IR 05000528/1999002

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Insp Repts 50-528/99-02,50-529/99-02 & 50-530/99-02 on 990125-29.No Violations Noted.Major Areas Inspected:Licensed Operator Requalification Program Assessment Including Walkthroughs Review of Facility Documents & Written Exam
ML17313A818
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 02/24/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17313A817 List:
References
50-528-99-02, 50-528-99-2, 50-529-99-02, 50-529-99-2, 50-530-99-02, 50-530-99-2, NUDOCS 9903020287
Download: ML17313A818 (24)


Text

ENCLOSURE U.S. NUCLEAR REGULATORYCOMMISSION

REGION IV

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved By:

50-528; 50-529; 50-530 NPF-41; NPF-51; NPF-74 50-528/99-02; 50-529/99-02; 50-530/99-02 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona January 25-29, 1999

.S. McCrory, Lead Inspector, Senior Reactor Engineer, Operations Branch T. Meadows', Senior Reactor Engineer, Operations Branch D. Corporandy, Resident Inspector, Project Branch D J. L. Pellet, Chief, Operations Branch Division of Reactor Safety ATTACHMENT:

Supplemental Information 9903020287 990224 PDR ADOCK 05000528

PDR

-2-EXECUTIVESUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report No. 50-528/99-02; 50-529/99-02; 50-530/99-02 This inspection assessed the licensed operator requalification program to determine whether the program incorporated appropriate requirements for both evaluating operators'astery of training objectives and revising the program in accordance with 10 CFR Part 55.59(c). The licensed operator requalification program assessment included an evaluation of the program's controls to assure a systems approach to training, and evaluation of operating crew performance during biennial requalification examinations.

This included review of the facilitydocuments, observation of operating and staff crews during dynamic simulator scenarios, plant walkthroughs, and a written examination.

The inspection also assessed the licensee evaluators'ffectiveness in conducting examinations.

~oeratione The licensed operators on both shift and staff crews demonstrated strong capability to respond to and mitigate a variety of abnormal and emergency conditions to protect the public health and safety. Operators exhibited improved performance in several behavioral skills including communication, self-verification, concurrent or peer verification, and supervisory oversight (Section 04.1).

The operations training organization exhibited a sustained high level of performance in implementing a systems approach to training for the licensed operator requalification program (Sections 05.1, 05.2, 05.3, 05.4).

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-3-Report Details

Conduct of Operations 01.1 Control Room Observations 71001 a.

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The inspectors observed operator performance in Unit 1 to compare to that seen in the dynamic simulator scenarios.

Observations and Findin s During the observations, the control room operators performed a number of system operations and evolutions including operating the containment spray pumps in the recirculation mode, surveillance testing of plant protection System Channel D, and post-maintenance testing of the E charging pump. The operators referred to procedures throughout the performance of the various tasks, and routinely performed self-verification and concurrent-verification activities while operating various equipment controls. The

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control room supervisor maintained close oversight of less frequently performed evolutions.

The operators routinely used three-leg communication techniques while performing these and other, more routine, tasks.

c..

Conclusion The inspectors evaluated this performance as comparable to that observed in the dynamic simulator portion of the operating examination.

Operator Knowledge and Performance 04.1 0 erator Performance on Annual Re uglification Examinations a.

Ins ection Sco e 71001 The inspectors observed two shift crews and one staff crew during the operating examination.

b.

Observations and Findin s The scenarios presented the operators with a diversity of abnormal and emergency conditions including: station blackout, loss of all feedwater, and a'steam generator tube rupture concurrent with a loss of safety injection flow. The operators promptly and accurately diagnosed the nature of the malfunctions and responded effectively using abnormal and emergency operating procedures.

Shift managers made timely and accurate emergency action level classifications.

The inspectors observed consistent and frequent

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-4-application of self-verification, concurrent-verification, three-leg communications, and direct supervisory oversight.

In the prior requalification inspection (NRC Inspection Report 50-528;-529;-530/97-01), the inspectors observed inconsistent application of these human performance skills. The inspectors observed a comparably high level of operator performance among shift and staff crews during this inspection.

The inspectors observed nine operators during portions of the walkthrough examination.

The operators performed the assigned tasks in the same competent manner that they exhibited during the dynamic simulator scenarios.

On January 27, 1999, an evaluator was stationed inside the radiologically controlled area of the auxiliary building to administer a task that required entry into the auxiliary building.

During the transfer of one operator from the oversight of the evaluator outside the radiologically controlled area to the one inside, the operator asked to review the initial conditions and procedure that applied to the task inside the radiologically controlled area.

The evaluator inside the radiologically controlled area handed this information to the operator before the operator had entered the radiologically controlled area.

This resulted in the passing materials outside of the boundaries of the radiologically controlled area without a proper survey of the material.

Both the evaluator and operator promptly recognized their error and took immediate. actions to notify health physics personnel and to survey the material, as well as, the operator who was outside the radiologically controlled area.

The surveys identified that there was no contamination present.

While the initial performance did not meet license requirements for control of the spread of contamination, the inspectors assessed the consequences of the actions as minor particularly in light of the prompt recognition and corrective action taken by the affected individuals.

C.

Conclusions The licensed operators on both shift and staff crews demonstrated strong capability to respond to and'mitigate a variety of abnormal and emergency conditions to protect the public health and safety.

Operators exhibited improved performance in several behavioral skills including communication, self-verification, concurrent or peer v'erification, and supervisory oversight.

05.1 Operator Training and Qualification Re uglification Examination Develo ment and Quali ao Ins ection Sco e 71001 The inspectors reviewed the biennial requalification examinations, including job performance measures, dynamic simulator examinations, and the written examination.

The inspectors evaluated general quality, construction, and difficultylevel ~ The inspectors also reviewed the methodology for developing the requalification examination I'

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-5-Observations and Findin s The inspectors determined that the written examinations adequately sampled the training provided in the two-year requalification training cycle. The written examination questions discriminated well and tested an appropriate mix of cognitive levels. The inspectors determined that the quality of the individual questions was comparable to that observed in a recent initial licensing written examination prepared by the licensee (NRC Inspection Report 50-528;-529;-530/98-301).

Both Parts A and B of the examinations were administered in the simulator. The examinations consisted of 35 questions total. This was consistent for all of the examination weeks that were inspected.

The inspectors noted that there were over 7000 questions in the licensee's written

examination computer bank at the time of the inspection. The licensee revised approximately 20 percent of the bank during each 6-week training cycle. The inspectors determined that the written examination bank was being well maintained and controlled by the licensee on a computer data base.

The inspectors observed that the dynamic simulator scenarios contained a diversity of malfunctions and major transients.

Most of the malfunctions both before and after the major transient intentionally compounded the complexity of responding to and mitigating the major transient.

For example, one scenario began with a steam generator tube leak which was compounded by an inadvertent main steam isolation signal that shut all main steam isolation valves, which increased the potential for a direct release path in the leaking steam generator via the atmospheric relief valve. Then tube leak degraded to a tube rupture. Subsequently

'an electrical malfunction resulted in the loss of all high pressure safety injection which complicated cooldown and depressurization efforts to mitigate the steam generator tube rupture.

The scenarios contained crew critical tasks that conformed to the definition in NUREG-1021,

"Operator Licensing Examination Standards."

These critical tasks formed the primary basis

'or assessing operator performance in the dynamic simulator against regulatory requirements.

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The job performance measures used to assess individual system tasks contained all the attributes described in NUREG-1021, Appendix C, "Job Performance Measure Guidelines."

The licensee selected tasks identified in the job task analysis which were important to safe operation of the plant.

The inspectors reviewed the security measures that were used to prevent physical compromise of an examination and determined that they were adequate.

The inspectors found that it was the licensee's policy to not release any of the two year cycle examinations until after the last cycle, as an additional security measure to prevent examination compromis t

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Conclusions The licensee developed examinations that provided a good foundation for the effective evaluation of licensed operator knowledge and ability to respond to abnormal and emergency events to protect the public health and safety.

05.2 Evaluator Performance Ins ection Sco e 71001 The inspectors observed the administration of all aspects of the requalification examinations to determine the evaluators'bilities to administer an examination and assess adequate performance through measurable criteria. The inspectors also noted the fidelityof the plant simulator to support training and examination administration.

Observations and Findin s

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The inspectors observed the evaluation of crew performance following the completion of the dynamic simulator scenario set for one of the shift crews. The evaluators u'sed crew critical tasks and crew competency check lists (similar to those found in ES-604 of NUREG 1021,

"Operator Licensing Examination Standards" ) to focus their evaluations.

The evaluators discussed crew and individual performance in great detail and identified numerous diverse performance errors. They assessed those errors against regulatory thresholds and licensee expectations to determine the final grade recommendation.

The evaluators determined that all crews and individuals passed the dynamic simulator portion of the operating examination.

However, they assigned a remediation. requirement to one operator who fell below management expectations, but who demonstrated adequate regulatory performance.

The inspectors concurred with the final evaluations of crews and individuals for'he dynamic simulator portion of the operating examination.

The inspectors observed six evaluators during portions of the walkthrough examination.

The evaluators provided accurate'instructions of the task to be performed and gave the appropriate cues during tasks simulated in the local equipment spaces.

During the briefing and proctoring of the written examination, the evaluators provided clear instructions regarding the rules governing the process.

While proctoring the examination, the

" evaluators did not provide responses to examinees'uestions about particular test items that compromised any portion of the examination.

The inspectors interviewed an instructo'r on the licensed operator requalification training staff. The instructor was knowledgeable of the various aspects of examination development, administration and security, feedback processes, and remediation.

C.

Conclusions The licensee's evaluators demonstrated sustained high levels of competence in examination administration and operator performance assessmen e-7-05.3 Review of Trainin Feedback S stem Ins ection Sco e

71001 The inspectors reviewed the methods and effectiveness of the licensed operator requalification training program feedback system.

Observations and Findin s The mechanisms and processes for feedback into the licensed operator requalification training program were essentially the same as reported following the last inspection of the licensed operator requalification training program (NRC Inspection Report 50-528;

-529;-530/97-01).

The program's strength was derived from its diversity and a well-structured review process (the operations training coordination committee and the training advisory board) staffed with individuals committed to high training standards and effectiveness.

The inspectors noted that since the last inspection, the facilityhad improved the involvement of the shift managers with the training and evaluation of their crews. At the beginning of the training week each shift manager formally briefed the training staff of any training needs specifically requested by the crew. At the end of the training week, a shift manager would

'eceive a formal debrief of training results and recommendations for continuing on-the-job-training followup. The shift managers formally submitted for approval to the advisory board an on-the-job-training, "Crew Commitment Plan." The plan would be implemented while on shift.

The inspectors reviewed the training student observation for'ms received by the training department in 1997 and 1998. The inspectors found that training had provided appropriate responses when requested.

They had also responded to many comments for which responses had not been requested.

The inspectors noted that the training staff formally logged relevant comments in a computer data base 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.

I During interviews, operators remarked favorably regarding overall program implementation.

Most of the operators expressed a desire for more simulator training during unit outages to be able to sustain a high level of readiness to respond to abnormal and emergency events.

It had been the licensee's practice to suspend operator requalification training during outages.

In response to the operators'equest for simulator time during outages, operations management expressed the intent to try to provide some limited simulator time (probably no more than one day) during each crew's scheduled training week that fell during an outag \\

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Conclusions 05.4 The licensee continued to implement an effective feedback process as a key element to their overall systems approach to training.

Additionally, the inspectors determined that the development of on-the-job-training crew commitment plans was a notable enhancement to the feedback process.

Review of Remedial Trainin Pro ram Ins ection Sco e 71001 The inspectors reviewed the methods of the licensed operator remedial training program and operator and crew remediation, which occurred between January 1997 through January 1999.

b.

Observations and Findin s The licensee described a comprehensive remedial training program in "Licensed Operator Continuing Training Program," Revision 10, and "Instructor Training Program Description,"

'Revision 9. After interviewing operations and training personnel and reviewing remediation records for 1997-1999, the inspectors concluded that the remedial training program was being implemented as designed.

Passing a remedial examination comparable to the original examination was required for all evaluation failures. The operators expressed general satisfaction with the few remediation actions they had experienced.

The remediation records reviewed indicated that, at a minimum, the instructor and operator discussed exhibited weaknesses prior to administration of the remedial examination.

The licensee's procedures required that the remedial examination cover the exhibited student weaknesses.

However, the procedures also required a substantial number'f different questions on the remedial examination to prevent a student from passing by only learning the answers on the questions he/she missed.

Finally, the procedure required remediation and re-examination following a failed examination within 6 weeks of the end of the requalification training cycle. There was a similar requirement for makeup training.

For repeated examination failures, the licensee had a policy of escalated action levels.

For a second failure during a 2-year program, the licensee removed the individual from licensed duties and a performance review board determined remediation actions.

This occurred for two individuals during this biennial cycle. The inspectors discussed the remediation actions, which were taken for the individuals with the department leader and found them to be appropriate.

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Conclusions The licensee had implemented a formal and effective remedial training program.

Repeated e'xamination failures were aggressively remediate I P

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-9-05.5 Conformance With 0 erator License Conditions a.

Ins ection Sco e 71001-The inspectors verified that the facilityand individual licensees conformed with the requirements 10 CFR Part 55.

b.

Observations and Findin s The facilitylicensee maintained a computer data base system on their local area network to track the status of all licensed operators.

The list reported the status of each individual licensed operator with regard to currency. in the requalification pr'ogram and the active status of their license and received daily updates.

During an on-shift interview, the shift manager demonstrated familiaritywith the file and how to ensure that only individuals with current and active licenses were allowed to assume licensed duties on shift.

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 in order and that all of the operators in this sample were in compliance.

Furthermore, the facilityensured that the biennial medical requirements, such as a physical, were met by conducting comprehensive physicals and training for all licensed operators in January of every year.

Conclusions The inspectors determined that the facilityadequately tracked and maintained the conditions of their individual licensed operators in accordance with 10 CFR 55.

V. Mana ement Meetin s X1 Exit Meeting Summary The examiners presented the inspection results to members of the licensee management at the conclusion of the inspection on January 28, 1999. The licensee acknowledged the findings presented.

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

ATTACHMENT SUPPLEMENTAL INFORMATION PARTIALLIST OF PERSONS CONTACTED Licensee D. Edmonds, Instructor, Operations Requalification Training R. Hazelwood, Engineer, Regulatory Affairs Compliance A. Kiainik, Department Leader, Regulatory Affairs J. Levine, Senior Vice President R. Nunez, Department Leader, Operations Training Support G. Overbeck, Vice President, Nuclear Production F. Riedel, Department Leader, Operations Training D. Smith, Director, Operations DOCUMENTS REVIEWED Procedures Reviewed

"Licensed Operator Continuing Training Program Description," Revision 10 15DP-OTR69, "Training and Qualification Administration," Revision 2 Instructor Training Program Description," Revision 9 40DP-90P02, "Conduct of Shift Operations," Revision 0 15TD-OTR03, "Nuclear Training Department Instructor's Handbook," Revision 0 Other Documents Reviewed

'I Guidelines for Instructor Training and Qualification," dated December 1997, Academy Document 97-014

"NLO/LOCTEnd of Training Week Feedback," Cycle 96-05, Week 1, Crew 42, Unit 3, dated November 8, 1996

"NLO/LOCTEnd of Training Week Feedback," Cycle 96-05, Week 1, Crew 22, Unit 2, dated November 8, 1996

"Training Feedback Crews 15/25/35/45/55," Week 2, Cycle 96-05

"NLO/LOCT.End of Training Week Feedback," Cycle 98-04, Week 3, Crew 24, dated November 22, 1998

"NLO/LOCTEnd of Training Week Feedback," Cycle 98-04, Week 5, Crew 14, dated November 22, 1998

"NLO/LOCTEnd of Training Week Feedback," Annual Examinations, Week 1, Crew 11, dated January 8, 1999

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"NLO/LOCTEnd of Training Week Feedback," 1999 Annual Examinations, Week 2, Crew 33, dated January 15, 1999

"Training Feedback Crews 13/43/33/23/53," Week 3, Annual Examinations

"Training Feedback Crews 11/21/31/41/51," Week 4, Cycle 96-05 Training Management Assessment Forms (Management Observation Tool), Cycles 97-01 through 98-05 Training Management Assessment Forms (Student Observation Tool), Cycles 97-01 through 98-05

"Quarterly Training Performance Assessment

- July.1, September 30, 1996," Nuclear Training Department

"Open Simulator Operator Feedbacks," dated January 16, 1997,

"Simulator Discrepancy Reports Sorted by Due Date," dated January 15, 1999 Written Requalification Examination Question Bank Cycles 97-01 through 98-05 JPM Evaluation Banks Cycles 97-01 through 98-05 Scenario Evaluation Banks NUA 97-00, 1997 Annual Evaluation, Weeks 1 and 2 ID¹054-02447-RAN/W ES(PRIVATE)

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"1997 Annual Requalification Exam Remediation," W E Stearns to Mike Baughman, dated January 16, 1997

"1997 Annual Requalification Exam Remediation," ID¹ 054-0241-RAN/WES, Mike Baughman to R.

BlaKley, dated January 16, 1997

"1997 Annual Requaiificatiori Exam Remediation," ID¹ 054-02457-RAN/WES, W. E. Stearns to Mike Baughman, dated, February 3, 1997

"Crew 22 (Mark McGhee) Failure/ Remediation," ID¹ 054-02522-FWR/TEM, Thomas E. Mock to file, and associated exam materials, dated 1/30/99.

"1998 Requal Exam Remediation," ID¹054-02521-FWR/TEM, Thomas E. Mock to Paul J. Kicker, dated January 27, 1998 and associated remediation packages.

1999 Annual Exam Results, Weeks 1-4, and all associated remediation packages.

Licensed Operator Continuing Training (LOCT) weekly schedules, weeks 1-4, annual exam cycle, starting 1/26/9 Operations Department Practices, Number 4, Revision 02 Operations Department Practices, Number 2, Revision.02 40DP-9OP33, "Shift Turnover," Revision 3 List of Active Non-Shift an Shift personnel licensed condition tracking, dated 1-22-99, and associated computer data bases Emergency Response Notification, Action Closure and feedback training documents, ID¹219-02632-SAH through ID¹ 099-01590-P JK, and associated examination material.

Documents

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"1999 Revisions in LOCT Program"

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"Results of the 1997 PVNGS Annual Licensed Requalification Examination"

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"Results of the 1998 PVNGS Annual Licensed Requalification Examination," and associated remediation letters and materials 1998 and 1999 Annual Requalification examination bank materials (Scenarios, JPMs, and written examinations.

All 1998 and 1999 Annual Requalification remediation and student feedback documents, 10 percent of the PVNGS licensed operator medical and licensing conditions files, including the associated computer data base

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