IR 05000298/1982036
| ML20028G233 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/11/1983 |
| From: | Jaudon J, Johnson W, Mccrory S, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028G217 | List: |
| References | |
| 50-298-82-36, NUDOCS 8302070543 | |
| Download: ML20028G233 (13) | |
Text
{{#Wiki_filter:. APPENDIX C U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-298/82-36 Docket: 50-298 License: DPR-46 Licensee: Nebraska Public Power District P. O. Box 499 Columbus, Nebraska 68601 Facility Name: Cooper Nuclear Station Inspection at: Cooper Nuclear Station, Brownville, Nebraska Inspection Conducted: December 6-10, 1982 Inspectors: // M /////F 3 em J. P. Jd0 don, Reactor Inghector, Reactor Project Date Section C (paragraphs 1, 2, 4, 5, 6, and 7) l LW h / // 3 S. L. McCrory,' Reactor Inspectof', Reactor Project /Daf.e Section A (paragraphs 1, 3, 4, 7) Approved: [[4) f/18/8 3 W. D. g nson, Chief, Reactor Project Section C Date 7'EAZ1h <No T. F. Westerman, Chief, Reactor Project Section A Date Inspection Summary Inspection Conducted December 6-10, 1982 (Report 50-298/82-36) Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, maintenance, audit implementation, and requalification training.
The inspection involved 76 inspector-hours by two NRC inspectors.
Results: Within the four areas inspected, one apparent violation was identified (violation - failure to follow requirements of approved requalification program), and one deviation was identified (deviation - failure to conduct training as committed).
8302070543 830118 PDR ADOCK 05000298 (g PDR
DETAILS 1.
Persons Contacted Nebraska Public Power District W. Gilbert, Training Coordinator K. Goebel, Administrative Supervior R. Jansky, Shift Supervisor L. Lawrence, Maintenance Supervisor
- L. Lessor, Station Superintendent D. Majeres, Maintenance Planner and Supervisor G. Smith, Quality Assurance Specialist K. Wire, Operations Supervisor V. Wolstenholm, Quality Assurance Supervisor The NRC inspectors also contacted other plant personnel including administrative, clerical, health physics, and operations.
- Denotes presence at the exit interview conducted December 10, 1982.
2.
Licensee Action _on Previous Inspection Findings (Closed) 8114-05 (Unresolved).
This item was unresolved because the licensee was behind senedule in carrying out the 1981-1982 requalification lecture schedule.
The NRC inspector reviewed the summary record of completed training for the 1981-1982 requalification year.
The lecture schedule had essentially been completed. On this basis the item is closed.
During this review, the NRC inspector also noted that two licensed individuals had not received training in areas identified as weak for them on the basis of the 1981 requalification examination.
It was also noted that one individual was not tested on his knowledge of the requalification lecture series after lectures which he was required to attend.
The approved requalification training plan requires that personnel identified as weak in specific areas on the annual examination be given lectures in those areas and then tested.
Failure to meet these requirements constitutes a lessening of the scope of the approved requalification training program, and is an appe. rent violation of the requirements of 10 CFR Part 50.54(1-1).
(8236-01) (Closed) C114-06 (Unresolved).
This item was unresolved because minor discrepancies were noted in the records of reactivity manipulations either made or directed by licensed operators.
During this inspection, the NRC inspector reviewed both the records of reactivity manipulations l l l l ' _ _
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on the plant and at simulator.
The discrepencies noted during NRC Inspec-tion 50-298/81-14, which were not accounting for all reactivity . manipulations, were not found during this inspection.
This item is closed.
3.
Maintenance The NRC inspector reviewed maintenance records to verify that maintenance activities on safety-related components and systems were conducted in accordance with license requirements. These requirements are found in the FSAR, Volume V, Section XIII; Technical Specification 6.3.3., the quality assurance program and ANSI N18.7-1972.
The NRC inspector sampled records from November 1981 to the time of this inspection reviewing the following areas: Instrumentation Reactor Coolant Systems Emergency Core Cooling Systems Containment Plant and Electrical Power Systems Also reviewed were Licensee Administrative Procedures 1.7.1 " Work Item Tracking: Corrective Maintenance," Revision 2, dated September 26, 1981, and Procedure 1.7.2 " Work Item Tracking: Presentive Maintenance," Revision 0, dated September 20, 1981.
The NRC inspector noted during the review of Procedure 1.7.2, that overdue Preventive Maintenance Items (PMI) are required to be placed on an overdue list when they have exceeded 33% of their prescribed interval.
Further, when a PMI is "significantly" overdue it is required to be brought to the attention of the maintenance supervisor.
The term "significantly" is not defined nor is any specific action directed to assure ultimate accomplishment of the'PMI.
While reviewing PM schedules, the NRC inspector noticed that several PMI's had intervals of 24 and 36 months.
The NRC inspector inquired as to the development of the 33% criteria for identifying overdue PMI's.
As explained to the NRC inspector, the criteria was arrived at primarily to accommodate quarterly-PMI's (the 33% conveniently equating to 1 month).
The NRC inspector pointed-out that PMI's with 24-and 36-month intervals could be 8 and 12 months overdue before being required to be reported as overdue and there was no assurance of final accomplishment.
The inspector asked if the performance character-istics of these components on which the preventive maintenance was over ' due had been evaluated to assure that these components would meet minimum . -,.
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acceptable performance levels if the PMI's were allowed to continue overdue for 8 months to a year or more.
Licensee personnel stated that they were not aware of any prior engineering analysis to address this matter.
The NRC inspector's concern was substantiated when, during the review of the overdue PMI lists, it was discovered that some PMI's were overdue by 2 and 3 years.
Maintenance personnel indicated awareness of these items and provided reasons ranging from: the equipment has been considered for-replacement over the last 2 years, to, a decision has not been made on how the PM will be accomplished (for PMI 3 years overdue).
None of the PMI's in question were associated with safety-related components.
The NRC inspector expressed further concern to maintenance personnel that such treatment of PMI's degraded the PM program and could foster a lax attitude toward PM accomplishment.
As a result of a review of Maintenance Work Request Work Item Number 82-1225, the NRC inspector noted that four snubbers had been replaced in the reactor coolant system.
This was the result of two out of four of the existing snubbers failing to pass surveillance procedure tests during the July 1982 outage (LER 82-13 reported the occurrence).
Four Bergen Patterson designed snubbers were installed, replacing the then existing Pacific Sciertific designed snubbers.
At the time of installation a temporary change to Maintenance Procedure 7.2.52, " Pipe Snubbers Removal and Installation," Revision 0, dated May 1,1981, was issued to allow for the design differences of the Bergen Patterson snubbers.
The change was
only effective for the accomplishment of work item number 82-1225.
It was brought to the attention of licensee management that no permanent revision to Procedure 7.2.52 has been issued in the intervening 5 months to account for the now installed Bergen Patterson snubbers.
No violations or deviations were identified during this portion of the inspection.
4.
Audits The NRC inspectors reviewed the licensee's audit program as executed by the quality assurance (QA) department.
Three QA audits were reviewed for 1982.
QAP - 200 Training QAP - 400 Calibration Control QAP - 1100 Routine Maintenance _.
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Overall, the audits appeared to be conducted in accordance with QA requirements.
However, the inspectors expressed concern to licensee management that QA activities may not be providing sufficiently comprehensive feedback to site personnel to identify program weaknesses or potential problem areas.
The August-September 1982 audit of routine maintenance reported findings similar to those observed by the NRC inspector.
In particular, there were numerous instances of failure to complete maintenance documents such as trouble reports, maintenance work requests, and quality control check-- lists.
In all cases, the work was verified to have been completed but maintenance records did not always reflect this.
The QA audit of maintenance indicated a review of the PM overdue list.
However, the audit report did not comment on the PMI's that were more than a year overdue.
The QA audit made no mention of an apparent lax attitude toward maintenance documentation and of the existence or treatment of PMI's more than a year overdue.
Maintenance documentation and PM accomplishment are the primary means by which management monitors equipment status and assures adequate equipment performance.
While the QA audit reports contain statements that the audit verifies that adequate site procedures are being used, it is apparent from audit report reviews and discussions with QA personnel that this is not necessarily the case.
QA audits often appear to take all site controlled procedures at face value and make no comment as to the technical adequacy or validity.
Specifically, in the case of routine maintenance, the 33% overdue criteria established by Maintenance Procedure 1.7.2 " Work Item Tracking Prever.tive Maintenance" was not questioned as'to its validity with respect to 24-and 36-month interval PMI's.
When interviewed, QA personnel indicated that investigating the adequacy of site procedures was not routinely a part of their QA activities.
They further implied that they lacked the technical competence to evaluate procedures, whereas the requirements for QA personnel is that they be familiar with and sufficiently competent in the areas being audited.
The NRC inspectors reviewed the 1982 audit of training (QAP-200, #82-05).
It was noted that this document stated: "The CNS Approved Operator and Senior Operator Requalification Program (8-76) is out-of-date, and is no longer used.
An updated requalification training program, in use at CNS, was schlitted for NRC approval on October 1, 1980.
The NRC is aware that the CNS is using the submitted requalification program as indicated not only by NRC Inspection Report 50-298/81-14, but also by NPPD's response dated November 23, 1981."
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The NRC inspector found this statement curious since NRC Inspection Report 50-298/81-14 had included a violation for implementing aspects of the revised (1980) requalification training program, without prior Commission approval. The NRC inspector also noted that NRC Inspection Report 50-298/81-14 had, in paragraph 10, pointed out serious deficiencies of the li.censee's 1981 audit of the training area.
It is further noted that, at the time of audit No. 82-05, the licensee had been given violations related to requalification training during the three previous inspections of this area (NRC Inspection Reports 50-298/78-17, 50-298/80-13, and 50-298/81-14). When this was considered, in light of the additional violation reported herein regarding rcqualification training and the other problems in this area, it led the inspectors to conclude that a more in depth review of the licensee's audit program was warranted.
Accordingly, the acceptability of the licensee's implementation of the audit program is considered unresolved pending further inspection and review. (8236-03) 5.
Requalification Training The purpose of this inspection was to verify that requalification training program was conducted in accordance with the requirements of 10 CFR Part 55 and the approved requalification program.
The licensee's approved requalification program was that which was approved in 1976 by a letter from P. F. Collins, NRC, to L. C. Lessor, . NPPD, dated August 18, 1976.
In 1980, the licensee submitted a revised requalification program to address NUREG 0737 requirements related to improved operator training.
This inspection used as a basis the licensee's 1976 requalification program plus the additional commitments made in the-1980 program revision and subsequent correspondence concerning this latter submittal.
The licensee's training department consists of the training coordinator and one part-time instructor.
This part-time instructor is a licensed senior reactor operator whose job title is " shift supervisor." The NRC inspector noted that this individual was used frequently as a replacement watchstander, and, in addition, conducted training for qualified operators and hot license candidates.
He also did the scheduling for requalification training and maintained the summary records of completed requalification training.
The training department did receive assistance from other departments; for example, health physics personnel conducted training in radiation health and safety.
The NRC inspector also noted that more senior licensed operators had left the licensee's organization than new candidates had been licensed.
This resulted in an apparent shift of emphasis from requalification training to hot license trainin, - _ - r ^
- . .. An additional impact noted by the NRC inspector was that the. licensee was short two licensed operators in his five watch rotation.(K. R. Wire memorandum dated November 10, 1982, serial CNSS820664, subject: " Crew Assignments"). These watch bill vacancies were filled by the use of overtime or from personnel in their " relief crew week.".The relief crew week is the period during shift rotation when classroom lectures and training can be accomplished on a nonovertime basis. The NRC inspector concluded that the impact of personnel shortages and the small training department on requalification training was a program that had diminished both in quality and quantity.
Subsequent paragraphs provide specific observations by the NRC inspector which support this conclusion.
The 1981-1982 requalification training year ended in May 1982 with the annual examination.
Based on this examination, the anticipated 1982-1983 training schedule was promulgated by R. A. Jansky's memorandum dated May 28, 1982, serial CNSS824114, subject: " Operator Training for 1982-1983." This schedule established seven training sessions, each of 5 weeks duration, starting June 27, 1982, and ending February 19, 1983.
The plant experienced material deficiencies, resulting in an unanticipated outage and a slip in the refueling date. The NRC inspector did not find that the original schedule had been reissued but he did note that 5-week schedules were issued.
Train-ing was not started as scheduled on June 27, 1982.
Review of payroll records for the period of July 1-15, 1982, indicated that 20 licensed operators worked an average of 32 hours of overtime for this period, with a high of 64 hours.
Review of the 5-week training schedules indicated both a trend to back off the original schedule and a reduction in training pro-jected.
The following is an example of the requalification training status during this inspection.
Through the end of session 4 (which was originally scheduled to end November 13, 1982), the original schedule included 68 hours of lectures for licensed operators.
At the time of the inspection, only 1 hour had been completed for all licensed operators, and this was only completed by the use of "self-study." Also, the original schedule called for five sessions of 4 hours each in heat transfer, fluid flow and thermodynamics.
At the time of this inspection, the initial session on these subjects had not yet been completed for all operators.
Licensee representatives informed the inspector that this training would be reduced to one session for the training year.
The NRC inspector noted that the licensee had scheduled a 2-hour classroom session to review the previous requalification examination.
This was not done as scheduled, but the exam-inations were distributed to operators for individual review.
The NRC inspector also noted that scheduled system lectures were either not given or were rescheduled from the classroom to onshift training.
Interviews with numerous licensed operators led the NRC inspector to conclude that the onshift system lectures, given by a member of the shift crew, were ineffective.
The licensed operators who were interviewed uniformly and
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unequivocally stated that they could not carry out their licensed duties effectively and concentrate on !ccture while on duty.
The NRC inspector also had concerns about the quality of this. training, since interviews with operators indicated that lesson plans were either out of date or were not used.
The licensee's original schedule also called for review of abnormal and ~ emergency procedures while on shift.
This had been the licensee's past practice and was done by walk-through.
Review of licensee records raised concern as to whether or not this training was effective.
For example, the licensee's summary records indicated one crew, which had been delinquent on these walk-throughs, completed approximately 40 of them on 'ift.
It was not determined if this actually occurred or was the I which the final walk-through occurred.
The licensee's approved requalification training plan requires a minimum of 60 hours of requalification lectures annually.
However, this 60 hours is apparently only achieved by ccunting onshift lecture hours.
During operator interviews, the inspector was repeatedly told that classroom lecture hours for the last year had not exceeded approximately 30 hours.
The NRC inspector also found by interview that very little formal requalification training was being accomplished during the relief crew week.
This was purportedly the result of both routine and nonroutine utilization of operators.
For example, a licensee memorandum dated February 15, 1982, serial CNSS82079, subject: " Relief Crew Duties," delineated five and one-half pages of routine duties for the relief crew (both licensed and nonlicensed operators); many of these tasks appeared to be purely clerical or administrative in nature.
Additionally, it became evident through interviews, that operate *s spent the majority of the relief crew week supervising various plant tasks or standing shifts as reliefs, but they were not involved in training.
It was also noted that the approved requalification plan required that written tests be given to cover the material presented in the requalification lecture series.
The NRC inspector found that no tests had yet been given during the 1982-1983 training year.
Licensee representatives stated that was because so little training had been accomplished it was "not worthwhile to give a test."
The NRC inspectors reviewed the licensee's process for evaluating operator performance and thereby for establishing training requirements.
The analysis of the annual examination was done on a question-by question basis.
This was apparently the principal source from which the requalification training schedule had been established.
In conducting a review of the examination, the NRC inspectors noted that the. licensee defined the subjects to be covered in requalification training by different titles.
The licensee's approved requalification training plan identified the nine subject areas delineated in 10 CFR Part 55, Appendix A, on a verbatim basis.
The licensee's submittal of a revised i l ! l
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requalification training plan changed the titles of some of these subjects and nominally picked up the two additional subjects delineated in NUREG 0737.
These two additional subjects are " heat transfer, fluid flow and thermodynamics" and " mitigation of core damage." The revised requalification training plan combined some subjects under more general headings, thus, there were only 9 subjects instead of 11.
For example, " mitigation of core damage" was not included, but the licensee stated in the enc 1csure to his letter on upgraded training, dated June 1, 1982, serial LQA820023: / 'The elements of the CNS Training Program for licensed operators which are pertinent to the degraded core address all of the areas identified in enclosure 3 of Denton's March 28, 1980, letter.
Many of these areas are addressed in the abnormal and emergency procedures which all licensed operators are required to review annually.
Formal classroom requalification training on accident mitigation involving a degraded core will include all pertinent areas in enclosure 3 of Denton's March 28, 1980, letter."
The NRC inspector noted that the licensee's Procedure 1.5, " Selection and fraining of Station Personnel," Revision 8, dated May 13, 1982, reduced the number of subjects to eight by dropping " Safety and Emergency Systems." The requalification examinations for SRO's and R0's used only five subject areas.
Initial analysis of the 1982 requalification examinations (there had been three - two for SR0's and one for R0's) indi-cated that none of the questions asked could be related to mitigation of core damage.
Subsequent review of the requalification examination with licensce representatives confirmed the NRC inspector's findings that, except one of the SRO examinations (given to approximately one-half of the SR0's), there were no questions which could be related to mitigation of core damage.
The NRC inspector also checked the licensee's training schedule.
This check did not indicate that there was any formal classroom training scheduled or completed in mitigation of core damage.
This is an apparent deviation from the licensee's commitments to NUREG 0737 regarding upgraded SRO and R0 training.
(8236-02) Other facets of the licensee's evaluation of operators were checked.
These included a loose-leaf log maintained in the control room.
In the log there was a form for each operator.
The form included space to record specific abnormal or emergency conditions, whether the conditions were actual or simulated, evaluation blocks titled " good," " fair," and " poor," and space to record the date and who made the evaluation.
The NRC inspector noted that there was often not a name entered for who_had made the evaluation and that the evaluation blocks were often'not checked.
All the 1981 forms had been reviewed and signed by the (at that time " acting") operations supervisor despite the many omissions notad.
The NRC inspector discussed the evaluation process with the new
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operations supervisor, who stated that he did consult with the training department's part-time SRO about training requirements; however, the examples provided of how evaluation of operators was accomplished were all concentrated on reactive situations, never on heading off potential problems.
The NRC inspector also noted that training department representatives were not present at all simulator training sessions.
Interviews with shift supervisors indicated that none of them were conscious of ever having had their opinions solicited concerning training needs.
The NRC inspector concluded that, with the exception of the annual examination review, the licensee had structured an evaluation program which met the minimal requirements of 10 CFR Part 55, Appendix A, paragraph 4, in a legal sense while essentially missing the obvious intent of operator evaluation as a program to identify and address training needs before these needs became problems.
This was expressed to licensee management as a concern.
The interviews with operators led the NRC inspector to the following conclusions related to training and retention, which are related to the findings delineated above: . The operators perceive that there are poor communications up their . chain of command.
This perception, coupled with other points of individual . dissatisfactions, may well lead to further attrition.
A second operator perception is that training has such a low . priority at Cooper Nuclear Station, that it is always the first program sacrificed.
Many operators complai7ed of excessive overtime; these complaints . appeared to coincide with the use of the relief crew week for nontraining related activities.
Operator morale is low.
. The NRC inspector summarized his findings and concerns to licensee management.
In summary, these were that the quality and quantity of requalification training have significantly deteriorated over the last year.
There are clear indications that the observed weaknesses result from an undermanned training department.
It is also noted that this is the fourth consecutive inspection of requalification training which has resulted in a violation (paragraph 2).
Although the violations were individually of a relatively minor nature, this historical pattern could be construed as evidence of a management philosophy that does not associate effective training with safety.
The entire question of the quality and quantity of requalification training, and, in a broader .- - - ..,
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context, all site training, is cc1sidered to be an unresolved item at - this time pending further review of licensee performance in this area (8236-04).
6.
Unresolved Item , Unresolved items are matters about which more information is required in order to ascertain whether the items are acceptable, violations, or deviations.
The following unresolved items are discussed in this report: Paragraph Item No.
Subject
8236-03 Audit Implementation
8236-04 Quality and Quantity of Requalification Training 7.
Exit Interview An exit interview was conducted December 10, 1982, with Mr. L. C.
' Lessor.
At this meeting, the scope of the inspection and the findings were summarized.
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APPENDIX D ' ~ ,'. Management Meeting Report 1.
Attendees Nebraska Public Power District R. E. Buntain, Division Manager, Power Operations C. R. Jones, Assistant beneral Manager, Operations R. S. Kanber, Senior Division Manager, Power Operations L. C. Lessor, Station Superintendent, Cooper Nuclear Station J. M. Pilant, Division Manager, Licensing and Quality Assurance D. E. Schaufelberger. General Manager J. Weaver, Licensing Manager Nuclear Regulatory Commissig J. T. Collins, Regional Administrator, RIV D. Dubois, Resident Inspector, RIV J. E. Gagliardo, Director, Division of Resident, Reactor Project and Engineering Programs, RIV J. P. Jaudon, Reactor Inspector, RIV E. H. Johnson, Director of Enforcement, RIV M. M. Martin, Staff, Licensing Qualification Branch, NRR T. F. Westerman, Chief, Reactor Project Section A, RIV 2.
Management Meeting The management meeting was held in Omaha, Nebraska, on January 5, 1983.
At this meeting, members of the Region IV staff outlined recent findings and observations of licensee performance, which could be related to deficiencies in training.
The staff presentation included three conclusions, which were that the training staff at the site was undermanned; that the management ovarsight of training, both corporate and site, required upgrading; and that immediate action was required to improve training and to address the high attrition of operators.
Although the key issue in training as a result of NRC Inspection Report 50-298/82-36 had been requalification training, the staff presentation at this meeting included of all aspects of training, licensed and nonlicensed, site and corporate.
Licensee management acknowledged that there was a serious potential problem caused by attrition of trained personnel.
Additionally, licensee management stated that corporate management would become more active in overseeing and assisting the site.
During subsequent discussions, which were frank and candid, licensee management indicated possible courses of , l
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remedial action that were under consideration.
NRC representatives stated that, although this management meeting was held for the purpose of presenting serious concerns, future NRC actions could include escalated enforcement if the licensee's remedial actions were not effective in both the short and long term.
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