IR 05000413/1993001

Insp Repts 50-413/93-01 & 50-414/93-01 on Stated Date.No Violations Noted.Major Areas Inspected:Training & Qualification Effectiveness of non-licensed Operators,Ros, SROs & Licensed Operator Requalification

ML20127K036
Person / Time
Site:	Catawba
Issue date:	01/15/1993
From:	Lawyer L, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K008	List: IR 05000413/1993001 ML20127K006
References
50-413-93-01, 50-413-93-1, 50-414-93-01, 50-414-93-1, NUDOCS 9301260024
Download: ML20127K036 (13)

Text

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Report Nos.: 50-413/93-01 and 50-414/93-01 .,

Licensee: Duke Power Company 422 South Church Street  ;

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Charlotte, NC 28242 Docket Nos.: 50-413-and 50-414- License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conducted: January 4-8, 1993

<, m Inspector: hht k L. Lawyer, Team Leader'

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Date Signed b

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Team Members:

. F. Aiello J. H. Bartley L. P. King L. S. Mellen R. M. Pelton Approved by: h/214/

T. A. Peebles, Chief ( Mb / - /f - 'M Date Signed

//y' Operations Branch Division of Reactor Safety SUMRTRY Scope: This was a routine announced inspection. in the area of trair.ing and qualification effectiveness of non-licensen ooerators, R0s, SR0s, licensed operator requalification, and STA training programs. Its purpose was to ensure that personnel have qualifications commensurate with the ;.rformance requirements of their jobs, to ensure training improvement programs were effective, and to ensure that active and inactive license control ensures reactor control manipulation by properly licensed personne Results: The NRC team identified one_ strength and six weaknesses-in the ,

training programs reviewed.. The strength was the SR0 licensing of STAS and their integration into the operating shift (paragraph 6). '

The weaknesses were in the areas of instructor continuing training (paragraph 2), operator communications (paragraph 3), operator-

- knowledge level (paragraph _3), hot license candidate screening. _ -;

(paragraph 3), STA knowledge level (paragraph 6), and STA Job Task '

Analysis.(paragraph 6).

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9301260024 930115 PDR ADOCK 05000413 G PDR .

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REPORT DETAILS Persons contacted

= ,abshire, Instructor

• Barron, Director of Operations Training

• S. Bredshaw, Shift Operations Maneger

• M. Brady, Operations' Training Ccordinator-

• R. - Buger t, Training Consulting Specialist S. Broer, Director, Maintenance Training

• J. Cox, Regulatory Compliance

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S. Fr.ye, Operations Support Manager K. Green, Instructor J. Humphries, Instructor R. Katalinich, Instructor C. Kiker, Instructor-  !

• J. Lowery, Regulatory Compliance

• W. Mc Collum, Station Manager D. McIntosh, Instructor

• W.-Miller, Work Control Supervisor ' Modine, Instructor Phillips, Instructor D, Phillips,. Instructor Ranseur, instructor Roberts, Instructor D. Tower, Lead Shift Manager J. Trofilak,- Nuclear Production Engineer P. Von Staden, Instructor A. Williams, Instructor G. Winkel, Instructor

• J. Wylie, Training Manager Other licenses employees contacted included instructors, technicians, operators, and office personne ,

NRC Representatives W. . Orders, Senior Resident. Inspector '

• Zeiler, Resident inspector ,

• Attended Exit Interview A listing of- abbreviations used in this repoit is contained in_ Appendix A-listing of procedures reviewed is contained in appendix . Non-licensed Operator' Training Program Review-The team observed five training sessions, intervieweditwo NLO instructors, interviewed eight NL0s, and observed NL0s while performing their norma dutie Report Details 2 Based on the results of the above observations, the team concluded that evaluation of the SAT process, as applied to the 14LO program, was not warranted, furthermore, they concluded that Catawba plant 14L0s have qualifications commensurate with the performance requirements of their jo The team also reviewed the operations instructor certification and continuing training program required by COTG-07, initial Instructor Certification and Requalification Administratio The team noted several deficiencies with the instructor cantinuing training progra These deficiencies incluced incomplete records documenting required continuing training, lack of management reviews for 1991, and instructor failure to --

complete the continuing training OJT requirements for 1992. The team identified these deficiencies in instructor continuing training as a weaknes Based on the results of the above reviews and discussions, the team concluded that evaluation of the SAT process, as applied to instructor training, retraining, and certification, is not warrante Furthermore, they concluded that Catawba plant operations instructors have quTlifications commensurate with the performance requirements of their jo IJo violations e deviations were identifie . Reactor Operator Training Program Review The team interviewed several R0s and training instructors. The team also observed the performance of normal duties b tw.; R0s while they were on shif The team reviewed and verified that the station policy concerning the authority of shift management, requirements for use of procedures and crew communications guidelines had been revised. The team also reviewed -

documentation regarding operations management involvement cotterning the requalification training progra Weaknesses were identified in examination report 50-414/92 300 concerning procedure usage, crew communications, E0P content, and training methodolog Station management had developed a revised policy which delineated the authority of shift management. This policy stated the requirements for the use of procedures and crew communications. The facility stated that deviation from approved emergency operating procedures will not be allowed except for situations covered by 10CFR50.54 The facility developed the following corrective measures to ensure these expectations were clearly communicated to the appropriate operations and training personnel: Operations management will conduct training with all licensed personnel and training personnel to convey management expectations frr use of procedures and crew communication _ _ _ _ _ - _ _ _ _ _ ____

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L Report Details 3 Selected operations management personnel will participate in licensed operator requalification simulator training sessions to ensure and reinforce conveyed management expectation I A team of senior site management, operations, and training management l will periodically observe and document crew performance in the Simulator  ;

Managenent Observation Book, located in the simulator, during simulator training sessions. They will also participate in crew critiques to ensure and reinforce conveyed management expectations. This process will be evaluated by the licensee in July, 199 The team observed two R0s performing their normal duties in the control room. The overall quality of work in the control room was consistently meeting or exceeding at least the minimum standards as delineated in NUREG 1220. However, operators rarely used repeat backs, as identified in the above mentioned report, which was not in keeping with procedure OMP l-8 or the way they are trained in the simulator,

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furthermore, both operators displayed weaknesses in the relationship between permissives P-10, P-13, and P-7, the reactor coolant loop flo detection system, the effects of an idle reactor coolant pump on the reactor coolant system, and main turbine, feed, and condensate thermo--

dynamics. This basic reactor operator knowledge was weak.. It was evident that periodic reinforcement was not occurring during the requalification .

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cycle to ensure that Catawba plant licensed operators possessed the knowledge and qualifications commensurate with the performance require-i ments of their jo Specifically, the remedial training given in segment 6 as a result of NRC comments in examination report 92-300 was not totally effective. Review of segment 6 showed that no testing to ascertain operator comprehension was performed. The team identified poor communications and the above mentioned shortcomings in operator knowledge as continuing weaknesse The NRC generally observes a 90 to 95 percent pass rate on initial examinations. In the case of the October 1992 initial R0 examination, the pass rate was only 20 percent () of 5). The team reviewed the study that ,

was performed by the operations training grou). This study was to determine any differences in the way the Octo)er class was conducted from -

previous classes. Early in the October class, the HLP examination bank was given to-the class as a study aid. This was the first hot license i class to receive the examination bank as a study tool. An analysis'was '

performed by the facility on the last three regular classroom, audit, and NRC examinations which compared the pass rate on new versus old examina-tion items. The analysis showed-that many of the students used the bank as their primary means of examination 3 reparation. The training depart-ment determined that they should have 3een more aggressive at modifying

. the examination bank earlier in the hot license class and increasing the discrimination ability of the examination items used in examinations that  !

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! .l Report Details 4 I-l are given prior to the NRC administered examination. Efforts were made in ,

this area beginning in July 1992, during HLP examination 9 of 11, which  ;

yielded a drop in the class average. The training department also '

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determined that had this been done earlier in the course, during the time f rame of HLP examination one, the weaker individuals could have been afforded the necessary attention they needed to pass. Two of the R0s failed the facility audit examinatio Another candidate was within two percent of the pass / fail criteri The operations department had the overall authority to override any recommendations that were made by the

. audit team. This authority was exercised for the class of R0s who took 4 the examination in October 1992. The operations department's decision to-

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send up R0s who did not pass the audit examination was not in keeping with '

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the audit team's recommendation. The team found it'to be questionable at Catawba whether individuals who train the operating staff have sufficient organizational freedom to ensure their independence from operating pressures. The team identified HLP candidate screening as a weaknes '

Several differences were identified by the facility between the conduct of the HLP 10/92 class and previous hot license classes. These '

differences were delineated in a memorandum by R.E. Kimray (CH 940.00)

dated December 12, 1992. Several corrective action recommendations wer made to the operations department by the training department in this memorandu These recommendations have not been fully implemented ye This open item is identified as Ifl 50 413,414/93-01 01: Corrective action implementation to prevent a repeat of the 10/92 initial examination high written failure rat Based upon the results of the above reviews and observations, the team concluded that evaluation of the SAT process as applied to the R0 program was not warranted. Furthermore, they concluded that Catawba plant R0s,- ,

while exhibiting the noted weaknesses, had qualifications commensurate  !

with the performance requirements of their jo '

No violations or deviations were identifie . Senior Reactor Operator Training Program Review The team reviewed the SRO training program using the guidance in NUREG ,

1220 to evaluate lectures, simulator sessions, and JPM administratio The team also observed SR0s performing their~ normal duties and interviewed SR0s, their instructors,'and the Training Superviso In addition, the team reviewed the training of IAE personnel who support the SR0 in his performance of E0P. EP/1/A/5000/2Cl, Loss of Secondary -

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Heat Sink, Enclosure 2, step 1 requires IAE to bypass the feedwater isolation signals, Interviews with IAE personnel and a review of

Maintenance Training revealed that IAE technicians were not receiving training on Emergency Procedure steps they are expected to perform nor are these steps addressed in the IAE JT _ - . _ _ .a n_._.._ . _ . _ _ _ _ _ . - -

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Report Details 5 i

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Based upon the results of the above reviews and observations, the team  ;

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concluded that evaluation of the SAT process as aaplied to the SRO program *

was not warri.nted. Furthermore, they concluded tlat Catawba plant SR0s r have qualifications commensurate with the performance requirements of theirjo No violations or deviations were identifie , Licensed Operator Requalification iraining Program Review The team reviewed the licensee's Operations Management Procedure 1-7, Revision 4, Emergency / Abnormal Procedure Implementation Guidelines, to ensure that inappropriate performance could be identified during the simulator and JPM observations. No violations of the procedures were

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noted during the team's observation-of the simulator scenario The team observed a simulator scenario for two separate shifts that included a loss of power to an essential bus followed by a loss of feedwater, an ATWS, and a loss of heat sink. The scenario was well .

planned, and during the course of the scenario, the instructor froze the simulator at several points to provide instruction. The instructor  ;

covered all areas in which the o)erators needed improvement. The instructor was well prepared. T1e team observed that the trainees acting in the shift supervisor position did not display a command presence.- They i, did not display an authoritative manner while acting in this positio The team also observed that while the instructor was briefing the shift on the observed weaknesses from the past and how they should be-improved,:the  !

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shift supervisor in charge conducted himself in an unprofessional manne This adversely influenced the rest of the shift and detracted from the message the instructor was trying to convey. The team identified this-as another example of the previously identified weakness in operator '

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communication Examination report 50-413/92-300 described training that the licensee had committed to perform in segments six and seven. .The team verified that requalification segments six and seven.had included training on the committed subject The team reviewed the LERs for 1991 and 1992 to determine which LERs might have been avoided by-increased training. The team also reviewed the _

training program to ensure that these LERs had been selected-for increased .i training. An example of this was LER 413/91-06, Technical Specification ,

Violation When Nuclear Service Water Valves Were Left Without an Emergency Power Supply Due to Inappropriate Action. -The operators used the Operator Aid Computer graphics and misread the graphic to conclude that the Nuclear Services Water Valves were left with an emergency power supply.- The licensee committed in_the LER to provide training on the OAC graphics.-

'The team determined by a review of the licensee training plan that this was included in trainin A discussion was held on OMP 2 23, Valve and

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Report Details 6 Breaker position Verification and Valve Operation, section 6.1.5 and 6. which states that procedures should not be completed by determining a valve's position from the OAC indication or graphics unless the procedure specifies to do so and that 0AC electrical graphics should not be used as the only means of ensuring a safety-related position for procedure verificatio Based upon the results of the above reviews and observations, the team concluded that evaluation of the SAT process as applied to the LOR program was not warranted. Furthermore, they concluded that Catawba plant licensed operators have qualifications commensurate with the performance __

requirements of their jo fio violations or deviations were identified. Shift Technical Advisor Training program Review The STA position was filled by the Shif t Manager during normal operations and the Shift Manager assumed the duties of STA during abnormal and emergency situations. The Shift Manager /STA received all of the required SRO training. During their development of the STA training program, the licensee identified 28 tasks and 101 knowledge / skills for the STA position. The licensee determined that these were all included in the SRO training program and elected to include the STA in the SRO training program in lieu of an STA specific training program. The team considered the inclusion of the STA in the entire SR0 training program and their integration into the operating shift as a strengt The team reviewed the STA training TS requirements, FSAR commitments, and NUREG 0737 requirements. The team also interviewed STAS and their -

supervisors and trainers and observed STA tasks in progress. They found that all commitments were being met but observed some weaknesse Simulator Training The team observed STA's under requalification instruction on the simulator. The team evaluated the STA trainee and instructor work practices and technical knowledge. Some deficiencies were noted in STA performance; instructor performance was found to be adequat The team observed the performance of a crew mitigation of an ATWS scenario on the simulator. lwo of the STA identified tasks related to this scenario were Task T020, which required the STAS to monitor the critical )

safety function status trees emergency procedure and Task 1019, which required the STA to monitor the nuclear power generation /ATwS emergency procedure. The team reviewed the same scenarios performed by two different crews with two different STA The evaluation of the scenario performances were as follows:

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Report Details 7

The first STA was unfamiliar with the procedure that required the monitoring of CFST parameters with a potentially unreliable SPOS. The STA did not continuously monitor the red path (heat sink). The STA did not identify the required switch in priorities when the heat sink path changed from red to yellow following CA flow recovery. At this '

point in the Core Cooling, an orange path became the dominant pat During the simulator scenario critique, the STA trainee told the

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instructor that he was unfamiliar with the procedure steps he was performin The balance of the STA functions were performed adequately. On the second run of the scenario, the STA functions were performed adeptl The scenario tasks being performed by the two foregoing STAS involved monitoring and evaluating rapidly changing and misleading CFST parameter This scenario comprehensively challenged the STA's skills. The team concluded that the STA training had not completely prepared inexperienced

STAS for these difficult tasks as evidenced by their requalification

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performanc The training program for the STAS contained no training beyond the scope of SR0 training. The team identified the incomplete- ,

preparation of STAS for difficult Tasks as a weakness, On the Job Training The team observed the conduct of training JPMs for STA trainees from the current STA requalification class. The team evaluated trainee and instructor work practices and technical knowledge. The team concluded the STA's performance on JPMs was adequat Job Task Analysis NUREG 1220 describes a SAT based training program as a program that contains five basic elements. The team reviewed the STA training program as it related to these five basic element The first element of a SAT based program is analysis. . The licensee accomplished this by developing an STA JT The current STA JTA has not been maintained up to-date with current changes in organizational procedures and changes in the STAS task The JTA was. conducted by

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analyzing the two documents existing in 1984 that itemi:ed STA responsibilities. Twenty-eight STA specific tasks were identified; nineteen involving CFST and nine from OMP l-11. At the time the JTAs were written, STAS were required to hold an active SRO license. The JTAs had not been-updated since OMP l-11 was deleted (1988). In addition, STAS were no longer required to keep an active license (1990). The result of this was a set of JTAs that did not accurately reflect the current STA position requirements. The team concluded the licensee met the intent of the analysis element, although the documentation had not been appropriately maintained. This was identified as a weakness in the STA training progra .- - . . - - - - - - _ _ _ - - . - . - . = . . . - . _ , . - _ _ . . - . - - --- . . -

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Report Details 8 Technical Specifications TS section 6.2.2 9 stated "On occasion when there is a need for both the Shift Supervisor and the SRO to be absent from the control room, the Shift Manager shall be allowed to assume the control room command function and serve as the SRO in the control room provided that: (1) the Shift Supervisor is available to return to the control room within 10 minutes, (2) the assumption of SRO duties by the Shift Manager be limited to periods not in excess of 15 minutes duration and a total time not to exceed I hour during any shift, and (3) the Shift Manager has a Senior Operating license on the unit."

The team discussed this section of the TS with licensee management and determined that none of the current STAS can assume the control room command function because although the STAS maintain a SR0 license on the unit, the license is inactiv There were no plans to activate the STAS'

SR0 licenses. Without an activated SR0 license, STAS / Shift Managers could not assume Control Room command functions. The team-did not find any examples of STAS / Shift Managers-inappropriately assuming Control Room command functions nor did the team find any STAS who misinterpreted this requiremen The team reviewed the general categories of simulator usage for the years 1988 through 1992. The unge was found to be almost entirely for operator training and examination. Simulator availability was in excess of 99 percent each of these years. Total usage-for all purposes ranged from approximately 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> per year _to 3700 (40 percent of total hours). Of this time, about 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per year were being devoted to non-operator training and examination activities such as plant drills, design engineering use and public relation Based upon the results of the above reviews and observations, the team concluded that evaluation of the SAT process as applied to the STA program was not warranted. The team also concluded that the licensee was appropriately dispositioning active and inactive operating-license Furthermore, they concluded that Catawba STAS had qualifications commensurate with the performance requirements of their jo .

No violations or deviations were identified. Action on Previously Identified items-(Closed) IFI 50-413.414/91r301-01, Procedure OMP l-8 does not clearly address what controls non-licensed operators can operate while under direct ~ supervision of a licensed operato While conducting control room walkthrough' examinations during initial examination 50 413,414/91-301, the examiner observed an unsupervised non-licensed individual simultaneously manipulate the Nuclear Instrument System recorder switches on the MCl Rod Control Panel. This practice was

Report Details 9 not in keeping with Operations Management Procedure 1-8 (Authority and Responsibility of Licensed R0s and Licensed SR0s) which states in paragraph 7.2.A.3 that " licensed operators cannot delegate the operation of the " CONTROLS" of a unit, but may allow non-licensed operators to manipulate the " CONTROLS" under the direction of a licensed operator for training purpos OMP l-8 now states in paragraph 10.0 that a non licensed operato who is not in an approved licensed training class may never operate the controls, as defined earlier in section 7.2. However, an NLO doing control room observation may operate control room equipment under the direct observa- _

tion of an actively licensed R0 or SR0 within the surveillance area except control rod motion, boration, or dilution of the NC or ND system, turbine generator control, or steam generator inventory control (modes 1-4).

(Closed) Ifl 50-413,414/91-19-01, Documentation methods used to qualify trainees and/or note deficiencies was wea The review of the training records indicated that the standard was weakly enforced. Several student training records did not indicate the nethod employed in determining the trainee's qualifications. Also, interviews with qualifiers determined that when the qualifiers felt that the student did not possess sufficient knowledge for the task, they would send the trainee off to conduct further study rather than annotate the deficiency and send the record to PTS for evaluatio The team inspected the employee training and qualification standards. All ETQS guides were rewritten to provide an element which specifically requires a demonstration of mastery of prerequisite knowledges. The revised guides also specifically identified the lessor. plans which were =

prerequisites for each guide. The instructions for the program were revised to provide specific instructions and general standards for the evaluation of prerequisites and intersystem knowledg No violations or deviations were identifie . Exit Interview The inspection scope and findings were summarized on January 8, 1993, with those persons indicated in paragraph 1. The NRC described the areas inspected and discussed in detail the inspection finding No proprietary material is contained in this repor No dissenting comments were received from the license Item Number Status Descrintion. Paragraph 413,414/91-19-01 Closed IFl - Documentation methods used to qualify trainees and/or note deficiencies was weak, paragraph i

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Report Details 10 413,414/91-301-01 Closed IFl - Procedure OMP 1 8 does not clearly address what controls non-licensed operators can operate while under direct supervision of a licensed operator, paragraph 7,

413,414/93-01-01 Open Ifl - Corrective action implementation to j prevent a repeat of the October 1992 j initial examination high written failure rate, paragraph !

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^opendix A List of Acronyms A0P Abnormal Operating Procedure ATWS Anticipated Iransient Without Scram CA Auxiliary feedwater CfST Critical Safety function Status Tree E0P Emergency operating procedure ERG Westinghouse emergency response guidelines ETQS Employee Training Qualification and Standard FSAR final Safety Analysis Report HLP Hot License Preparation IAE Instrumentation and Electrical Ifl Inspector followup ltem JTA Job Task Analysis LOCA Loss of Coolant Accident NC Reactor Coolant System ND Residual Heat Removal System NLO Non-licensed Operator 0AC Operator Aide Computer OJT On the Job Training OMP Operations Management Procedure PORV Power operated relief valve PTS Production Organization Services SAT Systems Approach to Training SGTR Steam Generator Tube Rupture SM Main Steam SPDS Safety Parameter Display System SR0 Senior Reactor Operator STA Shift Technical Advisor TS Technical Specifications WOG Westinghouse Owners Group

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Appendix B List of Procedures List of Procedures AP/2/A/5500/19, REV 15 LOSS OF RESIDUAL HEAT REMOVAL SYSTEM EP/1/A/5000/01, REV 15 REACTOR TRIP OR SAFETY INJECTION l EP/1/A/5000/IE REV 14 STEAM GENERATOR 10BE RUPTURE l

EP/1/A/5000/lE3, REV 11 SGTR WITH CONTINUOUS NC SYSTEM LEAKAGE - SUBC00 LED l RECOVERY  ;

EP/1/A/5000/2Al, REV 4 NUCLEAR POWER GENERATION /ATWS  :

EP/1/A/5000/2Cl, REV 12 LOSS OF SECONDARY HEAT SINK EP/1/A/5000/2F3, REV 8 VOIDS IN REACTOR VESSEL OP/1/A/6450/10, REV 5 CONTAINMENT HYDROGEN CONTROL SYSTEM i PT/1/A/4600/09, REV 5 LOSS OF OPERATOR AID COMPUTER SD 3.0.11 (OPS), REV 3 RESPONSIBILITIES AND QUAllFICATIONS OF THE SHIFT MANAGER AND REQUIRED MANAGEMENT NOTIFICATION SD 3.0.11 (IS), REV 2 RESPONSIBILITIES AND QUAllFICATIONS OF THE SHIFT MANAGER SD 3.1.3.0, REV 5 UNIT SHUTDOWN CONFIGURATION CONTROL

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OMP l-8 REV 20 AUTHORITY AND RESPONSIBILITY OF LICENSED REACTOR OPERATORS AND LICENSED SENIOR REACTOR OPERATORS OMP 2-33, REV 15 VALVE AND BREAKER-POSITION VERIFICATION AND VALVE OPERATION-OMP 5-1 REV 1 DUTIES OF THE SHIFT MANAGER

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DPC ETQS, REV 10 STANDARD 1002.0 (0JT AND QUAllFICATIONS, RECORDS)

DPC ETQS, REV 5 STANDARD 401.0 (INSTRUCTOR TRAINING AND CERTIFICATION PROGRAM)

DPC ETQS,

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REV 1 STANDARD 404.0 (SELECTION AND TRAINING 0F 0JT TRAINERS AND QUALIFIERS)

COTG-07,. REV- 2 INITIAL-lNSTRUCTOR CERTIFICATION-AND REQUAllflCATION ADMINISTRATION

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