IR 05000373/1993015
| ML20044G803 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/26/1993 |
| From: | Doonrnbos R, Jordan M, Shembarger K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20044G800 | List: |
| References | |
| 50-373-93-15, 50-374-93-15, NUDOCS 9306040290 | |
| Download: ML20044G803 (11) | |
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.i U. S. NUCLEAR REGULATOR' COMMISSION
REGION.III Reports No. 50-373/93015(DRS); No. 50-374/93015(DRS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-ll; NPF-18'
Licensee:
Commonwealth Edison Company i
Executive Towers West III i-1400 Opus P1 ace, Suite 300 l
Downers Grove, IL 60515 q
Facility Name:
LaSalle County Nuclear Station - Units 1 and 2 Inspection At:
Marseilles, IL 61341 Inspection Conducted:
Week of May 10, 1993 Inspectors:
dWA
$$oN3 R. Doornbos v U
Date (. T & k 5%l%
K. Shembargero Date Approved By:
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f3 Fi. 7 400rdan, Chief Date-Opetator Licensing Section 1 Inspection Summary:
Inspection conducted durino the week of May 10. 1993 (Reports No.
50-373/93015(DRSh No. 50-374/93015(DRS));
Area Inspected:
Licensed Operator Requalification Training-Program Inspection in accordance with NRC Temporary Instruction 2515/117.
Results: Overall, the inspectors determined that the licensed operator requalification training program met the requirements of ~10 CFR 55. ~ Several program strengths and weaknesses were identified, in addition to other observations.
No violations or issues requiring further NRC review were identified as a result of this inspection.
Proaram Strenaths:
The seventh week of training added to the beginning of each training
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module to allow for. operations management' review of module content.
prior to' its use in requalification training, was' considered 'a program strength. -(Section 2.10)'
The attendance rate at scheduled requalification training sessions was
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very high.
(Section 2.10)
.9306040290 930527 PDR ADDCK 05000373 O
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Inspection Summary
The facility's dynamic simulator scenario evaluation documents were very
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concise and complete.
(Section 2.1)
Crew communications in the simulator for two of the three crews observed
was very good.
(Section 2.3)
The performance of the job performance measure (JPM) evaluators was very
good, specifically in providing the required cues.
(Section 2.4)
z The JPM packages contained guidance for the evaluators to provide
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rudiological infor= tion, normally supplied by a radiological technician.
Inclusion of radiological cues added realism to task performance.
(Section 2.1)
Prooram Weaknesses:
Evaluator objectivity during the dynamic simulator exam was weak at
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times.
Specifically, since followup questions were used primarily for deficiencies linked to critical tasks, the causes for weaknesses-observed in operator performance of noncritical tasks were not always determined. As a result, evaluation of some crew competencies was based partly on speculation. Without determining the causes of observed -
deficiencies, adequate remediation and program revision may not be accompl i shed.
The minimal usage of-post exam ' questioning to follow up-on observed deficiencies was considered a program weakness..(Section 2.4)
The lack of required training on evaluation techniques for all simulator-
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evaluators in the requalification program was considered a program weakness.
(Section 2.7)
Training and/or evaluation for staff licensed individuals, at times,
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differs from the training and evaluation for crew licensees.
For example, during the reactivity management drills, a qualified nuclear engineer and an operations management representative are used_for operations crews, while they are not used for the' administrative crews.
The requalification program should provide all licensed individuals' with'
the same training and evaluation opportunities.. Differentiating between operations and administrative crews during training and/or evaluations was considered a program weakness.
(Section 2.3)
Program controls do not exist to control the amount of duplication
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between (1) module quizzes and practice exams and the annual written exam, and (2) quizzes and/or annual written exams administered during-the same module. Without program controls, an excessive amount of duplication from quiz to exam could occur, which could affect the validity of the exam.
Lack of program controls to limit question duplication was considered a program weakness.
(Section 2.12)
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Inspection Summary
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The requalification program feedback process was not closed looped, in f
that the licensee providing comments on training did not always get
feedback on the resolution of the issue. The number of trainee comments j
could decrease if the facility does not provide feedback on their
resolution.
Lack of a program requirement to provide resolution on
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program feedback to trainees was considered a program weakness.
i (Section 2.6)
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Other Observations:
l On occasion, the nonlicensed operators were integrated into the licensed
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operator requalification training program.
Including nonlicensed
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operators in the requalification program was viewed very favorably by
the licensed operators.
(Section 2.3)
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Weaknesses in the content of the Part A static exam were identified by
the facility exam administrators.
Specifically, it was identified during administration of the exam to the first crew that (1) one
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question was inadvertently omitted from the SR0 exam,-(2) one question was duplicated on the SR0 exam, (3) one question on the SR0 exam
contained the correct answer, and (4) one question on both the R0 and
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SR0 exams contained two correct answers as a result of a modification i
made to the initial conditions (IC) set after the exam'was developed.
j The tccining staff provided an analysis of why the weaknesses occurred,
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and what actions would be taken to prevent recurrence. Tha corrective L
actions were reviewed by the inspectors and appeared to be adequate.
(Section 2.4)
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REPORT DETAILS
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.l.0 Persons Contacted Commonwealth Edison Company (Ceco)
- W. Murphy, Site Vice President
- J. Atchley, Senior Operations Supervisor
- L. Blunk, Simulator Supervisor
- D. Carlson, NRC Coordinator i
- J. Lockwood, Regulatory Assurance Supervisor
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- K. Rack, BWR Operations Training Supervisor
- J. Schmaltz, Operations Manager
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- T. Schaffer, Executive Assistant t
U. S. Nuclear Reaulatory Commission (NRC)
- H. Jordan, Chief, Operator Licensing Section 1
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C. Phillips, Resident Inspector, LaSalle County Station
- L. Vick, HOLB, NRR
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Illinois Department Nuclear Safety (IDNS)
- J. Roman, Resident Inspector, LaSalle County Station
- Denotes those present at the exit meeting on May 14, 1993.
Other persons were contacted as a matter of course during the
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inspection.
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2.0 Introduction The purpose of this inspection was to perform a review of your licensed operator requalification training program in accordance with NRC Temporary _
Instruction 2515/117. The inspection focused on the content and effectiveness of your licensed operator requalification training program, which included a review of the following areas:
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Adequacy of selected facility licensee developed written and l
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operating examinations.
Significant operator errors that have occurred over the past two
years that may have been a result of ineffective training.
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Facility licensee's process for identifying operator performance i
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deficiencies and incorporating them into the evaluation portion of the training program.
Facility licensee's effectiveness in conducting written
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examinations and operating tests'to ensure operator mastery of program content.
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Facility licensee's use of objective performance standards when
conducting evaluations and critiques of operators'and crews to determine whether' pass / fail decisions were made objectively.
- Effectiveness of the licensee's process for revising its
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continuing training program to maintain it up-to-date, including the use of student feedback.
Adequacy of the licensee's process to train and evaluate the
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licensed operator training staff.
Training conducted as a result of operator errors that have
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occurred over the past two years to determine the effectiveness of the training.
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Previously administered remedial training to ensure it adequately
addressed licensed operator crew performance weaknesses.
Facility's process for managing the requalification training
program to ensure compliance with 10 CFR 55.
Simulator performance and its fidelity to the reference plant to
determine if it was adequate to support the requalification program, and the safety impact of any negative' training caused by'
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simulator inadequacies.
- Adequacy of administrative procedures that were-in place that
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ensure the integrity of examinations and ' tests, and observation of exam activities during the inspection week and review of-the
associated exam results for any indications of examination
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compromise.
The adequacy of Quality Assurance involvement in the area of
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licensed operator requalification training.
2.1 Adeauacy of selected facility licensee developed written and operatina examinations.
A review of the current module written and operating examinations developed by-
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the facility was performed using the associated exam review checklists in
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Appcndix A of Tl 2515/117, NUREG/BR-0122 and NUREG-1021. The following-i observations were made during the review:
The comprehension level tested on the current module examinations was
comparable to the comprehension level tested on the two previously administered NRC examinations.
The examinations were constructed.in accordance with the facility's
sample plan.
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The facility licensee used lesson plans and learning objectives for the
requalification program under review to construct the examinations, as
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denoted in the facility's sanple plan.
Objective performance standards were utilized for the written and
operating examinations administered during the. current module.
The written examinations were developed to discriminate at the-
appropriate level.
The SR0 and RO written examinations adequately sampled the items stated'
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in 10 CFR 55.41 and 10 CFR 55.43 and the operating examinations
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adequately sampled the items stated in 10 CFR-55.45.
The JPM packages contained guidance for the evaluators to provide
radiological information, normally supplied by a radiological technician.
Inclusion of radiological cues added realism to task performance and was considered a program strength.
The dynamic simulator simulator. scenarios administered during the
inspection week were of high quality and were challenging. The quality of the dynamic simulator scenarios was considered a program strength.
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The facility's dynamic simulator scenario evaluation documents were very
concise and complete. This was considered a program strength.
A review of seven modification packages was performed to determine'if
the modifications had been integrated into the requalification program.
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All were found to be adequately implemented into the training and
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examination process.
2.2 Sianificant operator errors that have occurred over the cast two years that may have been a result of ineffective trainina,
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A review of LaSalle County Station SALP Report 92001 and selected LERs (Unit 1: 92010, 92015, 92016; Unit 2: 92015) was performed to determine if previously identified operator errors may have been a result of ineffective training.
Results of the review did not indicate that ineffective training was a contributor to the operator errors.
2.3 Facility licensee's process for identifyino operator performance deficiencies and incorporatina them into the evaluation oortion of the trainina oroaram.
Through interviews and review of previously administered training, it was -
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identified that the facility licensee had identified operator performance deficiencies, and incorporated them into the training and evaluation portion of the training program. Operator performance deficiencies, if not documented in an LER, are primarily identified by operations management and communicated to the training staff. The following are examples that were identified-during the inspection:
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Operator performance deficiencies were observed by facility management
in the plant in area of feedwater control.
As a result, training was
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developed and administered in a subsequent training module.
l Crew communications in the simulator for two of the three crews observed
during the inspection was very good and was considered a program l
strength.
During interviews, it was revealed that crew communications
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was an area that was stressed in training due to previously identified weaknesses.
Due to identified operator performance deficiencies, a weekly reactivity
management drill was added to each requalification training module.
l However, it was identified that during the drills, a qualified nuclear j
engineer and an operations management representative were used for
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operations crews, while they were not used for the administrative crews.
The requalification program should provide all licensed individuals with
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the same training and evaluation opportunities.
Differentiating between operations and administrative crews during training and/or
evaluations was considered a program weakness.
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On occasion, the nonlicensed operators were integrated into the licensed i
operator requalification training program to improve crew teamwork.
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Including nonlicensed operators in the requalification program was viewed very favorably by the licensed operators.
2.4 facility licensee's effectiveness in conductina written
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examinations and operatino tests to ensure operator mastery of
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proaram content.
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The inspectors interviewed licensed operators and training instructors and observed the administration of the written and operating examinations r
administered during the inspection week to determine the facility licensee's -
i effectiveness in conducting written examinations and operating tests to ensure operator mastery of program content.
The following observations were made
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during the review:
Although the examinations were not always conducted as planned, the
errors in administration were detected and corrected for subsequent i
examinations.
For example, during administration of the Part A static
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exam to the first crew, the facility exam administrator identified that (1) one question was inadvertently omitted from the SRO exam, (2) one
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question was duplicated on the SR0 exam, (3) one question on the SR0
exam contained the correct answer, and (4) one question on both the RO j
and SRO exams contained two correct answers as a result of a
modification made to the IC set after the exam was developed. The
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training staff corrected the errors for subsequent exams, and an i
analysis of why the weaknesses occurred and what actions would be taken i
to prevent recurrence appeared to be adequate.
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The facility licensee's examination schedule facilitated reducing undue
operator stress.
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i Although' crew and operator performance errors made during simulator.
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evaluations were detected, they were not always adequately addressed by the facility evaluators. Specifically, since followup questions were i
used primarily for deficiencies linked to critical tasks, the causes for weaknesses' observed in operator performance of noncritical tasks were
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not always determined. As a result, evaluation of some crew competencies was based partly on speculation. Without_ determining the
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causes of observed deficiencies, adequate remediation and program
revision may not be accomplished.
The minimal usage of post exam questioning to follow up on observed deficiencies was considered a program weakness.
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The performance of the JPM evaluators was very good, specifically in
providing the required cues. This was considered a program strength, a
Errors made by individual operators during the walkthrough examinations a
were detected and adequately addressed by facility evaluators.
Overall, critiques of operators and crews after the simulator
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examination were effective in denoting both strengths and weaknesses.
However, due to the minimal usage of post exam questioning to follow up on observed deficiencies (as discussed above), the observed performance-may not have always been accurately appraised.
Management guidance parallelled the actual conduct of testing as it was.
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observed.
Overall, facility evaluators effectively identified individuals and'
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crews requiring remediation, and appropriately indicated when removal from shift activities was warranted.
2.5 Facility licensee's use of objective performance standards when conductina evaluations and critioues of operators and crews to determine whether pass / fail decisions were made objectively.
The inspectors interviewed training instructors and a training supervisor,
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reviewed written performance standards, and parallel graded selected written
and operating examinations to determine if the facility licensee used.
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objective performance standards when conducting evaluations and critiques of.
operators and crews to determine whether pass / fail decisions were made
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objectively. The performance standards were found'to be clear and relevent, and used consistently and objectively by facility evaluators.
2.6 Effectiveness of the licensee's process for revisina its
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continuina trainina oroaram to maintain it up-to-date. includina-
the use of student feedback.
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The inspectors interviewed licensed operators and training personnel and-
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reviewed student feedback forms to determine the effectiveness of the
licensee's process for revising its continuing training program to maintain it up-to-date, including the use of student feedback. The following observations
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were made:
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The instructor assigned to administer training on a given topic was
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required to either develop a new lesson plan or revise an associated lesson plan prior to its use to include changes in plant' design.and-applicable procedures, and in regulator requirements, as written plant and industry events.
Review of associated documentation revealed that the method used to upgrade training material appeared to be adequate.
Although procedures existed and were implemented to solicit _ student
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feedback on requalification training, the feedback process was not closed looped, in that the licensee providing comments on training _did.
not always get feedback on the resolution of the issue. The number of trainee comments could decrease if the facility does not provide feedback on their resolution.
Lack of a program requirement to provide resolutic,n on program feedback to trainees was considered a program weakness.
2.7 Adeauacy of the licensee's orocess to train and evaluate the licensed operator trainina staff.
The inspectors interviewed training instructors and a training supervisor,-
reviewed LAP-610-1, Rev. 6, " Instructor Qualification Program", and reviewed qualification packages for several instructors. Overall, the training and evalation process for the licensed operator training staff appeared to be adequate. However, it was identifiei that training on evaluation _-techniques for all simulator evaluators in the requalification program was not required and was not performed. Specifically, facility personnel performing as evaluators that were not members of the training staff did not receive training on evaluation techniques. The lack of required training on evaluation techniques for all simulator evaluators in the requalification program was considered a program weakness.
2.8 Trainina conducted as a result of operator errors that have-occurred over the past two years to determine the effectiveness of the trainina.
A review of the process for including training on operator errors was performed.
In addition, a review was performed to determine if the operator errors described in LERs 92010, 92015 and 92016 for Unit I and LER 92015 for Unit 2 were incorporated into the training program.
It was determined that training on the LERs was provided in the' form of required reading and a followup discussion in requalification training. Overall, the process for including training on operator errors appeared to be adequate.
2.9 Previously administered remedial trainina :9 ensure it aieouately addressed licensed operator crew performance weaknesses.
A review of remedial training for a crew that failed the dynamic simulator examination during the current module was reviewed to ensure it adeouately-addressed licensed operator crew performance weaknesses.
Overall, the remedial training provided to the crew appeared to be adequate.
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2 10 Facility's process for manaaina the reaualification trainina program to ensure compliance with 10 CFR 55.
Through interviews with training personnel and review of revision 8 of the Administrative and Course Management Instructions (ACMI) for the Licensed Operator Requalification Program (and prompt change request PCR 93-1 to the ACHI), the inspectors determined that adequate controls existed to ensure.10
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CFR 55 requirements were being met.
In addition, the following program strengths were identified:
A seventh week of training was added to the beginning of each training
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module to allow for operations management review of module content prior to its use in requalification training..The increase in operations management involvement in the requalification training program was
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i considered a program strength.
The attendance rate at scheduled requalification training sessions was
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very good, and was considered a program strength.
j 2.11 Simulator performance and its fidelity to the reference olant to determine if it was adeauate to support the reaualification oroaram. and the safety impact of any neaative trainina caused by simulator inadeauacies.
During administration of the dynamic simulator exam, simulator fidelity issues-l
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were identified and are described in Enclosure 2 of this report.
Overall, the-simulator performed well, and no negative training caused by simulator inadequacies was identified.
2.12 Adeauacy of administrative procedures that are in place that
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ensure the inteority of examinations and tests. and observation of i
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exam activities durina the inspection week and review of the associated exam results for any indications of examination compromise.
The inspectors interviewed training instructors, observed exam administration during the inspection week and reviewed associated exam results for any indications of examination compromise.
Although no concerns related to exam compromise for the observed exam were identified, a concern relating to
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question duplication was identified. Specifically, it was identified that i
controls do not exist to control the amount of duplication between (1) module quizzes and practice exams and the annual written exam, and (2) quizzes and/or annual written exams administered during the same module. Without program controls, an excessive amount of duplication from quiz to exam could occur, which could affect the validity of the exam.
Lack of program controls to limit question duplication was considered a program weakness.
2.13 The adeauacy of Ouality Assurance involvement in the area of
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licensed operator reoualification trainina.
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Quality Assurance involvement was reviewed te determine if the Technical Specification requirements for Quality Assurance audits were being satisfied.
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Discussions with Quality Assurance personnel and review of the audits revealed
that the audits focused primarily on documentation review, and that Technical i
Specification requirements were being satisfied.
l 3.0 Exit Meetino An exit meeting was conducted on May 14, 1993, at the LaSalle County Station to discuss the major areas reviewed during the inspection, the strengths and weaknesses identified, and the inspection results.
Licensee representatives
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and NRC personnel in attendance at this exit meeting are documented in Section 1.0 of this report.
The inspectors also discussed the likely informational content of the inspection report with respect to documents reviewed by the
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team during the inspection. The licensea did not identify any documents or i
processes as proprietary.
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