ML17289A978
| ML17289A978 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/20/1992 |
| From: | Morrill P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289A977 | List: |
| References | |
| 50-397-92-27, NUDOCS 9211120277 | |
| Download: ML17289A978 (15) | |
See also: IR 05000397/1992027
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Number:
50-397/92-27
Docket Number:
50-397
Licensee
Number:
Licensee:
Mashington Public Power
Supply System
P. 0.
Box 968
3000 George Mashington
May
Richland,
Mashington
99352
Facility Name:
Mashington Public Power Supply System Nuclear
Reactor
Facility, Unit 2 (MNP-2)
Inspection at:
MNP-2 site near Richland,
Mashington
Inspection
Conducted:
September
21-25,
1992
Inspectors:
T. Meadows,
Senior Licensing Examiner,
RV (Lead Inspector)
C. Gratton, Senior Licensing Examiner,
NRR/LOLB
H. Biamonte, Senior Training Specialist,
NRR/LHFB
Approved,by:
~Summar:
P. J
Morrill, Chief'
eactor Operations
Section
Date Signed
Ins ection
on
Se tember 21-25
1992
Ins ection
Re ort No. 50-397 92-27
Areas Ins ected:
This inspection
examined the facility's,licensed operator requali fication
simulator training and evaluator performance.
The inspectors
focused
on the
ability of the facility evaluators
to objectively evaluate
and critique
operator performance.
The inspection also evaluated
whether the facility's
licensed operator initial, licensed operator requalification,
and shift
technical
advisor
(STA) training programs
were in compliance with regulatory
requirements.
Inspection procedure
41500 was used
as guidance for the
inspection.
92iii20277 921020
ADOCK 05000397
8
0
1
I
Results:
General
Conclusions
and
S ecific Findin s:
The inspection
team found that, with one exception,
the operators
observed
performed well in the simulator and the facility evaluators
were able to
objectively evaluate
and critique operator performance.
The evaluation
and
feedback process of the licensee's
requalification training program was
adequate.
The one exception
was
a crew failure during a practice scenario.
This failure was correctly identified by the evaluators.
Subsequent
remediation plans
appeared
satisfactory.
The licensed operator initial, licensed operator requalification,
and shift
technical
advisor
(STA) training programs
were also in compliance with
regulatory requirements.
The inspectors identified three areas of potential training program weakness:
(I)
The operations liaison staff person
was not certified as
a training
evaluator,
even though
he conducted evaluations.
This did not appear
consistent with the standards
imposed
on the other training staff
evaluators.
(2)
There
was
no process
to ensure that the training and evaluation
skills developed for the operator requalification program instructors
were transferred to the initial operator
program instructors.
(3)
The licensee
was not adequately
conducting follow-up assessments
of
the effectiveness
of industry events
lessons
learned training conducted
for their operators.
Summar
of Violations and Oeviations:
None
0 en Items
Summar
No items opened or closed
Personnel:
INSPECTION DETAILS
NRC:
- T. Meadows,
Senior Licensing Examiner,
RV (team leader)
- C. Gratton, Senior Licensing Examiner,
NRR/LOLB
M; Biamonte,
Senior Training Specialist,
NRR/LHFB
- W. Ang, Senior
Resident
Inspector
- D.'roulx, Resident
Inspector
Supply System:
- J. V. Parrish; Assistant
Managing Director for Operations
- J. Baker, Plant Manager
- S. McKay, Nuclear License Training Manager
- W. Shaeffer,
Operations
Manager
- M. Mann, Assistant Operations
Manager
- D. Kobus, Manager,
Technical Training
- P. Taylor, Operations
Department Liaison
M. Baird, Requalification Training Supervisor
- J. Gearhart,
Director, guality Assurance
- G. Sorensen,
Regulatory
Programs
Manager
- T. Powell, Equipment/Licensed
Training Supervisor
Present at the September
25,
1992 exit meeting.
The inspectors
also interviewed other licensee
and contract 'personnel
during the inspection.
Overview of the Ins ection
This inspection
was conducted to evaluate
the adequacy of the
requalification program as it related to accurate
and objective
evaluation of the plant operators.
The inspection
team also examined
other attributes of the licensee's
training programs to determine if
regulatory requirements
were being met.
In regards
to the requalification program the inspectors
focused
on
scenario quality, the implementation of management
expectations,
operator
performance,
the remediation process, facility evaluator
objectivity, and the evaluation
and critique process.
The remainder of the inspection, examined operator
and training staff
perceptions
of the program, training. department organization
and
relations with operations, shift technical
advisor
(STA) training,
training department staffing, operator overtime,
and industry events
training.
Review of 0 erator
Re uglification Trainin
Pro ram
a ~
b.
I'K
Using the guidance of SECY 92-154,
"Guidance for Developing
Dynamic Simulator Scenarios
Used During NRC-Administered
Requalification Examinations,"
the inspectors
analyzed the quality
of eight scenarios
used in training and evaluation of shift crews.
The licensee's
training department
had recently completed
a
revision of the simulator scenario
bank by removing unrealistic
scenarios
and rewriting other scenarios
to ensure that all paths
of the
EOPs were exercised
during each
crew requalification
evaluation.
The team found that the scenarios
were adequately
complex, challenging,
and exercised
the
EOPs without being
unrealistic.
The inspectors
concluded that the scenarios
met the
guidance of SECY 92-154.
Mana ement
Ex ectations
C ~
Senior licensee
management
has developed
and provided training
with technical clari-fication of operating procedures
for steps
that require interpretation.
The licensee referred to these
clarifications as management
expectations.
They were developed to
promote operational
consistency primarily for the emergency
operating procedures
(EOP).
The team found that management
expectations
were appropriately placed in the training materials.
Observations of training and evaluations
scenarios
demonstrated
that this was effective in promoting consistent
actions
by crews.
The licensee's
actions
appeared
to have corrected inconsistent
training and operations
which were observed
in the past.
An example of a clarifying management
expectation
was within one
training scenari o involving an interpretati on of the
EOPs.
Thi s
clarification was
boxed in bold lines and stated:
"When
suppression
pool
(SP) level cannot
be maintained
above the heat
capacity level limit (HCLL): Direct termination of injection
sources."
A side note further clarified: "It is expected that
when the source of makeup to the
SP is lost, emergency
depressurization
(ED) will be directed
when the
HCLL is approached
-NOT- when it is reached."
When to take action in this situation
had been
a source of. confusion in the past for both trainers
and
operators.
The inspectors
concluded that the licensee's
management
expectations
appeared
to be an effective device to
clarify procedure
steps
to both trainers
and operators.
0 erator Performance
Operator
performance
was examined
by observing
one staff crew and
one control
room crew in the simulator.
A total of eight
simulator scenarios
were observed for each
crew.
The shift crew was evaluated
in their
normal shi ft configuration.
With one exception,
the inspectors
concluded that the performance
of both crews
was satisfactory.
In general,
the inspectors
observed
good crew communications skills and procedure
usage
during both training and evaluation scenarios.
The shift crew failed one practice scenario
for two reasons.
First, the crew lost control of reactor
system pressure
and
cooldown rate.
The facility evaluators
determined that the crew
had not adequately
monitored cooldown rate and failed the crew in
the competency for'pressure
control.
Second,
the evaluators
observed that the crew did not secure all emergency
core cooling
before 'emergency depressurization.
This could have resulted in an
overcooling of the reactor vessel
when low pressure
injection
'ccurred.
The licensee
evaluators
concluded that the crew had
a
significant weakness
and- required remediation.
The inspectors
concluded that the failure was
a conservative
decision,
and that the evaluators
were effective in identifying
performance
problems.
The inspectors
observed that the shift crew
had satisfactorily passed their previous evaluation
scen'arios.
Remediation
Process
After the scenario described
above,
the facility evaluators
completed the critique process
(described in paragraph
3.e').
The
failed crew appeared
to recognize their errors
and was eager to
learn from their mistakes.
The 'crew and the shift manager
(who
observed
the scenario)
met with the operations liaison and
training staff to conduct
a formal
exam failure analysis
as
required
by Licensed Training Procedure
(LTI) 5.8, "Licensed
Operator
Requal
(LORg) Evaluation Failures."
The lead crew
evaluator established
a timeline for actions during the scenario
as well as the thought processes
involved for the steps
taken.
After the scenario details
and crew deficiencies
had been
identified, the crew's senior reactor operators,
the operations
liaison, the requalification training supervisor,
key evaluator
staff,
and the operations
manager
convened to formalize the causes
of the failure and to determine the required corrective actions.
This included remediation training for the failed crew as well as
correction to parts of the general
operator training program.
The inspectors
observed that the licensee
had accurately
determined
the sequence
of events
and identified the crew'
weaknesses.
The remediation
and corrections to the training
program were reviewed.
Licensee
personnel
appeared
to have
a good
understanding of their procedures
and followed them properly.
The
operations
department
was very involved in the process.
The team
.,
concluded that the remediation
process for the crew was
satisfactory.
Evaluator Ob'ectivit
The team observed five evaluators. conducting evaluation scenarios
on the staff and operating crew.
The team concluded
from these
observations
that the evaluators
were knowledgeable
and objective
and applied the performance
standards
from NUREG-1021, "Operator,
Licensing Examiner Standards,"
in a consistent
manner.
The
following are
some examples of the evaluator perceptiveness
and
objectivity during the simulator observations:
(1)
In one scenario
a reactor operator
(RO) misaligned the feed
and condensate
system during a recovery from a compounded
LOCA event.
The error was subtle, involving one manual
.
valve with no direct indication.
The facility evaluator
immediately perceived
the error and subsequently
the
operator
was appropriately
downgraded in his control board
competency.
Since this item was not a individual simulator,
critical task
(ISCT) and would not have led to an unsafe
condition, the oper'ator did not fail the evaluation.
(2)
During a scenario involving an anticipated transient without
(ATWS), one
RO was required to implement
a scram-
reset-scram
procedure to attempt to scram the control
rods.'oncurrently
with this evolution,-the
emergency operating
procedures
(EOPs) required that the
RO insert individual
rods using the normal control rod drive
(CRD) system.
When
the reactor level reached -50'n automatic rod insertion
(ARI) signal occurred which decreased
control rod drive
.water pressure.
The
RO appeared
to be unaware of the ARI
and
seemed to be confused
as to why he could no longer
manually insert. the control rods.
~"
The RO's evaluator followed up by asking several
probing
questions
about the system status
and the inability to drive
the rods.
During the evaluation process,
the instructor
appropriately
downgraded the
RO for his weakness
in system
knowledge
and event diagnosis.
The weakness
was'iscussed
in the post evaluation
caucus with the crew.
Because'his
was. not an
ISCT and would not have
made the accident worse,
the
RO did not fail the evaluation.
The inspectors
concluded that the five observed facility
evaluators
were sufficiently objective and probing to accurately
evaluate
the crews being tested.
f.
Evaluation Criti ue Process
The licensee. has developed
a new evaluation
process that was
developed
based
on feedback
from the operations staff, the
training staff, peer evaluators,
and the plant operators.
The
grading process for evaluation of scenario
performance
occurs in
four steps.
(I) An initial post-scenario
caucus of the evaluators
reviews the performance of the crew executing individual
simulator critical tasks
and formulates follow-up questions
for those operators that displayed performance
weaknesses
during the scenario.
(2) Follow-up questions
are administered individually by .the
evaluators
to determine
the basis of the operators'ctions
and to probe their knowledge.
(3) The evaluators
and the crew separately
grade the
individual crew members
and the crew using competency
check-
sheets similar to those
used in the Operator Licensing
Examiner Standards,
ES-604 "Requalification
Dynamic Simulator Examination."
(4)
A joint caucus of the evaluators
and the crew members is
held to compare
and contrast the findings of each group.
The inspectors
observed
the grading of two weekly evaluation
scenarios
and found the evaluations
to be accurate.
The
inspectors
also observed that the results of the evaluators
and.
the crews evaluated
wer e consistent.
(see
paragraph
3.c,
above)
9.
~Summa@
The inspection
team found that the operators
observed during the
training week performed well in the simulator and that the
facility evaluators
were able to objectively evaluate
and critique
operator performance.
The evaluation
and feedback
process of the
licensee's
training program appeared
to be satisfactory.
Trainin
Ins ecti on
41500
0 erator
and Instructor Interviews
Interviews with eight operators
revealed that they have
a high
level of satisfaction with the training they are currently
receiving.
The operators
stated that the level of the training
effort was appropriate
given the goals they have established
to
prepare for the upcoming requalification examinations.
They
stated that the complexity of the simulator scenarios
remained
high, but the crews felt that the scenarios
were more realistic
than those
used in the past.
6
The six licensee instructors interviewed noted that improvements
in scenario
timing allowed for more realistic malfunction response
times resulting in more realistic scenarios.
Each operator
inter viewed stated that the methods currently used for evaluating
simulator performance
were more effective then what had been
done
in the past.
The greatest
improvement
was attributed to the crew
self-evaluation
sessions.
The operators specifically mentioned
that identifying and discussing
performance
weaknesses
within the
crew-first, improved the sessions
with the evaluators
(when the
formal evaluation is given).
This method has reduced
the-need for
the evaluators
to list and discuss
in detail all the performance
errors
and allows the evaluation sessions
to focus
on areas
where
differences in perceived
performance exist.
This approach
has
also increased
the effectiveness
of the evaluation
sessions
by
keeping
them more focused
and making them less confrontational.
Trainin
De artment
Or anization
and Relationshi
with 0 erations
In addition to the refinement of the evaluation
and critique
process
discussed
in paragraph 3.f, several
additional actions
have
been
taken to improve the relationship
between training and
operations.
The plant o'perations
manager
has
been
moved to the training
department
as the supervisor of operations training.
An
operations liaison position has been established
in training and
was currently filled by a former. control
room supervisor
(CRS).
The operations liaison worked with the instructors to evaluate
operator
performance in the simulator.
He also provided an
operations
management
perspective
in assuring consistent
incorporation of management
expectations.
Solutions to identified program deficiencies
were "fed back" into
the system through training curriculum modifications, procedural
changes,
or both; depending
on the appropriate resolution
determined
by the operations
manager.
All interviewed operators
indicated that they thought'his
process
worked,
and felt that
their role was important.
The organizational
changes
appeared
to have significantly
increased
the credibility of the training staff with the
operators.
At the end of the training week, the operators
were
.
given the opportunity to evaluate
the performance of the
instructors.
The inspectors
observed that this process of
operator
feedback
was improving the communications
between
the
operations staff members
and the training staff.
The inspectors
reviewed the training used to prepare
the
instructors for evaluation of operator technical
performance
in
the simulator (including discussions
on management
expectations)
and found this training to be adequate.
In addition to meeting
the requirements
of the licensee's
in'structor training program,
l
'
7
evaluator s parti ci pated in a week
of preparati on prior to the
start of each requal cycle.
During the p'reparation
week, the
simulator
scenarios
for that cycle were conducted with the
instructors in the role of the operators.
The instructors
validated the effectiveness
of the scenario in achieving the
.identified training objectives for the week and ensure their own
'nderstanding
of the various operator actions required.
The inspectors
concluded that the licensee
evaluation
team
observed evaluating the operators
in the simulator was performing
satisfactorily.
However,
two issues
involving evaluator
qualification should
be addressed,
by the licensee to ensure
consistent
operator
evaluations
in the future.
(I)
-The licensee staff assigned
to evaluate
operator
performance in the 'simulator met the instructor
qualification requirements
and participated in the
preparation
week activities.
However, the inspectors
found
no procedural
requirement for the operations liaison staff
person to be qualified as
a simulator instructor.
This
practice
appeared
inconsistent with the standards
of the
other evaluators.
(2) It appeared that the licensee
had not established
a
program to retrain initial license training instructors with
the
new simulator performance
standards.
This could result
in different evaluation
standards
between initial operator
training and requalification training.
The licensee
acknowledged
these
two issues
and stated that they
would evaluate corrective actions for them.
Trainin
Pro
ram
The inspectors
interviewed two STAs and observed their performance
during the requalification training week for the shift and staff
crews discussed
in paragraph
3.c.
Both STAs stated that they were
satisfied with the training program.
They said that the program
has
a specialized training segment for the entire
STA staff,
as
well as
STA integration into..the'equalification
week with
operating
cr ews.
This plan allows the
STAs to receive specialized
training,
such
as would be required for a nuclear engineer,
while
exposing the
STAs to different crews during the training weeks.
The
STA training program was
a rotational training program
centered
on a
STA specific training schedule
and the operator
requalification simulator training cycle.
The inspectors
found that the two STAs observed'n
the simulator
supported their assigned
crews well.
Their performance
was
consistent.
The operators
had high regard for their
STAs'bilities
and opinions.
The lead
STA evaluated
the
performance
during the simulator scenarios.
The one-on-one
coaching of the senior
STA trainer/evaluator
appeared particularly
effective for training.
Trainin
De artment Staffin
Operator requalification training is currently being handled
by a
staff of eleven,
which includes six contractors.
Contractors
have
been
used
as
a result of four open instructor positions.
A site-
wide effort is under way.to reduce
the number of- contractor
workers.
Current plans call for filling the open training
positions
by December
1992.
However, the licensee
stated that
they plan to keep the contractors
on staff to allow time for
training and orientation of new training staff.
This is intended
to ensure consistent
evaluation of operators
during the
transition.
The inspectors
concluded this plan appeared
acceptable.
0 erator Overtime
The team evaluated
the use of overtime for operator training.
Early in 1992, validation of EOP revisions
was completed
by
operators
on overtime.
Overtime was scheduled for and limited to
the validation effort.
During the last several
months,
the
operators
have
been working three
days of overtime {approximately
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per day) during their training week to get additional
training on the simulator prior to the November requalification
examination.
The licensee
explained that after a program review earlier in the
year,
both operators
and management
had agreed to increase
and
revise the requal cycle content.
The revised content
was designed
to ensure that the operators
would be involved with an adequate
number of appropriately
complex simulator scenarios
addressing
a
variety of specific competencies.
This required additional
simulator time.
Eight operators
were interviewed to determine their view of using
overtime for training.
All of the interviewed operators
agreed
with the licensee's
strategy to prepare for the upcoming
examinations.
Several
operators
stated that the training week was
tiring.
The current level of overtime combined with the knowledge
that the training program status will be determined
based
on the
November
exam results
appeared
to contribute to the pressure
being
experienced
by the operators.
The licensee
has stated that the
1993 requalification training schedule will not require using
routine overtime to meet anticipated training needs.
The
1 i censee
'
Techni cal
Speci ficati ons
(TS) state that adequate
shift coverage shall
be maintained without routine heavy use of
overtime.
However, the
TS allow substantial
overtime use in the
event of "unforseen
problems."
Even so, the following guidelines
still apply: (I) an individual should not work more than
16
consecutive
hours,
(2)
an individual should not work more than
16
hours in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period,
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, or 72
hours in any 7-day period,
(3) a break of at least
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should
be allowed between
work periods,
and (4) except during extended
shutdown periods,
the use of overtime should
be considered
on an
individual basis
and not for the entire crew.
The plant manager
must authorize
any deviations
from these guidelines.
The inspectors
determined that the licensee
had not violated
Technical Specification overtime guidelines.
The inspectors
also
concluded that the use of operator overtime for the simulator
appeared
appropriate.
Industr
Events Trainin
The inspectors
reviewed the lesson
plans
and scenarios
used for
industry events training for three recent industry events:
(I)
the core instability event at MNP-2, (2) the loss of annunciators
and
RPV level instrumentation at Nine Nile Point-2,
and (3) the
refueling cavity seal failure at Connecticut
Yankee.
The
'nspectors
then developed test questions
from this material
and
verbally interviewed six operators
to .determine their
understanding
of the lessons
learned
from these
events.
All but
one of the operators
adequately
answered
the questions.
One senior operator could not recall all of the immediate actions
required
when moving irradiated fuel and reactor cavity inventory
began to visibly decrease.
The expected
responses
included:
(a)
notify the control
room supervisor
(CRS),
(b) move irradiated fuel
in transit back into the nearest
storage location,
and (c)
evacuate
the refueling floor.
The senior operator said that he
would try to stop the inventory loss but gave
no indication that
he would contact the
CRS.
He did not recall
any other immediate
actions without prompting from the inspectors.
During subsequent
follow-up, the inspectors
determined that the licensee
had no
formal method for assessing
operator retention of event lessons
,
learned
between
the 'time of the initial event debrief and the
implementation of appropriate
changes into the training programs.
The inspectors
observed that the recent
NRC augmented
inspection
team
(AIT) also found that operators
had poor recall of previous
training dealing with reactor
power oscillations.
Based
on this
AIT finding and the deficiency outlined above,
the inspectors
concluded that the licensee
may not be adequately
assessing
the
effectiveness
of industry events
lessons
learned training
conducted for their operators.
10
The licensee
acknowledged
the concern
and agreed to reassess
their
events training process.
5.
Summar
of 0 en Issues
The inspectors identified three areas of potential training program
weakness.
The licensee
acknowledged
these
concerns
and stated
they
would consider corrective actions for them.
~
The operations liaison staff person
was not certified as
a
training evaluator,
even though
he conducted training evaluations.
~
There
was
no process
to transfer the lessons
learned
and
. improvements
made in the operator requalification simulato'r
evaluation
process
to the initial operator
program.
~
The licensee
did not adequately
evaluate
the operators for
retention of lessons
learned
from industry events.
No .deviations or violations were identified.
Exit Meetin
30702
n
An exit meeting
was held by the
NRC with representatives
of the
licensee's staff on September
25,
1992 to discuss
the
NRC inspection
results identified above.
The inspectors.requested
a response
to the
three areas of concern identified above.
The inspectors
stated that the
response
should contain
a plan for corrective actions, if appropriate,
and the projected date
by which the licensee
expects to complete those
corrective
actions.
The licensee
acknowledged
the inspectors'oncerns,
and agreed to
respond
as requested.