IR 05000498/1997020

Insp Repts 50-498/97-20 & 50-499/97-20 on 970811-14.No Violations Noted.Major Areas Inspected:Operations Re Annual Operating Requalification Exams

ML20217A428
Person / Time
Site:	South Texas
Issue date:	09/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217A407	List: IR 05000498/1997020 ML20217A402
References
50-498-97-20, 50-499-97-20, NUDOCS 9709190159
Download: ML20217A428 (12)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-498 50-499 License Nos.: NPF-76 NPF-80 Report No.: 50-198/97-20 50-499/97-20 Licensee: Houston Lighting & Power Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 l

Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas

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Dates: August 11-14,1997 Inspectors: M. E. Murphy, Reactor Engineer, Operations Granch Accompanying A. Lopez, Consultant, Pacific Northwest Laboratory Personnel:

Approved By: J. L. Pellet, Chief, Operations Branch Division of Reactor Safety ATTACHMENT: Supplemental Information

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C 9709190159 970916 PDR ADOCK 05000498 G PDR

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-2-EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/97-20; 50-499/97-20 Operations

The crews observed practiced good communications and teamwork during the dynamic simulator scenarios. Two of the three crews met all planned critical tasks g and successfully passed the requalification examination. One shift crew failed the

dynamic simulator portion of the examination (Section 04.1).

The inspectors concluded that overall, the annual operating requalification examinations were well constructed and discriminated at the appropriate knowledge level (Section 05.1).

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Licensee evaluators were consistent and objective in their evaluations. Critiques

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effectively identified strengths and weaknesses. Crew and individual weaknesses and failures identified by the licensee were consistent with those identified by the .

inspectors (Section 05.2).

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The inspectors concluded that the licensee was effective in developing and using feedback from licensed operators and that the feedback program was well administered and effective (Section 05.3).

The inspectors concluded that the remedial training program was well administered (Section 05.4).

The inspectors concluded that the licensee was generally effective in maintaining operator licenses and documentation (Section 05.5).

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3-1. Operations 04 Operator Knowledge and Performance 04.1 Operator Performance on Annual Reoualification Examinations Inspection Scone (71001)

The inspectors observed the performance of two shift crews and one staff crew during the third week of the a.inual requalification evaluations. The annual requalification examination included simulator dynamic performance evaluations and five job performance measures for each licensed operato Observations and Findinas l Overall, the inspectors observed good communication practices and teamwork being used by the operators during the examination. Individual crew members employed three way communication and feedback, with effective information transfer and j direction. One shift and the staff crew met critical tasks, diagnosed event l conditie s well, end mitigated the simulated events. One of the shif t crews and the staff crew passed all portions of their evaluations. One shift crew failed their simulator dynamic performance. The evaluators arrived at this conclusion based on extensivn and comprehensive discussions during the critique. The consensus was that there was a misinterpretation of the emergency plan, causing an improper declaration of an unusual event instead of an alert. In addition, the crew failed to correctly refer to procedures when required, resulting in incorrect safety system operation and unnecessary degradation in safety of the plant. The licensee was in the process of implementing remedial training and examination o' the crew, Conclusions The crews practiced good communications and teamwork during the dynamic simulator scenarios. Crews met all planned critical tasks and successfully passed the requalification examinati~1 with the exception of the noted crew f ailur Operator Training and Qualification 0 Review of Reaualification Examinations Insoection Scooe (71001)

The inspectors performed a review of the annual requalification examinations, including operating tests for the 1996 cycle and the annual simulator and job perf 7rmance measures requalification examinations for the 1997 cycle. The requalification biennial written examination was not reviewed. The writ':en l

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examination will be administered in October 1997. The examination sampling plan was also reviewed, and training personnel were interviewed to ascertain the methods used in developing the examination. The ;eview evaluated the general quality, construction, and difficulty level of the material, b. Observations and Findinag The operating examinations consisted of job performance measures and dynamic simulator scenarios. Development of the scenarios and job performance measures followed the guidelines as established by LOR-GL-0003, " LOR Exam Bank Gu:delines," and the guidelines of NUREG-1021, " Operator Licensing Examiner Standards," Revision 7, Supplement The inspectors reviewed 50 job performance measures that were administered during this requalification cycle and 10 job performance measures from the previous requalification cycle, LOR 966. The job performance measures met license program requirements similar to the guidance of NUREG-1021 and contained performant e

! standards that were clear, objective and relevant. The job performance measures were adequate in scope and depth ano appropriately covered a range of topics required by the requalification training program and the regulations. There were, however, several job performance measures that had steps that should have been identified as a critical step or contained steps that were identified as critical that should not have been, if such steps had been incorrectly performed, this could have resulted in incorrect examinee evaluations. The licensee staff acknowledged these job performance measure deficiencies and agreed to make appropriate l revisions. The licensee had established and maintained an excellent data tracking system to track the use of job performance measures during the requalification cycle Nine simulator scenarios administered during this requalification cycle were reviewed. The scenarios were written with clearly identifiable objectives, critical tasks, expected operator actions, and competency standards for evaluatio Review of the scenario bank indicated that the scenarios varied in the types of events evaluated and minimized the repeat of events from scenario to scenari There were some deficiencies noted with the acceptance criteria established for the critical tasks in the scenarios. Specifically, some of the critical tasks identifieddid not have an acceptance criteri6 to effectively evaluate the critical task. For example, the inspectors noted that Scenario LRf.036 contained an inadequate or incorrect standard for determination of whether one critical task was met. In Scenario LRS036, tripping the bistables for o f ailed pressurizer pressure transmitter, PT-456, had the acceptance criteria listed as "Does Not Trip Bistables for PT-456," yet all crews were given credit when-they tripped all of the bistables except the over temperature detta tempeicture bistable. Followup discussions

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-5-between and with the evaluators indicated that the crew had taken appropriate l action even though it was not clearly described in the acceptance criteria. The licensee's training representative agreed that the criteria were in error and would be correcte A review of the training sample plan determined that the licensee adequately covered the topics identified in 10 CFR 55.41 and 10 CFR 55.43. The sample plan was welllaid out and was used extensively during the first 4 weeks of this requalification cycle. Overlap of examination material between each of the weeks was well within the facility established guideline ~, Only one scenario was repeated once in a 4 week period of the requalification evaluation cycle. Only 6 Job performance measures, out of 50 that were being administered, were repeated once in a 4-week period of the requalification evaluation cycle. The review confirmed that the licensee's sample plan followed the standards as defined in Section 2.0 of LOR-GL-0002, " LOR Annual and Biennial Evaluation Guidelines." Conclusions The inspectors concluded that overall, the annual operating requalification examinations were well constructed and discriminated at the appropriate knowledge love .2 - Reaualification Examination Administration inspection Scoce (71001)

The inspectors obscrved the. administration of the simulator scenarios and the job performance measures to determine the evaluators' abilities to administer an

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examination and assess adequate performance through measurable criteria. Eight training evaluators and one operations management evaluator were observed

. participating in one or more aspects of administering the examinations, !ncluding pre-examination briefings, observations of operator performance, individual and group evaluations, technques for job performance measure cuing, and final evaluation documentation, Observations and Findinas Two different evaluator groups, one for the shift crew and one for the staff crew, were observed during the evaluation process of the scenarios. The licensee evaluators conducted the examinations professionally and thoroughly documented their observations for subsequent evaluation. The scenarios met the criteria for evaluation purpose _

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During the scenario requalification examination observed, the operations management involvement provided a balance to the training department evaluators'

assessments. The evaluators ware effective in identifying s+rengths and weaknesses of the crews and individuals. A formal evaluation method was used that reviewed crew and individual critical tasks following the scenario observations and then evaluated competencies for the crew and individuals. The post scenario evaluations were well organ; zed and conducted. The inspectors noted that the operations manager actively participated in the evaluation critiques of the crew Observation of the licensee evaluators and the requalification examinees was conducted during the administration of system-oriented job performance measure The job performance measures consisted of nonlicensed operator tasks outside the control room, licensed operator tasks in the control room and the performance of some tasks in the simulator in the dynamic mode. The licensee evaluators performed well during the examinations. There was nnly one case of inadvertent cuing observed during the performance of a job performance measure. This inadvertent cuing was attributed to the construction / application of a time critical task element in the job performance measure. The license acknowledged the time critical task application criteria deficiency and agreed to review the use and application of time critical elements in the job performance measure The inspectors observed that the performance of the simulator in supporting examination process was good and that there were no observed weaknesse Conclusions Licensee evaluators were consistent and objective in their evaluations. Critiques effectively identified strengths and weaknesses. Crew and individual weaknesses and f ailures identified by the licensee were consistent with those identified by the inspector .3 Review of Feedback Proaram Inspection Scope (71001)

The inspectors reviewed the licensee's process for obtaining and incorporating employee feedback for the training program en.J other plant activities. Section 6 of LOR-GL-003, " LOR Exam Bank Guidelines" and the section, " Training Feedback from Trainees," of the Nuclear Training Department, " Desktop Guide implementation," provide the licensee program guidance for the feedback progra This review included looking at various feedback documentatio Observations and Findinas A review of the feedback program indicated that various avenues (operations field observation, training observation, and plant assessment of training forms, etc.) were available to the employee to provide an input related to written materials, simulator scenarios, job performance ineasures, procedures, and job tasks. A review of feedback documentation indicated that feedback comments were seriously evaluated. Training changes (i.e., increasing class time, adding a subject area, changing a procedure, or improving instructor performance) have been made as a result of feedback. Interviews with selected licensed operators (reactor j operators / senior reactor operators) indicated that the feedback program was

thorough and effective in addressing concern Conclusions The inspectors concluded that the licensee was effective in developing and using feedback from licensed operators and that the feedback program was well administered and effectiv .4 Reviinv of Remedial Trainina Proaram Insoection Scoce (71001)

The inspectors reviewed the remedial training program to evaluate compliance with licensee program guidance contained in Section 4 of Procedure OPGPO3-ZT-0132,

" Licensed Operator Requalification,* Sections 5,7, & 9 of LOR-GL-0001, " LOR Training Program Guidelines," and Sections 4,6, and 8 of LOR-GL-002, " LOR Annual and Biennial Evaluation Guidelines," to determine the effectiveness of the program. This review included remedial training documentation from the 1996 and the first 3 weeks of the 1997 reoualification cycle Observations and Findinos The documentation from the 1996 and partial 1997 training cycles of requalification failures with training and operations staff analysis of the individual or crew weaknesses was found to be sufficiently detailed and directed an appropriate means of remediation. When appropriate, individual operators were removed from licensed operator duties until successful completion of remediation training and a subsequent evaluation. The individuals who passed with remediation were properly remediated and retested in accordance with established licensee guidelines. Interviews with selected licensed operators Practor operators / senior reactor operators) indicated that the remediation process was thorough'and comprehensive in addressing weaknesses in operator and crew performance,

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-8- Conclusions The inspectors concluded that the remedial training program was well administere .5 Review of Conformance With Operator License Conditions Insoection Scone (71001)

, The inspectors evaluated the adequacy of the roqualification program's compliance with 10 CFR 55.53, " Conditions of License." The inspectors interviewed operators, training management, and examined the licensee's records and administrative procedures to determine compliance with conditions to maintain an active operator license, reactivation of licenses, and medical fitness, Observations and Findinas Operator license conditions were being accurately identified and tracked by the operations support group. The official training records resided with the training department, the medical records with the medical department, and the official records of individual practical factors were contained in the official control room lo An updated roster of licensed personnel was issued the first of each calendar quarter. Operators with permanent medical conditions had their licenses properly conditioned. It was also verified that operators with reactivated licenses had received the prerequisite training prior to resuming shift dutie During the inspectors' review of the licensee's Administrative ,

Procedure OPGPO3 ZT-0132, " Licensed Operator Requalification," it was noted that exemption from the biennial written and annual operating tests could be granted to licensed personnel assigned to the examination development team, who develop, administer, review for approval, and grade the tests. This exemption was procedurally limited to one management senior reactor operator and one staff senior reactor operator per applicable cycle and could not be applied to the same personnel in successive annual or biennial examinations. From initial reviews by the licensee, it appeared that this allowance was incorporated in the procedure in late 1994 or early 1995. The licensee also performed a review of licensed personnel actively performing licensed duties and determined that none had been granted an exemption. The procedure exemption from taking a biennial written and an annual operating examination _was contrary to 10 CFR 55.53(h). However, this concern will be considered an unresolved item pending NRC assessment of the significance of the use of the exemption. -This will follow licensee completion of an extensive review to identify affected personnel and determine the cause and source of the procedure change allowing the exemptions (50-498;-499/9720-01).

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't 9 Conclusiona )

The inspectors concluded that the licensee was effectively maintaining operator

, licenses and documentation, but an unresolved issue was identified with respect to selected personnel meeting the requalification examinations required by 10 CFR 55.53(h).

08 Miscellaneous Operations issues (92701)

0 (Closedi) Violation 50-499/9612-01: Failure to follow surveillance test procedure requirement During the conduct of a surveillance on the solid state protection system, the crew failed to declare the surveillance test unsatisf actory after observing that the Safety injection System Valve MOV-OOl68 did not open as required to satisfy the acceptance criteria of Step 5.6.26 of Procedure OPSPO3 SP-OOO98, Revision The licensee had issued the lessons learned from this occurrence to licensed operators. The licensee had incorporated improved guidance on understanding of policies and practices in the new conduct of operations document that replaced the operations policies and practices manual. The licensee had also revised Procedure OPGP03 ZE-0004, " Plant Surveillance Program," to provide improved guidance for situations occurring that result in an indeterminate indication that the surveillance test acceptance criteria are met. No further incidents of this nature have occurred since this violation was issued. The inspectors concluded that the licensee's corrective actions were appropriat .2 (Closed) Violation 50-499/9612-02: Failure to fullow emergency procedure requirement Following a reactor trip, three ce. trol rods did not fully insert and licensed operating personnel did not initiate cinergency boration. The licensee issued written guidance on management expectations regarding emergency operating procedure compliance and each crew wr., briefed on this written guidance prior to assuming a shif t. The licensee revised Procedure OPOPO5-EO-ES01, " Reactor Trip Response," to incorporate criteria for determining control rods " fully inserted" and action if the expected response was not obtained. The licensee conducted t'aining on the procedure usage, reactivity management and control rod posi'Jan indication issues from the Unit 1 reactor trip event of December 18,1995. T'.e licensee upgraded the simulator with the capability to simulate a partial contral rod insertion on a reactor trip. The licensee also revised Procedure OPOPCI-ZA-0018, "Ernergency Operating Procedure User's Guide," to include speciCc criteria when alternate step performance in an emergency operating procedur', can be authorized and the method to document this type of decision. N'., turther incidents of this nature have occurred since this violation was issued. Tne inspectors concluded that the licensee's corrective actions were appropriat __ . _ _ _

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-10-IV. Plant Support F8 Miscellaneous Fire Protection Issues F Gsneral Comments The inspectors observed good housebeping and plant material condition in both units incident to observing administration of the inplant job performance section of the operating test. The facility was clean, welllighted, and the floors were clear and free of debri V. Manaaement Meetinas XI Exit Meeting Summary The iraspectors presented the inspection results to members of the licensee l management at the conclusion of the inspection on August 14,1997. The licensee l acknowledged the findings presented,

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l The licensee did not identify as proprietary any information or materials examined during the inspectio .

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee

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J. Calvert, Operations Training Manager, Nuclear Training G. Chitwood, Nuclear Training K. Coates, Manager, Nuclear Training T. Cloninger, Vice President, Engineering W. Cottle, Group Vice President W. Dowdy, Unit 2 Operations Manager T. Frahm, Nuclear Training J. Groth, Vice President, Nuclear Generation S. Head, Lead Compliance K. Klimple, Unit Supervisor T. Koser, Licensing Engineer C. Lawrence, Nuclear Training l R. Lovell, Unit 1 Operations Manager i

F. Mangan, General Manager, Plant Services L. Martin, General Manager, Nuclear Assurance and Licensing R. Masse, Unit 2 Plant Manager W. Mookhoek, Licensing Engineer

- W. Smith, Nuclear Training T. Werk, Nuclear Training W. Young, Nuclear Training NRC D. Loveless, Senior Resident inspector INSPECTION PROCEDURES USED IP 71001: Licensed Operator Requalification Program Evaluation IP 92701: Followup on Corrective Actions for Violations and Deviations ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-498;-499/9720-01 URI Review of procedure guidance that provided for the exemption from taking a biennial written and an annual operating examination (Section 05.5)

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2-Closed 50 499/9612-01 VIO Failure to follow surveillance test procedure requirements (Section 08.1)

50-499/9612-02 VIO Failure to follow emergency procedure requirements (Section 08.2)

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