ML17164A605
| ML17164A605 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/21/1995 |
| From: | Florek D, Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17164A604 | List: |
| References | |
| 50-387-95-03, 50-387-95-3, 50-388-95-03, 50-388-95-3, NUDOCS 9503060009 | |
| Download: ML17164A605 (16) | |
See also: IR 05000130/2002003
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
DOCKET/REPORT NOS:
50-387/95-03
50-388/95-03
LICENSEE:
Power and Light Company
FACILITY:
Susquehanna
Steam Electric Station
Salem Township,
DATES:
January 30-February 3,
1995
INSPECTORS:
D. Florek, Senior Operations
Engineer,
DRS,
RI
C. Tyn
NRC Consultant,
INEL
LEAD INSPECTOR:
. Florek, Senior Operations
Engineer
BWR Section
Division of Reactor Safety
D te
APPROVED BY:
G enn
W. Heyer, Chief
8
PWR Sections
Division of Reactor Safet
Da e
9503060009
95022i
ADQCK 05000387
8
INSPECTION SUMMARY
Combined Report Nos. 50-387/95-03
and 50-388/95-03
Two inspectors
evaluated
the Susquehanna
Steam Electric Station
(SSES)
licensed operator requalification training program during the week oF
January
30,
1995.
The annual
operating test
and written requalification
examination
were administered to an operating
crew.
~Oereti ens
Overall,
SSES performed
a very good requalification training program.
The
annual written examination'nd
operating test were high quality,
and the
evaluator s effectively reviewed operator performance to high standards.
This
resulted
in part of one operating
crew failing the simulator section of the
examination.
Further,
the relationship
between the training and operations
departments
was exceptionally good, the training feedback
and remedial
training programs
were effective,
and outstanding controls existed regarding
the status of active operator licenses
and reactivation of licenses.
Nonetheless,
some problems
and areas for improvement were identified.
A few
operators
involved in exam development
and review had
been inappropriately
exempted
from one year's
examination within the two year cycle.
This error
was corrected during the inspection.
JPNs
and scenarios
were not addressed
within the examination
sample plan, which had the potential to overemphasize
some training areas.
There
was
a scarcity of Unit 2 JPHs.
Event sequencing
within the simulator scenarios
was predictable,
and operators
seemed to
perform based
on the expected
sequence.
The STA's involvement in crew
activities
on the simulator was inconsistent
and often ineffective.
Training
records
had
some problems,
including misfiled records,
missing records,
and
weak guidance
on expected
records.
Two open items were closed
and related to corrective actions following the
submittal of an
SRO license
renewal without the applicant having successfully
completed the requalification program requirements
and secondary
containment
entry conditions
on area radiation levels.
11
DETAILS
1.0
BACKGROUND AND SCOPE (IP 71001)
During the week of January
30,
1995,
two inspectors
conducted
a performance-
based
inspection of the Susquehanna
Steam Electric Station
(SSES)
licensed
operator requalification training program using
NRC Inspection
Procedure
71001,
"Licensed Operator Requalification
Program Evaluation."
This
inspection took place
as part of Requalification Cycle 94-7 and evaluated
the
requalification training program, evaluators
and operators
during Week 4 of
their 1995 annual
exams.
The purpose of this inspection
was to eva'iuate
the acceptability of the
licensed requalification training program with respect to 10 CFR 55
regulations
and to assess
the effectiveness
of the training.
Also, the
inspectors
focused
on the training evaluation
process
and requalification
program revisions
made
as
a result of this evaluation process.
The inspection
included
a review of'the annual
operating
and written
examinations,
and observation of individual and crew performance for one
operating shift that was divided into three operating
crews for the simulator
portion of the examination.
In addition, interviews with licensed operators,
training instructors,
and supervisory
personnel
were conducted.
The
procedures for maintenance
and activation of operator licenses
were reviewed.
The inspectors verified that the requirements
were met to reactivate inactive
licenses.
The following administrative procedures
and documents
associated
with the training program
and its implementation
were also reviewed.
NTP-(A-31.2, "Licensed Operator Requalification Program
Implementation," Revision 3,
Change
94-007,
dated
May 20,
1994.
OP002,
"Licensed Operator Requalification," Revision 3,
Change 8, dated
March 24,
1994.
STCP-(A-323,
"Simulator Performance
Evaluation," Revision 3, dated
January
3,
1994.
The inspectors
used
"Operator Licensing Examiner Standards,"
Revision 7,
as
a basis for determining the adequacy of the Susquehanna
Steam
Electric Station operator examination
process.
2. 0
EXAMINATION DEVELOPMENT
SSES administered
annual written examinations
and operating tests
(job
performance
measures
(JPMs)
and simulator scenarios)
to an operating
crew.
Each portion of the examination is discussed
below.
2. 1
Examination
Sample Plan
The inspector
concluded that the examination
sample plan was not effectively
used to integrate all portions of the examination,
because
each portion of the
examination
was developed
independently
by different individuals and the
sample plan was only used to develop the written examination.
This minor
problem could enable
overemphasis
of evaluation in a training area
and absence
of evaluation in another.
The inspector
found that each portion of the examination
was developed
by
different individuals or teams.
A developer of one portion of the examination
did not discuss
his portion of the examination with another developer of
another portion of the examination.
The examination
sample plan was developed
to emphasize
the training provided over the last
12 months.
Approximately 20X
of the sample plan covered training provided in other years.
However, the
sample plan was only used to develop the written examination.
The sample plan
was not used to integrate all portions of the examination.
The inspector concluded that by not using the sample plan to integrate all
portions of the examination the potential existed that could result in an area
being overemphasized
by the examination process.
For example,
a scenario
could focus
on HPCI (high pressure
coolant injection),
a JPM could be
developed for HPCI,
and the written examination could also
emphasize
HPCI.
For the examination
observed,
this overemphasis
had occurred to a small
extent,
in that the
JPM administered to reactor operators
(ROs),
"Respond to a
Failure of RPS to Scram the Reactor,"
was
a task observed to be performed
by
ROs during the simulator portion of the examination.
Interviews with training
department staff identified that no review was performed for examination
duplication.
2.2
Written Examination
The inspector
concluded that the written examinations
were good evaluation
tools.
The inspector concluded that the questions
were at the appropriate
level for an open reference
examination
and the examinations
were
a good
evaluation of operator
knowledge.
Six written examinations
were developed for
the examination cycle based
on the examination
sample plan.
Each written
examination
included
a static examination
as well as
a classroom
examination.
Each written examination
included
a different static simulator setup.
For the
three examinations that the inspector reviewed,
the classroom portion of the
written examination
had less
than
30X of the questions
from a previous
classroom
examination.
This seemed to be
a reasonable
approach to preserving
the security
and validity of the examination.
2.3
Job Performance
Measures
(JPNs)
In addition to the absence of JPM coverage
within the examination
sample plan
as noted in Section
2. 1, the inspector identified concerns
on JPM duplication
week-to-week
and the scarcity of Unit 2 JPMs.
The inspector
noted that in contrast to the written examination,
in which
administrative
procedures
control the duplication of questions
on the
subsequent
week's examinations,
there is no such control
on duplication of
JPMs during subsequent
examinations.
Specifically,
one
JPM set
can
be
administered
during
a particular week with a repeat of the set in a subsequent
week.
While the inspector did not identify any specific examination security breach,
the
SSES methodology
used this year to repeat
an entire
JPM set in a
subsequent
week could result in a compromise of examination security.
Further, the inspector
noted that no JPHs this cycle were performed
on Unit 2,
All JPMs were Unit I or common JPMs.
Further,
review of the
JPM examination
bank identified that the
JPM identified for Unit 2 are focused
almost
exclusively on remote
shutdown.
The inspector judged the scarcity of JPMs
on
Unit 2 in the facility examination
bank to be
a weak approach to evaluating
operator skills on both units
and
a potential
hinderance
to effectively
administering the operating test.
2.4
Simulator Examination
The inspector concluded that the scenarios
were good evaluation scenarios;
however,
event sequencing
in the scenarios
was predictable
and tended to
diminish the effectiveness
of the evaluation.
Further,
some critical tasks
lacked specific measures
for performance,
and
some
had been miscategorized
in
that the tasks
were not safety significant in the given scenario.
The inspector
concluded that the scenarios
were good evaluation
scenarios
and
provided numerous opportunities for the crew members to perform,
such that
their performance
could be evaluated.
However, the scenarios
were predictable
regarding event sequencing;
The first ma'ifunction resulted in a technical
specification determination
by an
SRO,
then entry into abnormal
procedures,
and then the major transient with emergency operating
procedure
(EOP) entry.
The crews
seemed
aware of this routine
and did not really concern themselves
with the plant until after the technical specification
problems
had been
resolved.
The inspector judged that this predictability could inadvertently
train the operators
in sequences
unrelated to actual plant performance
and
tended to diminish the effective evaluation of the operators'erformance.
Further,
the critical tasks identified in the scenarios
frequently lacked
objective performance
indicators for determining pass/fail
decisions,
and
some
did not appear to be safety significant within the scenario.
Many critical
tasks relied on the judgement of the evaluators
to determine pass/fail
determination.
For example, if the critical task was to perform emergency
depressurization,
there were no specification
as to when the emergency
depressurization
was required to be completed.
In addition,
a few examples
were identified in which tasks that might be safety significant in other
situations
were not in the given scenario.
For example, inhibiting ADS (auto-
depressurization
system)
was not always critical to the safety impact
on the
plant in all scenarios.
The scenarios
used
on the operating test
had
been developed with good
involvement from the operating
crews, in an acceptable
manner to preserve
examination security,
and with a wide range of evaluated
malfunctions
and
events.
3.0
EXAMINATIONADMINISTRATION, RESOLTS
AND OBSERVATION
3.1
Written Examination
The written examination
was administered
in appropriate
environments,
and all
operators
passed
the examination
administered
during the inspection visit.
However, the inspector concluded that
a few operators
had been inappropriately
exempted
from the written examination,
but subsequent facility action
corrected the concern.
The inspector
concluded that
a few SSES licensed operators
were not receiving
a comprehensive
biennial written examination,
in that they could be exempted
from one year's
examination within the two year cycle based
on their
involvement in the exam's
development.
Specifically, the inspector
found that
administrative
procedures
allowed
an operator
who was involved with the
development,
grading or review of the written examination to be excused
from
that year's written examination.
An individual could not be exempted for two
consecutive
years.
A review of the
1994 records
and plans for the
1995
examination identified that two licensed operators
were exempted
from an
examination in 1994 and two different operators
were planned to be exempted in
1995.
The inspector
concluded that since the written examination is focused
on the
training received in the last year,
both examinations
would be necessary
to
assure that the written examination is comprehensive for the entire two year
requalification program cycle.
The
approach to written examination
results in each examination
being
a segment of the requalification cycle, with
some look back at previous training.
When brought to the attention of the
SSES training management,
the
SSES training management
determined that
a
change to the administrative
procedure
would be initiated and the exemption
from the annual
examination eliminated.
An annual'ritten
examination
would
be prepared
and administered to those
two individuals initially exempted
from
the
1995 written examination.
This was acceptable
to= the inspector.
3.2
JPMS
The inspector concluded that the JPHs were well administered
and that the
operators
performed well.
Some areas for improvement were noted with regard
to allowing operators
to observe other operators
and the understanding
of in-
plant equipment at the
SRO level.
The inspector monitored the administration of JPHs to three
and two SROs.
Four evaluators
administered in-plant JPHs in parallel,
and two evaluators
administered
the simulator JPHs in parallel.
All JPHs observed
were successfully
performed.
The inspectors
observed that
the
SROs were weak in stating what they expected
to see
by their actions
when
controls were manipulated during in-plant JPHs.
The
SROs simply simulated
operating the controls
as specified in the procedure with little discussion of
the consequences
of their actions.
The inspector concluded that
appeared
to have weak understanding
of in-plant equipment controls.
In general,
the facility evaluators
did a very good job of providing the
appropriate
cues
when required.
However, the cues contained
in the
JPM to
initiate SBGTS (standby
gas treatment
system)
in an emergency
were
inappropriately stated in the
JPM and did not allow the operator to determine
if his actions
were correct
and the system response
was consistent with his
actions.
The in-plant JPMs observed. were all on Unit I, and the four exam teams
kept
meeting
up with each other.
Also, the
SSES examination
team used the
technical
support center
above the control
room as
a meeting place for
operators to take the examination.
Some of the JPMs required the operators
to
go into the control
room.
The inspector
observed
some of the operators
who
would be taking the second
wave of examinations
in the control
room,
as the
first wave of operators
were conducting their examinations.
This was not
conducive to examination security.
The inspector did not consider that any of
the observations
in the control
room to be
a direct breach of examination
security.
However, the inspector judged that improvement in the
method
for in-plant JPM administration is desirable to avoid the potential for
examination
compromise.
3.3
Simulator
The inspector concluded that the simulator evaluation
was thorough, effective,
and complete,
and based
on
some
weak operator performance,
that the evaluators
appropriately failed one crew and two individuals within that crew.
Evaluated
crews demonstrated
a range
oF performance
from poor to superior.
During six simulator scenarios
on three evaluated
crews,
each consisting of
two SROs,
two ROs,
and
a shift technical
advisor
(STA), the evaluator
teams
did a very thor ough and complete job of monitoring and evaluating the actions
of licensed operators.
Al'I crews completed the critical tasks;
however,
the
evaluators
measured
operator
performance to high standards
of performance.
One crew was judged to have little or no weaknesses,
one crew was judged to
have minor weaknesses,
and the third crew was judged to have significant
weaknesses.
The evaluators
determined that one crew failed the examination.
Since
SSES also performed individual evaluations,
two individuals within that
crew were also failed.
The inspectors
independently
assessed
the crew performance
in the simulator.
The inspector 's assessment
of crew performance
was consistent with. the
evaluation
team's
assessments.
Also, the inspector determined that, despite
having the one
STA, the
STA involvement with each
crew was inconsistent,
and
the
STA was not utilized effectively .in two of the three examination
crews.
Some of the emergency
support
(ES) procedures
that implement in-plant operator
tasks to carry out emergency operating
procedure actions
were performed in an
accelerated
time.
This was done in order to obtain
a target simulator time of
about
50 minutes.
This had the potential to provide negative training to the
operators.
The inspector considered that real time implementation of ES
procedures
would reinforce real time expectations
and also provide meaningful
information as to adequacy of the
ES procedure
methodology to the overall
emergency operating
procedure strategy.
3.4
Other Observations
Based
on interviews with several
ROs,
SROs,
and trainer/evaluators
and other
inspector observations,
the inspector concluded that the relationship
between
the training and operations
departments
was exceptionally good.
The operators
felt that the training department
was there to support them,
and they
appreciated their ability to have
an input during training and examinations.
The inspector
also noted two other positive initiatives that contributed to
the exceptional
relationship
between operations
and training.
The first was
the ownership of each operating
crew of five evaluation scenarios
in the
simulator examination
bank.
This appeared
to help assure validation of the
scenario
scenarios
and enabled
an understanding
by the operators of the
examination
process
and management
expectations
on standards
of performance.
The second
was the use of an individual crew training week between the end of
one training cycle and the beginning of another cycle.
This week allowed the
shift supervisor to tailor individual training for noted weaknesses
on his
crew as well as allow the training staff to better establish
the training for
the next cycle.
The following observation is intended to provide feedback to the
NRC site
access training.
The read
and sign training did not provide any guidance
on
the expected
methods to enter the radiologically controlled area or
information on how to obtain
a self reading dosimeter.
4.0
TRAINING RECORDS
REVIEM
The inspector
found minor problems regarding
SSES training records that were
incomplete or misfiled.
Specifically, the inspector reviewed the
1994
examination records of five operators.
The results of the annual
1994
simulator and
JPH examinations
were not initially in the individual operator
folders, but had
been misfiled and were subsequently
found.
Four of the five
operators
had failed a portion of the
1994 examination
and remedial
programs
were required.
However,
one of the four operators'emedial
programs
was not
in his file and
as of the end of the inspection
had not been located.
Also,
the inspector
noted that incomplete procedural
guidance existed
on the
expected
contents of the training record files.
5.0
NANAGENENT OYERSIGHT
'AND CONTROLS
The inspector
reviewed guality Assurance
(gA) Audits94-030
and 94-067
and
found the audits to be generally effective management
oversight tools.
The
audits covered the effectiveness
of the
SSES training, retraining,
and
qualification programs for the entire plant staff and the
1994 annual
simulator certification testing.
The audits were complete
and findings were
transmitted to the appropriate level of SSES
management.
Also, the inspector noted
an audit finding that related to errors in the
training record
management
system,
similar to that discussed
above.
Training
management
stated that these findings were relatively recent
and that
a broad
approach to addressing'he
records
issues
was being formulated.
6.0
TRAINING FEEDBACK SYSTEN
The inspector concluded that the training feedback
system for operations
crews
has
been effective based
on review of training feedback records for the
current
and two previous requalification cycles
and
an interview with the
training instructor responsible for the program.
The training feedback
program provides weekly crew course critiques
and input
for future training.
This feedback is provided to training management
and is
discussed
at periodic meetings of the Training Curriculum Committee for a
determination
on incorporation into the training program.
An inspector
check
of some crew-identified weak training areas
showed that these
areas
had
been
incorporated into later requalification cycles.
The inspector noted that the
submittal of crew feedback
forms effectively involved the crew's supervision
in the feedback
process
but could potentially hinder the ability of
individuals to provide feedback.
No actual
problems
were identified in this
respect.
7.0
REMEDIAL TRAINING PROGRAN
The inspector
concluded that the remedial
program provided good retraining
and
support to operators
who have failed portions of their annual requalification
examinations.
The program addresses
individual
and crew failures or weak
areas resulting from the annual requalification examination.
The inspector reviewed the
SSES instructions for the remedial training program
and interviewed the instructor responsible for the program.
Additionally, one
operator
who failed the written examination during this cycle was interviewed
and his specific initial examination,
remedial
program,
and retake examination
were reviewed.
The operator
had
been
informed of his examination failure and was
made
aware
of his removal
from licensed operator duties until his remedial
program
and
reexamination
were completed.
The training department
developed
a remedial
program
based
on the operator's
demonstrated
weak areas
on the examination,
directed the operator's
remedial
actions,
and provided additional assistance
and simulator time as necessary
to support his efforts.
The operator stated
that
he received
good support during his remedial
program
and subsequent
reexamination.
8.0
ACTIVATION AND MAINTENANCE OF LICENSES
The inspector
concluded that the program for tracking status of active
operator licenses
and for reactivation of licenses
was outstanding.
The
inspector reviewed the
SSES instructions for maintaining licenses
active
and
for reactivation of licenses.
Two operators
who reactivated their licenses
within the last five months were interviewed,
as
was
an operations
department
supervisor.
The
SSES instructions for maintaining licenses
active
and for reactivation of
licenses
were very specific
and required actions of the operator
as well as
training and operations
management.
The instructions provided checklists,
including plant tours
and
an verbal examination, that must
be signed
by the
operator,
the shift supervisor,
and the manager
of nuclear operations.
Although the checklists
could have
been
more specific regarding expectations,
these checklists
appeared
to be effective mechanisms
to address
license
reactivation.
The inspector
concluded that both operators
interviewed
knew
their responsibilities for a license reactivation.
9.0
LICENSEE ACTION ON PREVIOUS INSPECTION FINDINGS
Closed
Unresolved
Item 50-387 94-25-01
This item related to the root cause
and corrective actions following the submittal of an
SRO license
renewal
application without the applicant having successfully
completed the
requalification program requirements.
An event
team was created to determine
the root causes
of the event.
As a
result of the event
team assessment,
changes
were being processed
to
Procedures
NTP-gA-31.2 and .OP002 to define the requirements for being current
within the requalification program.
It included time period limits that may
not be exceeded for missed training or weekly quizzes
as well as
end of
requalification year limits.
Additional training cycle reports will be
generated
to identify missed training and quizzes.
During the inspection
week, the
SSES training cycle reports indicated that no licensed individuals
had any missed training.
Based
on the
SSES event
team report
and actions
taken
by SSES to improve the procedures
and records
management
system, this
item is closed.
Closed
Unresolved
Items 387 93-06-02
and 388 93-06-02
This issue related to
establishment
of a single value for maximum normal radiation level
(500 mR/hr)
for areas
in secondary
containment.
has
changed
the secondary
containment
EOP entry condition for area radiation levels to any unexplained
area radiation level
above
maximum normal.
Maximum normal
has
been redefined
as
a high alarm on the specified radiation monitors.
This will eliminate
delay in implementing
EOP strategies
and is in line with the
Evaluation scenarios
observed
during the inspection
confirmed that using the
maximum normal radiation levels
as
a high alarm on the specified radiation
monitors resulted
in timely action by the operators to mitigate secondary
containment
challenges.
This item is closed.
10.0
EXIT MEETING
An exit meeting
was conducted
on February 3,
1995, during which the
NRC
inspectors
reviewed the scope
and findings of the inspection.
At the exit
meeting,
PP8L personnel
acknowledged
the inspector's
conclusions
and findings.
Personnel
at the exit meeting are listed below:
Pe
ns lvania
Power
and Li ht
K. Chambliss,
Manager,
Nuclear Operations
C.
Fedako,
Nuclear Operations Training Supervisor
A. Fitch, Nuclear Training Supervisor
M. Lowthert, Manager,
Nuclear Training
T. Markowski, Dayshift Supervisor Operations
E. Stanley,
Vice President,
Nuclear Operations
U. S. Nuclear
Re ulator
Commission
0. Mannai,
NRC Resident
Inspector