IR 05000382/1993021
| ML20058N657 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/08/1993 |
| From: | Pellet J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20057G045 | List: |
| References | |
| RTR-NUREG-1021 50-382-93-21, NUDOCS 9310200130 | |
| Download: ML20058N657 (11) | |
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APPENDIX A U.S. NUCLEAR REGULATORY C0NilSS10N
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REGION IV
Inspection Report:
50-382/93-21 License: NPf-38 Licensce:
Entergy Operations, Inc.
P.O. Box B
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Killona, Louisiana Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Waterford Steam Electric Station, Unit 3 Inspection Conducted:
September 13-17, 1993 Inspectors:
S. L. McCrory, Acting Project Engineer, Project Section D,
Division of Reactor Projects J. I. Tapia, Reactor inspector, Operations Section, Division of Reactor Safety Approved:
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/ 0 -J"- 9 3 p J~T~~ FelTeCthiefE0perations section Date Division of Reactor Safety Lqmiu;1 ton Summary Areas Inspected:
Routine, announced inspection of the licensees licensed operator requalification program.
Rgsults; The written examinations were adequate with respect to scope, depth,
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cognitive level, and the licensee's sample plan, and were properly controlled to prevent compromise (Section 1.1.1)
The scenarios appropriately sampled the items contained in
10 CfR 55.45(a) and were consistent with the guidelines in NUREG-1021, Section 604, Revision 7 (Section 1.1.2).
lhe level of emergency plan implementation and evaluation during the
dynamit simulator examinations was regarded as a positive initiative to create a more realistic operational environment and to make more effective use of simulator time and evaluation opportunities (Section 1.1.2).
9310200130 931013
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PDR ADOCK 05000382 G
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-2-The mix of tasks for the walkthrough examinations was appropriately
balanced between in-plant and control room tasks, and the JPHs adequately identified critical elements.
The tracking system to pgevent operators from being evaluated on JPHs they had validated was considered
a strength (Section 1.1.2)
The parallel evaluations of the inspectors agreed with those of the
licensee (Section 1.3).
- i The facility evaluators were generally well trained and qualified to i
perform objective evaluations of operator performance (Section 1.4).
The licensee's program for remediation training included those i
attributes necessary to assure proper remediation and retesting prior to
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the resumption of licensed operator duties (Section 1.5).
The recently developed procedures for the examination process was
assessed as a positive action (Section 1.6).
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The various feedback mechanisms were effective and generally well
perceived.
The communications interface between operations and training was a particular strength and a significant contributor to the overall success of the operations requalification training program (section 1.6).
i Revisions to the shift supervisor's control copy of the Emergency Plan
Implementing Procedures in the simulator had not been entered in a timely manner, which resulted in a noncited violation (Section 1.2.2.1).
Summary of In5DeClion findinqil A noncited violation was identified (Section 1.2.2.1).
- Attacheents:
Attachment l-Persons Contacted and Exit Meeting
Attachment 2-Documents Reviewed
Attachment 3-Simulation facility Report
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DETAILS j
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1 LICENSED OPERATOR REQUALIFICATION PROGRAM EVALUATION (TI 2515/117)
During the inspection, the licensee's requalification program was assessed to determine whether the program incorporated appropriate requirements for both evaluating operator's mastery of training objectives and revising the program in accordance with 10 CFR 55.
The licensed operator requalification program assessment included a review of training material for the past year, evaluation of the program's controls to assure a systems approach to training, and operatin crew performance during annual requalification examinations.
This includ a review of the facility documents listed in Attachment 2.
Further, the inspectors assessed the effectiveness of the examination evaluators in conducting the examinations.
1.1 (ramination Develgement The licensee developed the written and operating examinations using the guidelines of NUREG-1021, Licensed Operator Examinor Standards, which the licensee had reissued as Nuclear Training Instruction (NTI)-0P-004, Examination / Quiz Development, Revision O.
g 1.1.1 Written Examination The inspectors reviewed the written examinations fcr cognitive level, item
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construction, overlap across examination weeks, proper sampling of system and administrative knowledge areas, and linkage to the sample plan.
In all respects the examinations w.re adequate. The examinaticns all contained 40 multiple choice questions and were constructed to be taken in one 3-hour sitting in the simulator.
The examinations had been time validated in advance
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by licensed operators or training staff who actually took the examination, and were not a part of the crew being evaluated. The licensce's controls on examination material and the time validation process were considered adequate to prevent examination compromise.
The ratio between system knowledge areas and procedures, limits, and control knowledge areas was approximately 50 percent on all examinations reviewed.
Minor construction deficiencies were identified in the distractors of a few multiple choice questions; however, examination validity was not affected.
The senior reactor oper ator (SRO) examinations appropriately evaluated SR0 level knowledge and tended to test at higher cognitive levels overall.
The inspectors evaluated that test question re-use across examination weeks was no more than about 15 percent.
lhe inspectors determined that the examinations met the licensee's sample plan which properly reflected training over the requalification cycle.
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-4-1.1.2 Operating Examination 1.1.2.1 scenarios
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The inspectors reviewed the dynamic simulator scenarios for sampling of
10 CFR 55.45(a) items, critical task identification, emergency operating procedure (EOP) use, and complexity.
Each scenario set required the use of contingency E0Ps in at least one scenari:.
The scenarios appropriately
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sampled the items contained in 10 CFR 55.45(a) and contained numbers of
malfunctions, abnormal conditions, major transients, and critical tasks consistent with the guidelines in NUREG-1021 Section 604, Revision 7.
Critical tasks were properly identified along with expected operator actions for all planned evolutions, and the scenarios were previewed on the dynamic simulator as part of the validation process. Additionally, the scenarlos were
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constructed to require emergency classifications and activation of the emergency plan implementing procedures through initial notification and dose assessment if required by the simulated plant conditions.
Emergency preparedness specialists were assigned to the evaluation team to assess crew performance in event classification and emergency plan implementation.
The inspectors regarded this activity as a positive initiative to create a more realistic operational environment and to make more effective use of simulator i
time and evaluation opportunities.
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1.1.2.2 Walkthrough Examination Each examinee was evaluated on five tasks using Job Performance Measures (JFM).
The mix of tasks was appropriately balanced between in-plant and control room tasks, and the JPMs adequately identified critical elements.
As part of the examination development, the licensee reviewed operator JPM validation records to ensure that individuals were not examined using JPMs which they had recently validated.
In some cases, this resulted in different walkthroughs being given to individuals on the same crew. This level of tracking and development criteria was considered a strength.
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[ramination Administration the examinees were briefed in all aspects of the examination using guidelines that were virtually the same as those found in the appropriate sections of NUREG-1021. ES 600 series, Revision 7.
1.2.1 Written Examination The inspectors observed toe start of the written examinations, and periodical'y checked examinee progress during the examination, Examinee
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spacing and reference material availability in the examination facility were satisfactory.
All examinees completed the written examination within the allotted time with sufficient time for at least one review.
The completion times of the examinees indicated that the time validation process used for the examinations was appropriate to balance examination difficulty with allotted time.
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i f L-5-1.2.2 Operating Examination a
g 1.2.2.1 Dynamic Simulator Examination
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The inspectors observed the entire examination for at least one creu and portions of the examinations for all crews evaluated during the inspection week, and performed parallel evaluations of one crew.
Event timing was
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appropriate and simulator performance was generally satisfactory. A fidelity *
problem was observed when, after a manual reactor trip, electrical loads failed to automatically transfer to the startup transformer and the A2-A3 bus tie breaker would not remain shut once power was restored through the startup transformer. While these anomalies were not consistent with actual design performance, the simulator properly modeled plant behavior for these events.
Since the anomalies did not affect the examination validity, no adjustment to the examination was required to permit an adequate evaluation.
I in addition to the examination evaluation team, the operations su erintendent ob, served the performance of all shift crews which was assessed as a positive a'ctivity by the inspectors.
During the administration of the simulator portion of the examination on
September 15. 1993, the inspectors noted that Control Copy Book No. 105 (Simulator Shift Supervisor) did not contain a current revision of Procedure EP-001-030, " Emergency Plan Implementing Instruction Site Area Emergency."
Revision 16 of this procedure was being implemented in the simulator; however, Revisica 18 of the procedure had previously been transmitted to the Emergency Planning Department on August 18, 1993. The inspectors verified that the correct copy of the procedure was available in the plant control room. The Emergency Planning Department was the custodian of control copy no.105 and, as such, was responsible for updating the procedure within 10 days of receipt of the transmittal, in accordance with Administrative Procedure UNT-004-009,
" Control, Distribution, Handling and Use of Plant Procedures". The update to EP-001-030 was not made until September 15, 1993.
In addition, Revision 17 of this procedure could not be located in Control Copy Book No. 105.
It was I
subsequently determined that Revision 17 was transmitted to Emergency Planning
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on March 15, 1993. Available records indicated that the procedure was updated
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that same day.
The licensee issued Condition Report No. CR-93-151 on i
September 16, 1993, to perform an investigation into the root cause of the f
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outdated procedure.
In addition, the licensee initiated a full audit of all i
emergency preparedness procedures to assure that all procedures were current.
Emergency preparedness management personnel conducted interviews with individuals responsible for updating manuals and preliminarily determined that attempts at updating the manual had been made, but were unsuccessful because the simulator was unavailable as a result of ongoing training activilles.
The responsible personnel erred by not informing their management of the unsuccessful attempts 50 that other arrangements could be made.
Emergency preparedness management conducted briefings with the entire department to discuss this error and management expectations concerning procedural adherence requirements.
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This problem represented a failure to adhere to Technical Specification 6.8
" Procedures and Programs", which requires that procedural requirements for maintaining procedures be followed.
This problem was determined to be an isolated case which had no safety impact, and the licensee's corrective acticns were evaluated as adequate to prevent recurrence; therefore, the i
criteria specified in Section Vll.B.1 of Appendix C to 10 CFR Part 2 were satisfied to permit this to be a noncited violation.
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1.2.2.2 Walkthrough Examination i
The inspectors observed various portions of the walkthrough examination and performed parallel operator evaluations. The examinations were well
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coordinated and maximized use of the dynamic simulator for control room tasks.
j 1.3 hamination Pesults All examinees passed all portions of the requalification examination during the week of inspection.
The parallel evaluations of the inspectors agreed, I
with those of the licensee.
1.4 Licensee Evaluator Performanc.
h The inspectors observed evaluator performance during all aspects of the examinations.
The evaluators were generally well trained and qualified to perform objective evaluations of operator performance; however,sthe inspectors observed that during the evaluation process following the dynamic simulator portion of the operating examination, the evaluators tended to attribute
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multiple competency weaknesses to a single action or behavior on the part of an individual or crew.
This tended to dilute their ability to identify performance weakness root causes to permit optimum remediation or training i
feedback.
Further, the licensee used a five point scale (1.0 - 3.0 in 0.5 unit increments) for evaluating crew and individual performance in the simulator. The 1.5 and 2.5 points on the scale had no performance criteria associated with them, whereas the other points were defined with the same criteria found in NUREG-1021. The evaluators assigned subjective criteria to those points on a case basis throughout each evaluation.
That resulted in a tendency to raise grade point averages over what may have resulted from using only those grade points with predetermined performance criteria; however, the
inspectors reviewed results from the prior two weeks of examinations and concluded that the pass-fall determinations had been appropriate.
1.5 Remediation Training i
Prior to the inspection week, two weeks of requalification exams were administered which resulted in one failure of the written examination and one failure of the simulator portion of the operating examination. The inspectors reviewed the licensee's methodology for examination results feedback, as well as their proposed remediation training. The review included interviews with the two examinees to determine their perspective about how prompt and objective the feedback they received was. The inspectors determined that the
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licensee provided prompt oral dircussions to review the identified weaknesses
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and that the particular remediation requirements were consistent with
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correcting those weaknesses. The inspectors reviNed the draft written examination which was to be given to the examince who failed the written examination and concluded that the two examinations were sufficiently I
different to allow a valid evaluation. The inspectors also reviewed the remediation training for the examinee who failed the simulator examination and determined that it was adequate. The inspectors concluded that the licensee's'
program for remediation training included those attributes necessary to assure proper remediation and retesting prior to the resumption of licensed ope _rator duties.
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1.6 Programmatic Areas
While the requalif cation training and evaluation program at Waterford has been repeatedly assessed as strong, much of the process has been somewhat informal in that there was only a general commitment to develop, administer, and evaluate examinations using the guidelines of NUREG-1021. Recently, the licensee proceduraltzed these aspects of the requalification process at the encouragement of several experienced licensed operators who had been assigned to training as instructors and evalcators in recent months. With only minor exceptions, the licensee has incorporated the criteria and guidelines of the ES 600 Series, part of NUREG-1021, Revision 7.
The inspectors assessed the
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formalization of these portions of the process as a positive action in that it made the continued success of the program less dependent on individual personal skills and experience.
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The inspectors interviewed several individuals in both the training and operations departments regarding feedback processes and the effectiveness ofg the operations-training interface. The training department has a standard feedback form which operators are encouraged to complete for formal training, such as class room or simulator instruction. The form may also be used to provide feedback on training needs or desires identified apart frcm formal training. Additionally, there is an Operations / Training Improvement Committee (0 TIC) comprised of licensed and non-licensed shift operators and training instructors, and chaired by a shift supervisor. One of the stated objective os the OTIC is to " provide a mechanism to solicit input to enhance operator training and implement improvement to the quality of that training." The inspectors reviewed minutes of recent OTIC meeting and concluded that many pertinent issues were being addressed. The training department provides i
detailed performance feedback to all operators following routine evaluations and requalification examinations regardless of the pass-fall determination.
Through the interviews, the inspectors concluded that the various feedback mechanisms were effective and generally well perceived.
In addition to the feedback network, there was frequent and effective
interchange between operations and training managers.
The managers met formally at the beginning of each training cycle to agree on the training content of that cycle; however, the managers meet informally at least once a week to discuss emergent training needs or performance feedback. The
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inspectors observed a high level of cooperation and professionalism exhibited between the operations and training managers.
The inspectors assessed the comunications interf ace between operations and training to be a particular strength and a significant contributor to the overall success of the operations requalification training program.
1.7 Conclusions j
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All portions of the examinations were properly developed and adequate to effectively evaluate operator performance with respect to licensed responsibilities.
The parallel evaluations of the inspectors agreed with-those of the licensee. The level of emergency plan implementation and evaluation during the dynamic simulator examinations was regarded as a
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positive initiative to create a more realistic operational environment and to make more effective use of simulator time and evaluation opportunities. The
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tracking system to prevent operators from being evaluated on JPHs they had validated wa* considered a strength. The presence of the operations
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superintendent during the dynamic simulator examinations for shift crews was assessed as a positive activity.
The evaluators were generally well trained and qualified to perform objective evaluations of operator performance.
The licensee's program for remediation training included those attributes necessary to assure proper remediation and retesting prior the resumption of licensed operator duties. The feedback and comunication interfaces between orerations and training were particular strengths and significant contributors to the overall success of the operations requalification training program, p
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ATTACHMENT 1 1-
PERSONS CONTACTED
1.1 Licensee Personnel y
- P. O'Malley, Senior Operations Instructor
- R. Ciminel, Senior Operations Instructor'
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- R. Fletcher, Operations instructor t"
- B. Matherne, Senior Operations Instructor
- T. McCool, Senior Operations Instructor
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- J. O'Hern, Operations Training Supervisor
- D. Vinci, Operations Superintendent
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D. Ortego Shift Supervisor
- B. Loetzerich, Licensing Engineer
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- L. Laughlin, licensing Manager
- D. Packer, General Manager, Plant Operations
- J. Lewis, Emergency Planning Supervisor 1.2 NRC Personnel
- J. Dixon-Herrity
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- G. Constable
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In addition to the personnel listed above, the inspectors contacted other personnel during the inspection period.
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- Denotes personnel that attended the exit meeting on September 17, 1993.
2 EXIT MEETING An exit meeting was conducted on September 17, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during the inspection.
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ATTACHMENT 2 DOCUMENTS REYlEWED Nuclear Plant Training Instruction NTI-0P-001, " Training Course Coordination,"
Revision 0
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Nuclear Plant Training Instruction HTI-0P-002, " Examination Bank Control,"
Revision 1
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Nuclear Plant Training instruction HTI-vP-004, " Examination / Quiz
Development," Revision 0
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i Nuclear Plant Training Instruction NTI-0P-005, " Examination / Quiz Administration," Revision 0 Nuclear Training Course Description NTC-108, " Licensed Reactor Operator
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Requalification," Revision 3
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Company Directive Nv. C7.830, " Training and Qualification," Revision 0 -
i Operations / Training Improvement Comittee Charter Operations / Training Improvement Comittee Meeting Hinutes for 2/4/93,
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5/11/93, and 6/1/93 Operations Curriculum Committee Meeting Hinutes for 3/14/91
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i-Operations Department Policy No. 5, " Simulator Training," Revision 0-i Administrative Procedure UNT-004-009, " Control, Distribution, Handling and Use
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of Plant Prceedures," Revision 11 Emergency Plan leplementing Procedure EP-001-030, " Site Area Emergency,"
l Revisions 15 & 18
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Condition Report 93-151 - Failure to enter revisions to control copy books in-a timely manner.
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ATTACHMENT 3 i
SIMULATION FACILITY REPORT Facility Licensee:
Entergy Operations Inc.
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Facility Dockets:
50-382 Operating.ests Administered at: Waterford Steam Electric Station Unit 3
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Operating Tests Administered on:
September 15, 1993
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During the conduct of dynamic simulator portion of the operating tests, the following items were observed:
ITEM DESCRIPTION
Following a manual reactor trip, the electrical distribution system failed to automatically shift to the startup transform 7r.
As a result, the A3 vital AC bus was de-energized since its associated EDG was not available.
Following restoration of electrical power through the startup transformer, the A2-A3 bus tie breaker could not be shut from the control panel. No faults or lockouts were present to prevent shutting the breaker to a dead bus.
These events did not affect the validity of the examination because the simulator properly modeled plant behavior for the existing conditions.
The loss of the vital bus in addition to the planned major transient caused the operators to enter the contingency procedures which required the evaluators to more carefully record operator actions. The failure of the A2-A3 bus tie breaker confused the operators briefly and caused them to take extra time to investigate the problem, which delayed recovery actions. Overall, these fidelity discrepancies did not significantly affect operator performance.
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The anomalies did not repeat in subsequent scenarios.
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