IR 05000382/1999014

Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Major Areas Inspected:Operator Requalification Training Program

ML20217N223
Person / Time
Site:	Waterford
Issue date:	10/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217N216	List: IR 05000382/1999014 ML20217N211
References
50-382-99-14, NUDOCS 9910280142
Download: ML20217N223 (16)

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ENCLOSURE l U.S. NUCLEAR REGULATORY COMMISSION l REGION IV l Docket No.: 50-382 License No.: NPF-38 Report No.: 50-382/99-14 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location:. . Hwy.18 Killona, Louisiana Dates: September 13-7 and October 4-8,1999 Inspector (s): Ryan Lantz, Lead Inspector / Chief Examiner Gary Johnston, Senior Reactor Inspector / Examiner Approved By: John L. Pellet, Chief, Operations Branch Division of Reactor Safety ATTACHMENTS:

Attachment 1: Supplementalinformation Attachment 2: Initial Written Examination Attachment 3: Answer Key and Post Administration Comments i

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9910280142 991019 PDR ADOCK 05000382 G PDR

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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report No. 50-382/99-14 This inspection included a review of the licensed operator requalification training program following the guidelines in Inspection Procedure 71001, " Licensed Operator Requalification Program Evaluation." The facility's annual operating test and biennial written examination for licensed operator requalification were administered to one shift crew September 13-15,1999, during the inspection period. Requalification examinations were also administered the 2 weeks prior to the inspectio This inspection also evaluated the competency of five reactor operator license applicants for issuance of operating licenses at Waterford, Unit 3. The licensee developed the initial examinations using NUREG-1021 Revision 8. NRC examiners reviewed and approved the  ;

examinations. The initial written examinations were administered to all applicants on October 1, 1999, by facility proctors in accordance with the guidance in NUREP.021, Revision 8. The i NRC examiners administered the operating tests on October 4-7,199 Ooerations l- *

The licensee developed and submitted a high quality examination, which was l administered, with only minor changes. All five applicants passed the initial licensing

examinations. No broad knowledge or training weaknesses were identified. With minor j exceptions, strengths were observed in communication, peer checks, and procedure l usage (Sections O1.1,04.2, O4.3, and 05.4).

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• - Good operator performance was observed in ar aspects of the requalification j examinations, with some exceptions noted. Communications, procedure use, and peer

checks were noted strengths. Overall, the operator requalification training program effectively implemented a systems approach to training with several improvements note The most significant improvements included stronger operations management involvement in observation and evaluation of licensed operator training, improved effectiveness of training review group meetings, and diversity and availability of program feedback methods (Sections O4.1 and 05.3).

• - ; The licensed operator requalification facility evaluators administered and evaluated the examinations professionally. The inspectors concurred with the facility evaluations (Sections O5.1).

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

• Excellent examination security was maintained (Sections 05.5).

• Licensed operator requalification facility audits were comprehensive, self-critical, and identified areas for potential improvement (Sections 07.1).

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• The licensee maintained appropriate operator license conditions by controlling all medical qualification and watch-standing requirements (Sections 07.2).

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-4 Report Details Summarv of Plant Status The facility was shutdown for the duration of the requalification program inspection due to repair efforts on the 2B reactor coolant pump seals. The facility conducted a startup prior to resumption of the initial examinations and was at 100 percent power for the remainder of the inspection. All plant observations were conducted during the day shift, coincident with conduct of the walkthrough examination l. Operations 01 Conduct of Operations 01.1 General Observations Inspection Scope During the in-plant task walkthrough section of the examinations, the examiners observed the on-shift operators during routine operations of the facility, Observations and Findinas .

The on-shift control room crews performed their duties professionally while supporting administration of the initial examinations in the control room. Communication and annunciator response in the control room was formal and consistent with observations of crews in the simulator _ during the requalification and initial examination Conclusions The control room staff exhibited good operating practices and were consistent with crews (

observed during examination Operator Knowledge and Performance 0 Operator Performance on Annual Reaualification Examinations Insoection Scope (71001)

The inspectors observed the performance of one shift crew of licensed operators during the dynamic simulator and job performance measure portions of the annual requalification operating examination. The inspectors also reviewed the results of the biennial written examination . . . - . . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ -

5-b. Observations and Findinas The crew in the dynamic simulator consisted of two reactor operators, two senior operators, and one nonlicensed shif t engineer who acted as the shift technical advise 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 test, including frequent peer review checks and appropriate procedure usag During the dynamic simulator portion of the examinations, the inspectors observed consistent three-legged communications, formal procedure usage, and frequent peer checks. Operators in the control room supervisor position displayed good direction and oversight of crew activities. Minor instances were observed where information was not shared with all members of the crew, which did not significantly delay crew response or event mitigatio I The inspectors observed consistent and appropriate use of alarm response procedures, j abnormal operating procedures, and the emergency operating procedure l The biennial written examination was administered by facility proctors on September 16, 1999. One reactor operator and one senior operator failed the written examination. A facility post administration examination review resulted in the deletion of two questions for no correct answer. The deletion of the two questions did not affect the results of the examination grading. The two operators were removed from licensed duties pending successful completion of a remedial written examination to be administered the following week. The two operators passed their remedial written examinations on September 23, 1999, and were returned to licensed dutie The inspectors noted that in the 3 weeks following the on-site inspection, three other licensed operators failed their examinations: two were written failures, and one failed the system tasks portion of tne operating test. These three licensed operators were also removed from licensed duties, remediated and retested, then returned to licensed dutie The inspectors considered the low number of operating test failures and four written exam failures to be consistent with expectations for a challenging requalification examination.

c. Conclusions

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Good operator performance was observed in all aspects of the requalification examinations with minor exceptions noted. Communications, procedure use, and peer checks were noted strength l-6 04.2 initial Written Examination Inspection Scope On October 1,1999, the facility licensee proctored the administration of the written examinations, as approved by the NRC, to five individuals who had applied for initial 4 reactor operator licenses. The licensee proposed grades for the written examinations and evaluated the results for question validity and generic weaknesses. The examiners reviewed the licensee's results. Observations and Findinas All applicants passed the written examination. The minimum score was 80 percen After final grading by the chief examiner, the overall average score was 86.3 percen Applicant scores ranged from 80.6 to 91.8 percent. The licensee's post administration analysis identified that 10 questions were missed by 50 percent or more of the applicants. These were Questions 1,17,22,29,35,42,44,45,57, and 80. Review of the 10 questions did not identify any generic training or knowledge weaknesse The licensee performed a detailed post administration examination analysis and recommended deletion of four questions from the examination. The analysis and recommendations are attached to this report in Attachment 3. The first question, number 29, was missed by 4 of the applicants and required them to recognize which component listed was powered from the AB DC bus. The facility recommended deletion of the question based on training that was conducted on an abnormal operating procedure for loss of the AB DC bus, noting that the procedure had not been revised to reflect a plant modification that changed the power supply for the charging header isolation valve, CVC-209, to the AB DC bus. Training had been conducted on the power supply change modification several months earlier. The chief examiner agreed to delete the question, not because of the reasons listed by the facility, but because the valve in question was infrequently operated (only for maintenance or if a leak in the charging header developed) and knowledge from memory of the power supply for that valve was considered beyond the recalllevel of knowledge required for the licens The second question, number 42, was missed by 3 of the applicants. The facility recommended deletion of the question because the numerical range of the answer '

choices were all within the reasonable tolerance when reading the provided graph to calculate the correct answer. The chief examiner reviewed the graphs and applied up to a 10 percent reading error, which resulted in two of the answer choices being accepted as correct. All of the applicants chose one of the two answers and, hence, all passed the questio The third question, number 57, was missed by all of the applicants. The facility recommended deletion of the question based on no correct answer. The chief examiner agreed with the analysis and deleted Se questio The fourth question, number 8C; vins mssed by 3 of the applicants. The facility recommended deletion of the awe.i based on no correct answer. The chief examiner reviewed the question and referen;es provided and retained the question unchange L ,

-7-i The three other choices in the question were clearly incorrect, and the answer as given was supported by the references as an acceptable action, although not specifically required by the referenc Conclusions All five applicants passed the initial licensing written examinations. No broad knowledge or training weaknesses were identifie .3 Initial Operatina Test Insoection Scoce i

The examination team administered the various portions of the operating examination to the five applicants on October 4-7,1999. Each applicant participated in two dynamic simulator scenarios. Each applicant received a walkthrough test, which consisted of tasks in 10 systems and tasks or questions in four administrative area Observations and Findinas l

All applicants passed all portions of the operating test. Overall, the applicants

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performed well in the dynamic simulator scenarios with communications, peer checks, and procedure usage noted as strengths. Similar to observations during the requalification examinations, minor instances were noted where information was not shared with all members of the crew, without significant consequenc In one instance, the crew failed to evaluate the significance of a failed pressurizer pressure instrument, which resulted in a more rapid depressurization of the reactor-coolant system. The crew mistakenly attributed the rate to a leak from the reactor coolant system.: Later in the scenario, the reactor operator was directed to change the controlling channel from the failed instrument channel. He neither communicated l understanding of why he was taking that action nor did he followup with the senior operator on expected results of the actio c, Conclusions All five applicants passed the operating tests. With minor exceptions, the applicants performed well and displayed strengths in communications, peer checks, and procedure usag Operator Training and Qualification 0 Reaualification Examination Administration i Inspection Scope (71001)

The inspectors observed the administration of all aspects of the annual operating test to f' determine the evaluators' ability to administer an examination and assess adequate l

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r-8-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 Findinas l 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 l

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l The inspectors observed the post scenario crew evaluation process. The evaluations l were led by the designated lead evaluator with the operations manager participating in the l l evaluation. Each of the evaluators participated in discussions of event observations, and strengths and weaknesses observed. The operations manager provided immediate

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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 evaiations was a significant strength of the training progra j The evaluators passed all of the operators on all portions of the operating tests. The i inspectors concurred with the facility evaluation Conclusions

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! The licensed operator requalification facility evaluators administered and evaluated the l examinatic. c orofessionally. The inspectors concurred with the facility evaluations.

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0 Reaualification Biennial Written Examination and Annual Operatina Tests 05.2.1 Reaualification Written Examinations l Inspection Scope (71001)

The inspectors reviewed the biennial comprehensive written examination that was administered September 15,1999. The examination was reviewed to evaluate its validity l 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 level.

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-9- Observations and Findinas l The biennial written examination consisted of 40 multiple choice questions, half of which l focused on system knowledge. The other half generally focused on administrative

! controls and Technical Specification applications. The examination questions tested at the appropriate level of comprehension were linked to important learning objectives and followed the established sample plan The sample plan was representative of the training accomplished over the training cycle and specifically identified senior operator only questions. The inspectors reviewed the designated questions and agreed that they were i senior operator level questions, sampled appropriately from 10 CFR 55.43 items, and met l the program requirements as described in NTI-OP-004, " Examination Development."

i Conclusions The comprehensive biennial written requalification examinations adequately sampled from accomplished training and were appropriate in scope, depth, and cognitive leve .2.2 Reaualification Annual Operatina Test ) Inspection Scoce (71001)

The inspectors reviewed the annual operating test administered on September 14 and 15, 1999, as well as the examinations given during the first 2 weeks of requalification examinations. The inspectors used the guidance in NUREG-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 system Observations and Findinas

! The inspectors noted that system and administrative tasks and simulator scenarios were l adequate for evaluation of operator and crew skills. The system and administrative tasks contained clear, measurable performance standards and critical task acceptance criteri The scenarios contained clearly stated objectives and crew critical tasks. Scenario initial conditions were realistic and events were a logical progression of related event Guidelines of NUREG-1021 for qualitative attributes of job performance measures and ,

dynamic simulator scenarios were met, although the degree of challenge and level of I difficulty varied notably between operating tests given in different weeks. The inspectors did not consider this a programmatic vulnerability, only a consistency issue with quality l reviews of the examinations.

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I The annual operating examinations were comprehensive and discnmiria. 3d at the j appropriate leve '

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-10-l l 05.3 Review of Reaualification Proaram Guidance Inspection Scope (71001)

The inspection evaluated the effectiveness of the methodology used to develop and i construct the requalification examinations, assessed the effectiveness of the examinations to identify retraining needs, and measure the examinees' subject knowledge. The inspectors utilized tha guidance of NUREG-1220, " Training Review Criteria and Procedures," Revisicn 1, and 10 CFR 55.59, "Requalification," 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 program and interviews with training management, instructors, evaluators, and examinee Observations and Findinas l

The licensee's training staff indicated that the guidelines of NUREG-1021 were substantially utilized for the development and administration 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 i development, control, and administration of licensed operator requalification examinations l and quizzes,2-year training plan development, makeup training, and remediation guidelines. The licensee's procedures were comprehensiv The inspectors noted that program guidance in NTI-OP-008, " Licensed Operator Requalification," contained specific guidance for development and security of examinations, post-examination activities, removal from shift for failures of examinations, and remedial training of individuals. The remedial programs focused on identified weaknesses and adequately retested the operators prior to returning them to licensed I dutie l The inspectors noted that program revisions had been made to address recent audit and I 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's feedback mechanism, and a more defined requirement for training review group meeting attendance and frequenc Conclusions The licensed operator requalification pro' gram effectively implemented a systems approach to training to identify operator performance and training weaknesses and modify the training and evaluation program to correct identified weaknesses.

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j 0 initial Licensina Examination Development The f acility licensee developed the initial licensing examination in accordance with guidance provided in NUREG-1021," Operating Licensing Examination Standards,"

Revision 8.

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-11-05.4.1 Examination Outline Inspection Scope The facility licensee submitted the initial examination outlines on June 29,1999. The chief examiner reviewed the submittal against the requirements of NUREG-1021, Revision Obser ations and Findinas The initial examination outlines met the qualitative and quantitative guidelines of NUREG-1021. The chief examiner provided minor enhancement comments and j advised the licensee to proceed with examination developmen Conclusions l The licensee submitted examination outlines were adequate as presented with minor enhancement comments provided by the chief examine .4.2 Examination Packaae Inspection Scoce l The draft examinations were transmitted by the licensee to the NRC on August 31, 1999. The licensee submitted the completed final examination package on September 28,1999, following the chief examiner's on-site review. The chief examiner reviewed the examinations against the requirements of NUREG-1021, Revision Observations and Findinas The licensee submitted a technically valid draf t examination of excellent quality that was responsive to the outline. Following two independent examiner reviews, the chief examiner provided enhancement suggestions for 10 questions and other editorial suggestions. The enhancement comments generally related to distractor plausibility or adding detail to the question stem. After discussion of the examiner review comments, the licensee modified the examinations as agree The licensee submitted four scenarios including a backup that were of excellent qualit The NRC reviewers had no significant comments following in-office reviews. The examiners valide.ed the scenarios during the week of September 13,1999, and determined that one of the scenarios required an additionalinstrument failure with substantial action by the reactor operators. Otherwise, the scenarios were adequate as

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proposed and fully supported by the simulation facility.

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l To support the systems walkthrough section of the operating test, the f acility licensee provided 10 job performance measures (JPMs) of excellent quality to evaluate selected operator tasks. The chief examiner required replacement of one task basad on its focus on administrative rather than system knowledge. The examiners provided additional r

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-12-minor enhancement comments to the remainder of the tasks during the examiner's onsite revie To support the administrative topics section of the operating test, the licensee submitted a mix of administrative questions and tasks. The examiners provided minor editoria!

comments and one enhancement comment to correct a technical error in one task during the chief examiner's on-site revie Conclusions The licensee developed and submitted a high quality examination, which was administered with only minor change .5 Examination Security Scope The examiners reviewed examination security during the examination administration week for compliance with NUREG-1021 requirement Observations and Findinas Members of the licensee's operations and training staff signed onto the NUREG-1021 examination security agreement, acknowledging their responsibilities for examination security. Daily security briefings were conducted for the examinees. Examination security plans were effective and properly implemented. Applicants were maintained under a constant escort as needed to prevent any actual or appearance of compromis Simulator security was strictly maintaine Conclusions Excellent examination security was maintaine Quality Assurance in Operator Training 0 Review of Operations Quality Assurance Audits Inspection Scoce (71001)

The inspectors reviewed the results of "Waterford-3 Training Programs Combined Assessment /OA Audit," May 11-15,1998, which included an audit of the licensed operator requalification program. The inspectors reviewed additional audits of the licensed operator requalification program dated June 14 and July 12-15,1999, that were conducted by peer groups and outside organization .

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-13- Observations and Finding

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The quality remance audit and the additional audits both utilized personnel from outside

.. 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 improvemen Conclusion The licensed operator requa!ification program audits were comprehensive, self-critical, and identified areas for potential improvemen .2 Maintenance of Licensed Operator Qualifications insoection Scope (71001)

The inspection determined the eff> ,,, ass of the licensee's program to monitor and

+ controllicensed operator profit ywW s and medical qualifications. The inspectors utilized the guidance of ANSl#/ *P' '

sdical Evaluation of Licensed Personnel for Nuclear Power Plants, rem 1 P 65.21, ' Medical Examination"; and 10 CFR 55.23,"Certificatio 'y * to medical qualifications.10 CFR 55.53,

" Conditions of Licenses," provioes e asnce on requirements for maintaining en active license and the actions required to reactivate when a licensed operator is in the inactive status, Observations ar'd Findinos Licensed operators were required by 01-024-000," Maintaining Active SRO/RO Status," to-perform five proficiency watches each quarter to maintain an active license. A review of the licensee computer-based tracking system indicated that all active licensed operators were completing at least five watches per quarter. The inspectors also determined that licensed operators were performing those watches for a full 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period and had stood those watches in the appropriate licensed position for which the individual was license Licensee management indicated that it is the individual licensed operators' responsibility to schedule and maintain proficiency watch status. However, operations management monitors the watch standing closely through periodic checks of the status in the computer-based tracking syste ;

F,imlarly, a computer tracking data base is maintained for training and medical qualifcations. The inspector reviewed the current status of licensed operator qualifications and determined that all currentiv licensed operators have maintained their qualifi.:ations. A review of eight individus medical record files found that the medical examinations were conducted annually and conformed with guidance in ANSI /ANS 1.134,

" Medical Evaluation of Licensed Personnel for Nuclear Power Plants." The inspector noted that the licensee emphasized in a recent licensed operator newsletter, operators'

responsibilities with regard to keeping medical and operations management informed of any changes in their medical status. This was apparent with several operators having

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recent changes to conditions in their licenses due to various surgical corrections to their

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-14-eyes. Each change was promptly reported to the facility medical staff, and the change in condition was also reported to the NRC via NRC form 39 Conclusions The licensed operators maintained appropriate license conditions by meeting all medical qualification and watch-standing requirement IV. Plant SuppoA F8 Miscellaneous Fire Protection issues F General Comments The inspectors observed general plant hcasekeeping incident to administration of the in plant job performance section of the operating test. The facility was reasonably clean and well lighted and the floors were clear and free from debris. The applicants were conscientious to note discrepancies and inform the main control roo V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented thu inspection results to members of the licensee management and staff at the conclusion of the inspection on October 8,1999. An interim exit meeting for the requalification program inspection was held on September 16,1999. The licensee acknowledged the findings presente The licensee did not identify as proprietary any information or materials examined during the inspectio .

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ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. DeDeaux, Licensing Supervisor E. Ewing, Director, Nuclear Safety Assurance R. Fili, Quality Assurance Manager R. Fletcher, Operations Training Supervisor -

J. Hoffpauir, Operations Manager T. Leonard, General Manager, Plant Operations D Madere, Site Support ~

J. O'Hern, Director, Training O. Pipkins, Licensing Engineering NRC P. Gage, Senior Reactor inspcctor, RIV LIST OF INSPECTION PROCEDURES USED

IP 71001 Licensed Operator Requalification Program Evaluation l

l PROCEDURES REVIEWED Trainina Audits

. "Waterford 3 Training Assessment," July 12-15,1999

. "WESTRAIN Assist for NRC 71001 Audit," June 14,199 . "Waterford-3 Training Programs Combined Assessment /QA Audit," May 11-15,199 Trainina Procedures

. ' NTP-101, " Operations Training Programs," Revision 10, June 24,199 . NTP-006, " Control and Administration of Examinations," Revision 9, May 27,199 NTI-OP-004, " Examination Development," Revision 8, September 12,199 NTI-OP-005, " Examination Administration," Revision 6, January 6,199 .. NTI-OF-008," Licensed Operator Requalification," Revision 4, August 23,199 Operatina Procedures

. OP-001-003," Reactor Coolant System Draindown," Revision 18

. OP-901-313 " Loss of a 125V DC Bus," Revision 1

- 01-024-000, * Maintaining Active SRO/RO Status," Revision 5 l

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2-Other Documentation

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Condition Report 1999-0939, September 14,1999

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Training Review Group Meeting Minutes of May 20, July 8, and August 19,199 .

1999 Biennial Written Examinations W-3-EXM-LOR-9951-3

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1999 Annual Operating Tests, Weeks 1- )

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