IR 05000528/1992032
| ML20125D733 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/18/1992 |
| From: | Morrill P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20125D724 | List: |
| References | |
| 50-528-92-32, 50-529-92-32, 50-530-92-32, NUDOCS 9212160009 | |
| Download: ML20125D733 (18) | |
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V. S. NUCLEAR REGULATORY COMMISSION
REGION V
Beport Nos.
50-528/92-32, 50-529/92-32, and 50-530/92-32 Docket Nos, 50-528, 50-529, and E0-530 License Nos.
NPF-41, NPF-51, and NPF-74 Licensee Arizona Public Service Company P. O. Box 53999, Station 9012 Phoenix, AZ 85072-3999 Facility Name Palo Verde Nuclear Generating Station Units 1. 2, and 3 Inspection October 13 through 23, 1992 Conducted Inspectors G. Johnston, Team Leader, Licensing Examiner, Region V J. Russell, Licensing Examiner, Region V R. Pelton, Training Specialist, NRR D. Desaulniers, Engineering Psychologist, NRR H. McWilliams, Consultant, SAIC Corp.
Prepared BY G. Johnston, Licensing Examiner O
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///MkL Approved By P.J.ho'rri Chief Date Signed Operations Section Inspection Summary:
Inspection on October 13 throuah 13,_L992 (Report Numben 50-528/92-32, 50-529/92-32 and 50-530/92-32)
Emeroency Operatina Procedures:
The inspectors conducted simulator exercises of Emergency Operating Procedures (E0Ps). The exercises demonstrated that the E0Ps can be used by a trained operating crew.
No technical problems were identified in the E0Ps, and the operators demonstrated little difficulty in carrying out E0Ps transitions.
9212160009 921203 i
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Operator Continuina Trainino (Recualification):
The inspection determined that the licensee has maintained a systems approach to training as described in 10 CFR 55.4. The requalification training program appeared to have improved over the last three years since the last training inspection. During the inspection the inspectors observed that Operations involvement with the preparation of training material could be improved.
Management appeared to have a strong commitment to the operator requalification training program. The recent high annual simulator test failure rate was examined during the inspection. The inspectors concluded that the high failure rate was due to increased performance expectations. The operators stated that they had not been adequately informed of the aerformance standards before the examinations. The inspectors concluded that tie licensee standards related to the annual simulator tests were reasonable and enforced uniformly.
The inspectors made an observation during interviews of licensed operators.
Specifically, the operators questioned the credibility of new caerations instructors. The operators stated that the new instructors lacted site saecific experience, and therefore, credible knowledge of facility operations.
Tae inspectors found the new instructors fully qualified to perform the activities they were assigned.
Safety Sianificant issues:
No safety significant issues were identified.
Status of Ooen items:
Nine open items from previous inspections were closed.
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DETAILS 1.
Attendees at Exit Meetino Arizona Public Service Company (APS)
R. Gouge, General Manager, Plant Support E. Firth, General Manager, Nuclear Training J. Dennis, Manager, Operations Standards R. Adney, Plant Manager, Unit 3 F. Riedel, Operations Manager, Unit 1 P. Wiley, Operations Manager, Unit 2 R. Nunez, Manager, Operations Training L. Florence, Senior Advisor, Operations Standards B. Grabo, Acting Supervisor, Operations Training R. Fullmer, Manager, Quality Assurance and Monitoring G. D'Aunoy, Auditor, Quality Assurance and Monitoring R. Horton, Auditor, Quality Assurance and Monitoring S. Smith, Monitor, Quality Monitoring P. Coffin, Engineer, Compliance M. Saba. Lead Engineer, Simulator Support Site Representatives J. Draper, Southern California Edison Co.
F. Gowers, El Paso Electric Co.
NRC Personnel G. Johnston, Team Leader P. Morrill, Chief, Operations Section R. Pelton, Training Specialist, NRR
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D. Desaulniers, Engineering Psychologist, NRR J. Sloan, Senior Resident inspector The persons above were present at the exit meeting held on October 23, 1992.
2.
Annual Operatino Examination Failures (92701)
The inspectors reviewed licensee documentation related to the facility annual requalification operating tests to determine the cause of the high failure rate. Overall, 35 of 108 operators taking the simulator examinations failed. Only 17 of the operators failed based on the guidance provided in NUREG-1021. " Examiner Standards," section ES-604.
The remaining failures were due to the operators not performing to the new and more extensive management expectations.
The new expectations included:
(1) procedural adherence as defined by a memorandum from W. Conway to all staff, (2) following the " Conduct of Shift Operations" procedure (which governs shift activity, and defines operator responsibilities), and (3) implementation o.f the guidance within documents-40DP-9AP05, " Emergency Operating Procedures Technical
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Guidelines," and 40DP-9AP06 the Plant Specific Technical Guidelines (PSTGs).
Procedure 40DP-9AP05 was amended by the licensee during the course of the examinations to eliminate a requirement to implement guidance in the PSIGs. The change required the operators to implement only what the E0Ps direct.
The inspectors concluded from a review of the examination results that the change to the procedure did not result in a significant
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change in operator evaluations. The inspectors observed that a majority of the failures involved poor communications, and failures to perform steps in the E0Ps as described. The licensee chose not to change the results of any licensed operator annual examination failures that occurred prior to the amendment to 40DP-9AP05.
The inspectors observed two examples that occurred prior to the change to 40Dp-9AP05 where operators were inappropriately failed for following their E0Ps, when their E0Ps conflicted with the PSTGs. One instance the inspectors noted was one operator terminated Safety Injection as the E0Ps direct. However, the licensee evaluators failed the individual. This was because the PSTGs stated that all available charging pumps were required to be running if there was evidence of a steam space LOCA in the pressurizer. The procedure step in use did not include this as the required action. Another operator failed when he did not continue cooling down the RCS using the steam generators. He was at a procedural step where he was to stabilize RCS T(cold) at 570*F, which he had done.
However, he failed because the RCS had lost subcooling, and the PSTG requirement was to continue cooling down until subcooling is re-established. The inspectors concluded that the facility licensee's decision not to change the results of the examinations was consistent with examining to the procedures in effect at the time.
The inspectors concluded that the licensee had high standards of performance and had applied them uniformly. The inspectors interviewed some of the operators who failed the examination. These operators stated that management had not informed them beforehand that these higher standards could result in failure during the simulator exams. The inspectors informed management of the operators statements.
Further, the E0Ps included two instances (described above) where the operators had to l
implement technical guidance instead of the actual step described in the I
procedure which resulted in operator failures. The licensee reviewed the two instances and concluded that changes to the E0Ps should correct the
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l No items of non-compliance or deviations were identified.
l 3.
Previously Identified items (42001)
a.
(Closed) Open item 50-528/529/530/92-12-01 Open item 92-12-01 involved an inadequate isolation strategy for a loss of coolant accident outside of containment. The E0Ps did not adequately address the isolation of a leak outside of containment
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(intersystem LOCA) and, in a later step, delayed the restoration of containment integrity. Also, the E0Ps did not direct a rapid cooldown, which was necessary to reduce the leak. When the procedure did direct a cooldown, it was a controlled vice a rapid plant cooldown. The urgency for plant cooldown implied by the owners group guidance (CEN-152) was not transferred to the station E0Ps, nor was the deviation justified.
The inspector reviewed revision 0.02 of 41EP-lE001, " Emergency Operations," and noted that for an intersystem LOCA, the operators would have transitioned to 41EP-lR002, " Loss of Coolant Accident."
The inspector noted that step 3.10 of revision 0 of this procedure directed the Control Room Supervisor (CRS) to check for an intersystem LOCA. The next step directed the isolation of the intersystem LOCA. Step 3.33 of the same procedure directed the CRS to begin a controlled cooldown under these circumstances at a rate close to, but less than,100 F/hr.
100 F/hr. was the maximum cooldown rate allowable under Technical Specification 3.4.8.1.
The inspector concluded that this revision adequately addressed an intersystem LOCA and did not delay the restoration of Containment integri ty. The cooldown step was incorporated at a point consistent with CEN-152 guidance. Although the licensee used the term controlled cooldown, the inspector concluded that this met the guidance in CEN-152.
Further, CEN-152 stated that the rate was to be within Technical Specification limits. The licensee directed a rate close to this limit, which would be, in effect a rapid cooldown (in excess of normal administrative limits.
This item was considered closed, b.
(Closed) Open item 50-528/529/530/92-12-02 Open item 92-12-02 involved the use of concurrent procedures if a steam generator tube rupture (SGTR) in one steam generator (SG)
occurred with a fault in the other SG. The operator would have entered the " Functional Recovery" procedure, 41EP-lR008, and would have to perform the main body of the procedure as well as " Steam Generator Tube Rupture," attachment 5.
This use of concurrent procedures was ccatradictory to CEN-152 guidance.
It also resulted in contradictory procedural guidance for the operator, requiring continual re-entry into the concurrent procedure. even after mitigation of the SGTR, i.e., an endless loop with no exit.
The inspector noted that 41EP-lR008, " Functional Recovery," was revised (revision 0.02) to drop the use of concurrent procedures.
For a simultaneous SGTR and faulted SG the operator was directed to go to attachment 3 of the " Functional Recovery," which would first mitigate the SGTR and then the faulted SG. The operator would then reenter the main body of the procedure. This eliminated contradictory steps and the endless loop.
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This item was considered closed.
c.
(Closed) Open item 50-528/529/530/92-12-03 Open item 92-12-03 involved the use of calculations to determine adverse containment values for instruments located inside containment. This need to perform calculations while in the E0Ps appeared cumbersome, unreliable, and contrary to guidance in NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures."
The inspector reviewed a sample of the E0Ps and found adverse containment values were in brackets next to normal containment values. This removed the need for the operators to calculate adverse containment values. The inspector reviewed 41EP-lE001,
" Emergency Operations" and found the procedure directed the use of these harsh containment values if containment temperature reached 150*F during performance of the " Safety Function Flowchart." The inspector concluded that 41EP-lE001 complied with the guidance in NUREG-0899 and the procedure properly incorporated harsh containment values.
This item was considered closed.
d.
(Closed) Open item 50-528/529/530/92-12-04 Open item 92-12-04 involved inconsistent application of the CEN-152 standard post trip actions with regard to safety functions. The facility E0Ps contained three inadequately justified deviations from CEN-152. They were all contained in 41EP-1E001, " Emergency Operations." The three deviations were:
If a loss of vital alternating current (AC) occurred the procedure directed the CRS transition to 41EP-lR007, " Blackout" before completion of the check of safety functions.
The procedure directed the CRS to transition to " Blackout," on a loss of vital AC and direct current (DC).
The procedure did not address combustible gas concentration in containment.
The inspectors reviewed revision 0.02 of 41EP-lE001, " Emergency Operations." The inspectors noted that all safety functions were checked prior to any transitions. This was in accordance with CEN-152 guidance.
The inspectors also noted that 41EP-lE001, after a check of safety functions, directed the CRS to transition to 41EP-lR007, " Blackout,"
if no vital AC buses were energized and reactivity control was jeopardized (and all other safety functions were satisfactory). The CRS was also directed to transition to " Blackout" if no vital AC
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buses were energized and two cr more safety functions were Jeopardized. However, the CRS was directed to 41EP-IR008,
" Functional Recovery" on a loss of vital AC and DC power, regardless of the safety functions in jeopardy. This was in accordance with CEN-152 guidance.
The inspectors also reviewed revision 0.02 of 40DP-9AP06," Emergency Operations Technical Guideline." The inspectors noted that the CRS safety function flowchart in " Emergency Operations" did not include
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combustible gas control. Procedure 40DP-9AP06 justified this omission because of the time it would take for hydrogen to build up i
after an accident. Hydrogen concentration was monitored during the
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loss of coolant accident (LOCA), excessive steam demand event
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(ESDE), and in functional recovery guidelines. The inspectors also noted that containment temperature and pressure (the parameters used in CEN-152 to verify the combustible gas safety function) were checked in the secondary operators safety function flowchart.
If containment temperature exceeded a plant specific value then the procedure directed containment fans verified operating or placed in operation. This was the action directed in CEN-152 to lower temperature and mix any pockets of hydrogen in containment, thus
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minimizing the hydrogen concentration. The inspectors concluded that containment combustible gas control was addressed in " Emergency Operations." The inspectors also concluded that the elimination of containment combustible gas as an explicit safety function was adequately addressed in " Emergency Operations Technical Guideline."
This item was considered closed.
e.
IClosed)Ooenitem 50-528/529/530/92-12-05 Open item 92-12-05 involved deficiencies cpecific to the following procedures: " Loss of Coolant Accident," 40EP-9R002; " Loss of all Feedwater," 41EP-1R005; " Loss of Offsite Power," 41EP-1R006;
" Blackout," 41EP-lR007; and " Functional Recovery," 41EP-lR008. This open item contained 43 separate deficiencies in the procedures listed above and three plant deficiencies.
The inspectors reviewed the procedures listed above to verify correr tion of these deficiencies. The inspectors received, from the licensee, a list of five of these deficiencies not corrected at the
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l time of this inspection. These five deficiencies were to be corrected in a future revision of the E0Ps. The inspectors verified that the licensee corrected the other 38 deficiencies in the procedures. Methods to correct these deficiencies included direct correction, deletion, clarification, and further justification, for deviation from CEN-152, in the Technical Guideline. The inspectors further noted that the five items requiring correction were incorporated in the Palo Verde Commitment Action Tracking System (CATS). The inspectors had confidence, based on resolution of the 38 deficiencies and the inclusion of the remaining deficiencies on
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the CATS system, that the licensee would address all deficiencies.
The inspectors verified correction of the three plant deficiencies.
This item was considered closed.
f.
(Closed) Open Item 50-528/529/530/92-12-06 Open item 92-12-06 involved incorporation of safety significant comments from a review of the Plant Specific Technical Guidelines (PSTGs) conducted by Combustion Engineering (CE) into the Emergency Operating Instructions (E01s).
During the inspection, the inspectors reviewed portions of an Emergency Procedures Technical Guideline (EPTG) review done by Asea Brown Boveri (ABB) dated March,1992. ABB was the owner of CE. The inspectors noted that 17 items, based on comments made in the ABB audit, were incorporated into the E01s. The inspectors concluded the necessary changes had been made.
This item was considered closed.
g.
(Closed) Open Item 50-520/529/530/92-12-07 Open item 92-12-07 involved a temporary effluent sample monitor (RU-52) staged in the auxiliary building permanently as a backup to RU-01. The UFSAR described RU-52 as a movable airborne monitor attached to a portable monitor connection box.
In the report, the inspectors concluded the UFSAR should be revised if it was intended that RU-52 be a permanently installed backup.
The inspectors interviewed the cognizant system engineer and observed that RU-52 was seismically restrained, via anchor bolts, but that it still had wheels and could be moved. The inspectors concluded that RU-52 was a portable monitor. The inspectors also concluded that the equipment in place did not contradict the description of the equipment in the UFSAR. The inspectors noted the licensee documented the anchor bolts used as a seismic restraint as a site modification.
This item was considered closed.
h.
(Closed) Open item 50-528/529/530/92-12-08 Open item 92-12-08 involved conflicting direction given to the operators concerning procedural adherence when in the E0Ps. Palo Verde management stated they expected operators to complete all portions of the " details" column to complete individual steps.
However, the operators had received contradictory training and the-procedure that discussed procedure usage, " Emergency Operating Procedures Technical Guidelines," 40DP-9AP05, was not explicit in this area.
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The inspector reviewed revision 0.02 of 40DP-9AP05. The inspector noted step F.1.a.iii on page 41 of this procedure stated ' Operators shall perform the details c.s written, except with the concurrence of the CRS." The inspector concluded that revision 0.02 of 40DP-9AP05 was sufficiently explicit concerning procedural adherence. The inspectors interviewed selected ooerators on site to determine their understanding of the requireme.d to aerform the details column as written. The inspectors concluded 11at the operators understood this requirement.
This item was considered closed.
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(Closed) Open item 50-528/529/530/92-12-09 Open item 92-12-09 involved less than adequate quality assurance (QA) involvement in E01 development (specifically independent verification and validation).
In the report, the inspectors noted that QA had not performed an indepandent validation of the E01s.
TheirspectorsreviewedQualityAssuranceandMonitoring(QA&M)
monitoring reports dated September and October, 1992. The inspectors also reviewed monitoring conducted by QA&M with other organizations. This was an improvement over the previous level of activity observed during the previous inspection. The inspectors concluded that QA had adequate involvement in the verification of the E01s.
This item was considered closed.
No deviations or violations were identified.
4.
Simulator Exercises of Emeroency Operatina Procedures (42001)
During the inspection of April 6 - 10, 1992 the inspectors determined that the simulator exercise of the E0Ps could not be completed at that
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time because of the lack of training of the operators on the functional recovery procedure. This effort was delayed until this inspection. The inspectors prepared four scenarios for simulator exercises. The four scenarios were:
1)
The plant was on Shutdown Cooling in Mode 3 with the reactor suberitical. One reactor coolant pump was running. A Steam Generator Tube Rupture in excess of charging pump capacity -
occurred. A Station Blackout followed such that no vital AC power was available.
2)
A steam generator tube rupture occurred in one Steam Generator and an Excess Steam Demand Event (ESDE) in the other Steam Generator. This led to potential loss of Subcooling and forced a cooldown on the ruptured SG using the Functional Recovery procedure.
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ESDE occurred with loss of all feedwater which required Functional Recovery actions.
4)
A small loss of Coolant Accident (LOCA) with electrical bus failure in one train and major equipment out of service in the other train.
Two crews of operators participated in the simulator exercises. During the exercises the inspectors did not observe any procedure usage in violation of licensee management policy or administrative requirements.
The inspectors noted that the operators made all anticipated transitions, and carried out all procedural actions as required.
The inspectors used the Mode 3 shutdown condition scenario (1 above)_ to evaluate the operators usage of the E0Ps in an unanticipated situation.
The inspectors found that the operators chose not to implement 41EP-12Z01
" Emergency 0:erations." The first procedure entered was the Steam Generator Tuse Leak Abnormal Operating Procedure (AOP). This was followed by the implementation of the Degraded Electrical Systems-A0P.
The inspectors ob arved that both procedures appeared to be appropriate-for the conditions wresent.
The Emergency Operations procedure was not specific about entry requirements other than a Reactor Trip. As the scenario progressed.-the operators determined that the Functional Recovery actions in the E0Ps -
contained the only available actions that addressed a loss of all AC-
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power situation.
Based on that analysis they chose to carry out the actions of that procedure.
The inspectors concluded the operators understood the event mitigation strategy of the E0Ps, the basis of the procedures, and the rules of usage. Operator knowledge of the procedural actions also appeared satis factory. The inspectors asked Operations Standards personnel to determine if the licensee was participating in the CE owners group i
efforts to develop lower mode E0Ps. A licensee representative stated that the licensee was participating in this effort and committed to provide Region V with an estimate of when procedures will 'e developed after the initial validation effort is complete.
No items of non-compliance or deviations were identified.
5.
Classroom Observations (41500)
The inspectors watched two presentations of "1992 Inhouse Exam Observation _ Briefing" (lesson number NUB 48-01-RS-001-001). The purpose of the_ observations was to determine that the training was appropriately organized, presented, and sequenced. During the-observed presentations, the instructor controlled the class, exhibited good platform presentation skills, good command of the training material, and had good site-specific-technical and procedural knowledge.
Licensed operators were attentive-and demonstrated a knowledge of the material presented. They
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clarification and answered questicas posed by the instructor. Some student questions and statements reflected resistance to the more stringent procedural adherence policy and the newly adopted higher management expectations.
The pace of the presentations and use of available training time was effective. The self-study guide provided the students an outline of the lesson in a format that helped student note-taking on lesson details.
Presentations concerning specific procedures were su)plemented with overhead projections of the referenced sections of t1e procedures.
However, in several instances the student handout did not include the referenced procedures and the projacted print was too small to be read.
During these classroom sessions, the instructor used red markers on the white board. Due to the lack of contrast between the marker and the board the writing appeared pink and was extremely difficult to read.
Other than this one deficiency, the inspectors concluded that classroom instruction was effective.
The inspectors observed that Operations involvement with the preparation of continuing training material for their staff may have been lacking.
For example some training material requested by the inspector had not been reviewed by Operatioi s.
Prior to arriving on the site the Team Leader had requested advance copies of training material. The Team Leader was informed that some material might not be ready until his arrival on the site on October 13, 1992. The material was associated with events related training. The inspector determined that the material had been approved for instructional usage on Friday October 9,1992. No signature or other indication was found to establish that Operations personnel had reviewed the training material. During interviews with Training supervision and Operations supervision personnel neither group indicated that the material had been reviewed by operations. Operations supervision stated that some of the training material content had been requested by Operations. The inspectors established that Operations provided input for training and, when required did review training material. However, as a matter of routine, Operations did not review training material. Operations usually provided comments on training materials after the training had been given.
During one of the presentations, a licensed operator referenced ?
memorandum (dated October 14,1992) concerning Emergency Action level classifications. The training department was not on distribution for the memorandum and consequently the instructor was unaware of this information and guidance. During past requalification examinations the Senior Reactor Operators had difficulty in classifying emergency events.
Considering the past event classification difficulties experienced by the operators, the information contained in the memorandum could be relevant to licensed operator requalification training. The failure by the Operations Department to distribute the memorandum to training shows an apparent lack of coordination between Operations and the Training Department related to operating philosophy. This was discussed with licensee management at the exit intervie,
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No items of non-compliance or deviations were identified.
6.
Simulator Scenario Observations (41500)
The inspectors watched three crews participate in two licensee simulator scenarios. The purpose of the observations was to determine that the simulator training was appropriately organized and sequenced. The scenarios observed were " Plant Shutdown Due to Failed Fuel" (scenario NUS40-01-RS-001-000), and " Reactor Startup" (scenario NUS01-02-RS-001-001). These scenarios were on the licensee's list of scenarios required to be performed on a recurring basis. During the simulator exercises, all crews exhibited a professional demeanor and conducted themselves in a manner appropriate to the control room.
It should be noted that the operators on the observed crews did not consistently acknowledge communications such as by using repeat backs.
The scenario briefings conducted by the instructors provided enough information to allow the o>erators to assume the watch. The instructor:
showed more than adequate (nowledge of control room responsibilities and questioned operators to ensure their understanding of the material being presented.
It was noteworthy that the instructors modified the scenarios during the run of the scenario when it became apparent that the length of the plant shutdown scenario was becoming excessive. Modifying the scenarios in this manner during training increased the amount of training available for the operators.
No items of non-compliance or deviations were identified.
7.
Interviews (41500)
The inspectors interviewed several groups of personnel associated with the training programs. These included supervisors, instructors, and job incumbents (licensedoperators). The purpose of chese interviews was to evaluate the understanding and perceptions of the participants in the operator licensing continuing training program, a.
Operations - Operators The inspectors conducted interviews with nine licensed operators.
Licensed experience of these operators ranged from slightly over one year to more than eight years. During the interviews, the operators stated that the training received was effective and job rclevant.
The inspector noted that continuin, training had improved over the past three years and showed signs that it will continue to improve.
Operators stated that they felt that the tiuining department was responsive to operator feedback and that training usually provided information about the disposition of comments when requested by the originator of the comment. Most operators stated that they felt that the process of training returning comments on their feedback could be improve.
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Host operators stated that they especially liked being able to identify their training needs and understood that it was not always possible to get all the training they wanted. Operators stated they felt more ownership of the training program.
The operators questioned the credibility of new instructors (i.e.,
those hired into the APS system and cualified as instructors within the past year). The operators statec that credibility was an issue because the first time many of the operators remember seeing these new instructors was during the recent facility administered requalification examination. These individuals also questioned the new instructors knowledge of operations and operating experiences at the Palo Verde site. The operators stated they felt that training personnel, especially the continuing training instructors, should-have spent more time out in the plant.
Regarding the plant-specific credibility of the instructors, several operators stated they felt that the instructors could be more critical cf operator performance in simulator training exercises.
They stated that when a performance issue arose involving detailed plant-specific knowledge, the instructors glossed over the issue which could result in negative training.
In order to improve their performance, the operators also stated that more instructor feedback on the category " adequate, but could be improved," performance should have been provided during the simulator training sessions.
Some of the operators stated that they considered team building training to be very helpful. Team building training consisted of training related to communication skills, command and control, conflict management and resolution, and decision making. This training was conducted in the simulator.
The operators stated that the standards group, operations, and training appeared to be isolated from each other and not communicating adequately. Further, the operators stated that this isolation contributed to the poor results of the most recent facility administered requalification examination. The operators also stated that frequent procedural changes did not allow enough time for operators to be completely trained, and feel comfortable with a procedure prior to the next revision. These operator comments were related to licensee management at the exit interview for evaluation and appropriate action.
b.
Operations - Suoarvisors The inspectors conducted interviews with Operations department supervisors. The following are highlights of those interviews.
Operations was working through the training interface group to get more flexibility into training to meet quick turn around trainir,g requirements. Over the past 8 - 9 months the process for meeting
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these training requirements had improved and continued to get better.
Training for changes in job assignments, procedures, and equipment had improved. Most plant modifications were taught in the classroom or simulator before the modification was installed in the plant.
On-the-JobTraining(0JT)wasadministeredintheplantbyths Training Snoroinator and evaluated by peer operators. Operators were required to complete OJT requirements once per year. The OJT program was affective and had resulted in a very qualified and knuledgeaMe staff. Streamlining improvements could be made to the program to make the program more effective and efficiet:
The supervisors stated that personnel performance was good but the staff was generally resistant to change. Management was not always effective in communicating the reasons for changes. Operations management and the training department were trying to challenge the operatcrs. The operators had tried to adapt to the procedure c1anges and to increased management expectations. Training had done a good job at making operators acceptable and was working on making operators Detter than acceptable. This was a step change.in the minds of the operators and was causing some consternation.
The Operations supervisors overall assessment of the program was
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that it was getting better and has been for the past two to three years.
Some training areas could be improved (through flexibility andstreamlining). Training commitments needed to be evaluated to determine those that can be removed or modified (such as requircecnts to attend corporate training that may be redundant).
c.
Trainina - Instructors The inspectors conducted interviews with three licensed operator requalification training instructors. Two of the instructors had l
recently completed the instructor certification program and one had accepted a new position outside the training organization.
Certified instructors at Palo Verde were involved in training
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development, implementation, instruction in the classroom and in the sinielator, and conducting JPMs in the plant.
The instructors stated that the training the operators found most difficult was training on the Abnormal Operating Procedures (A0Ps)
and the new E0Ps.
Instructors stated that the amount of information
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there was too much information for the operators to use.
Instructors considered AOP/EOP entry conditions cumbersome. This was corroborated by similar comments received from the operators.
Instructort, stated that training materials were complete and accurate prior to use in the classroom or simulator. However, some l
materials were usually ready for use just prior to the seneduled i
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session. As a result the instructors interviewed stated that having time available to prepre to teach new materials was a luxury. The instructors stated that training materials could be improved by minimizing conflicting procedural guidance due to chenges in the E0P basis documents by the standards group. The instructors also stated that improvements could be made by evaluating operations training commitments to eliminato tnnecessary training, and by revising and updating the task list and the task to training matrix.
The instrettors all stated that the training needs of the operators were identified by, and was the responsibility of, the Operations Department. Training needs were identified through feedback from the operators following training, through the Training Impact Study, in t.',e irrining-operations interface meetings, and through requests for training.
helations between training and operations were stated to be good and getting better.
The inspectors believed that increasing Operations involvement in the development of training would further improve the quality of
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training, would reduce the amount of training that had to be repeated due to changes identified in the evaluation of training, and would reduce the potential for negative training.
The instructor certification program utilized at Palo Verde appeared to ensure, in a performance-based environment, that instructors have the skills necessary to impart knowledge to the analytical and discriminating licensed operators. The program would start with an evaluation of the current skill level of the instructor.
Based on the evaluation, the training necessary to train the individual to be a certified instructor was determined. The training received by the instructor was provided by on-site staff, by on-site contractors, or through the use of off-site training. The inspectors concluded that
the instructor certification program appeared to provide well trained and qualiti e instructors. This conclusion was discussed with licensee management at the exit interview in conjunction with the operator statements discussed above.
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Trainina - Supervisors The inspectors interviewed three training department supervisors.
Their involvement in the training process ranged from full responsibility to approval of training materials.
All the training supervisors stated that a notable strength of the continuing training program was the experience of the instructional staff. The inspectors noted that recent personnel additions to the training department were new instructors that are accustomed to change and could affect change.
In the long term, this would probably be helpful to the program.
In the short term, and as noted in the interviews with the operators, this had resulted in an instructor credibility problem. Comments from the operators related l
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to the instructors plant-specific knowledge, not the presentation skills of the instructors.
The supervisors stated that they were trying to make non-licensed operators (NLO) feel that they were part of the operations training program.
This had been done by increasing NLO involvement in the simulator, and evaluating needed training versus desired training to improve the needed training. Further, modifications to the job task analysis software made the data easier to use and maintain.
No items of non-compliance or deviations were identified.
8.
Trainina Records (41500)
The inspectors examined facility training records. The purpose was to ensure that the required records were maintained and reflected the training the personnel have received. The licensee appeared to be maintaining records that assured that the operators had received required training. The inspectors examined the files of several operators and determined that the records were complete and up to date.
The inspectors, during queries of training records personnel, determined that a change was being made as to how records of class participation would be kept. The licensee was impicmenting a change which would document training class attendance for each training class, rather than in each individuals' file. This was being done to reduce the volume of files.
The individual scores and evaluations would be in the class file. A record entry in the training records data base would track pass / fail determinations and attendance. The inspectors concluded that this change captured required training records. The change would result in some extra effort to recover information about individuals.
The inspectors concluded that the facility training records appeared to be complete and the facility had continued to maintain the records in a retrievable manner.
No items of non-compliance er deviations were identified.
9.
Overall Assessment (41500)
During the on-site inspection period, the inspectors observed two
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L classroom training sessions and three crews participating in scenarios on I
the plant referenced simulator. The inspectors interviewed licensed operctors, instructors, and management representatives from within the
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Operations and Training DeparLnents,
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l Over the past three years, improvements had been seen in the program.
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l The operators stated that they were part of the process and the program was becoming more operationally oriented. The feedback process had improved considerably - from a process where feedback was solicited but i
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not acted upon; to a process where all coments were evaluated, acted upon, and in many cases, the outcome was provided to the comenter.
The inspectors observed that facilities for the training department staff were much better than those of three years ago and ap) eared to be getting better. The credibility of the newer instructors migit require management attention. The training manager stated that the credibility of the new instructors should improve over time. He also stated that the instructors were required to spend some time each quarter in the plant.
During those periods the instructors were expected to interact with the shift crews. The inspectors concluded that Operations involvement with the preparation of continuing training material for their staff could be improved. Specifically, as a matter of routine, Operations did not review training material. Operations usually provided coments on training materials the after training had been given.
The inspectors concluded that the program had maintained the systematic approach to training required for accreditation. Further, the inspectors considered that each of the five functional areas were improved over the three year interval from the last inspection. The five functional areas were:
Systematic evaluation of the jobs to be performed.
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Learning objectives that are derived from the analysis and that
describe desired performance after training.
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Training design and implementation based on the learning
obj ectives.
Evaluation of trainee mastery of the objectives during
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training.
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Evaluation and revision of the training based on the
performance of trained personnel in the job setting.
Continuing training of licensed operators appeared to be a good program and it appeared that the intent of training management was to make the program better.
10. Exit Meetina The inspectors met on October 23, 1992 with the facility representatives indicated in Section 1.
During this meeting, the ins sector summarized the scope of the inspection activities and reviewed tie inspection findings as described in this report. The Team Leader discussed the observation of a lack of Operations involvement in the praparation of training material.
During the exit meeting the Region V Operations Section chief asked the licensee representative when emergency operating procedures for Mode 3 through 6 would be developed. A followup telephone call from the
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i licensee (Mr. John Dennis and staff) discussed the actions the licensee has taken to address the situation in the near term. The licensee planned to amend the 40DP-9AP05 "EOP Technical Guideline' procedure ta include guidance on the use of the E0Ps in Modes 3 and 4.
The licenssc representative stated that the amendment would be effective prior to the next cycle of operator requalification training in December 1992. The licensee representative also stated that the " Loss of Shutdown Cooling" A0P covered events that occur in Modes 5 and 6.
The licensee did not identify any specific information as proprietary to
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the inspectors.
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