ML20057G044
| ML20057G044 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/13/1993 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20057G045 | List: |
| References | |
| RTR-NUREG-1021 NUDOCS 9310200121 | |
| Download: ML20057G044 (5) | |
See also: IR 05000382/1993021
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UNITED ST ATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA ORIVE, SUITE 400
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ARLINGTON, TEXAS 76011-8064
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OCT I 31933
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Docket:
50-382
License: NPF-38
Entergy Operations, Inc.
ATTN:
Ross P. Barkhurst, Vice President
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Operations, Waterford
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P.O. Box B
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Killona, Louisiana 70066
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SUBJECT:
NRC INSPECTION REPORT 50-382/93-21
This refers to the inspection conducted by Messrs. S. L. McCrory and
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J. I. Tapia of this office on September 13-17, 1993. The inspection included
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a review of activities authorized for your Waterford Steam Electric Station,
Unit 3 facility. At the conclusion of the inspection, the findings were
discussed with those members of your staff identified in the enclosed report.
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Areas examined during the inspection are identified in the report. Within
these areas, the inspection consisted of selective examinations of procedures
and representative records, interviews with personnel, and observation of
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activities in progress.
The results of this inspection are documented on
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page 1, in the enclosed report.
It was identified that procedure revisions to a control copy book in the plant
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simulator were not entered in a timely manner and this was in violation of
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This violation is not being cited because the
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criteria in paragraph VII.B.1 of Appendix C to 10 CFR Part 2 of the NRC's
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" Rules of Practice," were satisfied.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosures will be placed in the NRC Public Document Room.
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Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
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Sincerely,
,
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irector
ivision of Reactor Safety
Enclosure:
Appendix - NRC Inspection Report
50-382/93-21
cc:
(See next page)
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9310200121 931013
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ADOCK 05000T80
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Entergy Operations, Inc.
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cc w/ enclosure:
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Entergy Operations, Inc.
ATTN: Harry W. Keiser, Executive
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Vice President & Chief Operating Officer
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P.O. Box 31995
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Jackson, Mississippi
39286-1995
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Entergy Operations, Inc.
ATIN: John R. McGaha, Vice President
Operations Support
P.O. Box 31995
Jackson, Mississippi 39286
Wise, Carter, Child & Caraway
ATTN:
Robert B. McGehee, Esq.
P.O. Box 651
Jackson, Mississippi 39205
Entergy Operations, Inc.
ATTN:
D. F. Packer, General
Manager Plant Operations
P.O. Box B
Killona, Louisiana 70066
Entergy Operations, Inc.
ATTN:
L. W. Laughlin
Licensing Manager
P.O. Box B
Killona, Louisiana 70066
Chairman
Louisiana Public Service Commission
One American Place, Suite 1630
Baton Rouge, Louisiana 70825-1697
Entergy Operations, Inc.
ATTN:
R. F. Burski, Director
Nuclear Safety
P.O. Box B
Killona, Louisiana 70066
Hall Bohlinger, Administrator
Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884-2135
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Entergy Operations, Inc.
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Parish President
St. Charles Parish
P.O. Box 302
Hahnville, Louisiana 70057
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Mr. William A. Cross
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Bethesda Licensing Office
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3 Metro Center
Suite 610
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Bethesda, Maryland 20814
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Winston & Strawn
ATTN: Nicholas S. Reynolds, Esq.
1400 L Street, N.W.
Washington, D.C.
20005-3502
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APPENDIX A
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Inspection Report:
50-382/93-21
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License: NPF-38
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Licensee:
Entergy Operations, Inc.
P.O. Box B
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Killona, Louisiana
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Facility Name: Waterford Steam Electric Station, Unit 3
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Inspection At: Waterford Steam Electric Station, Unit 3
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Inspection Conducted: September 13-17, 1993
Inspectors:
S. L. McCrory, Acting Project Engineer, Project Section D,
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Division of Reactor Projects
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J. I. Tapia, Reactor Inspector, Operations Section,
Division of Reactor Safety
Approved:
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f J. L. Pellet, Chief, Operations Section
Date
Division of Reactor Safety
Inspection Summary
Areas Inspected: Routine, announced inspection of the licensees licensed
operator requalification program.
Results:
The written examinations were adequate with respect to scope, depth,
cognitive level, and the licensee's sample plan, and were properly
controlled to prevent compromise (Section 1.1.1)
The scenarios appropriately sampled the items contained in
10 CFR 55.45(a) and were consistent with the guidelines in NUREG-1021,
Section 604, Revision 7 (Section 1.1.2).
The level of emergency plan implementation and evaluation during the
dynamic simulator examinations was regarded as a positive initiative to
create a more realistic operational environment and to make more
effective use of simulator time and evaluation opportunities
(Section 1.1.2).
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The mix of tasks for the walkthrough examinations was appropriately
balanced between in-plant and control room tasks, and the JPMs
adequately identified critical elements. The tracking system to prevent
operators from being evaluated on JPMs they had validated was considered
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a strength (Section 1.1.2)
The parallel evaluations of the inspectors agreed with those of the
licensee (Section 1.3).
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The facility evaluators were generally well trained and qualified to
perform objective evaluations of operator performance (Section 1.4).
The licensee's program for remediation training included those
attributes necessary to assure proper remediation and retesting prior to
the resumption of licensed operator duties (Section 1.5).
The recently developed procedures for the examination process was
assessed as a positive action (Section 1.6).
The various feedback mechanisms were effective and generally well
perceived. The communications interface between operations and training
was a particular strength and a significant contributor to the overall
success of the operations requalification training program
(Section 1.6).
Revisions to the shift supervisor's control copy of the Emergency Plan
Implementing Procedures in the simulator had not been entered in a
timely manner, which resulted in a noncited violation (Section 1.2.2.1).
Summary of Insoection Findinas:
A noncited violation was identified (Section 1.2.2.1).
)
Attachments:
Attachment 1- Persons Contacted and Exit Meeting
Attachment 2- Documents Reviewed
Attachment 3- Simulation Facility Report
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DETAILS
1 LICENSED OPERATOR REQUALIFICATION PROGRAM EVALUATION (TI 2515/117)
During the inspection, the licensee's requalification program was assessed to
determine whether the program incorporated appropriate requirements for both
evaluating operator's mastery of training objectives and revising the program,
in accordance with 10 CFR 55. The licensed operator requalification program
assessment included a review of training material for the past year,
evaluation of the program's controls to assure a systems approach to training,
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and operating crew performance during annual requalification examinations.
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This included review of the facility documents listed in Attachment 2.
Further, the inspectors assessed the effectiveness of the examination
evaluators in conducting the examinations.
1.1 Examination Development
The licensee developed the written and operating examinations using the
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guidelines of NUREG-1021, Licensed Operator Examiner Standards, which the
licensee had reissued as Nuclear Training Instruction (NTI)-0P-004,
Examination / Quiz Development, Revision O.
1.1.1
Written Examination
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The inspectors reviewed the written examinations for cognitive level, item
construction, overlap across examination weeks, proper sampling of system and
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administrative knowledge areas, and linkage to the sample plan.
In all
respects the examinations were adequate.
The examinations all contained
40 multiple choice questions and were constructed to be taken in one 3-hour
sitting in the simulator.
The examinations had been time validated in advance
by licensed operators or training staff who actually took the examination, and
were not a part of the crew being evaluated. The licensee's controls on
examination material and the time validation process were considered adequate
to prevent examination compromise.
The ratio between system knowledge areas and procedures, limits, and control
knowledge areas was approximately 50 percent on all examinations reviewed.
Hinor construction deficiencies were identified in the distractors of a few
multiple choice questions; however, examination validity was not affected.
The senior reactor operator (SRO) examinations appropriately evaluated SR0
level knowledge and tended to test at higher cognitive levels overall.
The
inspectors evaluated that test question re-use across examination weeks was no
more than about 15 percent.
The inspectors determined that the examinations
met the licensee's sample plan which properly reflected training over the
requalification cycle.
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l.1.2 Operating Examination
1.1.2.1
Scenarios
The inspectors reviewed the dynamic simulator scenarios for sampling of
10 CFR 55.45(a) items, critical task identification, emergency operating
procedure (E0P) use, and complexity.
Each scenario set required the use of
contingency E0Ps in at least one scenario.
The scenarios appropriately
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sampled the items contained in 10 CFR 55.45(a) and contained numbers of
malfunctions, abnormal conditions, major transients, and critical tasks
consistent with the guidelines in NUREG-1021 Section 604, Revision 7.
Critical tasks were properly identified along with expected operator actions
for all planned evolutions, and the scenarios were previewed on the dynamic
simulator as part of the validation process. Additionally, the scenarios were
constructed to require emergency classifications and activation of the
emergency plan implementing procedures through initial notification and dose
assessment if required by the simulated plant conditions.
Emergency
preparedness specialists were assigned to the evaluation team to assess crew
performance in event classification and emergency plan implementation. The
inspectors regarded this activity as a positive initiative to create a more
realistic operational environment and to make more effective use of simulator
time and evaluation opportunities.
1.1.2.2
Walkthrough Examination
Each examinee was evaluated on five tasks using Job Performance
Measures (JPM). The mix of tasks was appropriately balanced between in-plant
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and control room tasks, and the JPMs adequately identified critical elements.
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As part of the examination development, the licensee reviewed operator JPM
validation records to ensure that individuals were not examined using JPMs
which they had recently validated.
In some cases, this resulted in different
walkthroughs being given to individuals on the same crew. This level of
tracking and development criteria was considered a strength.
1.2
Examination Administration
The examinees were briefed in all aspects of the examination using guidelines
that were virtually the same as those found in the appropriate sections of
NUREG-1021, ES 600 series, Revision 7.
1.2.1 Written E w . nation
The inspectors observed the start of the written examinations, and
periodically checked examinee progress during the examination.
Examinee
spacing and reference material availability in the examination facility were
satisfactory. All examinees completed the written examination within the
allotted time with sufficient time for at least one review. The completion
times of the examinees indicated that the time validation process used for the
examinations was appropriate to balance examination difficulty with allotted
time.
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1.2.2 Operating Examination
1.2.2.1
Dynamic Simulator Examination
The inspectors observed the entire examination for at least one crew and
portions of the examinations for all crews evaluated during the inspection
week, and performed parallel evaluations of one crew.
Event timing was
appropriate and simulator performance was generally satisfactory. A fidelity '
problem was observed when, after a manual reactor trip, electrical loads
failed to automatically transfer to the startup transformer and the A2-A3 bus
tie breaker would not remain shut once power was restored through the startup
transformer. While these anomalies were not consistent with actual design
performance, the simulator properly modeled plant behavior for these events.
Since the anomalies did not affect the examination validity, no adjustment to
the examination was required to permit an adequate evaluation.
In addition to the examination evaluation team, the operations superintendent
observed the performance of all shift crews which was assessed as a positive
activity by the inspectors.
During the administration of the simulator portion of the examination on
September 15, 1993, the inspectors noted that Control Copy Book No. 105
(Simulator Shift Supervisor) did not contain a current revision of Procedure
EP-001-030, " Emergency Plan Implementing Instruction Site Area Emergency."
Revision 16 of this procedure was being implemented in the simulator; however,
Revision 18 of the procedure had previously been transmitted to the Emergency
Planning Department on August 18, 1993. The inspectors verified that the
correct copy of the procedure was available in the plant control room. The
Emergency Planning Department was the custodian of control copy no.105 and,
as such, was responsible for updating the procedure within 10 days of receipt
of the transmittal, in accordance with Administrative Procedure UNT-004-009,
" Control, Distribution, Handling and Use of Plant Procedures". The update to
EP-001-030 was not made until September 15, 1993.
In addition, Revision 17 of
this procedure could not be located in Control Copy Book No.105.
It was
subsequently determined that Revision 17 was transmitted to Emergency Planning
on March 15, 1993. Available records indicated that the procedure was updated
that same day. The licensee issued Condition Report No. CR-93-151 on
September 16, 1993, to perform an investigation into the root cause of the
outdated procedure.
In addition, the licensee initiated a full audit of all
emergency preparedness procedures to assure that all procedures were current.
Emergency preparedness management personnel conducted interviews with
individuals responsible for updating manuals and preliminarily determined that
attempts at updating the manual had been made, but were unsuccessful because
the simulator was unavailable as a result of ongoing training activities. The
responsible personnel erred by not informing their management of the
unsuccessful attempts so that other arrangements could be made.
Emergency
preparedness management conducted briefings with the entire department to
discuss this error and management expectations concerning procedural adherence
requirements.
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This problem represented a failure to adhere to Technical Specification 6.8
" Procedures and Programs", which requires that procedural requirements for
maintaining procedures be followed.
This problem was determined to be an
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isolated case which had no safety impact, and the licensee's corrective
actions were evaluated as adequate to prevent recurrence; therefore, the
criteria specified in Section VII.B.1 of Appendix C to 10 CFR Part 2 were
satisfied to permit this to be a noncited violation.
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1.2.2.2
Walkthrough Examination
The inspectors observed various portions of the walkthrough examination and
performed parallel operator evaluations.
The examinations were well
coordinated and maximized use of the dynamic simulator for control room tasks.
1.3
Examination Results
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All examinees passed all portions of the requalification examination during
the week of inspection. The parallel evaluations of the inspectors agreed
with those of the licensee.
1.4
Licensee Evaluator Performance
The inspectors observed evaluator performance during all aspects of the
examinations. The evaluators were generally well trained and qualified to
perform objective evaluations of operator performance; however, the inspectors
observed that during the evaluation process following the dynamic simulator
portion of the operating examination, the evaluators tended to attribute
multiple competency weaknesses to a single action or behavior on the part of
an individual or crew. This tended to dilute their ability to identify
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performance weakness root causes to permit optimum remediation or training
feedback.
Further, the licensee used a five point scale (1.0 - 3.0
in 0.5 unit increments) for evaluating crew and individual performance in the
simulator. The 1.5 and 2.5 points on the scale had no performance criteria
associated with them, whereas the other points were defined with the same
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criteria found in NUREG-1021. The evaluators assigned subjective criteria to
those points on a case basis throughout each evaluation. That resulted in a
tendency to raise grade point averages over what may have resulted from using
only those grade points with predetermined performance criteria; however, the
inspectors reviewed results from the prior two weeks of examinations and
concluded that the pass-fail determinations had been appropriate.
1.5
Remediation Trainina
Prior to the inspection week, two weeks of requalification exams were
administered which resulted in one failure of the written examination and one
failure of the simulator portion of the operating examination. The inspectors
reviewed the licensee's methodology for examination results feedback, as well
as their proposed remediation training.
The review included interviews with
the two examinees to determine their perspective about how prompt and
objective the feedback they received was.
The inspectors detormined that the
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licensee provided prompt oral discussions to review the identified weaknesses
and that the particular remediation requirements were consistent with
correcting those weaknesses. The inspectors reviewed the draft written
examination which was to be given to the examinee who failed the written
examination and concluded that the two examinations were sufficiently
different to allow a valid evaluation.
The inspectors also reviewed the
remediation training for the examinee who failed the simulator examination and
determined that it was adequate. The inspectors concluded that the licensee's'
program for remediation training included those attributes necessary to assure
proper remediation and retesting prior to the resumption of licensed operator
duties.
1.6
Proarammatic Areas
While the requalification training and evaluation program at Waterford has
been repeatedly assessed as strong, much of the process has been somewhat
informal in that there was only a general commitment to develop, administer,
and evaluate examinations using the guidelines of NUREG-1021.
Recently, the
licensee proceduralized these aspects of the requalification process at the
encouragement of several experienced licensed operators who had been assigned
to training as instructors and evaluators in recent months. With only minor
exceptions, the licensee has incorporated the criteria and guidelines of the
ES 600 Series, part of NUREG-1021, Revision 7.
The inspectors assessed the
formalization of these portions of the process as a positive action in that it
made the continued success of the program less dependent on individual
personal skills and experience.
The inspectors interviewed several individuals in both the training and
operations departments regarding feedback processes and the effectiveness of
the operations-training interface. The training department has a standard
feedback form which operators are encouraged to complete for formal training,
such as class room or simulator instruction. The form may also be used to
provide feedback on training needs or desires identified apart from formal
training. Additionally, there is an Operations / Training Improvement Committee
(0 TIC) comprised of licensed and non-licensed shift operators and training
instructors, and chaired by a shift supervisor. One of the stated objective
os the OTIC is to " provide a mechanism to solicit input to enhance operator
training and implement improvement to the quality of that training." The
inspectors reviewed minutes of recent OTIC meeting and concluded that many
pertinent issues were being addressed. The training department provides
detailed performance feedback to all operators following routine evaluations
and requalification examinations regardless of the pass-fail determination.
Through the interviews, the inspectors concluded that the various feedback
mechanisms were effective and generally well perceived.
In addition to the feedback network, there was frequent and effective
interchange between operations and training managers. The managers met
formally at the beginning of each training cycle to agree on the training
content of that cycle; however, the managers meet informally at least once a
week to discuss emergent training needs or performance feedback.
The
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inspectors observed a high level of cooperation and professionalism exhibited
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between the operations and training managers.
The inspectors assessed the
communications interface between operations and training to be a particular
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strength and a significant contributor to the overall success of the
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operations requalification training program.
1.7
Conclusions
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All portions of the examinations were properly developed and adequate to
effectively evaluate operator performance with respect to licensed
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responsibilities. The parallel evaluations of the inspectors agreed with
those of the licensee. The level of emergency plan implementation and
evaluation during the dynamic simulator examinations was regarded as a
positive initiative to create a more realistic operational environment and to-
make more effective use of simulator time and evaluation opportunities.
The
tracking system to prevent operators from being evaluated on JPMs they had
validated was considered a strength.
The presence of the operations
superintendent during the dynamic simulator examinations for shift crews was
assessed as a positive activity. The evaluators were generally well trained
and qualified to perform objective evaluations of operator performance.
The
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licensee's program for remediation training included those attributes
necessary to assure proper remediation and retesting prior the resumption of
licensed operator duties. The feedback and communication interfaces between
operations and training were particular strengths and significant contributors
to the overall success of ;he operations requalification training program.
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ATTACHMENT 1
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PERSONS CONTACTED
1.1
Licensee Personnel
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- P. O'Malley, Senior Operations Instructor
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- R. Ciminel, Senior Operations Instructor
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- R. Fletcher, Operations Instructor
- B. Matherne, Senior Operations Instructor
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- T. McCool, Senior Operations Instructor
- J. O'Hern, Operations Training Supervisor
- D. Vinci, Operations Superintendent
D. Ortego, Shift Supervisor
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- B. Loetzerich, Licensing Engineer
- L. Laughlin, Licensing Manager
- D. Packer, General Manager, Plant Operations
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- J. Lewis, Emergency Planning Supervisor
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1.2
NRC Personnel
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- J. Dixon-Herrity
- G. Constable
In addition to the personnel listed above, the inspectors contacted other
personnel during the inspection period.
- Denotes personnel that attended the exit meeting on September 17, 1993.
2 EXIT MEETING
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An exit meeting was conducted on September 17, 1993.
During this meeting, the
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inspectors reviewed the scope and findings of the report.
The licensee did
not identify as proprietary any of the materials provided to, or reviewed by,
the inspectors during the inspection.
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ATTACHMENT 2
DOCUMENTS REVIEWED
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Nuclear Plant Training Instruction NTI-0P-001, " Training Course Coordination,"
Revision 0
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Nuclear Plant Training Instruction NTI-0P-002, " Examination Bank Control,"
Revision 1
Nuclear Plant Training Instruction NTI-0P-004, " Examination / Quiz
Development," Revision 0
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Nuclear Plant Training Instruction NTI-0P-005, " Examination / Quiz
Administration," Revision 0
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Nuclear Training Course Description NTC-108, " Licensed Reactor Operator
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Requalification," Revision 3
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Company Directive No. C7.830, " Training and Qualification," Revision 0
Operations / Training Improvement Committee Charter
Operations / Training Improvement Committee Meeting Minutes for 2/4/93,
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5/11/93, and 6/1/93
Operations Curriculum Committee Meeting Hinutes for 3/14/91
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Operations Department Policy No. 5, " Simulator Training," Revision 0
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Administrative Procedure UNT-004-009, " Control, Distribution, Handling and Use
of Plant Procedures," Revision 11
Emergency Plan Implementing Procedure EP-001-030, " Site Area Emergency,"
Revisions 16 & 18
Condition Report 93-151 - Failure to enter revisions to control copy books in
a timely manner.
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ATTACHMENT 3
SIMULATION FACILITY REPORT
Facility Licensee:
Entergy Operations Inc.
Facility Dockets:
50-382
Operating Tests Administered at: Waterford Steam Electric Station Unit 3
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Operating Tests Administered on: September 15, 1993
During the conduct of dynamic simulator portion of the operating tests, the
following items were observed:
ITEM
DESCRIPTION
1
Following a manual reactor trip, the electrical distribution
system failed to automatically shift to the startup transformer.
As a result, the A3 vital AC bus was de-energized since its
associated EDG was not available.
2
Following restoration of electrical power through the startup
transformer, the A2-A3 bus tie breaker could not be shut from the
control panel. No faults or lockouts were present to prevent
shutting the breaker to a dead bus.
These events did not affect the validity of the examination because the
simulator properly modeled plant behavior for the existing conditicns. The
loss of the vital bus in addition to the planned major transient caused the
operators to enter the contingency procedures which required the evalua'. ors to
more carefully record operator actions. The failure of the A2-A3 bus tie
breaker confused the operators briefly and caused them to take extra time to
investigate the problem, which delayed recovery actions. Overall, these
fidelity discrepancies did not significantly affect operator performance.
The anomalies did not repeat in subsequent scenarios.
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