IR 05000483/1999007

Insp Rept 50-483/99-07 on 990809-13.No Violations Noted. Major Areas Inspected:Licensed Operator Requalification Program to Determine Whether Program Incorporated Appropriate Requirements for Evaluating Operators

ML20212B160
Person / Time
Site:	Callaway
Issue date:	09/10/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212B157	List: IR 05000483/1999007 ML20212B152
References
50-483-99-07, NUDOCS 9909200002
Download: ML20212B160 (9)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-483 License No.: NPF-30 Report No.: 50-483/99-07 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Fulton, Missouri 3 Dates: August 9 to 13,1999 Inspectors: G. W. Johnston, Senior Reactor Engineer, Operations Branch J. D. Hanna, Resident inspector, Project Branch B Approved By: J. L. Pellet. Chief, Operations Branch Division of Reactor Safety ATTACHMENT: Supplemental Information

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9909200002 990910 PDR ADOCK 05000483 G PDR i

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2-EXECUTNE SUMMARY Callaway Plant NRC Inspection Report No. 50-483/99-07 This inspection evaluated the licensed operator requalification program to determine whether the program incorporated appropriate requirements for evaluating operators' mastery of training objectives in accordance with 10 CFR 55.59(c). The licensed operator requalification program assessment included an evaluation of the program's controls to assure a systems approach to training and evaluation of operating crews' performances during biennial requalification examinations. This included review of the facility documents, observation of operating crews during dynamic simulator scenarios and plant walkthroughs, and an assessment of the examination evaluators' effectiveness in conducting examinations. The inspection also evaluated the plant referenced dynamic simulator used to conduct the exarnination Operations

• The inspectors concluded that the operations training organization responded to feedback in a timely manner, and had incorporated operational experience into training lesson plan = The inspectors concluded the operators performed acceptably during the examinatio The operators practiced three-leg communications, peer checks, and effective crew briefings during the simulator portion of the operating examinatien. The operators exhibited weaknesses in procedure usage, situational awareness, and knowledge of system response of the power operated relief valve = The inspectors concluded that, overall, all portions of the examination were well constructed, properly focused, and appropriately challengin * The facility evaluators generally were effective in examining operators to identify deficiencies or weaknesses in the trainees and the training program. The facility evaluators administered the examinations professionally and documented their findings well to support their evaluations. Operations management involvement in the licensed operator requalification program was noted to be present at all stages of the program implementatio j

= The documentation of contributors to the root cause analysis of the performance concerns related to the staff crew in the simulator examination did not include all significant factor The narrow documentation reduced the effectiveness of long-term performance tracking using the post examination review record ;

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3-Reoort Details Summarv of Plant Status The facility operated at 100 percent of full power from August 9,1999, the first day of the

' inspection until 9:17 a.m., August 11,1999, when the facility experienced a manual reactor trip from 100 percent power following a steam line break in the plant secondary system. The plant remained in Mode 3 through August 13,1999, when the inspection was complete . Operations 04 Operator Knowledge and Performance 0 Operator Performance on Annual Recualification Examinations Inspection Scooe (71001)

The inspectors observed the performance of one shift crew and one staff crew during

~ the dynamic simulator and job performance measure portions of the annual requalification examination. The inspectors also reviewed the results of the written examinatio Observations and Findinas Both crews had performance-related concerns associated with communication of pressurizer power operated relief valve (PORV) position and procedural actions with regard to isolating the PORVs when required by procedure. The operating crew had an instance where an operator, when asked in what position the PORVs were, looked at the indication for the pressurizer spray valves and noted the valves were closed. The spray valves were closed; however, at the time of the question, one of the PORVs was ope The staff crew, in particular, did not attempt to close a stuck open PORV for a period of 18 minutes during a loss of all ac power scenario. In this instance, the crew noted that the PORV was open, and was aware of the position for a period of 18 minutes; however, the control room supervisor did not note that the action of step 3 of Procedure ECA-0.0," Loss of All AC Power," had the requirement to ensure the PORV was closed. This required the operators to take the panel switch for the PORV to the close position to ensure that the valve had a valid closure signal in place. This action would have closed the valve in this cas . The shift technical advisor in the scenario did not clearly convey the threatened safety furction that the reactor coolant system integrity was degraded sufficiently to require immediate corrective action. This would have prompted the control room supervisor to the need for corrective actions based on the conditions present in the reactor coolant syste The control room supervisor would not have had to exit Procedure ECA-0.0, as it took a higher priority than a functional recovery procedure. The shift technical advisor's performance was noted as being unsupportive to the staff crew in both scenario ,

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l-4-The control room supervisor noted that he believed that the requirement in the " response ,

not obtained" column of Procedure ECA-0.0, step 3, was similar to the requirement in I

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other emergency operating procedure action statements with regard to open PORVs, which was to close the associated block valve. Because Procedure ECA-0.0 addresses the coadition that normal power was not available and the block valve would not close, it i directed the action to close the PORV, with the PORV hand switch on the pane j Multiple instances were available to the crew to note that action was required. The doubling of source range nuclear instrumentation count rate from lowering reactor coolant system vessel level and reactor coolant system pressure continuously deceasing provided I clear indicators of the continuing leak from the open PORV. The inspectors' assessment l was that a lack of situational awareness was the primary cause of the operators' slow l response to close the open PORV. The crew did not fail to meet the critical task for the i event, which was to avoid core uncovery. Indications at the time of the closure of the )

PORV indicated that core uncovery was not imminent; however, recovery would have l been chslienged if the PORV had not been closed at the time it wa ) ,

Overall, the crews generally used three-leg communication techniques, with only minor occurrences where the practice was not employed, which was a measurable improvement in implementation performance from that of previous observations. Management commitmem to improving communications was apparent in that the critiques of the crews noted that the practice required improvement. Peer checking did not appear to be consistently practiced during routine activities or transient conditions. The crews conducted effective briefs, when convenient, that conveyed current plant condition The inspectors reviewed the operators' responses on the written examinations. All j operators except one passed the written examinations. The single failure was remediated, i retested, and passed. The licensee's post-examination review noted several areas for minor improvement. No significant generic concerns were identified from that revie , Conclusions The inspectors concluded the operators performed acceptably during the examinatio The operators practiced three-leg communications, peer checks, and effective crew briefings during the simulator portion of the operating examination. The operators exhibited weaknesses in procedure usago, situational awareness, and knowledge of system response of the PORV Operator Training and Qualification OS.1 Review of Reaualification Examinations Inspection Scope (71001)

The inspectors reviewed the annual requalification examinations, which consisted of the written and operating tests, to evaluate general quality, construction, and difficulty leve The inspectors also reviewed the methodology for developing the requalification

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5-examinations and discussed various aspects of examination development and security with members of the licensee's training staf Observations and Findinas i The operating examinations consisted of job performance measures and dynamic simulator scenarios. The job performance measure tasks were operationally important and supported by the facility's job task analysis. Each job performance measure included initial conditions, initiating cues, references, performance standards, criteria for successful completion and identification of critical steps. The dynamic simulator scenarios contained realistic initial conditions, clearly stated objectives, and related events. The scenarios had multiple instrument and component failures. The sequence and timing of the events were reasonable and allowed the evaluators to gather sufficient information on individual and crew actions to arrive at an informed performance ratin j

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The inspectors noted that the written examinations were appropriately balanced with respect to systems, procedures, and administrative areas. The questions were well written with easily understood stems and answers. Most questions tested at the ,

application cognitive level. Licensee process controls for the written examination I development ensured 10 CFR 55.43 representative sampling for senior operator responsibility area Interviews with training personnel confirmed that the examination was developed by sampling from the requalification training plan. A review by the inspectors of the sampling plan determined that the sampling was objective and well documented. Each week of the requalification examinations was represented in the sampling plan and overlap of the examination material from week to week was substantially minimized. The sampling plan also assured overall coordination between the written and operating portions of the examiriation by areas of emphasi Examination administration was well planned, efficient, and conducted in a manner designed to reduce stress on the examinees. Examination security was well maintained throughout the sessions observed by the inspector Conclusions The inspectors concluded that, overall, all portions of the examination were well constructed, properly focused, and appropriately challengin .2 Examination Administration Insoection Scooe (71001)

The inspectors observed the administration of all aspects of the requalification examination to determine the evaluators' ability to administer an examination and assess adequate performance through measurable criteria. The inspectors also observed the fidelity of the plant simulator in the support of training and examination administratio The inspectors observed one shift crew and one staff crew during conduct of the dynamic

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simulator sccaarios and job performance measure evaluations. Five evaluators inclWg licensed operator trainers and one operations department manager were observed administering the examinations, including pre-examination briefings, observations of operator performance, individual and group evaluations of observations, techniques for job performance measure cuing, and final evaluation documentatio b. Observations and Findinas The evaluators conducted the examinations thoroughly and professionally and documented observed weaknesses and areas for improvemen For the job performance measures, the evaluators provided appropriate responses as necessary with no inadvertent cuing. Scheduling of the operators was orderly, and effectively implemented the security plan while efficiently processing the operators through the simulator and the plan The inspectors attended the post-simulator examination debriefings held by the licensee's evaluators for each of the scenario sets. The debriefings were comprehensive and candid l I

with detailed discussions by each evaluator on relevant subject The documented post-simulator evaluations of the crews, however, were narrow in dept The staff crew's performance evaluation was particularly narrow in describing the root .

cause. The evaluation did not clearly identify the root cause of the crew's inability to recognize the necessity of closure of the PORV in th; second scenario. That scenario presented a condition where emergency ac po. er was not available and the plant had an isolable leak through the PORV. As noter!in the earlier discussion of the staff crew's performance (Section 04.1), the evalua'. ors deemed that the crew did not fail any competencies, but did warrant evaluatUns of '1' in several of the behavioral anchors associated with four of the competency area !

The inspectors agreed that the root cause of the error for the first crew was not correctly observing panelindications. The facility evaluators identified the primary root cause of the weak performance of the second crew to be in the use and understanding of the emergency operating procedures. However, they also noted in observed discussions that the staff crew's performance was affected by both procedural use problems and the lack of situational awareness and system knowledge as significant contributors to the performance of the crew, but these contributors were not documented in the final crew evaluation documentation. The unambiguous plant conditions present in the scenario provided significant cues to the operators to direct them to a success path early in the scenario. These conditions presented significant factors that the facility evaluators should have used in the assessment of the staff crew's performance. The inspector reviewed the remedial training exercises and concluded that they sufficiently addressed the crew's performance concerns with regard to the performance of the crew despite the narrow root-cause determination.

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-7- Conclusions The facility evaluators generally were effective in examining operators to identify deficiencies or weaknesses in the trainees and the training program. The facility evaluators administered the examinations professionally and documented their findings well to support their evaluations. Operations management involvement in the licensed i operator requalification program was noted to be present at all stages of the program {

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The documentation of contributors to the root cause analysis of the performance concerns related to the staff crew in the simulator examination did not include all significant factor The narrow documentation reduced the effectiveness of long-term performance tracking using the post examination review record O5.4 Review of Reaualification Feedback Process Insoection Scope (71001)

The inspectors verified the licensed operator requalification training program eff ectively incorporated feedback (e.g., assessments of operator performance, plant events, and industry events) into the training. The inspectors assessed both the methods and eft >ctiveness of the feedback proces Observiitions and Findinos The inspectors reviewed performance records and documents to assess the nature and effectiveness of the feedback process as a means of revising the licensed operator requalification training program. These documents included training assessments / audits, plant events, industry events, and training cycle evaluations, and a review of nuclear quality services audits of operator training (AP 99-009) dated July 29,1999. The inspectors determined that multiple sources of feedback were used to improve the requalification training program. However, the nuclear quality services audit revealed some minor issues concerning closure of training tracking items and the documentation of course enhancements. These items were entered into the licensee's corrective action program via Suggestion Occuru ;,ce Solutions 99-1206 and 99-117 Interviews with licensed operators, instructors, and management personnel indicated that the feedback process was timely and effective in addressing questions or concerns raised by personnel. The inspectors also observed that the operations personnel performed a key role in providing feedback and input to the program. For example, operators and management ensured that plant occurrences and lessons learned from industry events were appropriately factored into the licensed operator requalification program, l

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8-c. Conclusions The inspectors concluded that the operations training organization responded to feedback in a timely manner and had incorporated operational experience into training lesson plan V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 12,1999. The licensee's management acknowledged the findings presented. No proprietary information was identifie l

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ATTACHMENT SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Affolter, Manager, Callaway Plant '

G. Czechin, Superintendent of Training J. Laux, Manager Quality Assurance R. Neill, Shift Supervisor, Operations Training S. Putthoff, Operating Supervisor, Training G. Randolph, Vice President and Chief Nuclear Officer NRC J. Pellet, Chief, Operations Branch i

INSPECTION PROCEDURE USED t

71001 Licensed Operator Requalification Program Evaluation i

DOCUMENTS REVIEWED Procedures Procedure TDP-ZZ-00022 Licensed Operator Continuing Training Program Miscellaneous Nuclear Quality Services Audits of OperatorTraining (AP 99-009) July 29,199 Suggestion Occurrence Solutions 99-1206 and 99-1175 1998-1999 LOCT Training Cycle Sample Plan

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