IR 05000361/1997020

Insp Repts 50-361/97-20 & 50-362/97-20 on 970828-0919. Violations Noted.Major Areas Inspected:Licensed Operator Requalification Program Following Guidelines in IP 71001, Licensed Operator Requalification Program Evaluation

ML20211Q305
Person / Time
Site:	San Onofre
Issue date:	10/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211Q295	List: IR 05000361/1997020 ML20211Q289 ML20211Q299
References
50-361-97-20, 50-362-97-20, NUDOCS 9710220235
Download: ML20211Q305 (13)

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- ENCLOSURE 2 3 I U.SINUCLEAR REGULATORY COMMISSION -

REGION IV

Docket Nos.: 50-36 License Nos:i NPF-10 NPF-15 i

Report No.: 50-361/97-20 50 362/97-20 Licensee: - Southern California Edison C Facility: San Onofre Nuclear Generating Station, Units 2 and 3

- Location:- 5000 S. Pacific Coast Hw San Clemente, California Dates: August 28 through September 19,1997 Inspectors: S. McCrory, Senior Reactor Engineer, Operations Branch R; Lantz, Reactor Engineer, Operations Branch J. Kramer, Resident inspector Approved By: J. L. Pellet, Chief, Operations Branch, Division of Reactor Safety -

ATTACHMENT: Supplemental Information

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EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/97-20; 50-362/97-20 This inspection included a review of the licensed operator requalification program following tne guidelines in inspection Procedure 71001, ' Licensed Operator Requahfication Program Evaluation." The inspecticil covered the period of August 28 through September 19,199 Ooerations

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Operator performance notably improved over the previous requalification inspection findings and was generally consistent with oerformance observed in other recent inspection activities. However, operators occasionally fell short of management expectations with regard to communications and supervisory oversight (Section 04.1).

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The licensee implemented the requalification program adequately. However, the

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licensee informally controlled important aspects of the program (Section O5.1).

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The licensee developed requalification examinations that were generally well constructed, challenging, and discriminated at the appropriate knowledge level, The inspectors determined that written examination quality had improved notably over previous requalification inspecuon findings (Section 05.2).

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The facility evaluators effectively identified strengths and weaknesses in crew and individual performance and conducted good critiques. The licensee had developed objective evaluation criteria that improved the efficiency and effectiveness of the evaluation process (Section 05.3). j

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The licensee implernented a remedial training program that was responsive to identified

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weaknesses and effective in retraining and retesting (Section O5.4).

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The inspectors concluded that the licensee's practices generally :issured conformance with operator license conditions. However, the inspectors identified a violation for inadequate procedures to ensure that operators with licenses conditioned to require corrective lenses could cortinue to satisfy that condition while wearing a self-contained breathing apparatus. Further, tie inspectors concluded that the licensee's compliance reviews of regulatory requirements could be improved (Section 05.5).

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. Report Details i Summary of Plant Status Units 2 'and 3 remained at 100 percent power during this inspection period. No major equipment problems or transients were experience L_Qantations 04 Operator Knowledge and Performance 04.1 Ooerator Performance on Annual Recualification Examinations Insoection Scooe (71001)

The inspectors observed the performance of two crews of on-shift licensed operators during the dynamic simulator and job performance measure portions of the annual requalification operating examination, Observations and Findinas The crews in the dynamic simulator consisted of four reactor operators, two senior operators, and one nonlicensed shift engineer, who acted as the shift technical adviso Each licensed operator was administered five job performance measures and participated in two dynamic simulator scenario During the operating examination, the inspectors observed the following generic behaviors among the operators:

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Operators were inconsistent in conducting formal three-legged communication The inspectors observed several instances where an order from the senior -

operator was acknowledged by body language only or a partial response from the control board operator, and a more complete acknowledgement was not requested by the senior operator.

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Operators routinely referred to appropriate procedures for alarm response, normal and abnormal operations, as required. Senior operators displayed good familiarity and usais of the emergency operating procedures and Technical Specification Operators exhibited good systems knowledge and plant awarenes Senior operator supervisory oversight was generally good, although the inspectors otrserved some instances when lines of authority were not well defined. The inspectors observed the response of one crew to an instrument failure in which the control operator

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(a reactor operator) directed the recovery efforts of the assistant control operator. After several minutes of discussion between the two reactor operators without completion of the actions of the alarm response procedure, the control room supervisor directed the control operator to assist the assistant control operator at the control boards while the control room supervisor read the procedure. The coordination of the crew to this instrument failure appeared confused and inefficient. In another example, the crew was given a dropped control rod at power, which required a power reduction as a subsequent action in the abnormal operating procedure. The control operator initiated the power reduction without direction from the control room supervisor or shift supervisor. This performance was not consistent with licensee expectation During the administration of the walkthrough examinations, an inspector observed several noncritical performance errors committed by an operator while performing a task being evaluated with a job performance naasure. The licensee scheduled the operator

- for remedial training for exhibited weaknesses even though he passed the job performance measure. The inspector concluded the that remedial training was appropriat The inspectors interviewed operations and training managers regarding operator and training program performance. NRC Inspection Report 50-361;-362/95-19 identified a number of weaknesses and areas for improvement in the requalification program and a number of operator performance issues. The most recent Systematic Assessment of Licensee Performance Report,50-361;-362/97-99 continued to highlight performance matters similar to those identified in the 1995 inspection report. The operations manager

< stated that the licensee determined that the greatest need for improvement was in operator performance during outages. Therefore, the licensee had focused most of its efforts on improving operator and crew performance during outages by addressing quality of outage-related procedures, use of procedures for infrequent and complex evolutions, communications, and supervisory oversight. The licensee stated the perception that operations performance in recent outages was evidence of significant improvement in that area. The managers acknowledged that there was still room for improvement in operator and crew performance during routine operations with regard to procedure use, communications, and control board awareness. However, they perceived that performance had improved notably over the last 2 years and that most of the recently observed performance shortfalls were best characterized as brief lapses rather than general performance weaknesses. The managers indicated that in response to the recent Systematic Assessment of Licensee Performance Report, the licensee would increase emphasis on control board awareness, communications, procedure use and fundamental knowledge. Additionally, the licensee was considering obtaining interactive softwa e designed to improve and re-enforce self-checking behavior coupled with procedure us _ - _

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-5-t Conclusions Operators exhibited generally good knowledge and ability in all aspects of the requalification examinations, but occasionally fell short of management expectations with regard to communications and supervisory oversight. However, operator performance was notably improved over the previous requalification inspection and generally consistent with performance ob. served in other recent inspection actlvitie Operator Training and Qualification 0 Review of Recualification Proaram Guidance Inspection Scope (71001)

The inspectors reviewed programmatic guidance for examination development and overall requalification program implementation. The inspectors interviewed members of the training staff with regard to actualimplementation of the requalification program, Observations and Findinos The training staff described a process which differed in conservative ways from that described in the program guidance. The inspectors identified one instance in which the procedures provided apparent conflict in describing the 2-year equalification training program. The broader programmatic procedure described the 2-year program as beginning in the odd number years with the comprehensive written being administered in even numbered years at the same time as the annual operating examinations The procedure for examination development described the 2-year program as a combination of the current annual cycle and the previous year annual cycle. A member of the training staff later told the inspectors that the differentiation was only intended to apply to the scope of the written examination given annually instead of biennially.

Y Through discussions with training staff members, the inspectors determined that several activities to enhance examination validity and integrity were implemented and controlled informally. Most training personnel responsible for development of a specific part of the operating examination kept records of past examination content to prevent examinees from being exposed to the same operating test items in successive annual examinations. However, this activity was not described in programmatic guidanc The inspectors reviewed examinations from the last annual examination and the current examinat;on cycle and observed minimal owflap of written examination test items between successive examinations, including remedial examinations. Overlap of operating examination test items was comparably low within the examination cycle ongoing during the inspectio _ _ _ - _ _ - _ _

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-6-The inspectors identified that the remedial training program did not describe criteria for question reuse on remedial examinations, as compared with the originally failed-examination. The inspectors reviewed the actual reuse of questions on remedial examinations and noted that on average, approximately 5 percent of questions were-repeated on the remedial examination Conclusions The licensee implemented the'requalification program adequately and often went beyond specific programmatic requires. However, the licensee informally controlled important aspects of the progra !

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05.2 Review of Reoua';fication Examinations Inspection Scope (71001)

The inspectors performed a review of the annual requalification examinations,

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including operating tests and biennial / annual written examination, to evaluate general quality, construction, and difficulty level. -The inspectors also reviewed the methodology for. developing the requalification examination Observations and Findinos The operating examinations consisted of job performance measures and dynamic simulator scenarios. The scenarios followed the guidelines of NUREG 1021,

" Operator Licensing Examiner Standards," Revision 8,in complexity and quantitative ,

event requirement The inspectors reviewed the scenarios used in the 1996 annual operating examination and those used in the dynamic simulator examinations that occurred during the weeks of the inspection. The scenarios were written with clear objectives, expected operator actions, and critical task identification and evaluation criteria. The inspectors determined that the quality of the scenarios was consistent with that observed in the

. previous requalification inspection (NRC Inspection Report 50-361;-362/95-19).

During observations of the administration of the walkthrough examination job performance measures (JPMs) on August 28 and September 4,1997, an inspector detected deficiencies that were not corrected during the validation proces JPM J031F contained a step that incorrectly indicated the position of the temperature channel selector and contradicted the procedure. The licensee concluded that this error was not identified because of inattention to detail during validation of the job performance measur JPM J106S contained the wrong time for calculating an estimated criticci position. The licensee determint.d that the original developer of the job

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• JPM J106S contained the wrong time for calculating an estimated critical positio The licensee determined that the original developer of the job performance measure used the correct time, however, the verifier incorrectly changed the tim JPM J110S was incorrectly modeled on a simulator computer touch r,creen. The licensee recognized a difference between the procedure actions and the simulator response during validation, but did not initiate a simulator trouble report until after the problem was again identified during the task performance and further evaluation of the problem was performe . A job performance measure referenced Procedure SO23-2-8 " Saltwater Cooling System Operation," to perform the task. The controlled copy of the procedure in the simulator was not the current revision which had been issued on August 21, 1997. The licensee indicated that their practice was to update the simulator procedures within one day of issuance and initiated an action request to identify necessary enhancements to the procedure update proces During the week of September 15,1997, the inspectors reviewed seven walkthrough examination sets each comprised of five tasks evaluated by job performance measure The inspectors noted some minor discrepancies in the job performance measure steps identified as critical. In one case the task required a recontiguration of electrical distribution, which involved closing a breaker to supply a bus powering essential equipmen+ The step that closed the breaker to the affected bus was not identified as critical nor was any step that relied on the closure of the breakeridentified as critical. In another case, simulated shift supervision directed the operator to establish specific plant conditions at the completion of the primary task. The establishment of those conditions l was not identified as critical even though the direction was specific.

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When reviewing the job performance sets used for the walkthrough portion of the operating e) amination, the inspectors noted that there was significant variance in the total numtur of critical steps (20 - 31) and expected duration to cortplete all tasks (46-71 r.iinutes). The individual responsible for walkthrough examination development stated that the intent was to keep the examinations roughly equal with regard to total time out that no specific effort was made to keep the total number of critical steps equa The individual went on to remark that greater emphasis was given to ensuring that operators were not given the same tasks as in the previous annual examinatio The inspectors discussed the job performance measure defMiencies with the manager of the nuclear training division. The manager indicated that the errors identified in the job performance measures did not meet his expectations for the quality of the job performance measures and initiated an action request to evaluate the conditio The written examinations were developed and administered each year coincident with the administration of the annual operating test. Each wntten examination covered

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8-25 percent of the examination from topics not covered during the training. -The licensee utilized a systems approach to training process to identify tasks, develop objectives and

_ lesson plans, and then develop test questions representative of those lesson plans. The examination outlines were then developed as a representative sampling of the lessons presented during the 2-year period. The inspectors reviewed the examinations and .

noted good question construction, adequate difficulty level, and a representative sampling of topics in 10 CFR 55.41 and 55.43, as required by 10 CFR 55.59. The inspectors also noted 'a higher percentage of senior operator level questions on both the reactor operator and senior operator examinations in the current year examinations over

• he previous year examinations. The inspectors noted that the overall quality of the

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written examinations had improved over that observed in the previous requalification inspectio Conclusions The licensee developed requalification examinations that were generally well constructed, challenging, and discriminated at the appropriate knowledge level. The inspectors determined that written examination quality had improved notabl .3 Reaualification Examination Administration insoection Scooe (71001)

The inspectors observed the administration of all aspects of the requalification operating examinations to determine the licensee evaluators' abilities to administer examinations and assess adequate performance through measurable criteria. The inspectors also observed the plant simulator in support of training and examination administratio Observations and Findinas The evaluators conducted the walkthrough examinations professionally, and thoroughly documented observations for later evaluation. The evaluators appropriately provided job performance measure cues as needed, with no inadvertent cuing observe l The inspectors noted that in each instance where the job performance measures differed from the procedure or the simulator, as reported in Section 05.2 above, the evaluators effectively compensated for the deficiency and the overall job performance measure task was accomplishe The licensee utilized a formal evaluation method to review crew performance against crew critical tasks, crew competencies and individual competencies following the scenario sets. The post-scenario examination evaluation caucuses were well organized and efficient with the evaluation team reaching an accurate consensus on performance result ._

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. During the simulator evaluations, the inspectors noted that the evaluator staff was particularly effective in identifying and properly categorizing operator performance deficiencies and weaknesses utilizing objective evaluation enteria. This was a significant improvement over the previous requalification inspection, which assessed the lack of evaluation enteria as a weaknes The inspectors observed strong operations staff participation. A representative from the operations department performed the crew evaluation in the simulator and was ir.volved with making the pass or fail decision for the cre The inspectors observed that the performance of the simulator in supporting the e amination process was good. TI.e simulator did not exhibit any simulator fidelity problems during the examinatio Conclusions The facility evaluators administered the examinations professionally and consistentl The facility evaluators effectively identified strengths and weakr. esses in crew and individual performance and conducted good cr. ' ques. The licensee had developed objective evaluation enteria that improved the efficiency and effectiveness of the evaluation process.

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05.4 Remedial Trainina Proaram Review Inspntion Scooe (71001)

The inspectors assessed the effectiveness of the rernedial training conducted during this requalification cycle. The inspectors revkwed records associated with remediation to determine if the planned remediation was api repriate and timely Observationt_and Findinas The inspectors reviewed remedial documentation for the 1996 and 1997 periodic and annual examination failures, and compared it with the requirements of Procedure SO123-XXI-1.11.1," Licensed Operator Requalification Program Description,"

Revision 6, Section 6.5, and SO123-XXI-8.4, " Licensed Operator Requalification Examinations," Revision V. The inspectors determined that the licensee identified, scheduled and conducted remedial training as required by the appropriate procedure.

a The inspectors reviewed the scope of the remedial training that v>as conducted and determined it to be appropriate for the identified failures, as well as other identified weaknessee Rernedial training consisted of a minimum of review of areas failed and a similar type of re-examination following remediatio $

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-10- Conclu:,lons The licensee implemented a remedial training program that was responsive to identified weaknesses and effective in retraining and retestin .5 Review of Conformance with Ooerator License Condit!nny lDsoection Scoce (71001)

The inspectors evaluated the adequacy of the requalification program's compliance with 10 CFR 55.53, " License Conditions." The inspectors interviewed operators and training management, and examined the licensee's records to determine compliance for conditions to maintain an active operator license, reactivation of licenses, and madical fitnes Observations and Findinas Licensed operators were required to wear self-contained breathing apparatuses for performance of duties under abnormal environmental conditions in the control roo Additionally, those operators, whose licenses were conditioned to require corrective lenses while performing licensed duties, were required to continue to comply with that limitation while wearing a self-contained breathing apparatus. Following the issuance of NRC Information Notice 97-66, the licensee determined that a number of licensed operators (approximately 26), whose licenses were conditioned to require corrective lenses, either did not have special frarnes and lenses for self contained breathing '

apparatuses used in the control room, or did not have current prescriptions for those tenses. The licensee corrected this condition for all of the applicable licensed operators, except for one senior reactor operator who was a shift supervisor normally assigned to a control room cre This senior operator was required by his license to wear corrective lenses while performing licensed duties. Further, the licensee's Procedure SC123-XV-41, " SONGS Respiratory Protection Program," stated that, " respirator users who require corrective lenses . . . shall be provided with respirators which are fitted with the appropriate item (s)."

However, SCE Form 21213 (CW), * Medical Examination," stated that when " binocular distance vision was not correctable to at least 20/40 in the better eye, respiratory glasses may be indicated." Since the senior operator's binocular distant visual acuity without correction was 20/18, the licensee concluded that the operator was not required to wear conective lenses while wearing a self-contained breathing apparatus. The licensee failed to recognize that the guidance on the medical form did not account for the visual acuity requirements for licensed operatoro, and that it did not permit waiving those requirements. The lack of adequate procedures to ensure the availability of corrective lenses for the one senior operator was identified as a violation of Technical Specification 5.5.1.1.a (50-361;-362/9720-01).

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-11-As a result of a third party audit, the licensee revised the governing program procedure to require instructors, who held operator licenses, to participate as a crew member to be credited for simulator training. Prior to the revision, instructors with operator licensees were allowed to credit instructional activities in the simulator toward accornplishment of required participation in the requalification program. The inspectors reviewed the licensee's response to the audit finding and determined that it did not rigorously evaluate whether the licensee's prior practice satisfied regulatory requirements. The licensee had revised their practice to avoid vulnerability to unfavorable interpretation of regulatory wordin When this performance was coupled with the licensee's failure to recognize that medical requirements for Part 55 licensees took priority over guidelines for celf contained breathing apparatus corrective lenses, the inspectors concluded that the licensee could enhance its compliance review activitien with regard to 10 CFR Part 55 requirement Conclusions The inspectors concluded that the licensee's practices generally assured conformance with operator license conditions. However, the inspectors identified a violation for inadequate procedures to ensure that operators with licenses conditioned to require corrective lenses could continue to satisfy that condition while wearing self-contained breathing apparatuses. Further, the inspectors concluded that the licensee's compliance reviews of 10 CFR Part 55 requirements could be improve LEenagement Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on September 19,1997. The licensee acknowledged the findings presentn The licensee did not (dentify as proprietary any information or materials examined during the inspectio ' ' ' ' ' ' ' '

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee D. E. Nunn, VP Engineering and Technical Services G. T. Gibson, Compliance Manager R. L Sandstrom Training Manager K. A. Slagte, Nuclear Oversight Manager G. L. Plumlee Ill, Compliance K. Rauch Operations Training Supervisor A. Hegemeyer, Requalification Training Leader C. Williams, Compliance Supervisor T. Vogt, Plant Superintendent D. Cox, Compliance Engineer E. Gatto, Training Supervisor NRQ J. Russell, Resident inspector INSPECTION PROCEDURES USED 71001 Licensed Operator Requalification Program Evaluation ITEMS OPENED 50 361;-362/9720-01 NOV SCBA Prescription Lens for licensed operators DOCUMENTS REVIEWED Procedures Training Procedure, S0123-XXI-1.11.7, * Licensed Operator Requalification Training Program .

Description," Revision 6 Training Procedure, S0123 XXI 8.4, " Licensed Operator Requalification Examinations," Revision

General Health Physics Procedure, S0123-XV 41, " SONGS Respiratory Protection Program,"

Revision 2 Operations Procedure, S0123-0-7," Operator Training Responsibilities," Revision 4

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2 Forms Medica! Form, SCE 21213 (CW), * Medical Examination for Respirator Use and Asbestos Surveillance " Revised August 1996 Medical Form, SCE HP(123) 19, * Respirator User Medical Evaluation," Revision 4 Training Form, NTD 1.11.7-2," Academic Review Documentation Form," Revision 0 Training Form, NTD 8.4-6, t-Simulator Scenario Set Review Checklist," Revision 0 Training Form, NTD 8.4-7," Licensed Operator Annual Dynamic Simulator Examination Evaluation Form," Revision 6 Training rorm, NTD 8.4 9, " Remedial Training Documentation Form," Revision 3 Training Form, NTD 8.413, " Dynamic Evaluation Review Checklist," Revision 1 Training Form, NTD 8.4-18, " Written Question Checklist," Revision 2 Training Form, NTD 8.4-19," Licensed Operator Written Requalification Examination Review Checklist," Revision 0 Train;ng Form, NTD 8.5 2," Written Question Checklist," Revision 0 Training Form, NTD 8.5-3," Written Examination Quality Assurance Check Off Sheet,"

Revision 0 Other 1996 Annual Dynamic Simulator Examinations 1996 AnnualWritten Examination 1997 Annual Written Examination (weeks one and two of 1997 written examination cycle)

1997 Annual Job Performance Measure Examinations 1997 Annual Dynamic Simulator Examination (week one of 1997 simulator examination cycle)

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