ML20126E855
| ML20126E855 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/23/1992 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20126E849 | List: |
| References | |
| 50-285-92-34, NUDOCS 9212300014 | |
| Download: ML20126E855 (11) | |
See also: IR 05000285/1992034
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-285/92-34
Operating License: DPR 40
Licensee: Omaha Public Power District (OPPD)
444 South 16th Street Mall
Mail Stop 8E/EP4
Omaha, Nebraska 68102-2247
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Facility Name:
Fort Calhoun Station (FCS)
Inspection At:
FCS site, Fort Calhoun, Nebraska
Inspection Conducted: December 7-11, 1992
Inspector:
J. E. Whittemore, Reactor Inspector, Plant Support Section
Division of Reactor Safety
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Approved
.T.
FV Stetka, Chief, Maintenance Section
D' ate
Division of Reactor Safety
Insoection Summary
Areas Insoected: Routi..,
inounced inspection of the facility licensed
operator training (requalification) program including administrative controls,
response to plant modifications, response to industry and plant events,
response to changing administrative or license requirements, and training
staff performance. The inspection also reviewed the program performance in
identifying and responding to poor operator performance.
Results:
The licensee's program for assuring the continued competence of licensed
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operators was performing well. (paragraph 1.6)
The instructional staff was capable and experienced, with the majority
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holding a senior reactor operator license for FCS. (paragraph 1.1)
A cooperative relationship existed between the operations and training
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organizations, which resulted in a beneficial teamwork approach to
resolving training issues. (paragraph 1.4)
9212300014 921224
PDR. ADOCK 05000285
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So-ary of Insoection Findiggi:
The licensee intended to temporarily reduce the instructor staff for the
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initial and licensed operator training programs by a tcral of two
personnel. The licensee indicated their intent to monitor this matter
to assure that there was no impact on program effectiveness.
(paragraph 1.1).
A potential to comproelse examinations was identified, in that the
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Itcense's procedures for developing written examinations allowed
excessive use of identical questions on back-to-back examinations.
However, there was no indication that examination compromise had
occurred and the licensen-initiated action to revise the procedure.
(paragraph 1.3).
Attachments:
Attachment - Persons Contacted and Exit Meeting
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DETAILS
1 LICENSED OPERATOR TRAINING (41701)
This inspection involved a review of the performance of the FCS licensed
operator (requalification) training program which is required by the
regulations in 10 CFR Part 55. The review was conducted to determine if
various processes within the program would respond correctly to industry and
plant events, facility modifications, procedure revisions, and any changes to
administrative and license requirements. The program processes reviewed
included classroom training, trainee evaluation, examination failure
remediation, and the integration of the training staff effort toward program
implementation.
The ins)ection was conducted during the seventh and final
rotation for the 1992 scleduled licensed operator training.
The inspector reviewed the two documents that controlled the licensed operator
training
)rogram. The Licensed Operator Training Program Master Plan (TPHP)
defined tie program and provided a program overview, organizational
responsibilities, department interfacing instructions, qualification
requirements, and the training program task list. The training program was
conducted according to Training Administrative Procedure (TAP)-13. " Licensed
Operator Requalification Training," Revision 21, which contained the detailed
program implementing instructions.
The inspector concluded that the controlling procedures assured compliance
with the licensee's administrative requirements, facility license
requirements, and the regulations in 10 CFR Part 55.
1.1 Trainina Oro.aization And Responsibilities
Within the training organization, the responsibility for the licensed operator
and initial license training programs fell under the supervisor of operations
training. A total of 11 personnel were assigned to the supervisor for
administering the two programs. Two of the assigned personnel were
contractors whose contract was scheduled to end on December 31, 1992. At this
time, it appeared that the licensee did not intend to renew the contract. Of
the remaining nine personnel, eight were currently, or had been, senior
reactor operator licensed on the FCS facility. The remaining individual had
been licensed on another Combustion Engineering plant. The training personnel
were specifically assigned to one of the programs, but assigned duties would
overlap into the other program. Most often, this overlap would occur-in the
simulator training and evaluation area.
At the time of the inspection, the licensee was preparing to start the 1993
licensed operator program.
Additional effort was being expended to complete
the final training phase for an initial licensing class of nine, scheduled for
NRC licensing exams in June 1993. Recognized training technology standards
recommend that experienced instructors be allowed twice the time for
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preparation as required for presentation of classroom material.
Outside the
classroom, additional time is needed to validate and review materials for
dynamic training and evaluation sessions such as simulator guides and job
performance weasures (JPM).
It was also conceivable that instructors could be
tasked to develop additional training materials. Additionally, it normally
required two instructors to operate the FCS control room simulator. The
inspector conducted discussions with licensee representatives concerning the
instructional- staff and scheduled workload. The inspector asked if the nine
remaining instructors would have adequate preparation time to prepare for
their assigned instructional tasks with the planned reduction of qualified
instructors. The licensee could not provide a definite affirmative answer to
the question. Management indicated they were aware that instructional
personnel availability would be reduced temporarily, but in their opinion, no
significant problems would result from decreased staffing.
In order to avoid
any long-term problems, the licensee planned to limit the number of licenses
held at the facility.
In addition, there were plans to avoid conducting an
initial license class for about 2 years.
Further, when new operators were
licensed in mid 1993, as many as three licensed personnel would be r.ssigned to
the licensed operator training staff.
The inspector concluded that the initial and licensed operator training
programs would be at absolute minimum staffing until the latter part of 1993.
Licensee management stated ar intent to closely monitor program performance
during this period.
1.2 Classroom Trainino
It was not possible to observe operational training during the inspection
because the control room simulator was undergoing a modification outage.
All
scheduled classroom and operational training and evaluation for the 1992
program had been completed. However, the inspector observed three sessions of
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classroom training provided to licensed operators that had been requested by
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licensed personnel or the operations supervisor. The subjects of the three
sessions were fire protection, operability determination, and NRC notification
requirements.
The inspector observed two instructors during the administration of the three
classroom lessons. The instructors observed were experienced licensed senior
reactor operators and were well prepared for the training sessions. Both of
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the instructors had different but effective techniques for motivating the
students and provided good presentations. Additionally, both of the
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instructors exhibited a superior questioning technique to initiate discussion
of the subject matter.
Interaction was encouraged and several points were
addressed and cleared up by the dialogue between the instructor and students.
During two of the sessions, the students surfaced single issues that were not
finalized or closed out during the classroom session.
The student questions
concerned interpretation of conditions and management policy.
The instructors
did not refer to the issues during the lesson summaries or commit to
addressing the students' concerns later or through uther methods.
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inspector debriefed with the instructors and the supervisor and determined
there was an unwritten policy to address and answer all student questions
which arose in the classroom. There were no formal requirements or methods
specified for obtaining assistance on issues needing expertise from outside of
training. A licensee representative stated the instructor evaluation program
had identified the practice of failing to address issues not answered in the
classroom as a generic problem in classroom training, and would be addressed
in the future.
The inspector concluded that a potential existed for instructors to ignore
student concerns brought up in the classroom. Aside from this single
observat'on, the classroom training phase of the licensed operator training
program was effective.
1.3 Licensed Operator Evaluation And Corrective Action
The inspector reviewed the annual examination results from 1990 to the
present, and the remediation process for each failure.
Individual licensed
operator and crew perfomance on annual examinations indicated improvement
since 1990.
During the 1990 requalification year, 37 licensed individuals
were examined. One crew and two individuals failed the simulator examination.
There was one written examination failure. During the 1991 cycle 44
individuals, including 12 co-examined by the NRC, were tested. The NRC did
not fail any individuals or crews. OPPD failed one crew on the simulator,
four individuals on the simulator, one on JPN walkthrough, and one on the
written examination.
For the 1992 requalification year, 42 individuals were
examined. A total of 12 licensed individuals were declared exempt from the
annual examination because of holding a license for less than 3 months or
being enrolled in a Senior Reactor Operator upgrade training program. There
were no failures of the 1992 examinations.
According to OPPD procedures and policy, the failure of.any phase of the
annual requalification examination required the affected individual to be
removed from shift duties.
A review of the remediation effort for each
failure over the past 3 years indicated that an in-depth analysis was
conducted to determine the reason for each exaaination failure. The analyses
identified the specific weaknesses that had contributed to the failures, or
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identified problems with the examination. Once an operator's specific
weaknesses had been identified, a specific upgrade program was designed to
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improve the individuals performance in the weak area (s).
Some of these
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upgrade programs were simple and easy to complete while others were complex
and lengthy. The upgrade programs had been approved by managea nt in the
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operations and training departments.
Prior to being returned to shift duties,
the individuals were re-examined to determine if they had regained proficiency
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in the previously identified weak areas. Crew failures on the simulator had
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been handled in the same manner as individual failures. However, individuals
who had performed well and had not contributed to the failure, had been
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exempted from the remediation process.
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The remediation process was effectively implemented.
The crew or individuals
weaknesses were properly identified and the prescribed corrective action had
been beneficial and timely. A review of the makeup examinations indicated
that the affected operators had been tested on the individual simulator
critical tasks (ISCT) and in the knowledge areas where they demonstrated
weaknesses.
Written examinations were constructed from a computer-based examination bank
according to Procedure TAP-8, " Examination Control And Administration,"
Revision 16. Most of the test items in the database were in the preferred
objective (multiple choice) format.
The majority of the questions were
comprehensive or required conceptual knowledge, synthesis, and analysis by the
examinee to obtain the correct answer. One person on the training staff was
responsible for developing the six iterations of the annual exam that were
administered over the 6-week crew rotation. All versions of the examination
" quired peer review and management approval.
Examinations for the annual requalification examinations were developed by
using a sampling plan. The plan was generated from a computer database that
contained tie exact amount of training time that had been expended for each
subject. This time was then reflected as a percentage of the total training
time.
From this data, a plan could be generated to indicate the percentage of
questions to be used in the broad areas of systems, procedures, and
administration. The finished plan also showed the percentage of questions
needed to address smaller areas such as emergency procedures or abnormal
procedures.
The inspector reviewed the sampling plans that had been developed to support
the 1991 and 1992 cycle examinations. A review of the examinations to support
these cycles was also performed. The inspector determined that the quality of
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the test items used on the annual examinations was good.
Questions that
required memorized response from the examinee occurred infrequently. A rough
estimate comparing two examinations to the sample plan indicated favorable
comparisons to the sample plan. The examinations did not exactly agree with
the plan percentages, but the proportions.were close enough to confirm that
the sample plan h7d been used as intended.
Procedure TAP-8 dealt with using identical questions on back-to-back written
sxaminatibns. According to the procedure, only 30 percent of an examination
had to be different from the previous version. This translated to allowing 70
percent of the questions used on the first weekly examination to be repeated
on the second week of the examination. The inspector told the licensee that
the amount of identical- question overlap appeared to be excessive and could
result in examination compromise. A licensee representative agreed with the
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inspector's conclusion and expressed an intent to immediately commence a
procedure revision that would not allow an examination to be compromised.
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licensee representative also stated that very little, if any, question overlap
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had been used in the past.
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The inspector reviewed different versions of the last annual examination to
see if any questions had been used more than once. Also, an interview was
conducted with the individual who constructed the most recent set of six
weekly examinations. This review and interview revealed that no test items
had been used more than once on any of the six examinations.
The inspector concluded that the licensee's program for evaluating operators
was strong. The prescribed followup corrective action to address identified
. hile the potential
weaknesses was imaginative, timely, and beneficial.
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existed for examination compromise within the licensee's procedures, no
instance was identified where this had occurred and procedure revision was
initiated prior to the end of the inspection.
1.4 Trainina Prooram Response
The inspector reviewed the process for changing the training program content
in response to changes and modifications to the plant, procedures,
administrative requirements, license enditions, and regulations. Changes to
training programs content was conducted according to Procedure TAP-7,
" Revision Of Training Program,' Revision 21. Change was initiated within the
training program configuration management (TPCM) system. This system was
administered by a coordinator and committee members that represented each
training program. The committee was notified of all changes and met weekly to
decide what programs would be affected by a specific change. Once the
affected programs were identified, program supervisors determined the required
program content change, subject to management approval.
A problem had occurred recently when the training organization had not been
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notified that planned modifications to the facility had been completed. This
resulted in failure to implement training program content changes until after
the facility had recovered from an outage and was back on line. This issue
was resolved by changing the distribution methodology for design packages.
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The current practice was to provide training with the initial modification
package, significant revisions, and the final completed package, which
provided a signal to implement the training changes.
Also the supervisor of
licensed operator training had developed and implemented a special plant
modification status tracking system to prevent recurrence of the problem. The
TPCM system appeared to be effective in providing the necessary changes to
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program content.
There was a variety of methods for dispensing information about a change to
the licensed operators. Generally, existing training material such as lesson
plans or simulator guides would be revised.
Sometimes completely new material
would be developed.
For matters of relatively low importance, a licensed
operator required reading file was administered from the training department.
In the past, immediate training had been administered by the training
organization to licensed crews, prior to the assumption of shift duties. This
had become necessary when plant modifications had not been completed until
just before a crew assumed the shift.
The most frequently used approach was
to develop and administer a special topics classroom session for each
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rotation. There were typically seven rotations during a requalification
program year.
For each rotation a handbook was developed for the operators to
follow the classroom presentation. One instructor within the licensed
o)erator training program was responsible for developing and administering
t11s training. The session content was jointly agreed to by operations
management.
The inspector reviewed training material that had been developed for three
recent special topics sessions. The material for a session consisted of a
handbook and a generic lesson plan. The generic lesson plan contained
learning objectives specific to the lesson material and-the instructor had
highlighted the handbook to use as a presentation guide.
From discussions
with instructors, supervisors, and operators, the inspector detemined that
this method of instructing operators about plant and program revisions and
modifications had been very effective. However, the inspector noted that the
material development and presentation appeared to lack formal control.
In the
past, session content had been determined in telephone conversations between
operations management and an instructor.
It was not clear that training
supervision and management were systematically included in the concurrence of
the session content. The inspector informed licensee representatives of the
apparent lack of forni control for this otherwise effective effort and the
potential for excluding training meagement and supervision from the control
process.
The ins)ector tracked seven Licensee Event Reports (LER) through the-TPCM to
assess iow the licensed operator training progr u had responded.
It was
possible to determine how the training issues had been addressed and what
basic changes had been made. However it was not possible to determine the
details of revisions that had been made to existing classroom lesson plans. A
record hard copy of the revision request form was available, but this did not
provide the detail.
During the approval process, the detailed markup of the
change would have been attached to the revision request, but was not retained
af ter the change was final. The previous versions of the lesson plans were
not vaulted or retained, and there was no requirement to do so. The program
supervisor was able to point out most of the changes to the lesson plans, and
it appeared that the required changes had been made in all cases. The only
issue was that the licensee's methodology did not provide for a historical
change record, and this was not considered to be significant.
The inspector reviewed in detail the event that occurred on July 3, 1993 at
FCS.
This event consisted of a loss of coolant accident (LOCA) caused by a
pressurizer safety valve opening prematurely and failing to close after a
turbine valve closure at power.
The entire event was precipitated by an
interruption of the power supply to the turbine control system which caused
the turbine valves to close without a turbine trip signal which would have
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caused a reactor trip.
The training response to this event had been minimal as the licensed crew's
performance during the event was considered to be good.
A crew communication
problem had been identified, but the corrective action had been to revise the
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Emergency Operating Procedures. Another issue had arisen regarding which
reactor coolant system (RCS) subcooling instrumentation was the most viable
during the event. The training department's response had been to initiate an
extensive retlew of the event in the rotational special topics training.
Another training action was to fine tune a simulator scenario to duplicata the
event as precisely as possible. This effort was undertaken mainly to validate
the performance of RCS subcooling that was observed during the event. However
there were plans to use this information to develop training th.t would
encourage operators to consider long term effects of stopping and throttling
safety injection system flow during LOCA conditions. A final effort of the
training organization was to draft the detailed event report that would be
distributed to the industry.
The inspector interviewed three of the licensed operators that had been on
shift d9 ring the event of July 3,1993.
Ecch individual was candid and
expressed general satisfaction with their own performance during the event.
All three thought that the training they had received on responding to a LOCA
had been more than adequate. Another common area was the high regard for the
training they have received on the simulator. One individud expressed a
desire to receive more than the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of simulator training and evaluation
given during each rotation.
An operator also stated that he now understood
why the training scenarios usually consisted of multiple complex events with
difficult circumstances.
The inspector concluded that the licensed operator training was responding
properly to changes or events. The rotational special topics training was
very effective but appeared to lack formal control.
1.5 Trainina performange Indicators
The training department had initiated its own trending program in the form of
training performance indicators. Only one of the indicators was specific to
licensed operator training, but numerous indicators addressed all programs.
The program tracked 19 different indicators and issued a report every other
month.
The reports received wide distribution, including corporate
management. Below is a sample of indicators tracked that related to licensed
operator training:
Training Personnel Budgeted versus Actual Hours
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Student Contact Hours by Program
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Requests for Training
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Instructor Hours In Plant, Development, Continuing Training
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Trainee Progress
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Instructors With Licenses
Number of Critique Reports
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Test Item Development
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Number of Observations
Examination Pass / fall
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Attendance Percentage for Licensed Operator Training
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The inspector reviewed performance indicators dating back to August 1991. The
reports indicated that when the data was reduced and a trend was identified,
corrective action was initiated.
For example, the trend report for
September / October 1991 indicated that attendance at licensed operator training
sessions was low for some individuals.
In subsequent bi-monthly reports, the
attendance of the identified individuals, had increased significantly.
Several other examples of this type of identified trend and ensuing corrective
action caused the inspector to conclude that the performance indicator program
was effective.
1.C CONCLUSIONS
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The inspector concluded that the Itcensee's training program for maintaining
the skill and knowledge of the licensed operators was effective. One of the
indicators that supported this conclusion was the performance of the licensed
crew during the LOCA event of July 3,1993. A siellar but less severe event
occurred on August 22, 1993, and a different crew responded well. Another
indicator of success was the 100 percent pass results of the last annual
licensed operator requalification examination.
The licensee acknowledged the
inssector's finding concerning potential examination compromise and appeared
entiusiastic about correcting the problem. Management also understood the
concern about staffing and indicated that this situation would be closely
watched.
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AIIACHMEhT
1 PERSONS CONTACTED
1.1 Omaha Public Power District Personnel
- R. Andrews, Division Manager, Nuclear Services
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J. Braun, Licensed Reactor Operator
- G. Cook, Supervisor, Station Licensing
D. Daily, Licensed Operator Training Instructor
C. Darrow, Licensed Operator Training Instructor
- S. Gambhir, Division Manager, Production Engineering
- J. Gasper, Manager, Training
- G. Gu11ani, Supervisor, Operations Training
- R. Jaworski, Manager, Station Engineering
- L. Kusek, Manager, Nuclear Safety Review
R. Lewis, Principle Engineer, Design Engineering
- D. Lippy, Licensing Engineer
- R. Mehaffey, Principal Engineer, Electrical Engineering
- S. Miller, System Engineer
- R. Mueller, Supervisor, Electrical Engineering
- J. O'Connor, Manager, Design Engineering - Electrical
- W. Orr, Manager, Quality Assurance and Quality Control
- T. Patterson, Manager,. Fort Calhoun Station
- R. Phelps, Manager, Design Engineering
T. Reisdorff, Shift Supervisor
C. Rennerfeldt, Licensed Operator Training Instructor
R. Schreurs, Licensed Senior Reactor Operator
- R. Short, Manager, Nuclear Licensing and Industry Affairs
- C
Simmons, Station Licensing Engineer
J. Tesarek, Supervisor Operations and Technical Training (Acting)
- J. Tills, Assistant Manager, Fort Calhoun Station
R. Ward, Licensed Operator Training Instructor
1.2 NRC Personnel
- P. Goldberg, Reactor Inspector
- D. Kelly, Reactor Inspector
- P. Wagner, Team Leader
- Denotes personnel that attended the exit meeting conducted on
December 11, 1992.
2 EXIT MEETING
An exit meeting was conducted with licensee management personnel on
December 11, 1992. During this meeting, the inspector reviewed the scope and
findings of the inspection. The licensee did not identify as proprietary any
of the materials provided to, or reviewed by, the inspector during the
inspection.
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