ML17285B255
| ML17285B255 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/25/1990 |
| From: | Meadows T, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285B254 | List: |
| References | |
| 50-397-OL-90-01, 50-397-OL-90-1, NUDOCS 9005100159 | |
| Download: ML17285B255 (10) | |
Text
Examination Report No.:
. 50-397/OL-90-01 Facility Licensee:
Washington Nuclear Project, Unit 2 (WNP-2)
Facility Docket No.:
50-397 Facility License No.:
NPF-21 Licensed operator requalification examinations administered at WNP-2, Richland, Washington.
Chief Examiner:
T omas R. Meadows, Licensing Examiner Date Signed Approved:
F.
s er, ief, Operati Section Date Signe Summary:
During the period January 29, through February 8, 1990, the NRC conducted a validation review of the WNP-2 Licensed Operator Requalification Program testing materials.
Subsequently, during the period of February 27, through March 9, 1990, the NRC conducted the formal program evaluation (Report No. 50-397/OL-90-01).
Results:
The facility Licensed Operator Requalification Program was determined to be satisfactory.
However, three findings of concern were identified by the NRC examination team:
First, the quality of the program's written examination and Job Performance Measure (JPM) question bank testing materials, received during the validation portion of this inspection, were initially inadequate to conduct objective operator examinations.
The question banks contained subjective and open ended questions, to the degree that valid parallel grading determinations between our two examiner staffs would have been difficult.
Furthermore, some of these questions were technically inaccurate since their reference base was not current.
- Second, the program's JPM time validation process was imprecise.
The "validated" times were inaccurate for over twenty percent of the JPM's used for this program evaluation.
Third, the licensee's operating procedure validation system was not reliable.
Approximately twenty percent of the safety related operating procedures were sampled in this evaluation effort.
Most of these 9005100f59 900425 PDR ADOCK 05000397 POC
procedures had some degree of deficiency (erroneous panel labeling, misplaced steps, obscure
- steps, or insufficient detail).
Two examples of deficient procedure validation of safety related tasks were of particular concern during the program evaluation.
First, the task of mitigating an uncontrolled depressurization of the t1ain Steam System and Reactor, due to the failure of the Digital Hydraulic Control System (DEH), had no reference procedure.
- Second, Emergency Procedure, "Reactor Power Control" (PPH 5.1.3) provided inadequate guidance for performing the task of venting the overpiston area of an affected control rod, in an Anticipated Transient Without Scram (ATWS) scenario, after all other means of attempted rod insertion had failed.
The procedure provided two obscure
- steps, basically - open and vent the overpiston area, and then stop doing this when the rod is inserted.
Examination Results Summary:
The following table summarizes the test results of individual operators and operating crews as graded by the NRC:
Operating Crews:
Total Tested Total Passed Total Failed 0
1ndividual Operators:
RO:
12 SRO:
12 Total:
24 10 12 22 Licensee and NRC Examination results are in agreement except that the licensee failed one additional operator in the written portion of the examination.
REPORT DETAILS 1.
Personnel NRC Personnel:
J. Martin, Regional Administrator
- L. Miller, Chief, Operations Section
- T. Meadows, Chief Examiner C. Bosted, Senior Resident Inspector
- C. Sorensen, Resident Inspector
- M. Morgan, NRC Contract Examiner
- R. Orton, NRC Contract Examiner
- K. Mikkelson, NRC Contract Examiner MNP-2 Personnel:
- L. Oxsen, Assistant Managing Director for Operations
- C. Powers, Plant Manager
- A. Ogletree, Technical Training Manager
- J. Baker, Assistant Plant Manager
- S. McKay, Operations Manager
- B. Barmettlor, Manager, Nuclear License Training
- G. Kozlik, Shift Manager/Operations Liaison
- G. Fisher, Lead, Requalification Training
- R. Conserriere, Shift Manager J. Perry, Training Staff G. Richmond, Training Staff S. Bruce, Training Staff L. Monroe, Training Staff G. Smith, Training Staff S. Hutchison, Training Staff Identifies personnel present at the March 9, 1990 exit meeting.
2.
Pur ose of Pro ram Evaluation The evaluation was conducted to determine the effectiveness of the MNP-2 Licensed Operator Requalification Program and to evaluate licensed operators for renewal of their six year term license.
The evaluation was administered in accordance with NUREG-1021, ES-601, Revision 5, "Administration of NRC Requalification Program Evaluations."
3.
Pro ram Validation and Examination Develo ment Prior to the examination, the licensee provided Region V with a complete set of simulator scenarios, Job Performance Measures (JPM's),
and banks of questions for Category A (static simulator),
and Category 8 ('lassroom written) examinations.
Two findings of particular concern were found during the validation review of these program testing materials.
First, tPe quality of the program's written examination and Job Performance Measure (JPM) questions were initially inadequate to conduct objective operator examinations.
Contrary to the guidance given in the "Examiners'andbook for Developing Operator Licensing Examinations" (NUREG/BR-0122) and the "Operator Licensing Examiner Standards" (NUREG 1021, ES-601, 4), these question banks contained double jeopardy, subjective, and open ended questions, to the degree that valid parallel grading determinations between the examiner staffs would have been difficult.
Furthermore, some of the questions were technically inaccurate since their reference base was not current.
These weaknesses resulted in an extensive administrative effort=by the training staff to develop acceptable.,testing materials in time for the formal program evaluation.
The licensee staff committed to improve these test banks, commensurate with industry standards for objective testing materials, and to implement a
formal system of maintaining these materials current by their next program evaluation 'cycle.
- Second, the licensee's operating procedure validation system was not reliable.
Approximately twenty percent of the safety related operating procedures were sampled in this evaluation effort by the NRC.
Most of these procedures had some degree of deficiency (erroneous panel labeling, misplaced
- steps, obscure
- steps, or insufficient detail), to the extent that correct and timely task performance by licensed operators under actual emergency conditions might be hampered.
Two examples of deficient procedure validation of safety related tasks were of particular concern during the program evaluation:
a
~
During the NRC validation review (January 29 --February 8, 1990) one simulator operating scenario required the operating crew to mitigate an uncontrolled depressurization of the Main Steam System and reactor from 100% power.
The event was initiated by the failure of the Digital Hydraulic Control System (DEH) and subsequent failure of the Main Steam Bypass Valves to close or remain closed.
The operating crew was expected to mitigate the event consequences by timely remote closure of a common isolation valve to the steam bypasses.
This action would stabilize the plant before the automatic low pressure group isolation occurred.
No operating procedure addressed this action.
This raised the following issues:
Apparently, there was no procedure encompassing a malfunction of a Pressure Control/Main Steam to Turbine system, as required by Regulatory Guide 1.33 and the licensee's Technical Specifications.
This issue is further documented in Inspection Report 90-09.
Apparently, the licensee trained its operating crews to mitigate such an event without clear procedural
- doctrine, since this scenario was a part of their program's simulator scenario examination bank.
b.
Emergency Procedure, "Reactor Power Control" (PPM 5. 1.3) provided inadequate guidance for an operator to perform the task of venting the overpiston area of an affected control rod, in an Anticipated Transient Without Scram (ATWS) scenario after all other means of
0 l
attempted rod insertion failed.
The procedure provided two obscure
- steps, basically - open and vent the overpiston area, and then stop doing this when the rod is inserted.
The NRC inspectors and the licensee's operating staff determined that this task required a
minimum of 10 comprehensive steps to complete successfully.
This issue is of particular concern considering the safety significance of hydraulically locked control rods, and is further documented in Inspection Report 90-09.
The Chief Examiner noted that the a procedural validation program would encompass three elements:
Prioritization of validation efforts - stressing
- safety, Management commitment, and Procedure revision feedback to the Training Department in a timely manner.
The 1'icensee's management staff committed to resolve this issue by upgrading their existing procedure validation program to meet these expectations.
4.
0 erator Selection The operating crews were selected by the licensee in accordance with NUREG 1021, ES-601.
Operator selection and crew composition were reviewed and approved by the Chief Examiner.
5.
Examination Administration An NRC Licensed Operator Requalification Program evaluation was administered at WNP-2 during the period of February 27, through March 9, 1990.
The WNP-2 site specific simulation facility operated satisfactorily during the performance of the scenarios, JPM's, and the Category A
static scenarios selected for this evaluation.
- However, some simulator anomalies and fidelity problems were noted by the NRC examiners, and are documented in Enclosure 4, "Simulation Facility Report."
It should be noted that the test scenarios had been extensively validated by both the training and operating staffs.
Furthermore, the majority of these scenarios required meticulous manual simulator operator involvement.
This effort taxed the licensee's training resources, and subjected the operating crews to increased simulator operator input errors during any given scenario.
The licensee has committed to have a
new plant specific simulation facility ready for training in June, 1991 (see inspection report No. 50-397/88-44, "NRC Review of Washington Nuclear Project No.
2 Simulation Facility").
Written examination sets were administered to two operating crews on February 27,
- 1990, and to the remaining two operating crews on March 5, 1990.
Each examination set was developed independently by the licensee, in accordance with their sampling plan of required knowledges and abilities.
This process ensured proper examination
coverage and security.
Although adequate to accommodate the parallel grading requirements of the program, these examinations still suffered from some of the deficiencies identified during the validation period (see paragraph 3, above).
This resulted in the answer keys being finalized after each respective ex'amination set by the Chief Examiner and licensee management.
Some questions were still open ended and subjective to the extent that the initial answer keys were not complete.
Three questions, total, were deleted from the sets of examinations.
Two of these were deleted primarily because they were too subjective to solicit a specific correct answer.
One question, from one static simulator examination (part A), was deleted because it was compromised by pre-existing annotations on one reference print that was available to the operators.
The Chief Examiner verified that these changes did not affect the comprehensiveness of the examinations, and had the licensee document these changes in writing for each respective examination week.
These documents were endorsed by the Chief Examiner before leaving the site, and are included as Attachment A to this report, "Written Examination Key Resolution".
It should also be noted that the one written examination grading conflict resulted from the subjectiveness of the respective examination and the licensee deviating from the final key when grading.
During the walk through portion of the evaluation, the NRC examiners found the program's JPM time validation process to be imprecise.
This became
- evident, under actual test conditions, when approximately twenty percent of the selected JPM's were completed by the operators in approximately half the "pre-validated" estimated time.
One safety related JPM, involving emergency plant shutdown from outside the control room, required twenty minutes longer to successfully complete than the time estimate given.
The NRC examiners noted increased operator stress due to this deficiency.
The licensee's staff committed to correcting the JPM bank time validation
- process, such that valid completion times are indicated by the next program evaluation cycle.
6.
Evaluation of Licensee Evaluators The NRC examination team found that the licensee had no formal evaluator training program in place.
This was evidenced by their evaluators initially making numerous mistakes during the first week of the evaluation process.
The number of mistakes made by the licensee's evaluators decreased after appropriate NRC examiner remediation
.and their experience increased.
However, it is not the intent that the program evaluation process be used as a vehicle to train licensee evaluators.
Typical facility evaluator mistakes included:
Licensee evaluators not properly cuing operators when a
JPM step was not completed by the operator, or missing the cue altogether.
Telegraphing critical JPM performance steps in the body of the cue presentation.
Asking leading JPM questions, or rewording the question to the extent that it included the answer.
Altering JPM questions such that they were reduced in scope to look up exercises.
Facility staff designated to conduct requalification examinations must be properly trained as examiners, and familiar with the evaluation process.
The licensee agreed with this finding and committed to implement an evaluator training program prior to their next requalification examination cycle.
7.
0 erator and Crew Performance Twenty-two of the twenty-four operators were judged to be satisfactory by NRC examiners, and will be eligible for renewal of their six year term licenses.
The licensee confirmed that the operators that were determined by the NRC as failing the written and operating portions of their respective examinations were removed from licensed duties, remediated in the areas of identified weakness and then reexamined by their staff prior to being returned to licensed duties in accordance with NUREG 1021, ES-601.
The NRC scheduled a reexamination of these two individuals in the areas of identified weaknesses within six months of the initial notification of failure letters.
Licensee and NRC examination results are in agreement except that the licensee failed one additional operator in the written portion of the examination.
The licensee stated that this individua'1 was also removed from licensed duties, remediated in the area
'of identified weakness and then returned to licensed duties, in accordance with their program.
All four of the operating crews were evaluated as satisfactory by the NRC.
One of these crews was marginal, in their application of operating procedures.
All crews exhibited some weakness in the competency of comnunications.
8.
Exit Meetina An exit meeting was held with the NRC examiners, the WNP-2 resident inspector, and representatives of the licensee's staff on March 9, 1990 to discuss the program evaluation and the NRC findings.
The licensee staff acknowledged the examination team's findings and indicated that steps were being taken in these areas to correct the deficiencies.
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