IR 05000348/1989019

Insp Repts 50-348/89-19 & 50-364/89-19 on 890821-25.No Violations or Deviations Noted.Major Areas Inspected:Control Room Operator & Licensed Operator Requalification Training Programs Re How Tasks Analyzed & Objectives Derived

ML20247G560
Person / Time
Site:	Farley
Issue date:	08/31/1989
From:	Breslau B, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247G546	List: IR 05000348/1989019 ML20247G540
References
50-348-89-19, 50-364-89-19, NUDOCS 8909190097
Download: ML20247G560 (11)

Text

. . . _ _ - - _ _ - - - - - - - - - - - - - _ . - . .

- - - - - - . - - - - - - - . - - - - - - - - -

) ;

1{> MN 4 O' gR M? 2- t 6

' UNITED STATES ' i

/

e c NLICLEAR REGULATORY COMMISSION

- 47 REGION 18 a l7 l- 101 MARIETTA STREET,N.W.-

f t > ATLANTA, GEORGIA 30323

s '% .....

Y, Report Nos.:i 50-348/89-19 and 50-364/89-19

'

LicenseekAlabamaPowerCompan North 18th Street

- Birmingham, Al 35291

Docket No.

- 50-348'and;50-364 ' License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2

.

'

Inspection Conducted: ' August 21-25 1989 Inspectors:: [ /ddab N/ n a/ M J / / 9 8 'f B.EBreslau, Team Leader Dat4 Signed /

Team Members:

'

. L. Lawyer..L G. Salyers Approv d by': f(-IF87-

~ Kellogg,- Chief Date Signed

,

Operational: Pro' grams Section Division of Reactor Safety SUMMARY-Scope:

The control room operator and the licensed operator requalification training programs were inspected. The inspection focused on, (1) how the tasks were

- analyzed, (2) how training objectives were derived from the tasks, (3) how

. training for. the tasks was designed, developed, and implemented, (4) how trainees were observed and evaluated during training to determine their level

' of . task' mastery, and (5) how feedback on training, trainee evaluations, and on-the-job' performance indicators are incorporated into revision and evaluation of-the training program Results:

Although the ' documentation of the training programs is adequate, the inspection revealed a need-for the licensee to reevaluate the instructor staffing leve Interviews, classroom / simulator observations and documentation reviews indicate that the instructors are performing extensive overtime which is detracting from adequate preparation time for the classroom instructions, also the use of one simulator instructor doesn't allow desired utilization of simulator " freeze action" to critique faults when they occur during simulator exercise FDR ADOCK 05000348 g PDC .

+ _ _ _ . .. _

_ _ _ . . _ _ _ - _ _____ - _ - _ _ __ _ - ._ - _ _ . _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _

l

. *

4

REPORT DETAILS Persons Contacted 1 Licensee employees

• S. Fulmer, Supervisor, Safety Audit and Engineering Review Group

• R. Hill, Assistant General Manager - Operations V. Holley, Shift Supervisor, SR0 W. Jaasma, Shift Technical Advisor, NLO

• L. Jackson, Section Supervisor, CD&E

• M. McClendon, Engineering student

• D. Morey, General Manager, Farley Nuclear Plant

• J. Osterholtz, Operations Manager R. Schamp, Reactor Operator, R0 R. Taylor, Reactor Operator, SR0 R. Vanderbye, Simulator Instructor, SR0

• R. Wiggins, Supervisor, Operations Training

• L. Williams, Training Manager INP0

• L. Durham, Section Manager, Curriculum Development Other Licensee employees contacted included instructors, engineers, technicians, operators, and office personne NRC Representatives

• G. Maxwell, Senior Resident Inspector W. Miller, Resident Inspector

• E. Reeves, Senior Project Manager, NRR

• Attended exit interview Acronyms used throughout this report are listed in the last paragrap Procedures reviewed during this inspection are listed in Appendix A Licensed Operator Requalification Training (41500)

This inspection was conducted using the procedures and checklists of NUREG-1220, " Training Review Criteria and Procedures." Simulator Requalification Program The licensee submitted their simulator operator requalification program to the NRC as part of the broader operator requalification program prior to the issuance of the unit 1 operating license. The NRC reviewed that program and concluded, on May 2,1975, that it met the requirements of 10 CFR Part 50 and Appendix A of 10 CFR Part 5 That program was subsequently revised to meet the requirements of the Denton Letter of March 28, 1980, on Qualifications of Reactor Operators.

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ - ,

_ _ _ . _ _ _ - _ _ - _ _ _ _ - _ _ -

. .

,

.

.

. .

The program in effect on the dates of this inspection was described in UFSAR Chapter 13 Revision 7 dated July 89 and in Chapter 500, License Retraining' Program; course OPS-564, Simulator Retraining; module No. OPS-56401, . Normal Plant Operation and Control Manipulation, Revision 1 These documents continue to reflect the content requirements of the Denton Letter. The inspection team reviewed the content of the program as described in OPS-56401 and found it to be identical to that required in Chapter 13 of the UFSAR. The. training department intends to revise the UFSAR to meet the content requirement of 10 CFR 55.59 prior to the next requalification cycl The licensee has begun plans to' convert .to a plant specific-Job Task Analysis based program. The administration of the currently implemented program is described in FNP-0-AP-45, Appendix B, Licensed Retraining

"

Program, Revision 9. The program administration described meets the requirements of.10 CFR 55 and the Denton Letter for grading criteria and remedial actions for failure of the annual requalification examin-ations. The specific documents available to the shift supervisor for ensuring that only qualified watchstanders assume the watch were not examine The inspection team determined that both active and inactive licensed personnel, as well as selected non-licensed personnel (some Shift Technical Advisors) are included in the simulator requalification program. The grading criteria for the active and inactive licensed personnel are the same. Time for this simulator training is being

. adequately provided for by the operations group's five section, eight hour shift rotatio b. Job Performance Measures A group of four operators, three of which were licensed, were actively participating in simulator requalification during the period of this inspectio The inspection team reviewed the annual written examinations given in April,1989, including JPMs, for the three licensed operators. The examination questions were fair but training management post examination review disclosed that several changes were required to more precisely elicit the desired response as well as to improve the effectiveness in measuring operator proficiency. The inspection team's review disclosed only minor errors in grading and one indication of an administrative weakness associated with a JP ____ - _ _--___ _ _ - __ ___ _ _ a

. .

.

.

.

The administrative weakness indicated a tendency of personnel to ignore inaccuracies in procedures and JPMs when working in the examination atmospher Specifically, two teams of one training department evaluator and one licensed operator observed that an in-plant switch required in the performance of a JPM had only an 0FF and an ON position. Both the Control Room Operator Job Performance Measu re, 50-5449 entitled Supply Emergency Air to Steam Generator Atmospheric Relief Valves from Emergency Air Compressors, revision 0 and the governing procedure FNP-1-50P-62.0, Emergency Air System, revision 6, required the operator to place the local hand switch in a non-existent AUTO positio None of these four persons submitted any documentation to initiate changes to the JPM, the JPM grading key or the plant operating procedur In addition, a third pair of licensed operator and training evaluator, while they did mark up the JPM examination to indicate the correct switch position, did not institute change forms to get the procedure or JPM key change Once this error was identified to the licensee, corrective action was initiate Simulator Observations 1) General-The 1989 simulator retraining (requalification) program consisted of roughly 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in the spring and 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in the fall including reviews and testing. The subject matter meets the content requirements as discussed abov Generally, one instructor and four students are involved in the student to instructor contact par Three of the four students are normally licensed; one senior licensed operator and two reactor operator The fourth operator serves as the Shift Technical Advisor and may or may not be license The instructor performs all administrative duties such as record keeping, TV and audio recording, attendance, required reactivity and control manipulation tracking etc.; technical functions including scenario conduct, individual instruction, scenario planning, critique preparation, etc; and instructional duties such as team and individual critique delivery, on-the-spot remedial training, performing attachments and simulating the performance of any personnel who would interface with the operators during the use of normal, abnormal and emergency procedure The simulator scenarios observed by the team were well planned, documented on instructor aids, flexible enough to allow individual treatment of the students, well paced and time efficien l l

- _ - _ _ _ _ - _ _ _ _ _ _ _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______________________________

_-_

_ , - _ - _ _

u .

L ,

.,

.

. 2) Adequacy of instructional assistance The two and a half days of simulator instruction observed by-the inspection team was all performed by the same instructo . This instructor was very knowledgeable of the Unit 1 plant specific simulator; having had extensive experience in operating and teaching this vendor type . plant including simulators. The critiques and instruction provided by this person were. excellent considering the limitations imposed by manpower shortage. All simulator-instruction (administrative, technical and instructional noted above) were performed by one person .resulting in less time per student for critique, analysis and remedial instruction than is desirable. In addition, the critique notes prepared during the observed

- sessions were cryptic and nearly illegible to other than the preparer due to time constraints. Many of the instructional functions must be performed from the simulator booth thus removing the instructor from the proximity of the studen This remoteness is not compensated for by the TV and audio syste The licensee provided two instructors for this function at one time in the past (about one year ago) but was not able to maintain that staffin ) Material coverage Normal, abnormal and emergency operating procedures were adequately represented. The requirements of the licensee's course 564, Simulator Retraining, Revision 13 were either documented as having been performed in the spring sessions or were observed by the inspection tea Additional instruction and practice was provided in the preplanned training lesson ) Student performance Student performance was observed in simulator Sessions 8, 9 and 10. Prior to Session 8 the students had received 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator instruction during this requalification cycle. By both observation and instructor critique sheets, Sessions 7 and 8 demonstrated very poor operator performance. This inadequate performance was licensee identified and remediated during the team's observation. The inadequacies were numerous and seriou They occurred in the areas of communications, normal operations, immediate operator actions and vendor and licensee accident mitigation strategie __-___-_______________--_____s

_ _ - - . _ _ _ _ _ _ _ - _ - -

• -

.

.

, .

l 5 I

One communication inadequacy occurred when the 0ATC noticed that only the A train components had responded to an SI but did not report this failure to the Shift Supervisor or the crew nor did he attempt to regain this equipment during subsequent action Many other less significant communication inadequacies were observed during the one day Session 8. These communication problems were adequately corrected during Sessions 9 and 10 by more demonstrative performance by the student " Normal" operations problems - During a power ramp down the crew failed to adjust the ramp rate on the turbine after the reactor power was reduced with the result that they caused an overcooling event and lost control of the reacto On another scenario, the STA reported an orange path to the SS but the SS chose to not evaluate the reason for the orange pat Failure to perform immediate operator actions was commonplace during Sessions 7 and 8, improved in Session 9 and seemed to be fully corrected for these students for these scenarios during session 10. Examples include 1) a 20 gpm leak rate was in for 4 plus minutes before the 0ATC or any of the crew noticed or responded to it, 2) post LOCA, the 0ATC went on excess letdown too soon and thus prevented the performance of a good leak rate determination, 3)the crew was slow to isolate the mini-purge after indication of high levcis on the containment radiation monitors and, 4) on one reactor trip, the U0 did not check AFW initiatio More serious even than the failure to properly perform operator immediate actions were two cases of failure to use the approved accident mitigation strategy. First, following the identification of an ATWT event, the SS intentionally left the turbine on during the operator immediate actions. His rationale was that he didn't want to loose an important heat sink. This failure to trip the reactor resulted in overcooling, loss of pressurizer level, loss of control and SI. Second, following a SGTR when the pressurizer level fell to 5 percent, the SS intentionally ordered an SI prior to a reactor tri His rationale was that the SI would cause a reactor trip anyway and he wanted to get the water inventory restoration started before the shrink from reactor trip starte Following the ATWT event, both the SS and the STA were adamant that they were taught to leave the turbine on during power reduction on an ATWT. The inspection team verified that training materials indicated the proper accident mitigation strategy for both the ATWT and SGTR events above. Operator retraining, drill, and retesting of this crew were adequate even though it took several iterations to correct the problems.

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _

. _ _ . - _ - _ _

-

.

l 1 . .

1 6 In this area the team concluded that the licensee's program functioned well to identify and correct deficiencies in operators' knowledge; but, existence of these deficiencies so late in the requalification training (two days before final evaluation indicates the need for a more effective requalification training program, 5) Simulator performance The Farley simulator is Unit 1 plant specific and differs from Unit 1 only in the common areas, primarily core modeling under extended operations such as two phase flow. The limitations are known by the instructional staff thus avoiding negative trainin Due to the differences between Units 1 and 2, there are significant hardware deviations between the simulator and Unit 2, thus reducing its value as a training tool for Unit 2 operator During the period of this inspection the team observed that

. personnel supporting the simulator operation (repair personnel for the SPDS, recorders, audio-visual) were prompt, capable and effective in repairing fault The inspection team found the TV recording ability to be goo However, audio on the tape and as monitored in the simulator booth is poor for some control panel locations. The licensee recognizes this and is adjusting microphone location and type to improve the audio quality. During the two and a half days of observation of simulator retraining, total computer down time was only about one-half hou Peripheral equipment failure was minimal. The indicator lights on the main control board are veiled by the overhead lighting to the extent that it is necessary for the operators to shield the light with their hand in order to be certain of the status of indicated equipment. The lighting in the control room is not suffering from this difficult This is an important human factors difference between the plant and the simulato The only major concerns in this area were the veiling of indicator lights as discussed above and peacekeeping. The provision for keeping track of the operative steps and completed steps in E0Ps in the plant consists of marking left hand boxes provided for that purpose. In the simulator, these boxes are not utilized during E0P training, purportedly to prevent the necessity of changing the marked up pages after each us ;

_ _ - - _ - _ . - . _ - - - - . - _ . - . _ _ - - . - _

_

- _ _ _ -

. .

.

.

. .

d. Classroom instruction Observation The inspection team observed classroom instruction over a three day period; observing a different instructor each da The inspection team noted that all three of the instructors were teaching from the overheads instead of the Instructor Guide. After the class, each instructor was interviewed and all three stated they preferred to teach from the overheads instead of the lesson plan The inspection team agrees with teaching in a manner that is conducive to efficient learning, but if there is a better way to present the material, then the lesson plan should be rewritten, and the lesson plan should be followe The inappropriate practice of teaching from just overheads was brought to the licensee's attention. The licensee stated they did not see any problem with the practice as long as all of the material was covere However, as a result of lesson plan misuse, material presented by differing instructors to separate classes was inconsistent in depth and content. The instructors omitted a combination of 15 system discussions and lesson objective The specific items were discussed with each instructor during the breaks or at the end of the class sessio Any corrections to the Lesson Plans or Instructor Guides are logged in the front of the Instructor Guide and annotated in the text. The method of relaying the changes to the studer.ts is by the instructor verbally pointing out the corrections during class. Only one of the three instructors informed the students of the corrections in clas The reason for this was that the Instructor's Guide was not followe The inspection team reviewed the Instructors Guide used for each day's class and noted a number of corrections annotated in each lesson pla The facility has in place a method for effectively up dating lesson plan The Instructor Guide, if followed, has the operator read or go over the lesson objectives at the beginning of the class. One of the instructors chose not to state the lesson objective The instructor stated, "if you read the objectives at the beginning of the class, the student turns everything else in the lesson off".

HLC-17 weekly exam and HLC-16 equivalent exam were reviewed for content and to verify that the questions were covered by the lesson objective HLC-16 and HLC-17 questions were covered by the lesson objectives, but in one case the objective was not covered in clas _ _ - - _ - _ - _ - - _ _ _ - - - _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ - - - ____

____ __ _

. .

_

.

. .

The instructors were' dedicated and enthusiastic in their classroom presentation. However some wrong or misleading information was presented.in the class as illustrated by the following:

1) Stated Sparging Steam was used to remove air from the condense ) Drew a picture on the board of " Condenser Water Box" showing the tubes, then showed the Air Removal System taking a suction from the center of the tube bundle. It was never pointed out that the header was in the condense ) Stated the condensate system continuously dumped to the River Water using a manual valv ) Stated Exhaust Hood Spray was used to protect the flexible stainless steel boot located between the main condenser and the shel ) State the cooling towers were secured below approximately 35 'egrees. F because the chill factor, they could freeze ar 2xperience mechanical damag The instructor's extensive work load contributed to the foregoing problem On the average, the ten license instructors for the first six months of 1989 averaged approximately 46.9 percent overtime or a 58.8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> work wee e. Program Evaluation The licensee's retraining program encompasses a two year period, which consists of topics that are based on licensee commitments in accordance with 10 CFR 55, industry events / concerns, input from licensed personnel and management, prior annual requalification and examination results, and knowledges and skills associated with tasks that are infrequently performed and are important to successful job ~

performance. The licensee has not completed their plant specific JTA and the training, while performance based, is not plant specific performance base Training Curriculum Procedure TCP-1 describes the evaluation methodology in place at Farley. It includes methods for systematically evaluating the training programs and for revising the programs as required. The inspection team found documented evidence that such evaluations are taking place un a routine basis after each class, after each training cycle, and on an annual and biannual basis for full program evaluation Documentation included completed analysis of examinations, completed instructor critiques, trainee critiques, job performance feedback from supervisors and the results of internal and external evaluation Overall, the evaluation process contains most of the essential elements of a good evaluation progra _ _ _ - _ _ _ _ . _ _ - _ _ _ _ _ - _ _ - - _ _ - _ - - _ _ _ _ __-_--___a

_ _ _ _ _ _ _ _ - _

- .

. .

,

. -

However, the results of these evaluations were not overtly acted upo Trainee feedback forms indicated that several course objectives were vague and that some test questions were not related to objectives or material presented. Additionally, the trainees noted that the instructors on several occasions were not prepared for their presentation This fact was substantiated by the instructors during the interviews with the inspection tea No violations or deviations were noted i Exit Interview An exit interview was conducted on August 25, 1989, with those persons indicated in paragraph - 1 above. The inspectors described the areas inspected and discussed in detail the inspection results. Proprietary information is not contained in this repor Dissenting comments were not received from the license . Acronyms AFW Auxiliary Feed Water ATWT Anticipated Transient Without Trip CD&E Curriculum Development and Evaluation CFR Code of Federal Regulations E0P Emergency Operating Procedure FNP Farley Nuclear Plant HLC Hot License Class INP0 Institute of Nuclear Power operation JPM Job Performance Module LOCA Loss of Coolant Accident NLO Non Licensed Operator NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation 0ATC Operator-At-The-Controls OL Operator License R0 Reactor Operator SI Safety Injection SGTR Steam Generator Tube Rupture SJAE Steam Jet Air Ejector 50 System Operator SPDS Safety Paramete.' Display System SR0 Senior Reactor Cperator SS Shift Supervisor STA Shift Technical Advisor UFSAR Updated Final Safety Analysis Report U0 Unit Operator i

- - - --- _ - - -- _ _ _ - _

_ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _

. .

_

. -

APPENDIX A LIST OF PROCEDURES REVIEWED FNP-0-AP-27 Conduct of Operations - Training Group, Revision 9 FNP-0-AP-45 Training Plan, Revision 9 FNP-0-AP-65 FNP Operating Experience Evaluation Program, Revision 5 FNP-0-TCP-1 Farley Nuclear Plant Training Feedback and Evaluation Programs, Revision 9 FNP-0-TCP-6 Training System Development, Revision 4 FNP-0-TCP-7 Instructor Evaluation, Revision 3 FNP-0-TCP-11 Master Training Plan / Curriculum Guide Revisions and Approvals, Revision 4 FNP-0-TCP-12 Instructor Qualifications, Certification, & Development, Revision 6 FNP-0-TCP-13 Identifications of Changes To Training, Revision 5 FNP-0-TCP-14 Implementation of Simulator Modifications. Revision 2 FNP-0-TCP-15 Training Material Development, Revision, & Approval, Revision 5 FNP-0-TCP-16 Task Analysis, Revision 5 FNP-0-TCP-17 Operator License. Training Program Administration, Revision 4 FNP-0-TCP-17.3 License Retraining Program Administration (Classroom), Revision 3 FNP-0-TCP-21 Job Analysis, Revision 4 FNP-0-TCP-22 Test Development, Administration, & Analysis, Revision 0 FNP-1-SOP-62.0 Emergency Air System, Revision 6 L_-_______-________--___--_____-_-_-_-____--____--_____ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ - _ _ _ _ _ _ _ _