IR 05000445/1999001
| ML20207K645 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/09/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207K638 | List: |
| References | |
| 50-445-99-01, 50-445-99-1, 50-446-99-01, 50-446-99-1, NUDOCS 9903170261 | |
| Download: ML20207K645 (11) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-445 50-446 License Nos.:
NPF-87 NPF-89 i
Report No.:
50-445/99-01 i
50-446/99-01 i
Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 Location:
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Dates:
February 8 to 12,1999 Inspector (s):
Steve McCrory, Senior Reactor Engineer, Operations Branch-l Thomas Meadows, Senior Reactor Engineer, Operations Branch Scott Schwind, Resident inspector Approved By:
J. L. Pellet, Chief, Operations Branch i
Division of Reactor Safety
Attachment:
SupplementalInformation i
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9903170261 990309 PDR ADOCK 05000445 O
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-2-EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report No. 50-445/99-01; 50-446/99-01 This inspection assessed the licensed operator requalification program to determine whether the i
program incorporated appropriate requirements for evaluating operators' mastery of training objectives in accordance with 10 CFR 55.59(c). The assessment included an evaluation of the
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program's controls to assure a systems approach to training and evaluation of operating crew I
performance during annual requalification examinations. This included review of the facility
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documents, observation of operating and staff crews during dynamic simulator scenarios and i
plant walkthroughs, and an assessment of the examination evaluators' effectiveness in conducting and evaluating examinations. The inspection also included an evaluation of the plant referenced dynamic simulator used to conduct the examinations and the reference documentation used to produce the examinations and some control room observations.
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Ooerations
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J Operators generally performed at high skill and competency levels while exhibiting good
implementation of human performance skills including three-part communication, j
self-verification, peer checking, procedure use, and supervisory ove, sight. Crew
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briefings by the unit supervisor occasionally did not meet the expected frequency. This performance was consistent between shift and staff crews (Sections 01.1 and 04.1).
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The operations training organization continues to sustain a high level of performance in
implementing a systems approach to training for the licensed operator requalification
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program. The recent implemantation of the operations self-assessment data base for tracking lessons learned from evolution debriefs was an example of how the program continues to improve (Section O5.2).
Evaluators displayed the same high level of skill in examination administration,
observation, and assessment as observed in previous inspections (Section 05.2).
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-3-Report Details I. Operations
Conduct of Operations 01.1 Observations of Operator Performance a.
Inspection Scope (71001)
The inspectors observed activities ir) I" ; control room during normal plant operations.
Operator performance during the simulator examinations was compared to performance of daily control room activities.
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b.
Observations and Findinas The inspectors observed operator performance in the dual unit control room. Although the overall level of activity was low, the inspectors observed the operators responding to annunciators, operating instrument controls, and adjusting main turbine load in support of routine instrument and controls surveillances. The operators generally exhibited three-part communication, self verification, and peer-checking skills. The operators referred to procedures routinely, and the unit supervisor maintained oversight by remaining in the controls area most of the time. The inspectors discussed their observations with the resider;t inspector who was participating in the inspection activity.
The resident inspector confirmed that the operator performance observed during the inspection was consistent with resident inspector observations over recent months. The inspectors determined that the performance of the operators observed on shift was comparable to that observed during the dynamic simulator portion of the operating examination (Section O4.1 below) and had remained consistent over the last several months.
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Conclusions The operators performance was consistent with the performance in the simulator.
Operator Knowledge and Performance 04.1 Operato
.formance on Annual Reaualification Examinations e,
'Insoection Scooe (71001)
The inspectors observed the performance of one dual unit shift crew and orie staff crew, during their biennial requalification evaluations. The biennial requalification examination
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consisted of an operating examination that included simulator dynamic performance evaluations. five job performance measures for each licensed operator, and a written examination.
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-4-b.
Observations and Findinas The shift crew was divided into two groups each with a unit supervisor, two reactor operators, and an extra senior reactor operator. Only one of the groups had a shift manager. The operators rotated positions for the second scenario such that all operators were observed in diverse positions, at least one of which satisfied the requirement for their license level. Neither group included a shift technical advisor. The staff crew had a shift manager for both scenarios, a shift technical advisor for one scenario, and an extra senior reactor operator for the other scenario. All positions rotated between scenarios for the staff group.
All groups, shift and staff, performed comparably well. The operators exhibited generally consistent application of human performance skills including three-part communication, self verification, peer checking, procedure use, and supervisory oversight. The inspectors noted, as did the facility evaluators, that some senior operators performing as the unit supervisor did not hold crew briefs on plant status in accordance with management expectations for frequency or comprehensiveness.
During the first scenario for one group of the shift crew, the operator performing the reactor operator duties initiated emergency boration as a result of the loss of rod position indication immediately following a reactor trip. The onset of a reactor coolant leak resulted in safety injection actuation. At that time, the reactor operator discontinued emergency boration via the preferred path and relied on the charging pumps discharging from the reactor water stor" ank to accomplish continued emergency boration. However, the operator n er verified pump flow against plant curves to ensure that emergency boration equivalent flow was present nor did he inform the unit supervisor of his actions. The facility e tatuators determined that the operator's performance was unsatisfactory.
During the second scenario, the staff crew was responding to an anticipated-transient-
without-a-reactor-trip event. Early in the implementation of the functional recovery
procedure, FRS-0.1, the control room staff directed an equipment operator to go to the I
reactor trip breakers and stendby. The operators carried out the actions of the procedure in the crder spec.fied. When the unit supervisor came to the step to direct
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the equipment operator to trip the reactor locally, he asked the shift manager if the shift manager wanted to de-energize the rod drive motor-generator sets from the control room or have the equipment operator open the trip breakers. The shift manager's choice affected the prescribed emergency action level classification. Tripping the reactor from outside the control room required a " Site Area Emergency" classification, where as, tripping the reactor by de-energizing the rod drive motor-generator sets from the control room only require an " Alert" classification. Since an operator was already standing by at the trip breakers, the shift r;nnager directed that the reactor be tripped by opening the trip breakers. There was no discussion regarding the relative merit of the emergency action level classification options. The shift manager then declared an emergency action classification level of " Site Area Emergency." During the post-scenario discussions, one of the evaluators expressed concern that an emergency action level classification.evel of " Site Area Emergency" created an unnecessary and undesirable emergency preparedness response. The other groups responding to the same scenario interrupted power to the rod drive motor-generator sets, which resulted in j
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-5-an emergency action level classification of " Alert." The inspectors encouraged the licensee staff to review the intent of the emergency action level classification guidelines with respect to an anticipated-transient-without-a-reactor-trip and the link with the emergency operating procedures.
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Conclusions Operators generally perfonned at high skill and competency levels while exhibiting good implementation of human performance skills including three-part communication, self-verification, peer checking, procedure use, and supervisory oversight. Crew briefings by the unit supervisor occasionally did not meet the expected frequency. This performance was consistent between shift and staff crews.
Operator Training and Qualification O5.1 Review of Reaualification Examinations a.
Insoection Scope (71001)
The inspectors reviewed the annual requalification examinations that consisted of the written and operating tests. The inspectors assessed the general quality, construction, and difficulty level of the tests. The inspectors also reviewed the methodology for developing the requalification examinations and discussed various aspects of examination development and security with members of the licensee's staff.
b.
Observations and Findinas The operating examinations consisted of job performance measures and dynamic simulator scenarios. The job performance measures tasks were operationally important and supported by the facility's job task analysis. Each job performance measure included initial conditions, initiating cues, references. performance standards, criteria for successful completion, and identification of critical steps. The dynamic simulator scenarios contained realistic initial conditions, clearly stated objectives, and related events. The scenarios had multiple instrument and component failures both preceding and following the major transient. The sequence and timing of the events were reasonable and allowed for the evaluators to gather sufficient information on individual and crew actions to arrive at an informed performance rating.
The inspectors noted that the written examinations were appropriately balanced with respect to systems, procedures, and administrative areas. The questions were generally weil written. Most questions tested at the application ctgnitive level, c.
Conclusion.s The inspectors concluded that, overall, all portions of the examinations were well constructed, properly focused, and appropriately challengin L
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6-05.2 E_xamination Administration and Prooram Imolementation
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Inspection Scope (71001)
The inspectors observed the administration of all aspects of the requalification examinations and observed the fidelity of the plant simulator to support training and examination administration. The ir,spectors observed seven licensad operator requalification training evaluators and one operations management evaluator administering one or more aspects of the examinations, including pre-examination briefings, observations of operator performance, individual and group evaluations of observations, techniques for job performance measure cuing, and final evaluation documentuon.
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Observations and Findinos During the administration of the in-plant portion of the walk-through examination, the evaluators provided clear instructions to the operators regarding their assigned tasks. The evaluators provided objective system and component performance cues that required the operators to diagnose the system conditions and assess the effectiveness of simulated actions.
The evaluators exhibited the same high level of skillin observing and evaluating operator
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performance in the simulator as was noted in the last inspection of the licensed operator
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requalification program (NRC Inspection Report 50-445;-446/97-06). The inspectors also j
observed strong operations staff participation consistent with previous inspections. As noted above, the evaluators assessed the performance of one operator as unsatisfactory and identified a procedural irregularity that warranted further review. The evaluators determined that all crews and a0 but one operator passed the dynamic simulator examinations. The inspectors concurred with the evaluators' assessments.
The inspectors noted that the performance of the simulator in supporting the examination process was good. The inspectors did not identify any simulator fidelity performance problems that affected observed activities.
The inspectors found that the licensee had enhanced their program administration since the previous inspection evaluated the program. Some examples of these improvements were to:
Require operator reevaluation if the individual's score on a weekly exam fell below l
85% (was previously 80%).
Allow the program review beard to require enhancement training for individuals or
crews for reasons other than unsatisfactory performance. See SecGon 05.4.
Allow a training supervisor to make a recommendation to the PRB regerding an
individual's eligibility to stand watch.
Establish an operations lessons learned "Self Assessment Data Base." See
Section O5.3.
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Conclusions The operations training organization continued to sustain a high level of performance in implementing a systems approach to training for the licensed operator requalification program. The recent implementation of the operations self-assessment data base for tracking lessons learned from evolution debriefs was an example of how the program continues to improve.
Evaluators displayed the same high level of skillin examination administration, observation, and assessment as observed in previous inspections.
05.3 Review of Trainina Feedback Process i
a.
Inspection Scope (71001)
The inspectors reviewed the methods and effectiveness of the licensed operator requalification training program feedback system.
b.
Observations and Findinas
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The inspectors interviewed operators regarding their concerns and perceptions of operator requalification training and examination. The operators expressed high levels of j
satisfaction with the training program overall. They indicated that the training staff was
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' responsive to feedback and input in a timely and effective manner. They expressed
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satisfaction with the' scope of training to maintain their ability to respond to events to protect the public health and safety and to routinely upgrade proficiency for infrequently-performed evolutions such as reactor start-up and shutdown and reduced inventory operations. The operators reinforced the inspectors' perception, obtained through other inspection activities, that there was a close and strong working relationship between operations and training. The inspectors found that the licensee had increased the involvement of the shift management in the on-shift training of their crews with the implementation of the "Self Assessment Data Base." The lessons learned from the crew debrief on any plant evolution were entered into the data base by shift management. This data was reviewed by plant personnel prior to performance of the same or similar evolution. The inspectors determined that this information tool had the potential for improving overall plant performance by avoiding potential problems and ensuring the evolution is implemented in the most safe and efficient fashion.
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Conclusions Operations personnel utilized several diverse methods for providing feedback to the licensed operator requalification training program. The training department responded appropriately to the training feedback provided.
8-05.4 Review of Remedial Trainino Proaram i
a.
Inspection Scope (71001)
The inspectors verified the methods and effectiveness of the licensed operator requalification training program to ascertain whether assessments of operator performance were effectively incorporated into the requalification training.
b.
Observations and Findinas The inspectors learned that the operator who failed the dynamic simulator examination, had recently committed individual performance errors on shift that included a control i
manipulation error and communication weakness. The inspectors asked the licensee
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how this performance would be factored into the remedial action for the operator. The licensee stated that the process would deal first with the performance weaknesses observed in the requalification examination. Then operations management would factor in the operator's shift performance to determine with shift manager input, if further remediation was required before permitting resumption of licensed duties or if the operator should be removed from licensed duties indefinitely. In all cases reviewed, inspectors found remedial training was conducted when appropriate to the displayed weakness or deficiency and as required by the procedure. When an operator was remediated for a written examination failure, he was required to review applicable lesson plans, discuss the system or operation with an instructor or other system expert, and finally be retested. Similar activities were required for walkthrough or dynamic scenario failures.
The inspectors noted that the training staff formally logged relevant comments in a computer data base and sorted by topic and frequency, along with crew and individual examination results. The data base provided various information summary documents.
These were reviewed by training management at the end of each cycle to detect any generic operator or program weaknesses. The training staff then assessed the need for any changes to the training in the next cycle.
In addition to student feedback, the training department utilized feedback from the operations training coordination committee and the training program review board. The board included managers from operations and training and addressed emergent and ongoing operations training issues. After review of meeting minutes for several quarterly board and committee meetings, the inspectors concluded that the important training issues were being addressed appropriately.
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Conclusions The licensee's process for operator remedial training and retesting was comprehensive in practic..
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05.5 Review of Conformance with Operator License Conditions:
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Inspection Scope (71001)
The inspectors evaluated the adequacy of the requalification program's compliance with Subpart C, " Medical Requirements," and 10 CFR 55.53, " License conditions." The inspectors interviewed operators and training management, and examined the-licensee's records to determine compliance for conditions to maintain an active operator license, reactivation of licenses, and medical fitness.
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Observations and Findinas The inspectors verified that the licensee maintained individual operator licenses in compliance with 10 CFR 55.53(e) and (f). The inspectors also verified that the facility ensured that the medical fitness of their individual operator licenses were in compliance with 10 CFR 55 Subpart C, and Subpart F.
The inspectors sampled 10 percent of the individual medical and licensed condition records at the facility. The inspectors determined that all of the records were M order and that all of the operators in this sample were in compliance. The inspectors also found that the facility implemented a computer data base system to track operator condition status. This system was reviewed and updated by operations personnel on a routine basis.
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Conclusions Th6 inspectors determined that the facility adequately tracked and maintained the conditions of their individuallicensed operators per 10 CFR Part 55.
V. Manaaement Meetinas X1 Exit Meeting Summary The examiners presented the inspection results to members of the licensee management at the conclusion of the inspection on February 12,1999. The licensee acknowledged the findings and did not identify any information as proprietary.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee M. Blevins, VP, Nuclear Operations S. Falley, Supervisor, Nuclear Training D. Goslwin, Operations Support Manager B. Guldemund, Shift Operations Manager T. Jank, Operations Liaison T. Marsh, Supervisor, Nuclear Training
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D. Moore, Manager, Operations M. Sunseri, Manager, Nuclear Training NRC PROCEDURES USED inspection Procedure 71001, Licensed Operator Requalification Program Evaluation DOCUMENTS REVIEWED Licensee Procedures Reviewed Final Safety Analysis Report, Comanche Peak Steam Electric Station NPP-601, Senior Operator Certification, Revision 7 TRA-204, Licensed Operator Requalification Training Procedure, Revision 11 I
Procedure TRA-204, " Changes and Justification," dated 11/5/97 NTP-102, Analysis, Revision 6 NTP-103, Design, Revision 7 NTP-104, Development, Revision 8 NTP-402, Training Requests, Revision 6 NTP-603, Simulator Certification Management NTP-201 Training impact System, Revision 8 NTP-105, implementation, Revision 11 NTP-106, Evaluation, Revision 6 LORT Cycle 98-1 through 97-4 feedback comments and training response
. TRA-600, Instructor Training, Revision 3 ODA-315, Licensed Operator Maintenance Tracking, Revision 3
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Other Licensee Documents Reviewed l
L LORT Cycle 00-07 Annual Examinations (Written, Simulator, Walkthrough)
. LORT Examination Banks (Written, Simulator, Walkthrough)
LORT 1997-1998 Annual Examination results Facility Feedback Documents: LORT Cycle Weeks 99-2 through 99-4 LORT Remediation Plans and associated materials: LORT Cycle Weeks 99-1 through 99-5
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CPSES NOE Memorandum, A. B. Hall to D. R. Moore, "NOE-Eval-98-0000 64-00-00,
Simulator Training Evaluation," dated 1/21/99.
Accreditation Evaluation Report, CPSES, TU Electric, INPO, dated April 1998
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