IR 05000382/1997017

Insp Rept 50-382/97-17 on 970929-1003.Violations Noted. Major Areas Inspected:Licensed Operator Requalification Program Following Guidelines in Insp Procedure 71001, Licensed Operator Requalification Program Evaluation

ML20217K888
Person / Time
Site:	Waterford
Issue date:	10/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217K868	List: IR 05000382/1997017 ML20217K864 ML20217K883
References
50-382-97-17, NUDOCS 9710300105
Download: ML20217K888 (14)

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- ENCLOSURE 2 ;

l U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382 License No.: NPF 38

Report No.: _ _50-382/97-17

- Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: September 29 through October 3,1997

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Inspectors: Ryan Lantz, Reactor Engineer, Operations Branch Tom _McKernon, Reactor Engineer, Operations Branch Approved By: John Pellet, Chief, Operations Branch

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Division of Reactor Safety -

_ ATTACHMENT: _ Supplemental Information 9710300105 971023 PDR 8 ADOCK 05000382 PM

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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 7 NRC Inspection Report 50 382/97-1~

This inspection inc!uded a review of the licensed operator requalification program following the guidelines in inspection Procedure 71001, " Licensed Operator Requalification Program Evaluation."

Q0erations The facility's annual operating test for licensed operator requalification during the inspection period was administered September 29 and 30. The biennial comprehensive requalification written examination was administered on October 2. Inspection results are as follows:

• Severalimprovements were noted in the licensed operator requalification progra The most significant changes required operations management to observe and evaluate licensed operator training and improved the quality of training review group meetings and program feedback (Sections 05.1 and 05.4).

• The licensed operator requalification facility examiners administered and evaluated 3 the examinations professionally. The inspectors concurred with the facility evaluations (Section 05.1).

• Requalification examinations and remedial examinations were comprehensive, discriminated at the appropriate level, and were responsive to identified weaknesses (Sections 05.2 and 05.3).

• Overall, the licensed operator requalification training program effectively implemented a systems approach to training (Section 05.4).

• Licensed operator requalificr/ ion f acility audits were comprehensive, self-crit l cal, and identified areas for potential improvement (Section 07.1).

• Two instances were noted where operators were challenged by proceoures. For instance, one f ailure to maintain the emergency operating procedures as required by Technical Specifications resulted in a violation (Section 04.1).

• Good operator performance was observed in all aspects of the examination with some significant exceptions noted. All operators participating in the licensed operator requalification tests passed their evaluated examinations (Section 05.1).

Three-legged communications, procedure use, and peer checks were noted strengths (Section 04.1).

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Weaknesses were observed in crew direction and oversight on the part of senior operators in the control room supervisor position (Section 04.1).

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Reoort Details Summarv of Plant Status The f acility_was at 100 porcent power for the duration of the inspection, and all observations were conducted during the day shift, coincident with conduct of the walkthrough examinations, l. Onorations 01- ' Conduct of Operations-01.1 General Observations Insoection Scoce During the in plant' task walkthrough section of the examinations,-the oxaminars observed the on-shift operators during routine operations of the f acility, Observations and Findinas The on shif t crews exhibited professional demeanor and the senior operators m'aintained a position of crew direction and oversight. Shift operators were professional and aware of current plant evolutions and work in progress, Conclusions .

The control room staff exhibited professionalism and good awareness of work in progres _04 _ Operator Knowledge and Performance 04.1 Ooerator Performance on Annual Reaualification Examinations

- insoection Scooe (71001)

The inspectors observed the performance of two crews, one shif t and one staf f, of-licensed operators during the dynamic simulator and job performance measure portions of the annual requalification operating examinatio [o

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-5-b. Observatioris and Findinos The crews in the dynamic simulator consisted of two reactor operators, two senior operators, and one shift engineer who acted as the shift technical adviser. Each licensed operator was administered five job performance measures and participated in two dynamic simulator scenarios. The inspectors observed the licensee staff administer the dynamic simulator scenarios and some job performance measure The inspectors observed generally good examinee performance during the job performance measure section of the operating tes During the dynamic simulator and job performance measure portions of the examination, the inspectors observed the following generic behaviors among the operato s:

• Three-legged communications, procedure usage, and peer checks were noted strength * Although adequate, operators in the control room supervisor position displayed waak direction and oversight of crew activities. In each case, the observed weakness was compensated for by other crew member * The staff crew was weak in sharing information, which significantly challanged their ability to perform a prompt diagnosis of plant condition The operators have adopted three-way communications as a natural and expected practice. The inspectors observed consistent use of this method among control room operators a; well as with other technicians or managemenit outside of the control roo The inspectors observed consistent and generally apptcpriate use of alarm response procedures, abnormal operating procedures, and the emergency operating proceduret. Two challenges to the operators were noted in procedural guidance; one in response to a secondary system leak, such as feedwater, into the containment, and another in the interpretation of conditions required to meet the containment isolation safety function. Given clear indications of a feedwater leak inside containment, both crews entered the abnormal operating procedure for a reactor coolant system leak, which only provided guidance to confirm a reactor coolant leak was not in progress. Neither crew entered the procedure for abnormal steam generator water level control, which was more appropriate and provided more effective guidance for the feedwater leak. Additionally, one crew f ailed to recognize the indications for a feedwater break inside containment until post-emergency operating procedure entry formal diagnosis was conducte I

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6-One crew f ailed to close Containment Spray isolation Valves CS125A(B) following a manually initiated containment isolation and spray actuation, with f ailure of the containment spray pumps to properly operate. The operators also, subsequently and erroneously, declared the containment isolation safety function to be satisfie The guidance for closure of these valves to meet the containment isolation safety function was provided in Emergency Plan Procedure EP-002100, "TSC Activation, Operation, and Deactivation," however, this procedure was not referenced by tSe operators prior to TSC activation and manning, and no additional guidance was provided in the emergency operating procedures to ensure the containment spray containment isolation valves were closed given the above conditions. The licensee had modified these valves during the past outage to allow overriding the permissive signal for closure, but had not revised the emergency operating procedure The inspectors considered this condition as a violation of Technical Specifications 6.8.1.a for a f ailure to maintain the emergency operating procedures (50-382/9717-01).

Additionally, the senior operators in the control room supervisor positions had to be prompted in several instances by the board operators or the shif t supervisor to provide specific, timely direction to the crew. One contral room supervisor gave several broad scope directions, such as, " perform a rapid down power," without providing pertinent limitations or procedural references. The board operators compensated by adding the specific limitations on rate and procedural reference in the repeat back communication, which the control room supervisor acknowledged as conect. Both crews' control room supervisors required prompting by the shift supervisor to initiate the required actions in several instances. For example, one control room supervisor was directed to perform a crew brief then conduct a rapid shutdown. Following the brief, the control room supervisor hesitated, then sought the shift supervisor's concurrence to begin the shutdown, in another instance, the control room supervisor was procedurally guided to start a low pressure safety injection pump to meet containment temperature / pressure safety function success path criteria. The control room surervisor again sought the shift supervisor's permission to initiate low pressure safety injection instead of first performing the action, then informing the shift supervisor, Conclusions Operators exhibited general! _ cod knowledge and ability in all aspects of the requalification examination? Three-way communications, peer checking, and procedural usage were not i strengths. Crew direction and oversight was effective, although challenged by observed control room supervisor weaknesses. Procedures were observed to challenge the crews' timely and effective diagnosis of plant condition h.

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[ Operator Training c.d Qualification 0 ReauaP'. cation Examination Administration Insoection Scoce (710011

- The inspectors observed the administration of all aspects of the requalification examination to determine the evaluators' ability to administer an examination and assess adequate performance through measurable criteria. The inspectors conducted interviews to determine the knowledge level of the managers, supervisors, and instructors with regard to the requalification program implementation. The inspectors also observed the fidelity of the plant simulator to support training and examination administratio Observations and FindiDSS Six training staff evaluators were observed administering the examinations, including preexamination briefings, observations of operator performance, individual and group

, evaluations of observations, techniques for job performance measure cuing, and final ,

evaluation documentation. The evaluators conducted the examinations professionally, with no inadvertent cuing, and were thorough in their documentation of observed weaknesses and areas for improvement. The inspectors also noted that the timing of the malfunctions during the dynamic simulator evaluations enabled evaluation of senior operator competencies, such as crew direction and oversight,

- and ability to prioritize and integrate plant status. The plant simulator fidelity supported the examinations and no fidelity issues were observe '

The inspectors observed the post scenario crew evaluation process. The evaluations were led by the designated lead examiner, with the operations manager participating in the evaluation. Each of the examiners participated in discussions of event observations, and strengths and weaknesses observed. The operations manager provided immediate operations feedback for expectations, as well as, an independent observation of crew actions. The inspectors noted that the involvement of an operations department representative in examination observations and evaluations was a significant strength of the training program, and although not formally documented in program requirements, revisions were in the approval process to make the operations evaluation involvement a requirement of the licensed operator training progra The evaluators passed all of the operators on all portions of the examinations. The inspectors concurred with the f acility evaluation F}

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- Conclusions -

-The f acility examiners administered and evaluated the requalification examinations professionally. - Operations management involvement in the observation and evaluation of dynamic simulator scenarior. was a noted strength. The inspectora concurred with the facility evaluation .2 Recualification Written Examinations insoection Scone (71001) '

The inspectors reviewed the biennial comprehensive written examination that was-administered October 2,-1997. The examination was reviewed to evaluate its-

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validity and compliance with facility program requirements. The examinations were reviewed using guidance of NUREG 1021, " Operator Licensing Examiner Standards,"

for construction, scope of coverage, and cognitive leve Observations and Findinos The biennial examinatiori c',uestions tested at the appropriate level of comprehension and were linked to important leaming objectives. The questions were operationally oriented and realistic. The examinations were well structured and comprehensiv The inspectors noted that the sample plan for the biennial written examinations specifically identified senior reactor operator only questions. The inspectors reviewed the designated questions and agreed that they were senior reactor operator level questions, sampled appropriately from 10 CFR 55.43 items and met the program requirements as described in NTI-OP-004, " Examination / Quiz Development," Revirion 5, Section 5. Conclusions

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'The comprehensive biennial written requalification examinations administered by the facility were valid examinations, with appropriate scope, depth and cognitive leve l 9 .

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-9-05.3 He. Qualification Annual Ooerating Test inmestfon Scone (71001)

The inspectors reviewed the annual operating test cdministered on September 29 and 30,1997. The inspectors used the guidance in NUilEG 1021 to determine the validity of the examinations to provide a basis for evaluating the examinee's knowledge of abnormal and emergency operating procedures and operation of plant systems. The inspectors also reviewed the licensee's administrative procedures for developing, administering, grading, and evaluating the examinations and conducted interviews with training management, instructors, evaluators, and examinees, Observations and Findings The licensee's training staff indicated that the guidelines of NUREG-1021 were substantially utilized for the development and edministration of the licensed operator requalification examination, in addition to the facility requalification training procedures. The licensee supplemented the guidance of NUREG-1021 with training instructions for the development, control, and cdministration of licensed operator requalification examinations and quizzes,2 year training plan development, makeup training, and remediation guidelines. The licensee's procedures were comprehensiv The job performance measures were in accordance with the guidance of NUREG-1021, contained performance standards that were clear and objective, and the critical task acceptance criteria were well defined and measurable. The scenarios were also developed using the guidance of NUREG 1021 and contained clearly stated objectives. The initial conditions of the scenarios were realistic and the scenarios consisted of related event The inspectors noted that a recent modif' cation to the plant involving the capability for remote closing of Containment Spray Containment Isolation Valves CS125A(B)

had been reviewed in training lectures, and was incorporated into the annual operating test dynamic simulator scenarios. However, the inspectors noted that, while t'.te design change package identified the emergency plan procedures for the technical support center requiring revision, it did not identify the emergency operating procedures. As such, the operators were required to rely upon memory and their training to close the valves rather than specific emergency operating procedure instructions. This condition was identified as a violation of regulatory requireinents and is further discussed in Section 04.1. Overall, dynamic simulator scenarios used during the requalification examination were adequately challenging and provided a good evaluative tool for operator competencie ,

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i-10- Conclusiorui The annuel operating examinations were comprehensive and discriminated at the appropriate leve .4. Review of Reaualification Prooram Guidance

^ IDsoection Scone (71001)

The inspection determined the effectiveness of the methodology used to develop and construct the requalification examinations and to assess the effectiveness of the examinations to identify retraining needs and measure the examinees' subject knowledge. The inspectors utilized the guidance of NUREG-1220, " Training Review Criteria and Procedures," Revision 1, to evaluate the requalification program's ability to meet Elements 4 and 5 of a systems approach to training. This evaluation included review of the feedback tracking system and remedial training progra Observations and Findinas The inspectors reviewed the requalification program guidance and verified that it met and implemented the requirements of 10 CFR 55.59, "Requalification."

The inspectors noted that program guidance contained in NTC-108, " Licensed Operator Requalification," Revision 5, contained specific guidance for development and securi:y of examinations, post examination activities, removal from shift for f ailures of examinations, and remedial training of individuals. The inspectors also noted that the program was planned for revision to additionally require that any operator who f ailed a periodic cycle simulator quiz would also be removed from on shift licensed duties until completion of remediation. The inspectors reviewed three remedial training programs that had beta established for operators that failed a training cycle examination. The remedial programs focuseo on identified weaknesses and adequately retested the operators prior to returning them to licensed dutie The inspectors noted that additional program revisions were planned by the licensee to address recent audit and self-assessment findings. The most significant of these

. changes involved mandatory operations management participation in evaluated dynamic simulator crew examinations and quizzes, a modification of the instructor feedback mechanism, and a more defined requirement for training review group meeting attendance and frequency. Although none of these changes had been formally adopted into the program, they were in the process of being implemented and the governing procedures were being rev%e ,

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. - The lice 1 sed operator requalification program effectively implemented a systems

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approac h to training to identify operator performance and training weaknesses and *

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modify the training and evaluation program to correct identified weaknesses.

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07 ~ Quality Assurance in Operr. tor Training

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L .1 Review of Ooerations Quality Assurance Audits Insoection Scone (71001)

'he inspectors reviewed the asults of Qualie, Assurance Audit SA 97-003.1,

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" Performance, Training, and Qualification." dated August 21,1997, which included

an audit of the licensed operator requalification program. The inspectors reviewed i additional audits of the licensed operator requalification program dated August 7 and t

September 3,1997, that were conducted by peer groups and outside organization ,

c Qhsgivations and Findinas

! The qur.fity assurance audit and the additional audits both utilized perso'nnel from

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out:.ide the licensee's organization. All three audits were comprehensive and -

critical, with items for improvement noted in the reports. Training requests were __

initiated and tracked regarding the identified areas for improvement, f' Conclusion The licensed operator requalification program audits were comprehensive, self-

- critical, and identified areu, for potential improvement, which were being

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F8- Miscellaneous Fire Protection issues

- F General Comments The inspectors observed general plant housekeeping incident to administration of the in plant job performance _section of the operating test. The f acility was reasonably

- clean and welllighted and the floors were clear and free from debris. The applicants

< were conscientious to note discrepancies and inform the main control room.

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-12-V. Managsment Mee]]Dgs X1 Exit Meeting Summary The inspectore presented the inspection results to members of the licensee management and s;aff at the conclusion of the inspection on October 3,1997. The licensee acknowled0ed the findings presente The licensee did not identify as proprietary any intermetion or materials examined during the inspectio >

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_ _ ATTACHMENT

- SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSCNS CONTACTED -

Lingriten M. Brandon, Licensing Supervisor R. Burski, Director, Plant Modifications and Constructinn E. Ewing, Director, Nuclear Safety and Regulatory Aff airs R. Fletcher,- Operations Training Supervisor T. Gaudet, Licensing Manager J. Hoffpauir, Operations Manager S. Hymel, Licensed Operator Trainer

. R. Killian, Quality Engineering Supervisor

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-- T. Leonard, General Manager, Plant Operations

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J. Lewis, Emergency Planning Manager-

-J. O'Hern, Director, Training-

- O. Pipkins, Licensing Engineering W. Smith, Simulator Supervisor LIST OF INSPECTION PROCEDURES USED IP 71001 Licensed Operator Requalification Program Evaluation

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-LIST OF ITEMS OPENED-Onened 50-382/9717-01.-- VIO Failure to maintain emergency operating procedures

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PROCEDURES REVIEWED Trainina Audits

.- "Waterford Tieree Operations Assessment" September 3,1997

. -WESlRAIN Assessment "W3 Requalification Program" August 4-7,1997

. "W3 Quality Assurance Audit SA 97-003.1, Performance, Training and Qualification" August 21,199 ;

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-2 Trainino Procedures

. NTP-006, " Control and Administration of Examinations," Revision 8, March 21, 1997

. NTC-108, " Licensed Operator Requahfication," Revision 5, September 27,1995

• NTI-OP-004, " Examination / Quiz Developmer.t," Revision 5

. NTI-OP-005, " Examination Administration," Revision 5

. NTI-OP-008, " Licensed Operator Requalification," Revision 2 Ooeratina Procedurej

. OP 901-201, " Steam Generator Level Control System Malfunction"

. OP 500 012, Revision 12, Annunciator Response Procedure for L20 " Containment Water Leakage Hi"

. OP 902-008. Revision 10 " Safety Function Recovery Procedure" Other Documentation

. Condition Reports: 96-0281, 97-0770, 0771,-0781,-0812,-1702,-2381

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