ML20057D682
| ML20057D682 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/28/1993 |
| From: | Bielby M, Doornbos R, Jordan M, Mcneil D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057D678 | List: |
| References | |
| 50-461-93-14, NUDOCS 9310050175 | |
| Download: ML20057D682 (7) | |
See also: IR 05000461/1993014
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-461/93014(DRS)
Docket No. 50-461
License No. NPF-62
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Licensee:
Illinois Power Company
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Mail Code V-275
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Post Office Box 678
Clinton, IL 61727
Facility Name: Clinton Power Station
. Inspection At: Clinton Power Station
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Clinton, Illinois
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Inspection Condu,cted: , July 12 - 16, and September 2 - 3, 1993
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Inspectors:
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Operator Licensing Section 1
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Inspection Summarv
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Inspection on July 12 - 16. and September 2 - 3. 1993 (Report No. 50-
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461/93014(DRS)).
A eas Inspected:
Special, announced inspection of tne licenscd operator
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requalification program to include a review of training administrative
procedures, requalification training records and operating examination
material; observation and evaluation of operator performance, and of licensee
evaluators during requalification operating examination administration; an
evaluation of the program controls to assure a systems approach to training,
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remediation training administered; and an assessment of simulator fidelity.
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The inspectors used the guidance in Temporary Instruction (TI)~ 2515/117.
Medical records of twenty licensed operators were also reviewed to verify the
duration between medical examinations was in accordance with NRC requirements.
Results: The inspectors concluded that the licensee was implementing the
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licensed operator requalification training program in accordance with 10 CFR Part 55 requirements and that operations and training management involvement
with the process was a strength. Houever, two open items regarding training
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administrative procedures were . identified (461/93014-01 and 461/93014-02
(DRS)) (Section 2.1.1).
The controls that have been implemented to prevent
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licensed individuals from exceeding medical examination due dates appear to
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have been effective (Section 2.7).
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REPORT DETAILS
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1.0
Persons Contacted
Illinois Power Company
+J. Perry, Senior Vice President
-+D. Antonelli, Director, Operations Training
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+R. Derbort, Administrator, Medical Programs
+R. Langley, Director, NSED
+J. Owens, Supervisor, Operations Training
+J. Palchak,-Manager, Nuclear Support Services
+M. Reandeau, Licensing Specialist
+D. Thompson, Manager, NTD
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+R. Wyatt, Manager, Nuclear Assessment
+ Denotes those present at the plant management exit meeting on September 3,
1993.
Other persons were contacted as a matter of course during the inspection.
2.0
Introduction
The purpose of this inspection was to assess the licensee's requalification
program for licensed operators in order to determine whether the program
incorporated 10 CFR Part 55 requirements for evaluating operator mastery of
training objectives and revising the program.
The licensed operator
requalification program assessment included a review of training
administrative procedures, requalification training records, and operating
examination material. The 1 ispectors conducted an evaluation of operator
performance and the ability of licensee evaluators to administer and
objectively evaluate during requalification operating examinations.
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addition, an evaluation of the effectiveness of the program controls to assure
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a systems approach to training and remediation training was conducted.
Further, the inspectors assessed simulator fidelity.
2.1
Licensed coerator Recualification Proaram Assessment
2.1.1
Proaram Administration
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The inspectors concluded that the licensee was implementing the licensed
operator requalification training program in accordance with the licensee's
administrative procedures. The inspectors identified the following strengths
regarding requalification program administration:
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Plant, operations and training management observed crew evaluations
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during dynamic simulator examinations as verified by inspector
observation and interviews with plant personnel.
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P.lant, opetttions and training management actively participated in crew
evaluations during dynamic simulator examinations as verified by
inspector observation and interviews with plant personnel,
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Attendance at requalification training has an appropriately high
priority.
During the inspectors' review of training administrative procedure,
" Operations Continuing Training Program Description," OPS /TPD, Rev. O, the
following concerns were identified:
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A.
OPS /TPD, Rev. O,Section IV, Step 2.4.2.2 requires a minimum of
one simulator scenario be administered to licensed individuals
during annual requalification evaluation examinations.
The inspectors reviewed training cycle records (93.1 - 93.3) and
determined that six licensed individuals, one senior reactor
operator (SRO) and five reactor operators (R0s), only participated
in one annual requalification examination scenario for the purpose
of evaluation.
NUREG 1021, Operator Licensing Examiner Standards, Revision 7,
Section ES-604, Part B states that the dynamic simulator test will
consist of two scenarios. NUREG 1021 does not currently specify
that two scenarios be administered to each licensed individual on
a crew. This item is currently being reviewed by the NRC.
In the
interim, any NRC conducted requalification examinations will-
administer two scenarios to all licensed individuals.
Pending
further review by the NRC, this item is considered open
(461/93014-01 (DRS)).
B.
OPS /TPD, Rev. O,Section II, subsection 4.2.4 does not
specifically state that each RO shall manipulate the plant
controls and each SR0 either manipulate the controls or direct the
activities of individuals during plant control manipulations.
Step 4.2.4.3 requires a form to be utilized to document completion
of reactivity or plant evolution manipulations performed either in
the plant, or on the simulator. The form contains instructions
that require it to be completed by the individual who performed
the manipulation and by the authorizing Shift / Assistant Supervisor
or simulator instructor. Discussions with the training department
revealed that, although not specifically stated in OPS /TPD
procedure, past practice has been to give credit for reactivity or
plant evolution manipulations to the whole crew vice the
individual who directly performed or directed the manipulation.
10 CFR 55.59.c.3.1 requires, in part, that each licensed operator
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of a utilization facility manipulates the plant controls and each
licensed senior operator either manipulates the controls or
directs the activities of individuals during plant control
manipulations for items described in paragraphs c.3.i(A-L) on an
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annual basis and all other items on a two-year cycle.
10 CFR 50.54.1-1 states, in part, that the licensee shall have in effect
an operator requalification program which must, as a minimum, meet
the requirements of 55.59(c).
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The licensee reference 10 CFR 55.59.c, which states, in part, that
in lieu of paragraphs c(2), (3), and (4) of this section, the
commission may approve a program developed by using a systems
approach to training (SAT). The licensee stated their SAT program
incorporated Clinton Power Station Update Safety Analysis Report
(CPS-UFSAR),Section 13.2.2.1.3.B, and American National Standard
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Institute ANSI /ANS-3.1-1978, Section 5.5.1.2.1, guidelines, which
state, in part, that each licensed individual shall perform or
participate in a combination of reactivity control manipulations
and that SR0 licenses will be credited with these activities if
they direct or evaluate the control manipulations as they are
performed.
The licensee further stated that their requalification
training program was SAT based, INP0 accredited, and had a plant
specific certified simulator. Therefore, the program was in
accordance with 10 CFR 55.59.c requirements. Nuclear Regulatory
Commission policy, as stated in the March 20, 1985 Federal
Register, (53 FR 11147) and as amended on November 11, 1988 (53 FR 46603), endorses INP0 accredited programs.
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The records reviewed by the inspectors indicated that all licensed
operators had been given credit for all required plant control
manipulations. However, the inspectors could not conclude from
the records reviewed that all licensed R0s manipulated the
controls and that all licensed SR0s either manipulated the
controls or directed the activities of the individuals during the
plant control manipulations. All individuals on a particular crew
are given credit for all plant control manipulations performed
during each simulator training session they attend by virtue of
being a member of the crew.
The inspectors concluded that generally the licensee's program was
in accordance with 10 CFR 55.59 requirements, however, the
licensee is requested to provide a written response indicating
what actions are taken by their requalification program to ensure
licensed operators can perform plant control manipulations in lieu
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of actual performance.
Pending further review by the NRC, this
item is considered open (461/93014-02(DRS)).
2.1.2
Reaualification Trainina Records Review
The inspectors reviewed requalification training attendance records for
previous training cycles, 1992 cycles 1 through 5 (92.1 - 92.5), and 1993
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cycles-1 through 3 (93.1 - 93.3), and concluded that licensed operators had
attended or made up all scheduled requalification training as required by
their program.
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2.1.3
Reaualification Examination Material Review
The inspectors reviewed the Job Performance Measure (JPM) examinations
administered during the week of July 12, 1993, and compared them with the
examinations administered during other weeks in the exam cycle. The
inspectors also reviewed the dynamic simulator examinations administered
September 2-3, 1993, and compared them with the examinations administered
other weeks in the exam cycle. .The inspectors concluded that the examinations
were adequate.
The inspectors noted that adequate overlap existed for the JPM
and dynamic simulator examinations for the duration of the exam cycle.
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The inspectors made the following observations regarding the examination
material:
TI 2515/117, is based on NUREG 1021, " Operator Licensing Examiner
Standards," Revision 7.
The licensee's examination was
administered under NUREG 1021, Revision 7, guidelines, and the
JPMs and dynamic simulator scenario examinations reviewed were in
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accordance with those guidelines.
Licensee representatives stated
that the remaining requalification material in their examination
banks was being revised to meet NUREG 1021, Revision 7,
guidelines.
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The in-plant JPMs reviewed used appropriate cues, such as valve
position indication, or (for faulted JPMs), the valve handle would
not turn.
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The JPMs reviewed were of good quality. The critical steps were
appropriate and correctly identified. Alternate event path JPMs
were used.
Dynamic scenarios were written such that no discernable pattern
was evident and the operators could not predict the sequence of
events.
2.2
Operator Performance Evaluation
The inspectors evaluated the operators' performance on the dynamic simulator
and JPM examinations. The inspectors concluded that operator performance on
the requalification operating examinations was satisfactory.
2.3
Evaluation of Licensee Evaluators
The NRC inspectors and the licensee evaluators overall assessment of operator
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performance was in agreement. The inspectors concluded that the licensee
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evaluators could adequately administer the requalification examinations and
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objectively evaluate the performance of the operators.
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2.4
System Acoroach to Trainina Controls
The inspectors concluded that the licensee's program had' controls in place to
revise the training program as needed based on industry events (LERs), system
and procedure modifications, and student feedback. However, interviews with
plant personnel indicated there was no formalized direct feedback to students
who make suggestions or comments regarding the training program.
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The inspectors reviewed training material regarding an industry concern
involving the inaccuracies of BWR Reactor Pressure Vessel (RPV) level
indication under low pressure conditions. Training was considered to be
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adequate and timely.
Requalification material had been revised to reflect
this event.
The inspectors identified that Clinton LERs,92-001, 92-003,92-005, 92-006
and 92-008 were discussed or planned for requalification training as part of-
classroom training in 1993.
The inspectors also reviewed the process for students to provide feedback to
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the training program. 'A " Student Feedback" form can be filled out by
individuals to express any concerns or suggestions regarding the training
program. These forms are routinely reviewed by the training staff and any
suggestions are incorporated into the program as appropriate.
However,
interviews with plant personnel indicated there was no formalized direct
feedback to individuals who submit the student feedback forms.
Additionally, the inspectors reviewed the previous QA licensee audit report
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(Q38-93-08) of licensed operator requalification training, and interviewed
training staff to verify that appropriate comments had been incorporated into
the training program. The audit appeared to use performance based techniques
including audit of ongoing training by the auditors. The inspectors concluded
that appropriate comments from the audit had been incorporated into the
licensee's requalification training program.
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2.5
Remediation Trainino
During the inspection week, two individuals were administered remediation
training due to individual failures on their respective dynamic simulator
requalification examinations given during the previous week. The inspectors
compared the remediation training conducted with the identified weaknesses for
the individuals, and with the program requirements identified in OPS /NTD, Rev.
O, Section 2.4.3.
The inspectors concluded that the remediation training was
administered in accordance with program requirements and adequately addressed
the identified crew weaknesses. The individuals didn't demonstrate previously
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identified weaknesses; they passed their respective dynamic simulator r'etake-
examinations.
2.6
Personnel Interviews
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The inspectors conducted nine interviews with a cross section of management
and staff from both operations and requalification training groups.
Results
indicated: plant, training and operations management periodically observed and
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participated in requalification evaluations of licensed personnel in dynamic
simulator scenarios; operations management exhibited ownership of the
requalification training program; training management and staff were
responsive to operations requests; there was no formalized direct feedback to
students who make suggestions or comments regarding the training program.
2.7
Simulator Fidelity
The inspectors concluded that simulator fidelity was satisfactory.
No
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weaknesses were identified.
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2.8
Observations from Medical Proaram Review
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The NRC inspectors reviewed twenty licensed operator medical records at random
to verify the duration between medical examinations was in accordance with NRC
requirements. None of the licensed operator medical examinations were
identified as overdue. The NRC inspectors concluded that installation of a
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computer tracking system and notification of individuals two months in advance
has significantly reduced the likelihood of exceeding the due date for medical
examinations.
3.0
Open items
Open items are matters which have been discussed with the licensee, which will
be reviewed further by the inspector, and which involve some action on the
part of the NRC, the licensee, or both. The two open items disclosed during
the inspection are discussed in Section 2.1.1.
4.0
Exit Meetina
The inspectors conducted exit meetings on September 3,1993, with plant
management, and on July 16, 1993, wi}hthetrainingstaffattheClinton
Nuclear Plant to discuss the major areas reviewed during the inspection, the
strengths and weaknesses observed, and the inspection results.
Licensee
representatives in attendance at the exit meetings are documented in
Section 1.0 of this report. The team al < discussed the likely informational
content of the inspection report with r ,ard to documents reviewed by the
inspectors during the inspection. The .icensee did not identify any documents
or processes as proprietary.
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