IR 05000400/1990025

Insp Rept 50-400/90-25 on 901217-19.No Violations Noted. Major Areas Inspected:Simulator Exam Techniques,As Used in Licensed Operator Training Program

ML20128P608
Person / Time
Site:	Harris
Issue date:	01/16/1991
From:	Baldwin R, Mellen L, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128P607	List: IR 05000400/1990025 ML20128P603
References
50-400-90-25, NUDOCS 9610180023
Download: ML20128P608 (8)

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, s UNITED STATES p e terg^o i

3-NUCLEAR REGULATORY COMMISSION  ;

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, REGION 11 l

g 'j 101 MARIETTA STREET. j l * * ATLANTA, GEORGI A 303 \...../

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i Report No.: 50-400/90-25

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Licensea: Carolina Power and Light Company

' Box 1551 Raleigh, NC 27602 a

Docket No.: 50-400 License No.: NPF-63

) Facility Name: Shearon Harris

Inspection conducted

December 17 through December 19, 1990

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I Inspector:

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'L. Mellen

! u b' / //6 /9 f Ddte ' Signed i j rn t .b o llin/9s p r8 ft.~ Baldwin

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Dite/ Signed i

Approved by:

L. Wat' son, IChief

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f Datie Slg~n'ed Operational Programs Section

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Division of Reactor Safety

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! SUMMARY Scope:

l h This ww:, a special unannounced inspection in the area of simulator i examination techniques, as used in the licensed operator training program. The inspection's purpose was to verify that the Shearon j Harris Licensed Operator Requalification Examination techniques met i

requirements of the NRC and the licensee's approved program.

-j Results:

I Requalification examination techniques were found to be technically i adequate and found to meet NRC requirement The overall

assessment was the licensee needed to improve their practices in three area Tho specific areas that needed improvement were

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dissemination of significant procedural issues (paragraph 2), the number of available simulator scenarios (paragraph 4), and the use of simulator examination scenarios for licensed instructors (paragraph 6).

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-REPORT DETAILS I Persons Contacted'

Licensee Employees

• Boska, Manager - License Training

• Collins, Manager - Operations

• Martin, Manager - Nuclear Training

• Olexik, Manager - Regulatory Compliance

• w. Powell, Manager - Training a. Smith, Senior Specialist operator Training other licensee employees contacted included operators, trainers, and office personne NRC Resident Inspectors

• J. Tedrow, Senior Resident Inspector

• M. Shannon, Resident Inspector

• Attended exit interview on December 19, 199 . Individual Simulacor Critical Tasks for the Requalification Program l

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The inspectors met with training and operations management and i reviewed the records of the last NRC required, annual licensee administered, operator requalification examinatio These examinations were administered in October and November of 199 Several simulator scenarios were reviewed as administere Simulator Scenario l'i . 07 consisted of a pressurizer steam break loss of coolant acciden During Emergency Operating Procedure useage in this scenario two of three crews evaluated

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tripped the Reactor Coolant Pumps in accordance with the l Foldout A for Path 1 criteria; however, this was not - in accordance with the intent of the procedure as described in

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the Westinghouse Owners Group background document. The third l

crew acted in accordance with the intent.of the procedure;

however, their actions were not in accordance with the l procedur Foldout A for Path 1 stated "CSIP - AT LEAST ONE

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RUNNING", this terminology was not consistently interpreted between operating crew It was evident from the actions of the three crews that not all crews would have performed the i

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req m el actio The intent of this step was to ensure the core had adequate safety injection flow prior to stopping the

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Reactor Coolant Pump Only the crews involved received

[ remedial training after the simulator examination was i completed.

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This problem in procedural interpretation was initially identified by the licensee on July 7, 1989, in Operations Feedback Report 1528. However, the updating of this procedure j was not scheduled on a priority basis and was to be included

in the next Emergency Operating Procedure revision that will be completed by nid-1991.- The training department issued an additional Operations Feedback Report following their annual requalification examination During the inspection, Operations Management stated that this procedural interpretation would be included in real time training of all shifts and would be accomplished by January 11, 1991. This would ensure that indication of Safety Injection flow will be required to meet Reactor Coolant Pump tripping criteri Some discussion occurred as to whether the step requiring the tripping of the RCPs should have been designated an Individual Simulator Critical Task due to the way the scenario unfolde the inspectors agreed with the licensee that this step was not and should not nave been, designated as an ISCT in tne scenario, as t' 're was no evidence the plant was degraded by not having Re~ ~. Coolant Pump flow without Charging and Safety Inject 'n Pump flo The licensee had evaluated thi step prior to 4.he examinations and determined the appropriate Individual Simulator Critical Task was the establishment of Alternate Safety Injection flo ~~

The inspectors questioned the timeliness of the dissemination i of significant procedural issues identified by the training departmen The licensee committed to review this practice I and make the appropriate change . Simulator Examination Security Crew Separation During Annual Simulator Requalification l Examination During simulator examinations the same scenarios were used for each of the crews that were examined in a single day. Each crew of examinees received a briefing prior to their examination. The simulator examination briefing check list contained a requirement that stated: "No aspects of this examination should be discussed with any other examinees until the conclusion of the examination."

The crews were cautioned during the simulator briefing,

"as a minimum the exams would have to be repeated based on even the appearance of compromise." However, on days when more than two crews were examined, the first crew received their examination while the second crew was sequestere Once the first crew was examined and had been released from the examination process, the second crew entored the simulator for testing, thus maintaining e

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1 crew separatio The remaining crews were not This provided potential examination

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sequestere compromise, in that the first crew could have conceivably interacted with the third and/or fourth' crews, allowing information about the scenario to be exchanged. The crews were not required to sign examination security agreements. There were no instructions to the operators to preclude the discussion of their individual examinations with operators of subsequent week , When NRC administers examinations, NRC requests that the

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released personnel do not discuss the examination with others who have not taken the examination and that they

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depart the site for the day.

, Prior Knowledge of Simulator Scenarios During Annual Requalification Examinations.

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The inspectors determined there were three cases of licensed instructors evaluating a specific scenario, and i subsequently being evaluated on the same scenari This was caused by a limited number of scenarios and a lack of prudent scheduling of licensed instructors' examination The ramifications of the limited number of scenarios are addressed in paragraph 4, and the licensed instructor examinations in paragraph 6.

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The simulator area and booth were closed to all future examinees during the annual examination proces The annual simulator requalification examinations were viewed

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by operations management; however, they were not viewed i by any other operators. Therefore, there was no evidence  !

4 of compromise caused by prior witnessing of the annual

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simulator examinations.

. Prior Knowledge of Simulator Scenarios During Weekly 4 Training Evaluations.

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l The licensee's requalification program requires weekly l training evaluations and were reviewe l The simulator area and booth were not closed to all future examinees during the weekly evaluation proces This aspect of examination security primarily concerned management representatives that acted as the operations l Management Representative. Shift Foremen were tasked to l Operations

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fulfill 'the position of Management Representatives in the observation of weekly simulator training as well as weekly simulator evaluation This had the potential for Shift Foremen to witness performar.ce of specific scenarios prior to their i

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evaluation on these scenario This practice was in accordance with program guidance; however, it could lead to non-representative evaluations, in that the Shif t Foremen could have witnessed the evaluation scenario prior to being tested on that scenari A contributing factor was that the same' simulator evaluation was used for all the weekly evaluations for the particular segment being conducted. A' review of the available information indicated that Shift Foremen did not observe the evaluation scenario prior ta their weekly evaluation ,

The licensee stated that the instructions to 0perations Management Representatives designees will be revised to

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preclude the possibility of future compromis . shift Technical Advisor Prior Exposure to Simulator

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Examination Scenarios A different Shif t Technical Advisor was not available for each crew'for the annual examination. This resulted in Shif t Technical Advisors performing their duties for some scenarios more than once with different operating crew During the simulator . portion of the requalification examination given between October 16 and November 13, 1 1990, two Shift Technical Advisors repeated four j s ~~' scenarios with different crew One of the Shift i Technical Advisors performed the sarae scenario with three e different crew In all cases the Shift Technical Advisors were instructed to provide only specific information to the operating cre The instruction further stated the Shift Technical Advisor should provide other information only if specifically directed. - Without a fully. participating Shift Technical Advisor, the operating crew was not evaluated as a complete team, in that the normal flow of information from the Shift Technical Advisor was not given and therefore the crews use of this information was not evaluate Since the annual requalification examinations were completed, two additional Shift Technical Advisors have been added to the staf This.should minimize the limitations imposed on the operating crew by a restricted Shif t Technical Adviso . Available Simulator Scenarios There were a total of 15 simulator scenarios in the

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examination ban The licensee r,tated that five simulator scenarios required additional work before they were considered acceptable for use as requalification examinations, and one modified scenario was used for a practice examinatio Therefore, only nine simulator scenarios were available for use during the annual requalification examination, and per the

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Examiner Standards this did not meet the criteria for aaking them publi The licensee has not released the simulator '

examination scenario Due to the limited quantity of scenarios, licensed instructors who evaluated the performance of a crew of operators were subsequently examined on the identical scenario three weeks late This practice had the potential to reduce the effectiveness of the examination I process in that it may not have thoroughly evaluated those licensed instructors who had prior knowledge of the scenario This is further discussed in paragraph The use ot only nine simulator scenarios in the examination j process led to some repetition of scenario The reduced number of scenarios resulted from the implementation of NUREG-1021, Revision 6. The licensee decided to implement Revision 6 for the October 15, 1990, annual requalification examination Extensive modifications were required to the simulator scenarios due to NUREG-1021, Revision 6 clarification-of the definition of Individual Simulator Critical Task The licensee determined that only ten of the fifteen existing 1 simulator scenarios could be upgraded by the October 15, 1990, annual requalification examination i" The licensee was continuing the simulator scenario upgrade ,

progra By the July 1991 annual requalification examination l there will be twenty NUREG-1021, Revision 6 scenarios read'f for us The licensee does not release the simulator examination scenarios to the operator A licensee procedure

- for examination security (TI-905) required at least a 40%

change in examinations given on successive week The inspectors confirmed this requirement was me The licensee has implemented the drafting of a CP&L Administrative Instruction that will include not using the same scenario on multiple weeks during future annual i examinations. This Adninistrative Instruction will apply to  !

the three CP&L Nuclear Plant . Simulator Examination Objectivity Licensed instructors were tasked to evaluate crews that contained other licensed instructor These examinees would subsequently evaluate a crew that contained licensed instructors that had been their evaluators. A compromise of objectivity could have arisen if the examiner and the examinee exchangled places. The inspectors reviewed this area and found s that licensed instructors were-not reciprocal evaluator _ . _ _ _ _ -

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6. Simulator Examination for Licensed Instructors The inspectors reviewed scenarios giver. to all licensed instructors during the past requalification examination cycl l It was determined that in three cases licensed instructors l received a simulator examination scenario, for their annual requalification examination, they had used to evaluate other J licensed weeks

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operators during previous of the requalification examination schedule. In all cases the period from which a licensed instructor acted as an examiner to the time the licensed instructor acted as an examinee was at least three week The licensed instructors received a total'of I three simulator scenario examinations,. one of which they had previously evaluated. Upon review of the crew complement for i the three scenarios, it was noted that two of the three  !

licensed instructors stood the Senior control Operator position during the scenario they had previously evaluated, this was the position for which they hold a license and must ,

be thoroughly evaluated annuall '

The licensed instructors have access to the entire examination bank and have had access to all scenarios prior to being i evaluated on the scenario The licensed instructors l y table-topped the simulator scenarios prior to administering I the examinations. The training organization considered this ~

to be appropriate because the licensed instructors were unaware of the specific scenarios that would be included in their examinatio The requirements of 10 CFR 55 paragraph 55.59 (a) (2) require licensed personnel to participate in requalification and to participate in the annual examinations. Additionally, NUREG-1262, Question 345 (pg 94) states, in part "...will the SRO who writes the performance exam, and is thus exempt from taking the exam for. that year, comply with this (55.59(a)(2))

requirement?" Answer, "it is the Commission's intent that all licensed operators be enrolled in the requalification program and take the requalification exams; further, an individual must take an exam that he did not write or review."

Af ter the licensee reviewed the inspectors' findings, the licensee determined that this was not a suitable practice. The licensee committed to review this practice W make changes that were appropriate. Additionally, the licensee committed to prevent the three licensed instructors from standing watch until this situation was evaluated.

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7. Exit Interview The inspection scope and findings were summarized on December 19, 1990, with those persons indicated in paragraph 1. The inspectors described the areas inspected and l l

discussed in detail the inspection findings. No proprietary i l material is contained in this report. No dissenting comments l were received from the license ;

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