IR 05000440/1998021

Insp Rept 50-440/98-21 on 981019-22.No Violations Noted. Major Areas Inspected:Licensed Operator Requalification Program

ML20195J053
Person / Time
Site:	Perry
Issue date:	11/18/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195J037	List: IR 05000440/1998021 ML20195J031
References
50-440-98-21, NUDOCS 9811240184
Download: ML20195J053 (15)

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n l U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 50-440 License No: NPF-58 Report No: 50-440/98021(DRS)

. Licensee: Centerior Service Company Facility: Perry Nuclear Power Plant l

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Location: P. O. Box 97, A200 Perry, OH 44081 l

Dates: October 19 - 22,1998 Inspectors: R. M. Bailey, Reactor Inspector A. M. Stone, Reactor Inspector j I

Approved by:

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Melvyn Leach, Chief, Operator Licensing Branch Division of Reactor Safety

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9811240184 981118 PDR ADOCK 05000440 0 PDR _

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l l EXECUTIVE SUMMARY l

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Perry Nuclear Power Plant NRC Inspection Report 50-440/98021 This inspection report contains the findings and conclusiens from our inspection of your licensed operator requalification training program. The inspection included a review of the following: selected training manual procedures, annual written and operating examination material, licensed operator and evaluator performance during the administration of the l operating examination, program controls to assure a continued systems approach to training, l and continuing training records. In addition, the inspectors observed a period of control room i operations. The inspectors used the guidance in inspection procedures 71001 and 7170 Operations Licensed operators on shift in the control room area executed their duties in a professional manner and in accordance with station procedures and management expectation (Section 01.1)

Trainina Proaram In general, licensed operators at the plant specific simulator executed their duties in a safe manner during abnormal and emergency conditions, and in accordance with station procedures and management expectations. The licensee correctly identified minor deficiencies in individual performance which did not impact the crew's ability to implement necessarv safeguards measures. (Section 04.1)

The licensed operator continuing training program provided appropriate :mung on lessons learned from significant industry events. (Section 05.1)

The annual requalification examination for licensed operaters had been developed such that the minimum regulatory requirements were satisfied. However, specific weaknesses in the individual development of NRC-style performance evaluations (Job Performance Measures -

JPM format) and a lack of documented management validation and review demonstrated a lack of quality control. (Section 05.2)

Annual requalification examinations were administered according to program guidance and consistent with regulatory guidelines. Experienced evaluators were being used to verify operator mastery of needed skills. (Section 05.3)

Adequate evaluation means were in place to provide positive feedback into the licensed operator continuing training program. The variety of methods provided for operator feedback was a program enhancement. (Section 05.4)

l Licensed operator performance deficiencies requiring remediation training were appropriately l

identified, assigned, and completed prior to returning an operator to licensed dutie l

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- Satisfactory operator performance with noted weaknesses was given an appropriate level of remediation training. (Section 05.5)

The licensee appropriat'ely maintained individual operator licenses in an active status and ensured the medical fitness of each licensed operator consistent with program guidelines and in

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compliance with regulatory requirements.- (Section 05.6)

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The plant specific control room simulator provided consistent, realistic plant conditions under abnormal and emergency transients.- (Section 05.7)-

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Report Details I, Operations 01 Conduct of Operations i

01.1 Control Room Observations Insoection Scope (IP-71707 and IP-71001)  !

The inspectors observed routine control room activities during full power operation, performed a control panel walk-down, reviewed operator logs, and questioned operators l about plant and equipment status. In addition, the inspectors reviewed administrative procedure PAP-0201, " Conduct of Operations," Revision 9, for guidance on licensed operator conduct in the control roo Observations and Findinas Control room operators performed periodic reviews of control panel indications in the i

horseshoe area per management expectations. Panel annunciators were acknowledged i and the supervising operator was informed of equipment status in a timely manne Operator logs were neat and generally contained sufficient detail on plant statu Operators demonstrated appropriate knowl6dge on equipment operability and plant status. Operations personnel used clear and concise conversation during routine communication Conclusions Licensed operators on shift in the control room area executed their duties in a professional manner and in accordance with station procedures and management expectations.

04 Operator Knowledge and Performance 04.1 Annual Evaluation Performance Review Inspection Scope (IP-71001)

The inspectors reviewed the performance of one operating crew during the annual licensed operator requalification operating examination. That crew consisted of a shift supervisor, a unit supervisor, and a shift technical advisor who were licensed senior reactor operators, and three control operators who were licensed reactor operators. The review included the following:

• NUREG-1021, " Operator Licensing Examination Standards for Power Reactors,"

Interim Revision 8, and

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• TMP-2002, " Licensed Operator Requalification Program," Revision 2/PIC-2,Section I Observations and Findinas The operating crew successfully completed each crition ! <,k as identified in the dynamic ,

simulation test. In addition, all six licensed operators d cossfully completed the  !

required five job performance measures (;i'M). The licensee evaluation team assigned !

a passing grade for each licensed operator's performance during the annual requalification examinatio However, the periodic crew briefings conducted by the unit supervisor did not always I include clear, consistent direction to the crew. For example, an operating band for l reactor vessel level control was not stated and a specific task assignment was not i defined, which created some confusion. These findings as ne? e , :s failure to enter an emergency procedure to start the Hydrogen ignition system ,;me also identified by the licensee evaluators. Individual operator performance weaknesses for five of the six licensed operators were icientified during the dynamic simulation evaluation and each operator was assigned additional training under the remediation program. (See Section j 05.5 for additional comments)  ;

The evalw an team's findings and conclusions on the crew's performance during the dynanne ;.mulation evaluation agreed with the inspectors' overall assessment. In adoEn, no individual performance weaknesses were noted or identified by the licensee I duri:rg the in-plant JPM performance evaluatio l Conclusions In general, licensed operators at the plant specific simulator executed their duties in a safe manner during abnormal and emergency conditions, and in accordance with station procedures and management expectations. The licensee correctly identified minor deficiencies in individual performance which did not impact the crew's ability to implement necessary safeguards mear,e.e OS Operator Training and Qualification 05.1 Ooeratina History Insoection Scona (IP-71001)

The inspectors reviewed the plant's operating history from October 1996 to September L 1998 to determine if any operator errors occurred that could be attributed to ineffective or inadequate training. That review included the following:

• Most recent Systematic Assessment of Licensee Performance (SALP-15) report issued April 7,1998, i 5 f

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e Selected routine NRC inspection reports, and  !

e Selected Licensee Event Reports (LERs).  ! Observations and Findinas The inspectors noted that previously identified knowledge weaknesses and performance deficiencies har' %en addressed in licensed operator continuing training. Related l

licensee event 's and industry events involving operations were also included in the -

continuing training, Conclusions

The licensN operator continuing training program provided appropriate training on lessons iearned from significant industry event .2 Reaualification Examination Material Iqspection Scope (IP-71001)

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The inspectors reviewed the licensee's licensed operator requalification program sample plan, and compared that with the written examinations and operating tests administered i during the annual evaluations. The following documents were reviewed:  !

• Inspection Plan IP-71001, " Licensed Operator Requalification Program Evaluation," Appendix A, e Two dynamic scenarios administered to one operating crew during the inspection l period, I e Ten JPMs administered to one operating crew during the inspection period, e Part A and Part B written questions administered to one operating crew during the inspection period, e One set of written questions and an operating test administered just prior to the inspection period,

'e Complete set of written questions and operating tests administered during the 1997 annual licensed operator requalification program evaluation, and

• TMP-2002, " Licensed Operator Requalification Program," Revision 2/PIC-2, Sections 3.0,6.5, and Observations and Findinas Tt e r.omprehensive written examination, which consisted of a Part A and Part 3, was ,

constructed in accordance with program guidelines and provided an effective evaluation {

tool. Part A incorporated the plant specific simulator and Part B required a broad use of plent procedures to answer the open-reference questions provided. The incpectors determined that the examinations were comprehensive and contained minimal duplicatio The dynamic simulation portion of the annual operating test incorporated diverse risk

l significant events; such as Anticipated Transient without Scram (ATWS) in both scenarios, and Reactor Pressure Vessel (RPV) and Containment control problem The scenarios contained credible events that included appropriate precursors and the i proper number of critical tasks. Major events were sequenced such that simultanecus I ma! functions did not requke outside operator assistance. However, a review of the dynamic scenario bank revealed that 75 percent of the examination bank involved an ATWS condition at the beginning of the major transient. The inspectors expressed a concem, with the high probability of having to respond to an ATWS event during an ,

examination process, that operator awareness would be heightened to prepare for such I an event. The licensee ackncwledged the inspectors' concern but stated that an ATWS condition was necessary, in most instances, to exercise the major portions of each !

emergency operating procedur l l

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The in-plant portion of the annual operating test contained diverse safety system performance tasks. Each one of the ten JPMs contained clear reference task elements '

and critical steps. The five JPMs selected for operator performance evaluation did not

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overlap between the reactor operator or senior reactor operator examines In general, the JPM performance checklists used during in-plant task simulation failed to provide needed evaluator cues or adequate evaluation standards. The following items are provided as examples: l

• JPM No.116," Locally Transfer Bus EH11 to the Preferred Source from the Diesel Generator," directed an operator to perform a bus transfer then leave the diesel generator running unloaded. The Performance Checklist contained sesan steps requiring operator action for w% h only one prescripted eva!aator cue was provided. The cue was an "if asked" response to inform the candidate that a rapid diesel generator load reduction was not required. The inspectors identified l that all of the performance steps required an evaluator response to acknowledge l the examinee's stated action.

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• JPM No. 488, " Control Room isolation - Diesel Generator Room Veno lation,"

l directed an operator to perform actions necessary to isolate the Division 1 diesel l generator ventilation. The Performance Checklist contained two performance steps for which no prescripted evaluator cues were provided. The inspectors i

identified that both performance steps required an evaluator response to l l acknowledge the examinee's stated action. In addition, the evaluation standard for both performance steps stated that an operator only had to locate the correct panel or controller, and state the required position. These performance standards failed to identify detailed control and indication criteria, such as switch position and indicator bulb illuminatio * JPM No. 95, " Alternate injection via Fuel Pool Cooling and Cleanup Header i using the Hotwell Dump Line," directed an operator to align the primary system for an attemate injection path using condensate water. The performance evaluation standard for each of the six steps was to have an operator identify the

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correct valve (s) and state the required position. These performance standards failed to identify detailed control and indication critena, such as switch position and indicator bulb illuminatio Section 6.6 of TMP-2002 stated in part that the continuing training element lead j instructor shall develop an operating test and a comprehensive written examination to be administered to all licensed operators during the annual requalification examinatio In addition, the operator training unit supervisor shall review and approve the licensed i operator requalification prograrn's written examinations and answer keys. However, the  ;

inspectors noted that no program guidance had been provided to ensure a unit

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supervisor review and approval of the operating tes i l

In addition, training manual administration instruction TMA-4114, " Performance Evaluation Preparation, Review, Approval, and Administration," Revision 1, contained a purpose statement that the guidelines for developing and administering performance evaluations were to be used to provide consistent, up-to-date, and repeatable performance evaluations. Section 6.2, " Criterion Checklist Preparation," of this instruction contained a statement that a validation review was required for JPMs that l

would be administered during an NRC licensed operator requalification program examinatio The inspectors identified that 4 of the 10 JPM descriptive outlines contained a reference to procedures that were not current. Specifically:

JPM No. 68F referenced sol-E22A, Revision 4 versus Revision 5; JPM No. 98B referenced 101-11, Revision 4, PIC-9, versus Revision 6. PIC-8; JPM No. 61 referenced sol-B33, Revision 5 versus Revision 6; and JPM Wo 95 referenced PEl-SPI 4.3, Revision 0 versus Revision The inspectors determined that the reference to an incorrect revision had no impact on the performance task, as outline The inspectors identified that no review signatures were available to verify management  !

representative validation of each JPM prior to administration. The licensee was unable to provide any documentation supporting the validation review of previously used JPMs.

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However, the inspectors determined that such a review had been conducted prior to the l annual operating test administration.

l l Conclusions The annual requalification examination for licensed operators had been developed such that the minimum regulatory requirements were satisfied. However, specific weaknesses in the individual development of NRC-style performance evaluations (Job

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l Performance Measures - JPM format) and a lack of documented management validation and review demonstrated a lack of quality contro .3 Reaualifgation Examination Administration Practices

, Inspectior Scoce (IP-71001)

The inspecors interviewed operations and training staff personnel, and performed the following to assess the licensee's practices regarding requalification examination j administration, evaluation, and security; I

L e Observed the licensee's administration and evaluation of the annuallicensed

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operator requalification operating examination for one operating crew, ;

e Reviewed TMP-2002, "l.icensed Operator Requalification Program," Revision 2/

, PIC-2, Section 6.6, and l e Reviewed NUREG-1021 " Operator Licensing Examination Standards for Power l Reactors," Interim Revision ! Observations and Findinas The annual operating test evaluations and the annual written examinations were administered to one operating crew during Cycle 11 training week. The licensee implemented appropriate security measures throughout the administration process. No l evidence of undue operator stress or examination comprornise was observed.

j Overall, the conduct of the operating test and the written examination was in accordance

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with program guidelines and consistent with regulatory requirements with one exception.

l The emergency procedure implementation run time for one scenario was approximately l 25 percent of the total run time. The NRC guidance contained in NUREG-1021 l recommended that 40 to 70 percent of the total run time be spent evaluating the

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implementation of emergency procedures. The inspectors determined that adequate

emphasis had been placed on emergency procedure usage and no programmatic l deviation had occurre The licensee provided each operator with a complete copy of the plant procedures during the Section B portion of the written examination. However, the licensee provided only one complete set of procedures during the Section A portion of the written

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examination. During the Section A administration portion, the operators consistently returned referenced books to their proper location, and did not mark or annotate in the l

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procedures. In addition, the operators frequently skipped a question until the required reference material was made available. The inspectors determined that the licensee's evaluator had maintained adequate control during the written examination proces The licensee's evaluation team during the dynamic simulation test included an operations department supervisor and two operations training department instructors for

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one operating crew which cnsisted of six licensed operators. The inspectors observed l that two of the evaluators provideo direct input to the crew in a support role; such as

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nuclear engineers, instrumentation technicians, or security personnel. The inspectors also observed that evaluators did not always accompany the reactor operators during back panel operations performed outside of the view of the operators in the horseshoe area. The inspectors noted that the additional duties could distract the evaluators during critical operator actions resulting in a missed opportunity to identify a performance concer In general, the licensee's evaluation team members were professional and able to maintain an overall awareness of operator performance. The evaluators also provided appropriate system response cues during the JPM tasks. The inspectors agreed with the evaluation team's findings and recommendations. The operating crew's performance on the written examination was satisfactory which was consistent with past operator performance. No programmatic deviations were note Conclusions Annual requalification examinations were administered according to program guidance and consistent with regulatory guidelines. Experienced evaluators were being used to verify operator master / of needed skill .4 Recualification Trainina Procram Feedback Insoection Scoce (IP-71001)

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The inspectors interviewed operations and training staff personnel, and reviewed tk following documents to assess the licensee's training program feedback system effectiveness:

• Quality Audit Report, PA 98-09, addressing July - September,1908, and e Quality Audit Report, PA 97-13, addressing July - August,199 Observations and Findinas The licensed operator requalification program incorporated an evaluation process that involved classroom, control room simulator, and on-the-job training activities which required management feedback on performance and a review committee's inpu Licensed operators and trainers were required to provide program evaluation feedback at the end of training sessions. Computerized feedback was encouraged to promote an exchange ofinformatio The inspectors received favorable inputs from the licensed operators and trainers interviewed on the feedback process. The most noted comment made was on the prompt response given to a concem or problem identified. The training crew mentor program was mentioned as a positive method for providing tecdhack to the training proces ,. -.- . - . . .. - . - - . _ . . . . . _ , . - - - . - - - . . . . - - . . . - . . . - . _

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. Adequate evaluation means were in place to provide positive feedback into the licensed operator continuing training program. The variety of methods provided for operator feedback was a program enhancemen .05.5 RemedialTrainino Proaram Inspection Scope (IP-71001)

The inspectors performed a review of the following remediation records and procedures l to assess the licensee's remediel training program effectiveness

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I e Completed remediation package for one licensed operator that failed two

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e Completed remediation packages for two licensed operators that failed the annual written examination in 1998, and e TMP-2002, " Licensed Operator Requalification Program," Revision 2/PIC-2,

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Each remediation package contained a discussion of the significant weaknesses identified, assigned training to improve awareness, required evaluation action, and the i

. approval authority at completion. In addition, each opc ator was allowed to review the individual evaluation summary sheet with noted deficiencies. The remediat!an actions j were consistent with program guidanc '

Licensed operators were removed from licensed duties whenever individual performance l

was deemed to be unsatisfactory. The remediation packages were completed, as L outlined, prior to returning the operator to licensed duties, in addition, any licensed L operator's performance deemed marginally satisfactory was given a remediation training package to be completed prior to the next training cycle.

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The licensee took prompt corrective action to provide remediation training for individual performance weakness noted on five of the six licensed operators evaluated during the current annual examination. None of the individual operators were required to be l removed from licensed duties which was consistent with program guidance and in L compliance with regulatory requirement Conclusions

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Licensed operator performance deficiencies requiring remediation training were

. appropriately identified, assigned, and completed prior to returning an operator to

, licensed duties. Satisfactory operator performance with noted weaknesses was given an

. appropriate level of remediation training.

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05.6 Conformance with Operator License Conditions Inspection Scope (IP-71001)

The inspectors reviewed the licensed operator medical and active license qualification programs to assess licensed operator compliance with regulatory requirements and the following licensee procedures and records:

• TMP-2002, " Licensed Operator Requalification Program," Revision 2/PIC-2, Sections 6.7 and 6.8,

• HRI-0001, " Nuclear Reactor Operator Health Assessment," Revision 0/PIC-11, e

American National Standard Institute /American National Standard (ANSI /ANS)

3.4-1983, and e Seven licensed operator medical records selected at random e Licensed dut'es tracking databas Observations and Findinas Licensed operator medical examination dates and the documentation of test results were consistent with program guidance and in compliance with regulatory requirements to examine on a biennial basi Operators assigned to perform licensed duties during routine plant operations had valid licenses based upon maintaining a satisfactory participation in the licensed operator requalification training program. One operator who failed to maintain an active status was required to complete an inactive license retraining program prior to resuming licensed duties. Ali operators assigned a valid and active license were consistent with program guidelines and in compliance with regulatory requirement Conclusions The licensee apprcpriately maintained individual operator licenses in an active status and ensured the medical fitness of each licensed operator consistent with program guidelines and in compliance with regulatory requirement .7 Simulator Fide!!!y Inspection Scoce (IP-71001)

The inspectors reviewed the effectiveness of the licensee to identify and correct simulator discrepancies, and noted any simulator fidelity issues identified during the operating examination. The inspectors performed the following:

• Observed the annual operating examination during administration on the licensee's plant referenced simulator, and e Reviewed " Simulator Deviation Problem Report," dated October 19,199 l

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The plant specific control room simulator performed the required component malfunctions and provided realistic plant response to changing conditions. No simulator fidelity concerns were identified. (See " Simulation Facility Report") Conclusions The plant specific control room simulator provided consistent, realistic plant conditions under abnorma! and emergency transient V. Manaaement Meetinas X1 Exit Meeting Summary

'On October 22,1998, the inspectors presented the inspection results to members of the Perry Plant management. The licensee acknowledged the findings presented. The inspectors asked the licensee whetner any materials examined during the inspection should be considered proprietary. No proprietary information was identifie . . _ _ _ _ _. ._ - . .

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PARTIAL LIST OF PERSONS CONTACTED Cleveland Electric illuminatino Comoany R. Collings, Manager, Quality Assurance Sentice M. Haskins, Operations Training Supervisor T. Henderson, Compliance Supervisor H. Johnson, Continuing Training Lead W. Kanda, Manager, Perry Plant R. Keamey, Superintendent Plant Operations R. Luse, Manager, Training (Actio0)

L. Myers, Site Vice President, Nuclear S. Sanford, Compliance Engineer NRC C. Lipa, Senior Resident inspector J. Clark, Resident inspector INSPECTION PRGCEDURES USED IP 71001: Licensed Operator Requalification Program Evaluation

' IP 71707: Plant Operations ITEMS OPENED, CLOSED, AND DISCUSSED NONE.

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l-Enclosure 2 SIMULATION FACILITY REPORT i

Facility Licensee: Perry Facility Licensee Docket Nos: 50-440 Operating Tests Administered: October 20,1998 This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of

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noncompliance with 10 CFR 55.45(b). These observations do not c'fect NRC certification or

! approval of the simulation facility other than to provide it 'ormation'. hat may be used in future i

evaluations. No licensee action is required in response to these obso:vation While conducting the simulator portion of the operating tests, the following items were observed (if none, so state):

1 ITEM DESCRIPTION NONE i

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