IR 05000483/1993006
| ML20045A507 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/04/1993 |
| From: | Bailey R, Burdick T, Shepard D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045A506 | List: |
| References | |
| 50-483-93-06, 50-483-93-6, NUDOCS 9306110012 | |
| Download: ML20045A507 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-483/93006(DRS)
Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company P.O. Box 620 Fulton, MO 65251
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Facility Name: Callaway Plant Inspection At: Steedman, M0 Inspection Conducted: May 17 - 21, 1993
[A 6////C Inspectors:
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D. Shepard Date
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bW b!Hl!i R. Bailey Datet Approved By: T f /ahJ T. Burdick, Chief Date'
Operator Licensing Section 2 Insoection Summary Inspection conducted on May 17 - 21. 1993 (Report No. 50-483/93006(DRS))
Areas Inspected:
Special, announced inspection of the licensed operator requalification program to include a review of training administrative procedures, requalification training records and examination material; observation and evaluation of operator performance and of licensee evaluators during requalification examination administration; an evaluation of the program controls to assure a systems approach to training, remediation training administered; and an assessment of simulator fidelity. The inspectors used the guidance in Temporary Instruction (TI) 2515/117.
Results: The inspectors concluded that the licensee was implementing the licensed operator requalification training program in accordance with 10 CFR Part 55 requirements and that operations and training management involvement with the process was a strength. However, one open item regarding training administrative procedures was identified (483/93006-01(DRS))
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(Section 2.1.1).
Attendance at required requalification training was good
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(Section 2.1.2).
Dynamic simulator examination scenarios did meet the
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9306110012 93060T PDR ADOCK 05000483-G PDR-
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Inspection Summary
guidelines of TI 2515/117 (Section 2.1.3).
Operator performance was satisfactory (Section 2.2).
Licensee evaluators were considered adequate (Section 2.3).
The requalification program contained evidence of being based on a systems approach to training (SAT) (Section 2.4).
Remediation training administered was good (Section 2.5).
Simulator fidelity was satisfactory (Section 2.6).
The one open item identified will require further NRC review.
The inspectors also reviewed the licensee's actions related to a violation of 10 CFR 55.59 requirements for records retention. The inspectors concluded that the license's efforts to identify and correct the violation met the criteria specified in Section VII.B of the " General Statement of Policy and Procedures for NRC Enforcement Action,"
(Enforcement Policy 10 CFR Part 2, Appendix C (1992)) and the violation is not being cite.
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l REPORT DETAILS 1.0 Persons Contacted Qnjon Electric Company n
- J. Blosser, Manager, Operations Support i
- R. Barton, Operating Supervisor, Trainiag
- J. Cunningham, Shift Supervisor
- +G. Czeschin, Superintendent, Training
- S. Halverson, Shift Supervisor, Simulator
+M. Henry, Quality Assurance Engineer
- +W. Jessop, Shift Supervisor, Operations Training
- J. Laux, Manager Quality Assurance
- R. Nelson, Operating Supervisor, Training
- D. Young, Operations Superintendent Nuclear Reaulatory Commission
- B. Bartlett, Senior Resident Inspector
- +T. Burdick, Chief, Operator Licensing Section 2
- D. Calhoun, Resident Inspector
+ Denotes those present at the training exit meeting on May 20, 1993.
- Denotes those present at the inspection exit meeting on May 21, 1993.
Other persons were contacted as a matter of course during the inspection.
2.0 Introduction The purpose of this inspection was to assess the licensee's requalification program for licensed operators to determine whether the program incorporated 10 CFR Part 55 requirements for evaluating operator mastery of training objectives and revising the program. The licensed operator requalification program assessment included a review of training administrative procedures, requalification training records, and examination material. The inspectors conducted an evaluation of operator performance and the ability of licensee evaluators to administer and objectively evaluate during requalification examinations.
In addition, an evaluation of the effectiveness of the program controls to assure a systems approach to training, and remediation training was conducted.
Further, the inspectors assessed simulator fidelity.
2.1 Licensed Operator Reaualification Proaram Assessment 2.1.1 Program Administration The inspectors concluded that the licensee was implementing the licensed operator requalification training program in accordance with the licensee's administrative procedures.
The inspectors identified the following strengths regarding requalification program administration:
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Training and Operations management work together to ensure that the s
training given is consistent with the job requirements.
e Attendance at requalification training has an appropriate high priority.
e Operations management actively participated in crew evaluations during the dynamic simulator and JPM examinations.
During the inspectors' review of training administrative procedure TDP-ZZ-00022, Rev. 2, " Licensed Operator Requalification Program" and the system for ensuring that the required control manipulations are completed, the following concern was identified:
TDP-ZZ-00022, Rev. 2, Section 5.6, stated, "Each Licensed. Reactor Operator shall manipulate and each Certified Senior Reactor Operator shall manipulate or direct the manipulation of controls as specified in 10CFR55.59(c)(3)." However, the inspectors could not conclude from the records reviewed that all licensed R0s manipulated the controls and that all licensed senior reactor operators (SR0s) either manipulated the controls or directed the activities of the individuals during the plant control manipulations.
10 CFR 55.59.c.3.1 requires, in part, that each licensed operator of a utilization facility manipulates the plant controls and each licensed senior operator either manipulates the controls or directs the activities of individuals during plant control manipulations for items described in paragraphs c.3.i (A) through (L).on an annual basis and all other items on a two-year cycle.
10 CFR 50.54.1-1 states in part that the licensee shall have in eff ect an operator requalification program which must as a minimum, meet the requirements of 55.59(c).
The licensee cited 10 CFR 55.59.c which states, in part, that in lieu of paragraphs c(2), (3), and (4) of this section, the commission may approve a program developed by using a systems approach to training.
The licensee stated that their requalification training program was systems approach to training (SAT) based, INPO accredited, and had a plant specific certified simulator, and therefore was in accordance with 10 CFR 55.59.c requirements. The commission policy, as stated in the
March 20, 1985 Federal Register, (53 FR 11147) and as amended on November 11, 1988 (53 FR 46603), endorses INP0 accredited programs.
The records reviewed by the inspectors indicated that all licensed
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operators in a crew have been given credit for all required plant
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control manipulations performed during specific simulator sessions.
The inspectors identified instances when five individuals each received credit for plant control manipulations such as a Reactor Startup during a single simulator training session they attended. -The five member crews consisted of one Reactor Operator (R0 license), one-Balance of Plant Operator (R0 license), the Control Room Supervisor (SR0 license),
Shift Supervisor (SR0 license), and a Field Supervisor /STA (SRO license).
During a Reactor Startup, only the Reactor Operator
manipulates the controls to bring the reactor critical and the Field Supervisor /STA has no command responsibility for the startup; however,
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all individuals in the crew received credit for performing or directing the reactor startup.
The inspectors concluded that, generally, the licensee's program was in accordance with 10 CFR 55.59 requirements, however, the inspectors requested the licensee to provide a written response indicating what actions are taken by their program to verify that licensed operators have the ability to perform plant control manipulations in lieu of actual performance.
Pending further review by the NRC of this response, this item is considered open.
(483/93006-01 (DRS)).
The licensee inadvertently destroyed individual operator examination answer sheets for requal cycles 92-2 and 92-4 due to a clerical error.
Destroying the answer sheets is a violation of 10 CFR 55.59 (c)(5) which requires the facility licensee to maintain records of the written examination answers given by the operator or senior operator until the operator's license has been renewed. However, the licensee reported this violation and took immediate corrective action to prevent reoccurrence. The inspectors reviewed the corrective action taken by the licensee which included counseling the individual and formalizing the end of course actions required by the individual.
Therefore, because the efforts in identifying and correcting the violation met the crite:.a specified in Section VII.B of the " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C (1992)), the violation is not being cited.
Additionally, the licensee's requalification program contained a segment at the beginning of the examination week that administers practice examination scenarios prior to administration of the annual requalification examination.
The practice examination was administered in exactly the same manner as the
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annual requalification examination. The licensee stated that this segment was to allow the operators to get reacquainted and comfortable with the examination process. The inspectors compared the examination items used on the practice examination during the inspection week with the actual requalification examination administered. The dynamic simulator scenarios used on the practice examinations were not part of the requalification examination.
The inspectors concluded that this practice was acceptable.
A previous concern (examination report No. 50-483/0L-92-01) was that the licensee was using examination scenarios as training scenarios.
The licensee has changed their program to not use examination scenarios to train their operators.
The examination security was effective in preventing examination compromise.
The operators interviewed stated that examination security was not excessive or stressful.
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2.1.2 Reaualification Trainina Records Review The inspectors reviewed requalification training attendance records for the cycle years 92 and 93, and concluded that licensed operators had attended all scheduled requalification training or performed appropriate remediation as required by their program.
2.1.3 Reaualification Examination Material Review The inspectors reviewed the dynamic simulator, JPM, and written examinations to be administered during the week of May 17, 1993, and compared them with the examinations administered other weeks in the exam cycle. The inspectors concluded that the examinations were adequate. The inspectors also noted that only minimal overlap existed for the dynamic simulator, JPM, and written examinations for the duration of the exam cycle.
The inspectors made the following observations regarding the examination material:
TI 2515/117, is based on NUREG 1021, " Operator Licensing Examiner Standards," Revision 7.
The dynamic examinations met NUREG 1021, Revision 7 guidelines.
- The dynamic scenario examination bank did not contain any cold shutdown scenarios or scenarios leading to inadequate core cooling or loss of primary system integrity.
- The dynamic scenarios do not have a discernable pattern so the operators can not tell the sequence of events.
In addition, the licensee does not publish the examination scenarios to ensure exam security.
- The licensee's written examinations had no common questions on examinations that are to be administered within this examination cycle. The inspectors noted that the system used by the licensee to ensure that there was minimal overlap was simple and extremely effective. The licensee printed a hard copy of all the examination questions from the bank and then removed the ones chosen for an exam. This means that the subsequent written examinations can not include the questions previously used.
- The inplant JPM cues use "the valve is closed" vice more appropriate alternatives such as the valve position indication or that the valve handle will not turn.
2.2 Operator Performance Evaluation The inspectors evaluated the operators' performance on the dynamic simulator and JPM examinations and parallel graded the written examinations for the crew in training.
The inspectors concluded that operator performance on the requalification examinations was satisfactory.
In addition, the inspectors I
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observed a dynamic simulator training session attended by the crew prior to the dynamic simulator examination.
2.3 fyv31uation of Licensee Evaluators The NRC inspectors and the licensee evaluators agreed on the overall assessment of operator performance. The inspectors concluded that the licensee evaluators could adequately administer the requalification examinations and objectively evaluate the performance of the operators.
2.4 System Approach to Trainina Controls The inspectors concluded that the licensee's program had controls in place to revise the training program as needed based on industry events (LERs), system and procedure modifications, and student feedback.
The inspectors reviewed the training and examination material regarding a recent event involving the loss of annunciators. Training on this event was considered to be adequate and timely. The requalification examination material had been revised to reflect this event.
The licensee representative stated that specific examination items regarding modifications will be revised as they are selected for use on subsequent examinations.
The inspector made no conclusions on the licensee's process for updating exam bank items.
The inspectors identified that Callaway LERs,92-001,-002,-003, and -005 were discussed in requalification training as part of classroom training in cycle 92-3 as part of lesson plan T61.R923.8.
The inspectors also reviewed the process for students to provide feedback to the training program. A " Student critique" form can be filled out by individuals at the end of a training week to express any concerns or suggestions regarding the training program.
These forms are routinely reviewed by the training staff and any suggestions are incorporated into an action tracking system as appropriate. The operators interviewed stated that they receive appropriate feedback from the training staff including the use of electronic mail to the various crews to document replies to their concerns.
Additionally, the inspectors reviewed the last two QA licensee audit reports of licensed operator requalification training to see if appropriate comments had been incorporated into the training program. The audits appeared to use some performance based techniques including audit of ongoing training by the auditors.
2.5 Remediation Trainina The inspectors reviewed the last two individual failures of the annual requalification examination to assess the remediation process.
The licensee's program required an oral discussion with the individual to review weaknesses and the remediation requirements for that individual.
In addition, a form which documents completion of and attendance at the remediation training is
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required to be filled out.
In the two cases reviewed, the licensee followed the process.
One of the individuals failed the NRC administered requalification examination and then subsequently passed the NRC retake examination; this showed that the licensee remediation was successful in that case.
One individual had a letter from tne training department which delineated the errors committed, the remediation and retest required to resume operator duties.
This method gave the individual a clear picture of his required remediation.
2.6 Simulator Fidelity The inspectors concluded that simulator fidelity was satisfactory.
Two minor weaknesses had no major effect on the examination process and are identified in the enclosed Simulator Facility Report.
3.0 Doen items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. The open item disclosed during the inspection is discussed in Section 2.1.1.
4.0 Exit Meetina The inspectors conducted exit meetings on May 21, 1993, with plant management, and on May 20, 1993, with the training staff at the Callaway Nuclear Plant to discuss the major areas reviewed during the inspection, the strengths and weaknesses observed, and the inspection results.
Licensee representatives in attendance at the exit meetings are documented in Section 1.0 of this report.
The team also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspectors during the inspection. The licensee did not identify any documents or processes as proprietary.
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i SIMULATION FACILITY REPORT Facility Licensee: Callaway Plant Facility Licensee Docket No. 50-483 Operating Tests Administered On: Callaway Plant Specific Simulator This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of noncompliance with 10 CFR 55.45(b).
These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluations. No licensee action is required in response to these observations.
While conducting the simulator portion of the operating tests, the following items were observed:
ITEM DESCRIPTION 1.
MSIV accumulator charging R0 stated that the times to recharge MSIV accumulators were quicker in the simulator than in the plant.
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Critical Safety function (CSF)
CSF display did not show FR-H.1 as Display immediate action necessary during a loss of heat sink scenario until the simulator was frozen.
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