ML14178A457
| ML14178A457 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/02/1994 |
| From: | Ernstes M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A454 | List: |
| References | |
| 50-261-94-01, 50-261-94-1, NUDOCS 9403150273 | |
| Download: ML14178A457 (10) | |
See also: IR 05000261/1994001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
ENCLOSURE 2
Report No.:
50-261/94-01
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC
27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson Steam Electric Plant
Inspection Conducted:
January 31 - February 4, 1994
Inspector:
I
.
Michael E. Ernstes
Date Signed
Accompanying Personnel:
Mark Parrish, INEL
Diane Tamai, DRS Region II
Approved by: 1
L wrence L. Lawyer, Chief
Date Signed
Operator Licensing Section
Operations Branch
Division of Reactor Safety
SUMMARY
Scope:
The NRC conducted a special, announced inspection of the Robinson licensed
operator requalification program during the period January 31 - February 4,
1994.
The inspectors reviewed and observed annual requalification
examinations conducted by the facility licensee and conducted inspection
activities as specified in Temporary Instruction 2515/117, Licensed Operator
Requalification Program Evaluation. Seven Senior Reactor Operators and five
Reactor Operators received facility administered written and operating
examinations. Activities reviewed included examination development,
examination administration, and compliance with operator license conditions.
Results:
Inspectors identified the lack of alternate path JPMs used in evaluations and
the small number in the facility exam bank as an inspector followup item.
(paragraph 2.a.4) IFI 50-261/94-01-01.
9403150273 940304
PDR ADOCK 05000261
0
Enclosure 2
2
Inspectors identified the evaluators' ability to give critical objective
evaluations of the operators as a strength. (paragraph 2.b.1)
Inspectors identified a weakness in operators' ability to operate the steam
dump system. (paragraph 2.b.4)
Inspectors identified the failure to effectively track the active status of
operator licenses and other license conditions or deficiencies as an inspector
followup item (paragraph 2.c) IFI 50-261/94-01-02.
Inspectors identified the use of hours in a position other than those required
by Technical Specifications for purposes of maintaining an active license as
an unresolved item. (paragraph 2.c) URI 50-261/94-01-03.
Inspectors identified the inability to effectively address operator concerns
in the procedure change program as an inspector followup item.
(paragraph
2.d) IFI 50-261/94-01-04.
Inspectors identified the failure to maintain control of procedures as a
violation.
(paragraph 2.d) VIO 50-261/94-01-05.
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- H. Carter, Manager Requa] Training
- C. Dietz, Vice President -
Robinson Nuclear Project
- W. Doorman, Manager Regulatory Affairs
- M. Harrell, Manager Training
- D. Gudger, Regulatory Affairs
- R. Moore, Acting Manager, Shift Operations
- C. Olexik, Manager Plant Assessment
- M. Pierson, Plant Manager
- A. Sanders, Manager Operator Training
- C. Winters, Acting Assistant Manager, Shift Operations
Other licensee employees contacted included instructors, engineers,
technicians, operators, and office personnel.
NRC Personnel
W. Orders, Senior Resident Inspector
C. Ogle, Resident Inspector
- Attended exit interview
The last paragraph lists Acronyms used in this report.
2. Licensed Operator Requalification Program Evaluation (TI 2515/117)
a. Examination Development
The NRC inspectors reviewed examination materials developed for the
first three weeks of the licensee's annual requalification
evaluations.
The inspectors found them to be consistent with the
- A guidelines of NUREG-1021, Examiner Standards, except for specific
items listed below in the sample plan, written examinations and
walkthrough examinations.
(1) Sample Plan
The inspectors reviewed the facility's approved sample plan for
the 1992-1993 cycle.
The facility did not ensure evaluation of
training on facility modifications, procedure changes, and
operating experience feedback, on the requalification
examination. The sample plan showed 47 of the 358 curriculum
hours for these topics. However, facility examinations did not
evaluate these topics until changes had been made in the
associated system or procedure training material.
Once
incorporated into the facility training Material.
The facility
did not track the trainingof the modifications, selection for
examination of a modification, procedure change or operating
experience would be at random. A systematic process did not
learning objectives of these topics as
ubeeby a systems
dinotc trc
ttraining.
Report Details
2
The facility's procedure TUI-21, Development and Administration
of Annual LOR Exam, section V.A.3.i requires that recent safety
related issues or events be included in the sample plan.
Additionally, TUI-21 states that requalification examinations
will be developed in a manner that follows the instructions of
NUREG-1021. NUREG-1021 requires inclusion of training conducted
on plant modifications, LERs, and major changes to operation
practices or policy in the sample plan. The facility's sample
plan did not include these items.
(2) Written Examinations
Inspectors reviewed the written examinations administered during
the first three evaluation weeks. Most questions tested higher
level cognitive skills.
Questions generally followed the
guidelines of NUREG-1021. However, the inspectors identified
some examples of direct lookup questions on open book
examinations. In one example, the operator only needed to read
the given step of the EOP and note the RWST level given in the
stem. Some questions had inadequate distractors. For example,
one question had two technically equivalent distractors
therefore, neither of the distractors could be the correct
answer.
(3) Simulator Examinations
The inspectors judged the dynamic simulator scenarios to be
comprehensive and representative of an operationally challenging
series of events. The facility maintains a separate bank of
simulator evaluation scenarios, independent-of scenarios used for
training. The facility used the evaluation bank for both annual
operating tests and weekly evaluation scenarios. The evaluation
bank had thirty scenarios.
(4) Walkthrough Examinations
Each operator walkthrough examination contained five JPMs. None
of the proposed examinations for the entire five week
requalification evaluation contained alternate path JPMs as
defined in ES-603. The JPM bank contained only five alternate
path JPMs. TUI-21 paragraph VI.H.5.astates that JPMs shall be
developed to meet NUREG-1021 requirements.
ES-603 Attachment 1
of NUREG-1021 states that licensees are expected to be able to
use alternative methods to perform tasks. Alternate path JPMs
test the operator's ability to use procedures under abnormal
conditions. They also preclude operators from rote memorization
of the JPM exam bank instead of acquiring understanding of the
task. The inspectors identified the lack of alternate path JPMs
used in evaluations and the small number of them available in the
facility exam bank as IFI 50-261/94-01-01.
.Report Details
3
b. Examination Administration
(1) Dynamic Simulator Examinations
The licensee conducted simulator examinations by the guidelines
of NUREG-1021. The inspectors noted problems in Operations
Department's participation in the examination process and SRO
procedure reader evaluation.
Inspectors observed the licensee administer five crews of
licensed operators' simulator examinations. Two SROs, two ROs,
and an STA comprised the crews. The SROs filled the positions of
SS and Control Room Supervisor. Each evaluator observed one
operator. No one evaluated the STA individually.
The inspectors judged that the training department evaluators
gave an objective critical evaluation of the operators. They
effectively determined if the operators met the minimum
requirements and identified areas for remediation. When operator
performance satisfied established minimum criteria but showed
weaknesses, the training department evaluators identified the
operator as "pass with remediation." The inspectors identified
the evaluators' ability to give critical objective evaluations of
the operators as a strength.
The evaluators identified weaknesses during the scenarios then
discussed them among themselves and documented the weaknesses in
crew and individual written evaluations.
The Operations
Department assigned one representative to observe each simulator
examination. The Operations representative did not participate
in the post scenario evaluator caucus. This resulted in the
trainers resolving operational methodology issues. The trainers
noted specific items that they felt needed operations resolution.
On one day of scenarios, no Operations representative attended as
required by TUI-21.
TUI-21 section VIII.E.3 states that each SRO shall be evaluated
in his usage of EOPs and TS.
The licensee did not evaluate one
of the SROs on a staff crew in the position of procedure reader
(control room SRO) during his operating test. He stood RTGB and
SS. TUI-21 section VIII.E.1, states that each simulator
evaluation should place individual crew members in the most
senior watch standing position in which the individual normally
operates on shift.
This particular individual was soon to return
to Operations as a control room SRO.
(2) Walkthrough Examinations
The licensee administered JPMs in accordance with NUREG-1021 and
TUI-21 with one exception. TUI-21 section VIII.G.5.g provided
that an extra person will perform actions not relevant to the JPM
as directed by the operator. The extra operator in the simulator
silenced alarms without direction from the examinee.
Report Details
4
(3) Evaluators
Evaluators effectively identified operator weaknesses. The
inspectors identified a need for improvement in simulator
followup questioning and inconsistent documentation of individual
simulator evaluations.
The lack of on the spot followup questioning hindered evaluators'
ability to focus on the root cause of operators' problems. The
post scenario evaluator caucus made this evident. The evaluators
speculated as to operators' motives for actions or inactions.
The evaluators could have resolved these speculations through
directed followup questioning. For a given performance
deficiency, evaluators did not probe to identify if the operator
failed to diagnose a problem, lacked knowledge of the appropriate
actions, or could not carry out those actions.
This is important
in determining proper remediation and program feedback.
Evaluators inconsistently documented individual operator
simulator performance. The amount of detail and focus of
operator deficiencies depended on the evaluator. Some evaluators
gave written comments for a competency score of two, which
indicated minor problems, while others did not. Some evaluators
associated comments with a specific competency while others gave
general observations.
Licensee procedures contained no guidance
to standardize the format and extent of operator feedback.
(4) Operator Performance
Operator performance on the examinations revealed problems in
ROs' ability to effectively manipulate RTGB controls, SRO
procedure usage and crew oversight.
The facility evaluators identified deficiencies in the ROs'
ability to effectively manipulate RTGB controls to operate the
plant. One crew energized heaters during a SGTR and raised the
RCS pressure, increasing the leak rate. During the same SGTR
scenario, another crew did not reset SI when required and
overfilled the S/G. Most of the crews had errors in control
board manipulation of the steam dump controls.
For example, one
operator attempted use of the steam dumps without the condenser
available. Another failed to set the controller to the proper
mode for cooling down. The inspectors considered the operator
problems associated with the steam dump system a weakness.
Several of the SROs made errors in procedure usage such as
skipping steps, misuse of the RNO column, and not completing
procedures prior to transition. Usually other crew members
detected and corrected these errors.
On some crews, the SRO assigned the STA to complete EOP
supplements. This hindered the STA in maintaining an independent
overall view of the plant. The facility also identified the use
Report Details
5
of STAs in this role as a problem and pursued resolution. On one
crew, the SS made control manipulations, removing him from his
position of oversight.
(5) Exam Security
The inspectors saw no evidence of exam compromise. However, they
identified a need of improvement in the areas listed below.
One security agreement covered all of the examinations for all
five weeks. This system could not determine who had prior
knowledge of a particular examination. The licensed instructors
signed the security agreement that encompassed their own
examination. Instructors who trained the operators Monday,
administered their examinations Tuesday. This is contrary to
their signed security agreement which states: "I understand that
I am not to participate in any instruction involving those
licensees scheduled to be administered this requalification
examination from this date until completion of examination
administration."
In reality instructors did not see the exam
material until after the training session. The use of one
security agreement for all examinations did not aid in preventing
examination compromise.
An NRC inspector heard operators discussing their simulator
scenario while leaving .the simulator. An inspector heard one of
the operators from around the corner describing an event from the
scenario. This could have been within audible range of another
operator scheduled for the same scenario that afternoon.
This
particular operator exited the training staff offices moments
prior to the crew walking through the area. This contradicted
the guidance of TUI-21 section VII.e.19 which states that the
crew will be separated from subsequent crews taking the same
examination.
c. Conformance with Operator License Conditions
The licensee did not have information available in the control room
for the SS to determine active license status, requalification
failure, or license conditions (e.g. eyeglasses, no solo etc.).
One
SS stated that they previously had a book in the control room but
moved it to the Operations' office. Training sends the SS a letter
quarterly stating who has become inactive. However, this was not
available in the control room.
For tracking hours on shift, operators sent a sheet to the License
Training Technical Aide showing their hours for the month. She sends
a letter identifying anyone going inactive to the Scheduler,
Operations Manager, the operator and the operator's SS.
Due to
receiving some operator hour sheets two to three weeks after the end
of the quarter, she sent the letter for the last quarter of 1993 on
January 31,1994. She believed that Operations tracked operator hours
to determine active status and was not aware that Operations relied on
Report Details
6
her letter for active and inactive status of operators.
She
maintained records for license renewal data and forwarded a letter to
Operations as a courtesy.
The Scheduler said he relied on her letter
to know who is inactive. Although it is the individual operator's
responsibility to perform licensed duties only with an active license,
the facility's instructions would not have prevented a person with an
inactive license from performing the functions of a licensed operator
as occurred at another CP&L site. The inspectors identified the
inability to effectively track the active status of operator licenses
and other license conditions as IFI 50-261/94-01-02.
TS 6.3.2.c requires only the positions of Shift Foreman and an RTGB
operator during cold shutdown. The form for reporting hours on shift
noted that only the RO who was the RTGB operator got credit toward
55.53 active license requirements when in cold shutdown.
However, the
form did not make the same distinction for the SROs. The form merely
asked for time logged as SRO or SS for all plant operating modes.
Thus, operators may have been taking credit during cold shutdown for
standing watch in positions not required by TS.
The failure to credit
only persons in a TS defined position for purposes of maintaining an
active license in accordance with 10 CFR 55.53 is identified as URI
50-261/94-01-03.
d. Procedures
The licensee's procedure change request program had a massive backlog.
When operators or other plant personel find a deficiency in a
procedure, they document their concerns and forward them to the
Operations Department for resolution. The backlog contained more than
1600 requests dating back as far as three years. The procedure change
process did not address operator's concerns timely. The inability to
effectively address operator procedure concerns is identified as IFI
50-261/94-01-04.
The inspectors identified five out-of-date controlled copies of
emergency or abnormal procedures in the simulator control booth, and
one as missing. Procedure control records indicated that the changes
had been made in May 1993, however, the controlled documents had not
been updated. Examination Report 50-261/93-301 previously addressed
out-of-date procedures in the simulator control booth.
Inspectors
verified current revisions of the controlled procedures in the control
room and on the simulator floor. The failure to maintain controlled
copies of procedures is identified as VIO 50-261/94-01-05.
3. Action on Previous Inspection Findings
(Closed) IFI 50-261/93-300-01, "Inadequate guidance for the accomplishment
of FRP-H.1 (Rev. 4) step 13.a, Response Not-Obtained."
This item
concerned a step in the Loss of Secondary Heat Sink procedure for aligning
any low pressure water sources to a depressurized steam generator. The
procedure did not contain sufficient instructions to accomplish the task.
Revision 7 of FRP-H.1, dated 1/20/94, directs operators to align fire
water to the depressurized steam generator using a procedure attachment.
Report Details
7
Sufficient guidance is available in the attachment.
Interviews with
licensed operators indicated some lack of familiarity with the locations
of equipment identified in the new attachment. The inspectors determined
the corrective action for the procedure to be adequate and this item is
closed.
(Closed) IFI 50-261/93-301-01, "EOP RCP trip criteria discrepancies
between Path 1 and Foldout A."
This item concerned a conflict between the
two procedures for RCP trip criteria when at exactly 250 F. The
inspectors reviewed the licensee's revision to Path 1 RCP trip criteria
and determined that the Path 1 criteria now agrees with Foldout A
criteria. This Inspector Followup Item is closed.
(Open) IFI 50-261/93-301-02, "Mounting screws missing on rear of
containment high range radiation monitors R-32 A & B."
This item noted
that mounting screws identified in the Radiation Monitoring System
procedure, OP-920 step 8.1.4.1, were missing from the rear of the drawer.
The radiation monitors remained without rear mounting screws during this
inspection. The
inspector and the containment systems/seismic engineer
reviewed the licensee's close-out of this item and determined it to be
inadequate. The licensee had analyzed the wrong screws and wrong type
monitors to determine seismic requirements. This item will remain open
pending further corrective action.
(Open) IFI 50-261/93-301-03, "Ineffective Control of Operator Aids."
This
item concerned the lack of effectiveness of procedure OMM-016, "Control of
Operator Aids". The plant program to track operator aids did not include
two Halon fire suppression placards. The licensee did not monitor these
operator aids and subsequent changes for correctness. An interview with
the person responsible for the operator aids program revealed that no
action had been taken to incorporate these items into the program. The
licensee initiated action during this inspection to include the placards
in question, as well as several similar licensee identified placards into
the Operator's Aid Log. This item will remain open pending finalization
of the program update.
(Closed) VIO 50-261/93-301-04, "Licensee failure to report changes to
licensed operator medical status within 30 days as required by 10 CFR
50.25."
This item concerned the facility failure to report operator
medical status changes, specifically the need for corrective lenses.
The
licensee determined their procedure, "CP&L Corporate Medical Procedure for
NRC License Applications and Renewals" to be inadequate and issued
procedure NGGM-402-04, Administration of Medical Requirements for NRC
Licensed Operators, in December 1993 to supersede the former procedure.
This latter procedure explicitly assigns the Training Section Coordinator
the task to compare current medical statements with previous statements
and process NRC Form 396 via the licensee's Regulatory Affairs group
within the required time limit. This Inspector Followup Item is closed.
4. Exit Interview
At the conclusion of the site visit, the inspectors met with
representatives of the plant staff listed in paragraph one to discuss the
Report Details
8
results of the inspection. The licensee did not identify as proprietary
any material provided to, or reviewed by the inspectors. The inspectors
further discussed in detail the inspection findings listed below. The
licensee did not express any dissenting comments.
Item Number
Description and Reference
IFI 50-261/94-01-01
The lack of alternate path JPMs used in
evaluations.
IFI 50-261/94-01-02
Inability to effectively track operator
license conditions.
URI 50-261/94-01-03
The use of hours in a position other than
those required by Technical Specifications
for purposes of maintaining an active
license.
IFI 50-261/94-01-04
Inability to effectively address operator
concerns in the procedure change program.
VIO 50-261/94-01-05
Failure to maintain control of procedures.
5. List of Acronyms
FR
Functional Recovery
IFI
Inspector Follow-up Item
LER
Licensee Event Report
-
Licensed Operator Requalification
NGGM
Nuclear Generation Group Manual
OMM
Operations Management Manual
OP
Operating Procedure
Reactor Coolant Pump
RNO
Response Not Obtained
Reactor Operator
Reactor Turbine Generator Board
Refueling Water Storage Tank
S/G
Steam Generator Tube Rupture
Safety Injection
Senior Reactor Operator
Shift Supervisor (SRO licensed)
TI
Training Instruction
TS
Technical Specifications
TUI
Training Unit Instruction
Unresolved Item
Violation