ML18101A767
| ML18101A767 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/31/1995 |
| From: | Bissett P, Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18101A766 | List: |
| References | |
| 50-272-95-08, 50-272-95-8, 50-311-95-08, 50-311-95-8, NUDOCS 9506120513 | |
| Download: ML18101A767 (9) | |
See also: IR 05000272/1995008
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
DOCKET/REPORT NOS:
LICENSEE:
FACILITY:
DATES:
INSPECTORS:
INSPECTOR:
50-272/95-08
50-311/95-08
Public Service Electric and Gas Company (PSE&G)
Hancocks Bridge, New Jersey
Salem Nuclear Generating Station, Units 1 & 2
April 10 - 19, 1995
P. Bissett, Senior Operations Engineer/Examiner
S. Barr, Operations Engineer/Examiner
Paul Bissett, Sr. Operations Engineer
<1"74/)--
~'
APPROVED BY:
Division@tor Safety ~
~er, Ch
9506120513 950602
ADOCK 05000272
Q
Division of Reactor Safety
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EXECUTIVE SUMMARY
From April 10 - 19, 1995, the NRC performed an inspection of the Salem Nuclear
Generating Station, Units 1 and 2 licensed operator requalification training
program.
Operations
The inspectors reviewed the licensed operator requalification program and the
conduct of the annual operating examinations and concluded that these
activities were effective in ensuring the continued safe operation of the two
units.
The requalification program was determined to be based on the
systematic approach. to training method.
Requalification examinations were
found to be effective, and no serious deficiencies involving the content of
the examination were identified.
The inspectors determined that excellent .
evaluations were performed on individual and crew performances following the
conduct of their annual operating examinations.
Significant improvements from past observations were noted in crew manning,
crew communications and supervisory oversight of abnormal and emergency
conditions during the conduct of the simulator examinations.
Further, PSE&G
had effectively corrected weaknesses in remedial training and JPM
administration noted during previous inspections. Also, PSE&G management has
explicitly stated their expectations for operator performance, and have
subsequently terminated several operator licenses for poor operations or
training performance.
Some weaknesses were identified during the review of the administration of the
examination and program re~iew. These weaknesses included inadequate cues for
simulated JPMs, repetition of simulator scenario component failures, the
quality of self assessments, NRC notification of medical condition changes for
licensed operators, for which a NCV was identified, and the disparity between
the security agreement for annual examinations and the actual practice.
In
this last instance, the inspectors did not identify any compromise of
examination security .
i i
DETAILS
1.0
INSPECTION SCOPE AND OBJECTIVES
An announced inspection of Salem operations training and requalification
program was conducted from April 10 - 19, 1995.
The scope of the inspection
included review and observation of operations training, including
administration of the annual operating examination, required by 10 CFR 55.53.
The inspection objectives included verification that the requalification
program administered to Salem operators adequately evaluated how well the*
individual operators have mastered training and performance objectives.
The
inspection included an assessment of Public Service Electric and Gas'(PSE&G)
effectiveness in en_suri ng that i ndi vi duals licensed to operate the Sal em
facility had satisfied the license requirements of 10 CFR 55.53.
2.0
INSPECTION RESULTS
The inspectors reviewed the annual licensed operator requalification
examination, and observed its administration to a number of operating crews
and individuals. Overall, all parts of the examination were determined to be
appropriate, with good sampling, proper administration, and excellent
evaluation.
2.1
Written Examination
The inspectors did not identify any deficiencies during the review and
observation of the written classroom and static simulator portions of the 1995
requalification examination.* Each portion of the written examination was
administered properly; however, a couple of examination answers were later
changed upon further review by PSE&G.
All operators passed both parts of the
written examination.
2.2
Simulator Examination
The performance standards and evaluation of the dynamic simulator examination
were determined to be effective in discriminating between safe and unsafe
operations. All individuals evaluated were examined in at least two different
scenarios and satisfactorily passed all facility requirements.
Crew
performance was also deemed satisfactory in all instances by the facility
evaluators.
The NRC inspectors were in agreement with the facility
evaluators' results.
Facility evaluations were excellent, in that they were
very detailed and comprehensive in all facets of the examination.
Significant improvements were noted by the inspectors in regard to how the
facility has trained and examined licensed operators compared to previous
requalification inspections and examinations.
In an ongoing effort to
increase the number of personnel assigned to each unit, a crew now consists of
a third reactor operator (RO).
This RO is normally assigned to the work
control center which is located adjacent to the Unit 1 and 2 control rooms.
During abnormal or emergency conditions, this RO reports to one of the two
control rooms to assist the crew with control board manipulations.
Also,
there is now more active participation and supervisory oversight by the senior
shift supervisor.
He is now expected to report to the control room as soon as
an abnormal or emergency condition arises. Another change, involving more
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senior reactor operator (SRO) control and oversight, included the nuclear
shift supervisor relieving the desk RO once he has completed the immediate
action steps of E-0.
Significant improvement was noted on communications when
compared with previous inspections and examinations, and during crew
debriefings, the inspectors noted that management expectations included
continued emphasis on improvement in this area.
The inspectors identifiPrl a few concerns on the quality of the scenarios.
The
inspectors noted that in one scenario set, two scenarios started off with the
same component malfunction, an unnecessary repetition. It was also determined
that .one scenario given on one day was also administered to a different crew
on the following day.
The training personnel stated that this was an
oversight on their part and for future examinations, they will stress the
quality of independent reviews.
The inspector agreed that emphasis on the
quality of independent review was an appropriate corrective action.
2.3
Job Performance Measures (JPMs)
The inspectors reviewed selected job performance measures, observed conduct of
the JPM evaluations, and reviewed completed evaluations of performance.
The inspectors concluded that weaknesses in job performance measures
administration, identified in a previous requalification inspection, had been
corrected, and no repeat deficiencies were identified.
Some of the weaknesses
specifically corrected included consistency in administration and
documentation by the evaluators, use of correct procedures and procedure
revisions by the operators, and appropriate preparation for examination
administration by the evaluators.
None of these previously-identified
deficiencies were observed during this inspection.
However, the inspectors did identify a problem with cues during the simulated
in-plant JPMs.
For the two JPMs observed, it was evident that the evaluators
did not provide sufficient cues or feedback of equipment responses to the
operators as they simulated actions during performance of these JPMs.
Some
licensed operators asked for feedback from the evaluators following a
manipulative action, whereas others progressed through the JPM so quickly,
that it would have been impossible to provide a cue, if warranted. A review
of the structured JPMs indicated in many instances, JPM cues were not provided
within the written JPM and therefore, the evaluators often had to ad lib, if
the operators asked for a cue.
The inspectors discussed this weakness with
training personnel and stressed the importance of predetermined JPM cues for
those simulated in the plant or simulator. Training department personnel
agreed with the inspectors that more effort was needed in the area of JPM
cues, both in the area of written documentation and in stressing to the
operators that they should expect cues and feedback for all manipulative
actions.
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2.4
Operator Interviews
Interviews were conducted with many of the licensed operators,as well as a
number of training instructors and supervisors.
The results of these
interviews are summarized below:
The training department has provided feedback to the operators in regard
to the results of their performance immediately following completion of
the annual examination and this was viewed by operators as a positive
change.
In the past, a formal exam review was not performed until the
operators returned back to training, which in most instances was several
weeks later.
Management expectations of licensed operator performance, both in
training and plant operation, have been explicitly conveyed.
Both
licensed operators and management stated that poor performance would not
be tolerated.
2.5
Review of remedial training
The inspectors reviewed facility remediation used in response to performance
deficiencies by individual operators, and found the overall program to be
appropriate .
From past requalification inspections, licensed operator performance on
training cycle quizzes and remedial action for poor quiz performance was not
always effective in ensuring satisfactory performance on the annual
requalification examination.
Facility management had acknowledged that
consistent weak performance on training quizzes was unacceptable to them and
stated an intention to review remediation activities for poor quiz
performance.
Followup review of this area indicated that management had
reviewed this area and subsequently cautioned many of the licensed operators
as to the importance of performance excellence, both in the plant and in the
classroom.
In a few instances, operators failed to met the standards set by
management and their licenses were subsequently terminated by the facility.
As a result of the reactor trip with multiple safety injection event of
April 7, 1994, PSE&G management made an internal commitment to identify
historically marginal performers and develop long-term performance improvement
plans.
The inspectors reviewed operator performance in written exams and in
simulator scenario exams over the last year of the requalification training
cycle.
The results showed that 11 operators had failed one or more parts of
their exam.
The inspector reviewed the remedial actions taken by the training
staff with those operators and determined that the operators had been provided
proper additional instruction and re-testing.
The inspectors also concluded
that PSE&G had raised their standard of acceptable performance relative to
marginal performers, in that over the past requalification cycle, eight
licensed operators had been removed from licensed duties as a result of
repeated marginal performance .
. .
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3.0
MANAGEMENT OVERSIGHT AND INVOLVEMENT
Station management involvement in the requalification training program was
evident.
Station operations management has actively participated in the Salem
Operations Licensed Operator Training Review Group along with members of the
PSE&G nuclear training staff.
The inspector reviewed the minutes of the last
several review group quarterly meetings and noted good input from station
management and aggressive followup to commitments made by the Review Group.
The station operations management observed operator training during the first
and fourth day of each training segment, which always included an evaluation
of simulator sessions. Operations management also spent almost the entire day
at the training center when they attended these training sessions.
Also, they
evaluated crew performance in the simulator portion of the annual operating
test during the week in which the NRC witnessed licensed operator annual
examinations.
Weak performance of licensed operators on training quizzes had been routinely
reported to operations management by the training department.
As inspected
previously, both training and operations managers stated an intention to
develop better coordination of training and operator performance, thus raising
the threshold of management expectations regarcing operator performance.
The
more active involvement of station management in the requalificatitin training
program, as cited above, indicated that PSE&G management has indeed followed
through with informing licensed operators of their expectations.
Weak
performance, during both plant operations and training, has been seriously
addressed and evaluated on a continuing basis by training and operations
management.
In a number of documented instances, operator licenses were
terminated as a result of poor operator performance or failing to meet
management expectations.
As an additional measure of management oversight, the inspectors reviewed
PSE&G's self-assessments of the requalification training program.
The PSE&G
nuclear training department performed program reviews at three year intervals
to satisfy the self-assessment requirements of Training Procedure
SH.TO-TC.ZZ-0305(Z), "NRC Licensed Operator Requalification Program."
The
inspectors reviewed the latest review of the Salem licensed operator program,
which had been performed by PSE&G in October 1994, and determined the review
had been very administrative in nature and had not assessed the quality of the
requalification program on a performance-based level.
In contrast, the
inspectors' review of an audit of the nuclear training program performed by
PSE&G Quality Assurance in February 1995, revealed that the QA audit provided
a more performance-based assessment of the training program performance.
The
QA assessment of the training program was primarily based on measures of
actual operator performance rather than on the administrative quality of the
program.
After being informed of the inspectors' observations, training
department management informed the inspector of their plans to improve the
quality of department self-assessments, including the use of performance
indicators to assess the quality of training.
The inspector determined that
PSE&G had acknowledged the weaknesses of the previous self-assessments and had
begun to implement plans to improve the self-assessment process.
..
f<
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4.0
PROGRAM ADMINISTRATIVE REVIEW
The inspectors determined that the Salem requalification training program was
in conformance with the systematic approach to training (SAT) methodology.
Learning objectives and training were in conformance with a completed job task
analysis, and appropriate feedback systems were in place to evaluate training
effectiveness.
However, there were two instances in which the facility failed to adequately
meet their own internal standards or regulatory requirements.
In one
instance, instructional activities were conducted which were not in
conformance with signed examination security agreements, and in another
instance, the NRC was not notified of a change to an operator's license
conditions within the appropriate time frame.
During the inspectors' review of the facility's examination security measures,
it was determined that a practice existed that appeared to possibly compromise
the integrity of the examination. This practice involved an individual
signing a security agreement and then providing training or instruction to
licensed operators prior to the administration of the annual examination.
In
an effort to ensure the validity of an examination to be administered, the
training department has validated all segments of the examination prior to its
implementation.
Anyone invrilved in the examination development or validation
process has signed onto a security agreement which states that any information
or knowledge of the examination will not be divulged to any other individual
until completion of the examination.
It also states that he is prohibited
from providing any instruction, until the examination is completed.
The form
used was Form ES-601-1 from the NRC Examiner Standards, which did not fully
apply nor was it required in this instance by either NRC regulations or the
PSE&G requalification program specifications.
The form's use had been
established during previous NRC-administered requalification exams, and
apparently, the practice had continued.
However, during the review of this
area, it was determined that one individual had signed the security agreement,
but subsequently conducted simulator training sessions.
The inspectors performed a thorough review of this area to substantiate the
validity of the examination that they had just witnessed.
They determined
that there was no evidence or likelihood that the examination was compromised
and based this conclusion on the following results of this review.
The simulator instructor was given a total of seven test scenarios to
validate, of which only four would be administered during the
examination.
He did not become aware of which ones were to be on the
annual examination until all instruction had been completed.
Pre-written simulator training scenarios were different from pre-written
examination simulator scenarios.
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Separate discussions were held with the simulator instructor and his
immediate supervisor to ascertain why he was permitted to continue
instruction, even though signing the security agreement precluded him
from doing so.
Both individuals stated that they were aware that
instruction would be necessary after the exam validation due to the few
simulator instructors available.
Further, both individuals stated that
the simulator instructor was given explicit instructions to stay within
the bounds of the pre-written lesson plan.
He had been informed that
should questions arise that were outside the bounds of the lesson plan,
the questions and subsequent answers were to be provided by the other
simulator instructor who was assisting him.
This individual had not
been involved in the development of the examination and thus had not
signed onto the security agreement.
The inspectors held a general discussion with approximately half the
operators who were examined.
The operators were asked if the training
department overtly or covertly taught material immediately before the
exam that was on the exam.
The overwhelming response was that, if
anything, the opposite was true.
No one identified examples of the exam
material being taught.
Only one individual had complete knowledge of the examination's content.
He was totally responsible fpr examination development and was not
involved in any instruction during this time frame.
A previous NRC inspection finding involved the fact that security
measures were so stringent that it had an adverse affect on the
administration of the exam.
In this instance, evaluators were not told
of or given the JPMs that were to be administered until the actual day
of the examination; thus they were not given the opportunity to walk the
JPM down or little if any time to review the task.
The inspectors observed the conduct of all scenarios, and in no instance
was it evident that the operators had any knowledge of any planned
malfunctions or major evolutions.
The inspectors held discussions with training supervision in regard to the
statement on the security agreement and the implications involved should they
continue this practice. Training supervision stated their conclusion that the
security agreement statement needed to be changed to accommodate the manner in
which they have conducted training and developed examinations.
Overall, the inspectors concluded that the instance of the instructor having
trained after signing a security agreement, which prohibited such training,
represented an inappropriate use of an NRC security agreement form, and
insensitivity on the part of the instructor and his management to signing an
agreement with which they knew they did not intend to fully comply.
The inspectors performed a review of the medical certification records for
eleven licensed operators at the Salem Station.
The record review indicated
that PSE&G had performed medical examinations in accordance with the
guidelines set forth in ANSI/ANS 3.4, "Medical Certification and Monitoring of
7
Personnel Requiring Operator Licenses for Nuclear Power Plants." However,
during this review, the inspectors also determined that PSE&G had failed to
notify the NRC within 30 days, as required by 10 CFR 50.74(c), of changes to
the license conditions for one licensed operator. This licensed operator
previously had no medical restrictions in regard to his license conditions. A
review of his most recent medical examination, dated February 21, 1995,
revealed that he now needed corrective lenses; however, the NRC had not been
notified to date of this change to his medical fitness.
Further review of his
medical records indicated that the need for corrective lenses was first
identified during an examination performed on March 15, 1994.
PSE&G
immediately initiated efforts to update NRC Form 396 "Certification of Medical
Examination by Facility Licensee," including the recommendation that his
operator's license be conditioned designating that corrective lenses were to
be worn when performing licensed duties.
The inspectors considered the
facility's corrective actions to be prompt and appropriate, and determined
that this was an isolated instance and was of minor safety significance.
Therefore, per section VII.B of the enforcement policy, enforcement discretion
would be exercised and no violation would be issued.
5.0
EXIT MEETING
An exit meeting was held at the conclusion of the inspection with PSE&G
representatives on April 19, 1995.
PSE&G representatives acknowledged the NRC
findings and conclusions. A listing of exit meeting attendees is provided
below:
Public Service Electric and Gas. Salem 1 and 2
L. Catalfamo
G. Mecchi
A. Orticelli
Salem Operations Manager
Principal Trainer
Nuclear Training Manager
U.S. Nuclear Regulatory Commission
P. Bissett
S. Barr
Sr. Operations Engineer/Examiner
Operations Engineer/Examiner