was lost due to the LOCA.
The third and final fission product barrier, the containment, was not threatened based on the plant conditions. The correct emergency action level classification was a site area emergency; however, the NSS misdiagnosed the threat to the containment and declared a general emergency.
The inspectors reviewed other simulator evaluations conducted earlier in the requalification examination cycle and found another error associated with emergency action level classifications. One other crew misclassified an emergency condition and
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did not escalate to a site area emergency from an alert. The correct classification of the emergency was not a critical task, but was evaluated as a competency area. Both operators were evaluated by the licensee as satisfactory overall, but were noted to have areas of de%ency that needed improvements.
The inspectors observed weak performance from one of the two SROs in the Nuclear Assistant Shift Supervisor (NASS) position. The NASS was responsible to take
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command and control of the shift, and direct mitigating actions in accordance with the emergency operating procedures. The inspectors found that command and control was mostly passive. The inspectors felt that the SRO needed to be more aggressive and be-able to foresee the proper course of action, so as to take charge and direct actions to mitigate the emergency. At times, the NASS displayed unfamiliarity in performing emergency operating procedures, and was consister.tly being helped by the reactor operators (RO). For example, based on plant conditions with reactor water level decreasing rapidly, the ROs had to inform the NASS the need to defeat the automatic depressurization system before an unwanted depressurization occurred.
c, Conclusions Although the crew completed the critical tasks, the inspectors concluded that some operators displayed performance weaknesses. The inspectors concluded that
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a command ano atrol, use and familiarity of emergency operating procedures,1
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classification of emergencies, and three way communications were, at times, weak and '
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05J Operator Training and Qualification
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c lO5.11 Operating Historv
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Inspection Scope (71001)
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The inspectors reviewed the following to assess the licensed operator requalification _
training program's offectiveness regarding operator performance:
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'e i SALP 15 report No. 50 34196001.
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- D Resident inspector observations and reports covering the time frame of 1990 to
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present, in particular, report No. 97013 and 97014.
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Le Uoensee event reports covering the time frame of 1996 to present.:
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Licensed operator requalification training report No. 50-341-96014 (DRS).
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Observations and Findings
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' The inspectors noted that poor operator performance'as documented in the abnve -
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reports was attributable, in part, to inattention to details, incorrect use of procedures,
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- and inadequate procedures.' The inspectors no*.ed that the licensee was continuing to
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. take actions to improve operator performance pertaining to procedure usage. The-licensee's action items centered around procedure use and compliance, and overall
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- procedure development. The licensee's efforts to improve overall performance included
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. an Operational Excellence Plan, that focused on reducing operator errors and improving
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. training effectiveness. _ As part of improving training effectiveness, in 1996 the Training
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- The examination material bank'was now de4gned for instructor use only, and not s
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accessible to operators.-
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Conclusions The inspectors concluded that ' se licensed operator requalification program had not !
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orcing proper procedural usage and attent on to '
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- details. : Problems associated with procedures and use of procedures continued to be a :
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recurring problem _ throughout 1996.c However, during 1997, the licensee s corrective actions indicated some improvements; In_ general, based on recent resident inspection
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-4 l reports, improvements were noted in the conduct of plant operations due to the--
- continued implementation of the Operational Excellence Plan.
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05.2 Be_ qualification Examinations 05.2.1 Examination Material a.
Insoection Scone (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. In addition, the inspectors reviewed the overall maintenance of the examination material bank.
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QbscIyations and Finrfinos The inspectors found that dynamic simulator scenarios were straight forward and lacked sor e complexity, in one scenario the minimum number of malfunctions were met; however, there were no component or instrument failures following the major malfunction which would have enhanced the complexity of the scenario. The inspectors also found that the scenarios did not readily incorporate equipment out-of-service or have existing technical specification limiting conditions for operation as part of the initial conditions. The licensee's scenario development process ellows for such items as equipment out-of service, but was not used by the licensee during the requalification examination. The majority of the scenarios met the minimum criteria (total number of malfunctions and entry into different/ multiple emergency operating procedures) set forth as guidance in N JREG 1021, " Operator Licensing Examination Standard for Power Reactors," Revision 8, and subsequently, provided the minimum quantitative attributes to evaluate the crew and individual members on safety significant tasks and competencies, The job performance measures (JPM) contained clearly stated critical steps and termination cieria required for successful completion. However, program deficiencies were noted during the performance of JPMs: (1) the JPMs did not reference the knowledge and abilities (K/A) rating factors per NUREG 1123," Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors;" (2) JPM time validatien was inaccurate, more than double the validated time limits; and (3) one JPM contained performance tasks that were not consistent with the actual plant indications in use which required evaluator judgement. Pertaining to the time validation inaccuracy, one JPM had 8 minutes as the time validation for shutting down and placing the high pressure coolant injection (HPCI) system in a standby condition; however, all the operators took an average of 30 minutes to complete the JPM. The inspectors were concerned that the review and validation process had not identified these deficiencies even with a technical review being performed.
The written examination questions were operationally orientated and contained an appropriate level of difficulty. The static examination questions made good use of the simulator as a reference. The majority of the open reference questions were of higher cognitive knowledge level; however, the inspectors found some questions that were
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considered direct look-up questions. Also, the inspectors found additional administrative problems pertaining to written examination questions: (1) numerous questions had no K/A rating factors or time validation (computer setup apparently failed to print the information on the examination key; however, the information was retrievable from the computer); and (2) some questions had poor psychometrics (the process of applying sound qualitative processes to mental measurements, for example, weak or implausible distractors).
The inspectors reviewed the overall maintenance of the examination material bar k. The licensee had closed the examination bank in August 1996 and taken action to imptove the bank. However, the inspectors found that the licensee before 1996 had not adequately maintained the examination material bank in accordance with the guidance given in NUREG 1021, Section ES-601 D.3.a. * Examination Preparations - Reference Material," and Form ES-6012, " Evaluation Checklist for Faci!ity Reference Material."
The examination bank met the minimum quantity for open-reference written examination questions, simulator scenarios, and JPMs if it was based on the very first assessment of the licensee's requalification program. However, the requalification examination bank was considered to be a dynamic bank, with specific guidance to increase the bank each year following the initial requalification examination.
The guidance for maintaining the examination bank were as fol;ows: (1) open reference written examination was 350 per section with at least 150 revised, reviewed, or newly generated questions per year; (2) simulator scenarios was 25 plus five per year until at least 30 scenarios covering all aspects of the EOPs were developed; and (3) JPM was 95 plus ten per year until.'ll job task analyses were fully covered.
C ver 7 years have passed since the licensee's initial requalification examination. Based
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on the guidance, the amount of materialin the examination bank appeared low. For example, the licensee's JPM bank only had 108 JPMs, but if five new JPMs per year were developed in the last 7 years, then the examination bank should have at least 130 JPMs. Also, the guidance estimated that 125 to 150 JPMs would be the final result.
Pertaining to the simulator scenarios, the guidance indicated that at least five scenarios per year should be generated until all aspects of the EOPs were covered with sufficient variation in the type and scope of initiating events and level of degradation. The licensee had only 47 scenarios. Additionally, the licensee was not able to verify all aspects of the EOPs were sufficiently covered by simulator scenarios, and if the JPMs covered all safety-related tasks within the job task analyses, c.
Conclusions The inspectors concluded that the requalification examination material, in general, contained the necessary minimum qualitative attributes to provide an adequate evaluation of operator skills. However, the inspectors determined that the quantity of the examination material bank was marginal, which would potentially reduce the effectiveness of operator evaluation. Also, the inspectors determined that the licensee needed to enhance the complexity of the simulator scenarios. For example, the scenarios needed to incorporate equipment / system out-of-service and technical
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specification problems in the initial conditions, arid incorporate instrument / component
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failures following the major transient to make the dynamic simulator scenarios more
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realistic and challenging.
05.2.2 incorocration of CUERDt Industry Events
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insoection Scooe The inspectors reviewed the licensee's program to assess and incorporate current
--industry events applicable to the facility into training and testing. Particular attention was placed on recent industry events related to boiling water reactors. The following lesson plans were reviewed:
' Conservative Decision Making, LP-OP-233-9711 (Clinton ConfirmStory Action e
Letter; Clinton Recire Seal Failure)
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The Face of Uncertainty, LP-OP-233-9731 (LaSalle Ultimate Heat Sink Threat)
Cycle 1 Operating Experience, LP-OP-233-9712 (Susquehenna EDG e-Inoperability)
Operating Experience Cycle 3 LOR, LP-OP-233-9732 (Fitzpatrick Event, Zion e
Reactivity Event)
Complacency, LP-OP-233 9752 (Calvert Cliff's CST Dive Fatality)
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Observations and Findings The inspectors identified and reviewed several training department lesson plans that incorporated significant industry events lessons teamed. The subjects of the lesson plans included classroorn presentation, quizzes, ar c simulator operation. The inspectors also identified that the licensee, on the stitten examination, had written specific examination questions dealing with significant events which recently occurred at another facility.
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. Conclusions The inspectors concluded that the licensee's incorporation of current industry events
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05.3.1 Recualification Examination Administration Practices a.
Insoection Scone (71001)
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The inspectors observed the licensee's evaluators during one operating crew's performance during dynamic simulator scenarios and JPMs.-- Also, the inspectors-
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w observed the licensee's administration of the two'part written examination using the
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licensed shift technical advisor (STA)/ The crew was required to take a written
. examination, and perform two dynamic scenarios and a set of five JPMs. The
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inspectors also attended the evaluator critiques, b.
Observations wi Findinas -
- The licensee's evaluation team identified no unsatisfactory crew performance during tha simulator scenarios. However, two operators were identified as having demonstrated
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unsatisfactory performance during the writtern examination and required remediation
prior to resumption of shi't duties. As a total, at the end of the requalification examination, the licensee identified 10 out of 37 licensed operators failed tha written.
examination. Of the 10 failures five were senior reactor operators and the other five were reactor operators.
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Following discussions with the licensee', the inspectors found that the missed questions were not concentrated in any single area, but were evenly distributed. At the conclusion
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of the inspection, the licensee had not yet evaluated the written examination failures for a root cause. The licensee had 18 additional operators to examine in the next two.
weeks, after which a root cause was planned to be performed. The inspectors -
considered that the failures were potentially due to the licensee's efforts in question upgrade and closure of the eramination bank from operator review.
After observing two dynamic sinulator scenarios and reviewing past simulator -
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evaluations, the inspectors noted some weaknesses in operator performance. The observed weaknesses were as follows: (1) error in emergency action level
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unfamiliarity in performing emergency operating procedures (one SRO was consistently being helped by the reactor operators); and (4) some lack of completing the third leg of the three-way communications (See Section 01.2 for further details).
- The evaluators performed the examination administration in a professional manner and
. properly documented operator performance deficiencies, inclu 9.:g the above weaknesses:- The inspectors noted that recommended remedial actions were being documented to deal with the weaknesses. No evaluator miscuing or prompting was
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?.ppropriate security measures were taken throughout the examination process.
Individual operators were sequestered and separated into test groups during each :
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portion of the examination process. No potential examination compromise _was identified.-
One new simulator fidelity issue was identN,. auring the examination observation (See Enclosure 2, Simulator Facility Report).
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Conclusions The inspectors concluded that the licensee was adequately implementing the Licensed Operator Requalification Training program in accordance with program guidance and regulatory requirements stated in 10 CFR Part 55.59. In general, the inspectors concurred with the licensee's evaluation. However, the overall performance (written and operating examinations) indicated some knowledge and operating weaknesses.
05.3.2 Examination Material Recetition a.
Insoection Scope f71001)
The inspectors reviewed the licensee's procedures and practices pertaining to requalification examination material repetition. The following licunsee's procedures were reviewed:
Operations Training Policy (OTP)-004. " Conduct of Simulator Assessments and
Evaluatior s," Revision 2 Nuclear Training Conduct Manual (MNT)-06, " Training Program Evaluation,"
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Revision 2 Nuclear Training Conduct Manual (MNT)-04, " Trainee Evaluation," Revision 5
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Observations and Findinas The inspectors identified that during the 6 week requalification examination cycle the licensee repeatea over 50 percent of the simulator scenarios. The licensee assembled a total of nine simulator scenarios for the requalification examination. During the first 3 weeks of the examination cycle seven independent scenarios were used. However, during the following 3 weeks, the licensee repeated six of the scenarios, la week number 4, one out of two scenarios was a repeated scenario, in week number 5, two out of three scenarios were repeat ccenarios, and in week number 6, all three scenarios were repeats. Although the sixth week was set aside for certified instructors and not necessarily for licensed operators, the overall practice of repeating simulator scenarios was not in accordance with the intentions of the examination standards.
The inspectors found that the licensee administered a written examination during each week of the requalification examination cycle. The inspectors also identified that more than 10 percent of the questions for the written requalification examination were repeated from week to week. The inspectors were informed that licensee's policy allows 20 percent repeatability of questions, cumulatively. Therefore, the inspectors determined that on the fifth week of examination, the written examination could foreseeably have as much as 80 percent repeated questions. The inspectors were informed by the licensee that the 20 percent was a matter of policy, but not the practice.
However, the licenses's policy does not clearly document a limit for repeating written examination questions. The inspectors confirmed that 80 percent repeat of questions
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was not the case. However, the licensee acknowledged the inspectors' concern and indicated a review of the program will be conducted to ensure the proper level of repeating written examination questions.
The inspectors noted that the examination standards (NUREG 1021) does not give clear guidance on the allowable percentage of examination material repeatability for the requalification program. However, NUREG 1021, Sections ES 301 and ES-401, does give clear gu! dance for limiting the examination material for the initial license program.
The guidance specified that no more than 30 percent repetition for JPM walkthrough and no more than 25 percent repetition for written examination questions. These quidelines were set to avoid compromising the integrity and security of the examination, c.
Conclusions The inspectors determined that the licensee's policy on examination material repeatability on written examination questions and simulator scenarios during the requalification examination cycle was a concern. The potential for excessive repetition of written examination questions and the repetition of over 50 percent of the simulator scenarios were considered excessive and poor. Although there was no specific guidance given in NUREG 1021 for the requalification program, the inspectors concluded that the excessive repetition of examination material was contrary to the intent of NUREG 1021. Additionslly, the excessive examination material repetition generated questions pertaining to past and present examination integrity. Based on further review by the NRC and the licensee's potential improvement to the program, this issue was considered an inspection follow up item. (IFl 50/341-97017-01(DRS))
05.4-Reaualification Trainino Prooram Feedback System a.
Insoection Scoce (71001)
The inspectors reviewed the following documents to assess the licensee's training program feedback system effectiveness:
Nuclear Quality Assurance Audit Report, Operations Program, May 12-22,1997 e
Nuclear Quality Assurance Audit Report, Training and Qualification Unit Staff,
April 14 - May 2,1997
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Nuclear Quality Assurance Special Surveillance, Operational Assessment,
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October 1 - 31,1997 Accreditation Renewal Self-Evaluation Report, July 1997 e
Nuclear Training Conduct Manual, MNT-06," Training Program Evaluation,"
e Revision 2
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Observations and Findinos The licensee's training organization performed self assessment activities by assessing identified individual operator and crew weaknesses, operator training requests, and plant and industry events. Additional self assessment processes inchided course evaluations, instructor evaluations, classroom feedback, simulator evaluations and critiques, and on-the-job training evaluations. Also, the licensee's Nuclear Quality Assurance group performed periodic audits of the Operations and Training programs.
Gutmequently, the Program Review Committee, Comprehensive Program Evaluation, anri Self Evaluation Reports gathered, evaluated, and assigned priorities for the results of all the self-evaluations, including those conducted by the Nuclear Quality Assurance group.
The inspectors found that in the first half of 1997 the licensee's continuing theme identified through the Nuclear Quality Assurance audits were procedure weaknesses, including improper procedure usage and control. Other problems identified by the licensee in the Quality Assurance audits included problems with the maintenance of training material, instructor evaluations, and correction of long standing problems.
Subsequently, the licensee has responded to these issues and shown some improvements in the later part of 1997.
The licensee's self assessment program appeared to be up to date, and flexible enough to incorpoiate emerging training issues.
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Conclusions The inspectors determined that the licensee's Training Department feedback process was satisfactorily implemented.
05.5 Remedial Training Program a.
Insoection Scoce (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. In addition, the inspectors reviewed the licensee's overall evaluation process, in particular, the differences between assessments and evaluations b.
Observations and Findings in previous evaluations, the licensee had identified a number of unsatisfactory performances on both the written and JPM portions of the examination process. The inspectors determined that selected remedial training plans had incorporated a comprehensive retraining process, and were consistent with the licensee's assessment of operator's poor performance.
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l During the recent requalification examination, the licensee acknowledged that the poor
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written examination performance could be attributed to the recent revision in examination question difficulty which made each question more operationally discriminating. However, a complete root cause analysit had not yet been performed.
The inspectors identified that the area of weakness in the written examination appeared not to be concentrated in any one area, but was a broad mix, which may indicate a comprehensive knowledge weakness.
The inspectors noted that the licensee had developed remedial training plans for individuals with demonstrated weaknesses and required successful completion of the remedial training prior to resuming license duties. However, during remediation for failures, the licensee's policy allowed the written re-examination be up to 40 percent of questions from the examination that the operator had failed, and 60 percent new questions. The inspectors informed the licensee that the amount of question repetition from the failed examination appeared to be excessive, and not conducive to an effective re-evaluation. The inspectors noted that questions on similar topics should be used, but the questions should be significantly altered so as not to use the identical question.
The inspectors identified that during the operations portion of the requalification examination on the simulator, not all of the SROs were rotated in the Nuclear Assistant Shift Supervisor position to direct crew performance in the emergency operating procedures (EOPs). The licensee indicated that all operators, specifically SROs, were evaluated in the use of EOPs during the year by either an assessment or evaluation process. The inspectors questioned the licensee about assessments vice formal evaluations, and was informed that, in general, there were no differences except that assessments were not performed as part of a licensed operator requalification examination. Also, the inspectors were informed that if an operator performs undatisfactorily during an assessment the operator was to be re-evaluated.
The Code of Federal Regulations (CFR) Title 10 Part 55.59, "Requalification," only states that an operator will be evaluated on abnormal and emergency procedures in an annual operating test associated with items specified in 10 CFR 55.45, " Operating Test,"
that determines areas needing improvement. The regulations does not exclude evaluations performed during an assessment; however, it does imply that the evaluation was performed during an annual requalification operating test.
The inspectors were concerned with the overall evaluation process following the remedial training as set forth in licensee's procedure OTP-004, " Conduct of Simulator Assessments and Evaluations," Revision 2, dated June 20,1997. The inspectors identified that assessments had a significant difference in Section 13 of OTP-004, the remediation phase, if an operator / crew was evaluated unsatisfactory during an assessment, that operator / crew was to be remediated and subsequently re-evaluated.
However, as part of the assessment remediation, the re-evaluation was performed using the same simulator scenario that the operator / crew failed during the assessment. The inspectors informed the licensee that this process was not conducive to effective remediation and re-evaluatim. The licensee was not familiar with this portion of the policy and informed the inspectors that this was not the practice. The inspectors
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reviewed some previous assessments and found that identical scenarios appeared not to be used for the re-evaluation. The inspectors noted that this was another case of practice not reflecting policy. The licensee immediately implemented a procedural revision prior to th'.r.8pectors leaving the site. Procedure OTP-004, Revision 3, dated December 5,1997, was implemented to properly re-evaluate using a different simJlator scenano.
c.
Conclusions The inspectors concluded that the remediation program contained adequate measures to ensure Individual and crew performance weaknesses were addressed prior to resumption of licensed duties. However, the policy to use up to 40 percent of questions from the failed examination for the remedial re-evaluation was considered excessive and not conducive to effective re-evaluation. Also, the inspectors determined that the differentiation made between assessments and formal evaluations posed potential problems for meeting the requirements of an annual evaluation of licensed operators, specifically the identified inadequacy in the remedial re-evaluation for an unsatisfactory assessment.
05.6 Conformance with Q.perator License Conditions a.
Insoection Scoce (71001)
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The inspectors reviewed the licensee's medical and operator qualification programs, and selected records to assess licensed operator compliance with regulatory requirements.
This review included a sampling (10 percent) of the available medical records. Also, the licensee's procedure for defining and maintaining formal quahfication of operator licenses, MNT-08, " Certification of Qualification," was reviewed.
b.
Observations and Findinos The licensee maintained a copy of individual medical records at the facility. The inspectors determined that the records contained appropriate documentation to validate operator qualifications to perform license duties. No physical examination dates exceeded the program allowed date and no violation of regulatory requirements was identified.
The licensee's guidance for maintaining operator licenses in an active status, based on procedure MNT-08, required that requalification training requirements and on-shift time requirements as specified in 10 CFR 55.53(e)," Conditions of Licenses," were met. The license defined on-shift time for a reactor operator as being either the Control Room Nuclear Supervising Operator or the H11-P603 Operator (Control Rod Panel), or the combination of the two positions. For tho senior reactor operator to maintain active license status, the individual must perform the required on-snift time as the Nusar Shift Supervisor and/or the Nuclear Assistant Shift Supervisor.
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c.
Conclusions The inspectors concluded that the operators' license conditions were in conformane s with program guidance and regulatory requirements stated in 10 CFR Part 55.53 ea.110 CFR Part 55.21.
Miscellaneous Operations issues 08.1 Resoirator Fit Procram a.
Insoection Scone (71707)
The inspectors performed control room tours to review the licensee's plant setup for maintaining adequate equipment (respirator mask) for an evacuation of the control room / relay room area.
b.
Observations and Findlegg The inspectors questioned the licensee on the availability of special corrective lens for respirator masks. The licensee indicated that access to special lens existed. The inspectors verified that special corrective lens did exist and were available for individual use when needed. N: concerns were identified by the inspectors.
c.
Concluslor:s The inspectors concluded that the licensee satisfactorily maintained equipment necessary to evacuate the control ro.am.
V. Management Meetinas X1 Exit Meetina Summarv The inspectors presented the inspection results to members of 'icensee management on December 5,1997. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials held by the inspectors following the insyction could be considered proprietary. No proprietary information was identified.
Attachment: Simulation Facility Report
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PARTIAL LIST OF PERSONS CONTACTED LICanHtt P. Borer, Vice President, Nuclear Generation D. Cobb, Superintendent, Operations R. Cook, Supervisor, Compliance J. Davis, Director, Nuclear Training P. Fessler, Plant Manager B. O'Connor, Nuclear Assessment Manager
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N. Peterson, Director, Nuclear Licensing
L. Sander, Supervisor Operations Training NBC G. Harris, Senior Resident inspector Fermi
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INSPECTION PROCEDURES USED IP 71001," Licensed Operator Requalification Program Evaluation" IP 71707, " Plant Operations" l
ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-341 97017-01 IFl Excessive repetition of requalification examination material from week to week.
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LIST OF DOCUMENTS REVIEWED
NRC SALP 15 Report No. 50-341-96001 Licensed operator requalification training Report No. 50-341-96014 (DRS)
Lesson Plan," Conservative Decision Making," LP OP-233-9711 (Clinton Confirmatory Action Letter; Clinton Recire Seal Failure)
Lesson Plan,"The Face of Uncertainty," LP-OP 233-9731 (LaSalle Ultimate Heat Sink-
Threat)
Lesson Plan, " Cycle 1 Operating Experience," LP-OP-233-9712 (Susquehenna EDG
Inoperability)
Lesson Plan, " Operating Experience Cycle 3 LOR," LP OP-233-9732 (Fitzpatrick Event,
Zion Reactivity Event)
Lesson Plan, " Complacency," LP-OP-233-9752 (Calvert Cliff's CST Dive Fatality)
Operations Training Policy (OTP)-004," Conduct of Simulator Assessments and
Evaluations," Revision 2 Nuclear Training Conduct Manual (MNT)-04, " Trainee Evaluation," Revision 5
Nuclear Training Conduct Manual (MNT)-06, " Training Program Evaluation," Revision 2
Nuclear Training Conduct Manual (MNT)-08, * Certification of Qualification," Revision 4
Nuclear Quality Assurance Audit Report, Operations Program, May 12-22,1997
Nuclear Quality Assurance Audit Report, Training and Qualification Unit Staff, April 14 -
May 2,1997 Nuclear Quality Assurance Special Surveillance, Operational Assessment, October 1 -
31,1997
Accreditation Renewal Self-Evaluation Report, July 1997 Detroit Edison Fermi 2 Nuclear Power Plant Operational Excellence Plan, Revision 4
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LIST OF ACRONYMS USED CFR
. Code of Federal Regulations CST Condensate Storage Tank DRS Division of Reactor Safety EDG Emergency Diesel Generator EOP Emergency Operating Procedure ES Examination Standards HPCI High Pressure Coolant injection IFl Inspection Follow up item IP inspect'on Procedure JPM Job Performance Measure K/A Knowledge and Abilities LOCA Loss c,f Coolant Accident LOR Licensed Operator Requalification MNT Nuclear Training Conduct Manual NASS Nuclear Assistant Shift Supervisor
--NRC Nuclear Regulator Commission NRR NRC Office of Nuclear Reactor Regulation NSS Nuclear Shift Supervisor
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OTP Operations Training Policy PDR Public Document Room RO Reactor Operator SALP Systematic Assessmant of Licensee Performance SRO Senior Reactor Operator STA Shift Technical Advisor i
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.f Attachment 1
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- SIMULATION FACILITY-REPORT-
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Facility Licensee: Fermi 2 ;
- Facility Licensee Dockets No: 50 341-
- Operating Tests Administered
- December-3 - 4,19971-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 -
- evaluationsc No licensee action is required in response to these observations.
- While conducting the ilmulator portion of the operating tests, the following items were observed c(if none, so state):
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IIEM DESCRIPTION High Pressure Coolant.
During the performance of JPM JP-OP-315-0139-001,
- Injection _ System Reactor
" Shutdown the High Pressure Coolant injection System,"
Water Level Control and '
the reactor water level rapidly increased even after the.
~ Level Indication :
system was secured.
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