Information Notice 1995-24, Summary of Licensed Operator Requalification Inspection Program Findings

Summary of Licensed Operator Requalification Inspection Program Findings

ML031060193
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date:	04/25/1995
From:	Grimes B Office of Nuclear Reactor Regulation
To:
References
IN-95-024, NUDOCS 9504190049
Download: ML031060193 (12)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001

April 25, 1995

NRC INFORMATION NOTICE 95-24: SUMMARY OF LICENSED OPERATOR REQUALIFICATION

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice to alert addressees to deficiencies and weaknesses uncovered while

conducting its licensed operator requalification inspection program.

It is

expected that recipients will review the information for applicability to

their facilities and consider actions, as appropriate, to avoid similar

problems.

However, suggestions contained in this information notice are not

NRC requirements; therefore, no specific action or written response is

required.

Background

Effective March 11,

1994, the NRC amended Part 55, "Operators' Licenses," of

Title 10 of the Code of Federal Regulations (10 CFR) to eliminate the

requirement for licensed operators to pass a comprehensive requalification

written examination and an operating test conducted by the NRC during the term

of the operator's license. The amendment enabled the NRC to shift its focus

from examining individual operators for the purpose of license renewal to

evaluating the effectiveness with which facility licensees conduct their

requalification programs.

The NRC developed an inspection procedure (IP 71001), "Licensed Operator

Requalification Program Evaluation," to implement the new requalification

oversight program and to guide inspectors as they review the subject programs.

The procedure includes assessments of facility licensee effectiveness in:

-

evaluating trainee (operator and crew) mastery of the training

objectives as required by 10 CFR 55.59(c) and by element 4 of a systems

approach to training (SAT)-based program as defined in 10 CFR 55.4;

-

evaluating and revising the requalification program based on operator

performance as required by 10 CFR 55.59(c) and by element 5 of a SAT-

based program;

-

ensuring the integrity of requalification examinations and tests as

required by 10 CFR 55.49; and

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11

I

IN 95-24 April 25, 1995 -

ensuring that licensed operators satisfy the conditions of their

licenses as specified in 10 CFR 55.53.

The NRC is using the inspection procedure to evaluate each licensed operator

requalification program at least once per Systematic Assessment of Licensee

Performance (SALP) cycle.

Discussion

During the period that the NRC conducted requalification examinations for the

purpose of renewing operator licenses (i.e., 1987 to 1993), the staff noted

significant improvements in the performance of the individual operators and

the quality of facility licensee evaluators and testing materials. As noted

in the March 1994 rule change, the NRC discontinued conducting routine

requalification examinations because licensees had established a high standard

of performance under the regulations and NRC examiners were largely

duplicating tasks that were required of, and routinely performed by, facility

licensees. The NRC resolved that it would not duplicate facility licensee

efforts to examine operators as long as the NRC staff remained confident that

the requalification program was maintaining licensed operator competence.

Facility licensees are expected to comply with the 10 CFR Part 55 requirements

for licensed operator requalification training and testing and with the

commitments contained in their respective NRC-approved requalification

programs.

Facility licensees having SAT-based requalification programs are

required by the NRC regulations to implement five program elements (i.e., Job

analysis, objective development, training design and implementation, trainee

evaluation, and program evaluation and revision) to ensure that licensed

operators and crews maintain the job performance standards necessary for

continued safe plant operation.

Furthermore, facility licensees must ensure

that operators comply with their 10 CFR Part 55 license conditions. As noted

earlier, the requalification program inspections conducted in accordance with

IP 71001 focus on many of these elements and factors. When necessary, the NRC

may inspect additional training program elements in accordance with IP 41500,

"Training and Qualification Effectiveness."

Since January 1993, the NRC has completed more than 50 requalification program

inspections using IP 71001 or its predecessor, Temporary Instruction 2515/117.

A number of specific findings, some of which were observed at several

facilities, are listed in Attachment 1.

The findings in Attachment 1 suggest that some facility licensees are relying

largely on the guidelines in NUREG-1021, "Operator Licensing Examiner

Standards,' for the development and administration of their requalification

examinations. NUREG-1021 provides instructions for conducting NRC

examinations only; it is not intended to be guidance on how to implement a

SAT-based training program or to ensure compliance with all the regulations

applicable to requalification examinations.

For example, the crew-based

dynamic simulator evaluation procedure in NUREG-1021 does not ensure that each

licensed operator will be individually evaluated during an operating test as

required by 10 CFR 55.59(a).

IN 95-24 April 25, 1995 The findings in Attachment 1 also indicate that the level of difficulty of

examinations at some facilities was questioned as to whether facility

licensees could determine that the operators had mastered their Job

performance requirements as stipulated by element 4 of a SAT-based training

program or whether the examinations would sufficiently require an operator to

demonstrate an understanding of and the ability to perform the actions

referenced by 10 CFR 55.59(a)(2)(ii). Simulator scenarios that verify

operator ability to implement the emergency operating procedures (EOPs) were

questioned as to whether they were at the level of difficulty necessary to

adequately complete the assessment.

The requalification inspections have identified a number of weaknesses and

deficiencies.

10 CFR 55.59(c) allows a facility licensee significant latitude

in the implementation of its requalification program if the licensee adopts a

systems approach to training. Many of the issues described in Attachment 1 are performance-based issues that raise questions regarding the effectiveness

of facility licensee training and testing programs.

Although the staff has not judged the findings at specific facilities to be of

sufficient concern, to date, to warrant NRC conducting requalification

examinations, it has concluded that the findings are sufficient in number and

significance to share them with the industry.

If an NRC inspection determines

that a requalification program is ineffective or if the staff concludes that

the inspection process will not provide the insight necessary to confirm the

adequacy of the program, the NRC may exercise its discretion, per 10 CFR

55.59(a)(2)(iii), and conduct requalification examinations in accordance with

NUREG-1021.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

g 8 ia' K.%ric

lrect

D vision of Projects Support

Off ice o Nuclear Reactor Regulation

Technical contacts: Stuart Richards, NRR

Mark Ring, R111

(301) 415-1031

(708) 829-9703 Glenn Meyer, RI

John Pellet, RIV

(610) 337-5211

(817) 860-8159 Thomas Peebles, RII

Neal Hunemuller, NRR

(404) 331-5541

(301) 415-1152 Attachments:

1. Program Deficiencies Identified by Inspections

2. List of Recently Issued NRC Information Notices

0-dt41

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Attachment 1

IN 95-24 April 25, 1995 PROGRAM DEFICIENCIES IDENTIFIED BY INSPECTIONS

Trainee Evaluation

-

The dynamic simulator scenario banks at some facilities did not contain

any shutdown scenarios or failed to adequately exercise the contingency

actions of the EOPs.

-

Some of the dynamic simulator scenarios consisted of unrelated events or

had critical tasks that could not discriminate between acceptable and

unacceptable operator performance because they were impossible to fail.

-

In one instance, written test items were worded in such a way that the

person taking the test could possibly select the correct answer based

solely on question construction.

-

The Job performance measures were sometimes overly simple and had little

evaluative merit (e.g., push one button) or they had procedural

verification steps that were inappropriately identified as critical to

task completion.

Some facility licensees were not able to explain their SAT-based

rationale for selecting the control manipulations that were included in

their training syllabus, the appropriate mode of completion (i.e.,

performance, supervision, or observation), or the method for evaluating

whether the operators had mastered the job performance requirements.

The written examinations and operating tests (walk-through and dynamic

simulator) at some facilities were so basic that it was questionable

whether the examinations and tests could adequately evaluate operator

performance or the effectiveness of the training or identify areas

needing improvement. The questions, job performance measures, and

scenarios did not test the operators at the comprehension and analysis

levels of knowledge, but strictly at the memorization level.

Some facilities did not sufficiently control how many test items were

repeated between practice and comprehensive examinations or among

successive examinations (i.e., week-to-week or year-to-year). Other

facilities attempted to avoid duplication by revising their dynamic

simulator scenarios between administrations, but the revisions were so

superficial that the types and sequence of malfunctions and the required

operator actions and mitigation strategies were essentially unchanged.

One facility that almost always operates with only two reactor operators

(ROs) on a control room crew, used three ROs on some of its dynamic

simulator examination crews in order to reduce the number of scenarios

required to conduct the examinations.

The operators at some facilities were given little or no retraining on

weak areas unless they failed the examination. Sometimes retesting did

not sufficiently address areas identified as weak.

Attachment 1

IN 95-24

April 25, 1995 Trainee Evaluation

-

The dynamic simulator scenario banks at some facilities did not contain

any shutdown scenarios or failed to adequately exercise the contingency

actions of the EOPs.

-

Some of the dynamic simulator scenarios consisted of unrelated events or

had critical tasks that could not discriminate between acceptable and

unacceptable operator performance because they were impossible to fail.

-

In one instance, written test items were worded in such a way that the

person taking the test could possibly select the correct answer based

solely on question construction.

-

The Job performance measures were sometimes overly simple and had little

evaluative merit (e.g., push one button) or they had procedural

verification steps that were inappropriately identified as critical to

task completion.

Some facility licensees were not able to explain their SAT-based

rationale for selecting the control manipulations that were included in

their training syllabus, the appropriate mode of completion (i.e.,

performance, supervision, or observation), or the method for evaluating

whether the operators had mastered the job performance requirements.

The written examinations and operating tests (walk-through and dynamic

simulator) at some facilities were so basic that it was questionable

whether the examinations and tests could adequately evaluate operator

performance or the effectiveness of the training or identify areas

needing improvement. The questions, job performance measures, and

scenarios did not test the operators at the comprehension and analysis

levels of knowledge, but strictly at the memorization level.

Some facilities did not sufficiently control how many test items were

repeated between practice and comprehensive examinations or among

successive examinations (i.e., week-to-week or year-to-year). Other

facilities attempted to avoid duplication by revising their dynamic

simulator scenarios between administrations, but the revisions were so

superficial that the types and sequence of malfunctions and the required

operator actions and mitigation strategies were essentially unchanged.

One facility that almost always operates with only two reactor operators

(ROs) on a control room crew, used three ROs on some of its dynamic

simulator examination crews in order to reduce the number of scenarios

required to conduct the examinations.

The operators at some facilities were given little or no retraining on

weak areas unless they failed the examination.

Sometimes retesting did

not sufficiently address areas identified as weak.

Attachment 1

IN 95-24 April 25, 1995 The evaluators at some facilities did not identify areas in which

retraining was needed to upgrade licensed operator knowledge because

they graded their operators exclusively on the basis of completing

critical tasks and did not conduct any individual competency evaluations

unless an operator failed.

Program Evaluation and Revision

Some licensed operator requalification training programs did not always

close the feedback loop by informing the originators of training

comments how their concerns were resolved.

Examination and Test Integrity

Some facility licensees permitted training personnel who had specific

knowledge of the examination content to continue their routine training

activities, thereby introducing the appearance of impropriety and the

possibility that examination integrity could be compromised.

Some facility licensees took minimal action to keep their operators

separated while individual examinations were in progress or to review

the examination results for possible indications that security had been

compromised.

Compliance with Operator License Conditions

One facility licensee failed to ensure that all of its licensed

operators completed the requalification training required by

10 CFR 55.53(h) and 55.59(a)(1).

Some licensees were in violation of 10 CFR 55.53(e) and (f) because they

performed or directed licensed activities without meeting the

requirements for maintaining an active license or because they returned

to licensed duties before completing the required reactivation training.

Some licensees were in violation of 10 CFR 55.53(i) because they did not

receive the required biennial medical examination.

In some instances, facility licensees neglected to inform the NRC of

permanent changes in licensed operator medical status (e.g., a medical

defect that might necessitate a conditional license or disqualify the

operator) as required by 10 CFR 55.25.

KY_

4tiachment 2 IN 95-24

April 25, 1995 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information

Date of

Notice No.

Subject

Issuance

Issued to

95-23

95-22

95-21

94-64, Supp. 1

95-18, Supp. 1

95-20

Control Room Staffing

Below Minimum Regulatory

Requirements

Hardened or Contaminated

Lubricants Cause Metal

Clad Circuit Breaker

Failures

Unexpected Degradation

of Lead Storage Batteries

Reactivity Insertion

Transient and Accident

Limits for High Burnup

Fuel

Potential Pressure-Locking

of Safety-Related Power-

Operated Gate Valves

Failures in Rosemount

Pressure Transmitters

due to Hydrogen Per- meation into the Sensor

Cell

04/24/95

04/21/95

04/20/95

04/06/95

03/31/95

03/22/95

All holders of OLs or CPs

for nuclear power reactors

and all licensed operators

and senior operators at

those reactors.

All holders of OLs or CPs

for nuclear power reactors.

All holders of OLs or CPs

for nuclear power reactors.

All holders of OLs or CPs

for nuclear power reactors

All holders of OLs or CPs

for nuclear power reactors.

All holders of OLs or CPs

for nuclear power reactors.

95-19

Failure of Reactor Trip

Breaker to Open Because

of Cutoff Switch Material

Lodged in the Trip Latch

Mechanism

03/22/95

All holders of OLs or CPs

for nuclear power reactors.

95-18 Potential Pressure-Locking

of Safety-Related Power-

Operated Gate Valves

03/15/95

All holders of OLs or CPs

for nuclear power reactors.

OL = Operating License

CP = Construction Permit

IN 95-24 April 25, 1995 The findings in Attachment I also indicate that the level of difficulty of

examinations at some facilities was questioned as to whether facility

licensees could determine that the operators had mastered their Job

performance requirements as stipulated by element 4 of a SAT-based training

program or whether the examinations would sufficiently require an operator to

demonstrate an understanding of and the ability to perform the actions

referenced by 10 CFR 55.59(a)(2)(ii). Simulator scenarios that verify

operator ability to implement the emergency operating procedures (EOPs) were

questioned as to whether they were at the level of difficulty necessary to

adequately complete the assessment.

The requalification inspections have identified a number of weaknesses and

deficiencies.

10 CFR 55.59(c) allows a facility licensee significant latitude

in the implementation of its requalification program if the licensee adopts a

systems approach to training. Many of the issues described in Attachment 1 are performance-based issues that raise questions regarding the effectiveness

of facility licensee training and testing programs.

Although the staff has not Judged the findings at specific facilities to be of

sufficient concern, to date, to warrant NRC conducting requalification

examinations, it has concluded that the findings are sufficient in number and

significance to share them with the industry. If an NRC inspection determines

that a requalification program is ineffective or if the staff concludes that

the inspection process will not provide the insight necessary to confirm the

adequacy of the program, the NRC may exercise its discretion, per 10 CFR

55.59(a)(2)(iii), and conduct requalification examinations in accordance with

NUREG-1021.

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

orig /s/'d by BDLiaw/for

Brian K. Grimes, Director

Division of Projects Support

Office of Nuclear Reactor Regulation

Technical contacts:

Stuart Richards, NRR

Mark Ring, RIII

(301) 415-1031

(708) 829-9703 Glenn Meyer, RI

John Pellet, RIV

(610) 337-5211

(817) 860-8159 Thomas Peebles, RII

Neal Hunemuller, NRR

(404) 331-5541

(301) 415-1152 Attachments:

1. Program Deficiencies Identified by Inspections

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: 95-24.IN

• See previous concurrence

To receive a copy of this document, Indicate In the box 'C'

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IN 95-XX

April xx, 1995 This information notice requires no specific action or written response.

If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Projects Support

Office of Nuclear Reactor Regulation

Technical contacts:

Stuart Richards, NRR

(301) 415-1031

Mark Ring, RIII

(708) 829-9703

Glenn Meyer, RI

(610) 337-5211

Thomas Peebles, RII

(404) 331-5541

John Pellet, RIV

(817) 860-8159

Neal Hunemuller, NRR

(301) 415-1152 Attachments:

1. Program Deficiencies Identified by Inspections

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME:

G:\\NKH\\INFONOTE.95

• See previous concurrence

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To receive a copy of this document, Indicate In the box: I'C

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OFFICE

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IN 95-XX

March xx, 1995

Pag

of 4 This information notice requires no specific action or written esponse. If

you have any questions about the information in this notice, lease contact

one of the technical contacts listed below or the appropri e Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Gri es, Director

Division o Projects Support

Office o Nuclear Reactor Regulation

Technical Contacts: Stuart Richards, NRR

Mark Ring, RIII

(301) 415-1031

(708) 829-9703 Glenn Meyer, RI

John Pellet, RIV

(610) 337-521

(817) 860-8159 Thomas Peebles, RII

Neal Hunemuller, NRR

(404) 331-5541

(301) 415-1152 Attachments:

1. Program Deficiencies Identified by Inspections

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\\NKH\\INFONOTE.95

• See previous concurrence

To receive a copy of this document, Indicate In the box: 'C -

Copy without attachmentlenclosure 'Et

Copy with attachment/enclosure

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IN 95-XX

March XX, 1995 This information notice requires no specific action r written response.

However, you are encouraged to review your licens

operator requalification

program to ensure it meets all applicable requi

ments and commitments.

If

you have any questions about the information

this notice, please contact

one of the technical contacts listed below

the appropriate Office of

Nuclear Reactor Regulation (NRR) project

nager.

Brian K. Grimes, Director

Division of Projects Support

Office of Nuclear Reactor Regulation

Technical Contacts:

Stuart Richards, NRR

Mark Ring, RIII

,"(301) 415-1031

(708) 829-9703 Glenn Meyer, RI

John Pellet, RIV

(610) 337-5211

(817) 860-8159

/

Thomas Peebles, R11

(404) 331-5541 Attachments' List of Recently Issued NRC Information Notices

DOCUMENT AAME: G:\\GUENTHER\\INFONOTE.95

• See previous concurrence

To receive a copy of this document, Indicate In the box 'C

- Copy without attachnent/anclosure

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- Copy with attachmentlenclosure

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-

IN 95-XX

February XX, 1995

Secondly, the NRC is concerned, based on its observations to date, that the

level of difficulty of examinations at some facilities may degrade to the

point that the examinations will not be sufficiently challand

discriminatory to determine whether the operators ILve-fltereUm their job

performance requirements as required by e1em

of a SAT-based training

program or will not sufficiently re uire-a operator to demonstrate an

understanding of the ability to pe

actions referenced by

10 CFR 55.59(a)(2)(ii). In pa

cular, the NRC is concerned that simulator

scenarios which verify an

rator's ability to implement the EOPs could lack

the level of difficult

ecessary to adequately complete the assessment.

Consistent with per r

se

r:0h

Ins, there is no regulatory

requirement which sp cifically defines the ap

iate level of difficulty, however for reference licensees should note that

55 was amended to change

the NRC's involvement based largely on the level of pe

ormance reached by the

industry in 1993, and in the area of simulator scenarios

he level of

difficulty at that time was largely defined by the guidance ontained in

NUREG-1021.

Licensees are reminded that if an NRC inspection determines t at a

requalification program is ineffective or if the staff conc

des that the

inspection process will not provide the insight nec

to confirm the

adequacy of the program, the NRC may

s

discretion, per 10 CFR

55.59(a)(2)(iii), and cond

ua ification examinations in accordance with

NUREG-1021.

This information notice re

o specific action or written response.

However, you are encouraged to rev e

ur licensed operator requalification

program to ensure it meets all applica le

irements and commitments. If

you have any questions about the information in is notice, please contact

one of the technical contacts listed below or the a

opriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Brian K. Grimes, Director

Division of Projects Support

Office of Nuclear Reactor Regu ation

Technical Contacts:

Stuart Richards NRR

Mar

i i5~- M-

I(708)

829-9703 Glenn Meyer, RI

John Pellet, RIV

211

(817) 860-8159

Thomas Peebles

(404) 331-5541 Attachment: List of Recently Issued NRC Information

ices

DOCUMENT NAME: G:\\GUENTHER\\INFONOTE.95 To receive a copy of this document, Indicate In the box: 'C -- Copy without attachrentlenciosure

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