IR 05000315/1985032
| ML17326B022 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/10/1985 |
| From: | Darrin Butler, Guldemond W, Morisseau D, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326B021 | List: |
| References | |
| 50-315-85-32, 50-316-85-32, NUDOCS 8512170344 | |
| Download: ML17326B022 (19) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/85032(DRS);
50-316/85032(DRS)
Docket Nos.
50-315; 50-316 Licenses No.
American Electric Powr Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
Donald C.
Cook Nuclear Power Plant, Units 1 and
Inspection At:
Donald C.
Cook Site, Bridgeman, MI Inspection Conducted:
November 4 through 8, 1985 8.J.g~
Inspector:
D. Butler g-fd-~l Date lz -ru -g+-
Date Team Leader:
.
.
ul e on
/g. - /4 -gs Date Approved By:
uis
.
Re
, Chief peration ranch
/~
ro g<
Date Ins ection Summar Ins ection on November 4 throu h 8 1985 Re orts No.
50-315/85032(DRS).
50-316 85032 DRS dp
1
11 d
d
d p
tra>ning, including training facilities, licensed operator requalification, nonlicensed activity training, status of attaining INPO accreditation for nonlicensed operator training, and quality assurance oversight of training.
The assessment involved a total of 69 inspector-hours onsite by three NRC inspectors including 0 inspector-hours onsite during offshifts.
Results:
ln the five areas examined no violations or deviations were 8512170344 851211
~DOCX 0S000Sig
DETAILS 1.
Persons Contacted a.
Licensee Personnel
"W.
G. Smith, Jr., Plant Manager
~A. A. Bund, Assistant Plant Manager
"B. A. Svensson, Assistant Plant Manager
~W.
A. Nichols, Training Manager
~J.
F. Stietzel, guality Control Superintendent
"K. R. Baker, Operations Superintendent
~L. J. Matthias, Administrative Support
~N.
A. Baker, guality Control Department Assistant
"J.
D. Dickson, Training Coordinator
~R.
L. Strasser, Operations Training Supervisor
~M.
L. Horvath, quality Assurance Site Supervisor
~J.
A. Kriesel, Technical Support
"C. A. Ross, Technical Engineering L.
S.
Gibson, Technical Engineering Superintendent
"J.
G. Geinstein, Manager, Nuclear Safety and Licensing
"M..S. Ackerman, Nuclear Safety and Licensing
"P.
A. Barrett, Nuclear Safety and Licensing
~D.
R. Leibel, Skills training Supervisor R.
K. Gillespie, Training Support Supervisor K.
R. Worthington, guality Assurance Auditor J.
A. McEllegott, guality Assurance Auditor D.
Loope, Emergency Plan Coordinator R.
Sims, STA Supervisor B. Bradley, Technical Engineering P. Pitcher, Control and Instrument Instructor T. Wagoner, Electrical Maintenance Instructor W. Davidson, Licensed Instructor L. Tatrault, Licensed Instructor D. Wedderburn, Instructional Technologist The inspectors also contacted and interviewed other members of'he licensee's staff.
b.
NRC Personnel.
"B.
L. Jorgensen, Senior Resident Inspector
"C.
W. Hehl, Chief, Reactor Projects"Section 2A, Region'II D.
L. Wigginton, Licensing Pr'oject Manager, NRR
"Denotes those personnel attending the.November 8, 1985 exit meeting.
2.
Trainin Facilities The licensee's current training facility consists of a combination of temporary buildings adjacent to the plant projected area.
These buildings contain six classrooms; two study areas; a general employee training (GET)
area; and office, administrative; and library space.
Environmental
conditions are adequately controlled and there is an adequate supply of audio/visual equipment to support current training activities.
The licensee has recently added a graphics section to the training department in response to a self-identified desire to improve the quality of visual aids.
It was noted that there are few "hands on" training aids and no plant specific simulator; however, it is concluded that the existing facility adequately supports currently scheduled training.
The licensee has plans for a new 83,000 ft~ training center to be completed in late 1986 or early 1987.
Ground breaking has not.begun.
The first floor o'f the new center, exclusive of a plant specific simulator, will house facilities for GET training, whole body counting, respirator training, and badging.
In addition,- two protected vaults will be installed to contain training records and plant construction records.
The first floor will also contain an electrical training shop (1000 ft~), a welding training shop (1000 ft~), a mechanical maintenance training shop (3000 ft~),
a radiological protection technician training facility (1600 ft~), an instrument and control technician training shop (1600 ft~), and a chemistry training laboratory (1600 ft~).
A complete video studio and graphics area will also be provided.
The second floor of the new building will contain an area (8000 fthm) for the operations training shift, a library and quiet study area, a lunch room, nine classrooms of various sizes, and a guality Control/Non-Destruc-tive Examination training lab (1000 ft~).
The simulator facility (14500 ft~) will, in addition to containing a plant specific simulator, contain a Technical Support Center mockup, instructor office space, study rooms, a classroom, a reference material library, and space for the technicians dedicated to simulator maintenance.
This expansion of training facilities will considerably enhance the quality of training to be performed by the licensee.
Re uglification for Licensed 0 erators Section 12.2 of the Amendment 79 of the licensee's Final Safety Analysis Report (FSAR) specifies a licensed operator requalification program established to satisfy
CFR 55, Appendix A.
The program, to be conducted on a two year cycle consisting of two one year periods, was to be administered by a site appointed Training Coordinator and consisted of classroom 'lectures, on-the-job training, annual evaluation of participants, and documentation.
The following details were provided with respect to the program phases:
Classroom Lectures:
A minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of instruction is to be provided, no more than 50X of which may be solely videotape or film.
Attendance may be waived for those individuals attaining a grade of 80K in the related areas of the previous year's annual written examination.
Lectures are to be conducted in the following areas with emphases on weak and historical problem areas:
4 H
I U
I/
t J
(1)
Theory and Principles by Operation (2)
General and Specific Plant Operating Characteristics (3)
Plant Instrumentation and Control Systems (4)
Plant Protection Systems (5)
Engineered Safety Systems (6)
Normal, Abnormal, and Emergency Operating Procedures (7)
Radiation Control and Safety (8)
Technical Specifications (9)
Applicable portions on Title 10, Chapter I, Code or Federal Regulations Mritten quizzes will be administered after each lecture with a minimum acceptable grade of 80K.
A grade less than 80K requires additional training in the.area of weakness.
On the Job Trainin OJT
- This phase of training consists of the performance of a min>mum of 10 reactivity control manipulations over the two year cycle on either Unit 1 or Unit 2. If the manipulations cannot be performed on the plant, use of a suitable simulator is permissible.
The manipulations may consist of a mix of the following evolutions with a maximum of three being credited toward the
required:
(1)
Startup to the point of adding heat (2)
Orderly shutdown (3)
Manual control of steam generators during startup or shutdown (4)
Operation of the turbine governor control in manual during startup (5)
Boration during power operation (6)
Dilution (7)
Operation of manipulator crane during refueling over the core (8)
Any significant (> 10K) power changes in manual rod control (9)
Manual rod control prior to and during generat or synchronization Abnormal and emergency procedures shall be reviewed by all licensed personnel on a regularly scheduled basis as assigned by the training coordinator.
Other areas may be included but all abnormal and emergency procedures must be reviewed at least annually.
Reviews of design, procedure, and license changes are to be reviewed to the depth specified by the Training Coordinator by formal lecture, self study during normal working hours, or on shift group review.
Annual Evaluation:
Annual evaluations are conducted by the adms nistratson of an oral examination by someone from plant management other than the individual's immediate supervisor or immediate shift members and the administration of an annual written examination comparable to an NRC written examination.
An operator who fails the oral examination shall be placed in an accelerated training program and required to pass a second oral examination.
A grade of less than 70K on the annual written examination shall require the individual to placed in an accelerated training program.
Following completion of
d.
this program the operator will be required to pass a second written examination in those areas in which he was deficient.
While in an accelerated training program for written examination failure, an operator shall not perform licensed duties.
Documentation:
A permanent record shall be maintained for each operator containing verification of each program completion and overall grade scores.
The following requalification records shall be maintained for two years following the date of the recorded event or requalification program completion:
(1)
gequalification summary (2)
Topic quizzes, answers, and answer keys (3)
On the job training records (4)
Change review records (5)
Annual written examination, answers, and answer keys
Annual oral examination reports
Accelerated training programs This program was approved by the HRC by letter dated July 21, 1977.
(P.
F. Collins to R.
W. Jurgensen)
In July, 1985 the licensee revised their FSAR description of the licensed operator requalification program, making the following changes:
a
~
b.
c ~
A statement was added concerning INPO accreditation and a caveat added that this made the program subject to revision.
Additional detail was added to the description of the control manipulations portion bf on-the-job training.
Specifically, the program now requires that normal control manipulations such as reactor startup must be performed while abnormal or emergency conditions may be walked through and evaluated by a member of the training staff; however, the preference is to perform these manipulations at an appropriate simulator.
The OJT control manipulation list has been expanded to 25 items from the original nine; however, three of the the original nine manipu-lations have been deleted from the list as follows:
d.
1.
Operation of the turbine governor control in manual during startup.
2.
Operation of the manipulator crane during refueling over the core.
3.
Manual rod control prior to and during generator synchronization.
The requirement to perform 10 reactivity manipulations over the two year period has been deleted and replaced with a requirement to perform certain manipulations annually.
Those which involve reactivity include plant startup to the point of adding heat, manual control of
I N
steam generators and/or feedwater during startup or shutdown, and any significant (greater than 10 percent)
power changes in manual rod control.
Boration/Dilution and plant shutdown are only required once every two years.
I
\\
This revised program description is implemented by the training department through a document entitled "Operator Requalification Training" dated May 1983.
Based on review of the above program documents, requalification year
lecture schedules, review of existing training records, examinations,
-and interviews with training department and licensed personnel, the following observations were made:
a 0 Pro ram Documents:
(1)
The required lecture topics specified in the implementation section of "Operator Requalification Training" differs from the list in the approved program and th'e program section of this document as follows:
(a) 'he separate topic of applicable portions of Title
CFR Part 1 was combined with radiation control and safety.
(b)
The separate topic of Technical Specifications was'ombined with engineered safety systems.
(c)
Two new topics have been added as follows:
1.
Features of Facility Design 2.
Heat Transfer, Thermodynamics, and Fluid Flow Two potential effects result from these changes:
(a)
Combining topics may dilute their individual significance.
(b)
Program satisfaction is tracked by lecture completion.where lectures are assigned to a given topical area.
Yiultiple lectures are assigned to a single topic.
Deletion of a given lecture (which does occur) could result in a topic from the approved program being 'missed.
(2)
As presently written, the manipulation requirements could be satisfied without performing 10 reactivity control manipulations as required by the approved program.
All of the 25 manipulations are required to be performed at least once every two years.
Three of the 25, which require reactivity manipulations, are required annually.
Only two of the remaining 22 involve reactivity manipulations from the originally approved list.
Thus, the present program could be satisfied with only eight reactivity manipulations, two short of the required 1 I
U N
II
(3)
OJT for fuel manipulator operatio'n has been deleted.
b.
Year 10 Lecture Schedule (1)
The schedule as written covered all topics required by both the approved program and the program in place; however, the schedule informally showed that two of the lectures were not performed.
(2)
Subsequent review of training records showed two additional lectures were not given.
Thus, the schedule was not accurate; however, all topics required by the approved program were covered.
C.
Trainin Records (1)
Review of several records showed that all training required by the approved and existing program was completed.
(2)
Certain documentation practices, while satisfying program requirements,.cause a loss of potentially valuable feedback information as follows:
(a)
Retraining programs caused by quiz failures are not documented as to content.
(b)
Accelerated training programs caused by exam (written or oral) failure are not detailed.
(c)
Lecture quiz grades are recorded under each topic the lecture addresses.
If there was more than one lecture for a given topic, the quiz grades are averaged to yield an apparent topic average.
This could be misleading as the quiz questions are not broken down by topic.
Thus, no good indication of topical weaknesses exists.
(d)
There is no record that the records are being reviewed or utilized by operations.
(e)
Oral exam records are very general.
No list of questions asked is provided.
No evaluation criteria are included.
No evidence exists in the records to demonstrate that weaknesses are followed up on.
(f)
Control manipulation records are for the simulator only.
There is no documentation of manipulations performed in pl ant.
(g)
Simulator records do not indicate in what capacity (RO vs SRO) the manipulations were performe A
d.
Examinations Mritten for Year 10 (1)
The examination content was consistent with requirements and subjects taught.
(2)
The examination contained few question exploring technical bases.
(3) It did not appear that examinations were comprehensively cross checked with other examinations for the same period to prevent excessive repetition of questions.
The fact that this was not done was confirmed during discussion with training department personnel.
Based on this information, the following conclusions were reached concerning licensed operator requalification:
a.
For requalification year 10, all minimum training requirements contained in the NRC approved requalification program and the program presently implemented by the licensee were satisfied.
b.
Subtle differences exist between the NRC approved program and the currently implemented program.
Most noteworthy of these differences are:
(1)
The OJT requirement for fuel manipulator operation has been deleted.
(2)
Non-plant specific simulator training is relied upon exclusively for documenting required reactivity manipulations.
These differences in total create the potential for failing to satisfy certain existing requalification requirements and should be resolved.
c.
Training records lack the detail necessary to establish that identified performance weaknesses were comprehensively evaluated and effective remedial actions taken.
4.
Nonlicensed Activit Trainin Existing training programs for Control and Instrument (C8I) Technicians, Electrical Maintenance personnel and Quality Control (QC) personnel assigned Control and Instrument inspections were reviewed to establish existing content.
Based on these reviews and discussions with craft personnel, the following observations were made:
a ~
Instructors 'are currently required to spend eight hours per quarter in the plant observing/participating'in maintenance activities, thereby maintaining and enhancing their technical skill II ll
b.
Electrical and C8I craft personnel have no less than 10X of their normal work time set aside for periodic training.
To date this time has not been structured; however, the fact that the licensee has dedicated time for training is to their credit.
C.
d.
Most of the electrical and CILIA craft training to date has been OJT.
a
,Currently, little traini'ng is provided on plant modifications, procedure changes, and industry experiences.
e.
Both electrical and C8I craft personnel expressed the need for training on the use of Electric Prints 'and Diagrams.
f.
gC inspector training consists primarily of training on inspection techniques with little emphasis on the skills necessary to perform the tasks being inspected.
It was identified during discussions with training department personnel that the training programs for maintenance and C8I personnel were currently under review/revision and that needed changes, some of which are identified above, were being acted on.
5.
Status of Attainin INPO Accreditation for Non-Licensed 0 erator NLO Trasnsn In order to assess the progress the l,icensee was making in achieving INPO accreditation for their non-licensed operator training program, two non-licensed operator t'asks,
"Take local/manual control of the feedwater regulating valves" and "Monitor the DC Electrical System,"
were selected and evaluated using the
"NRC Training Review Criteria and Procedures."
a.
~Anal ala The documentation reviewed indicated that a systematic method was used to select tasks for training.
Eighty-four percent of job incumbents validated the task lists through survey.
At present, tasks slated for full job task analysis are those for which no formal training existed.
Tasks for which there is existing"training go through a validation process.
INPO task lists were modified to reflect D.
C.
Cook nomenclature and plant specificity.
A second review was performed to verify accuracy.
For existing lesson plans and training already in place, objectives and standards are being validated and modified, if appropriate.
b.
Develo ment of Learnin Ob ectives For the tasks selected for review, learning objectives were developed.
Those objectives were related to skills and knowledges needed to perform the tasks.
By and large, objectives included conditions and
g)
I k
C.
standards, some of which were in associated operating procedures.
Where this was the case, the procedures were also, reviewed to establish an auditable link.
Because lesson plans are in a developmental stage for newly-developed formal programs, they are not complete.
However, procedures are in place for developing learning objectives as well as for changing them when job performance requirements change.
Desi n/Im lementation There is a written plan that clearly and specifically states the training organization goals, objectives, and lines of responsibil.ities.
Although much of this phase of the program is in a transitional phase, there are mechanisms in place that can, if implemented, result in development of lesson plans that ensure consistency in instructor presentation and trainee evaluation.
The class observed on the'Condensate
.System was conducted in an entirely adequate manner.
d.
Trainee Evaluation
'F d
Candidates are objectively evaluated with'espect to'entry level skills; exemptions from training are based on testing or certified waiver only.
Test items appear to be appropriate to learning objectives and job performance requirements.
Trainees for the NLO program are on six months probation as new hires.
Trainees who perform below standard after that are given remediation and retesting.
e.
Pro ram Evaluation There are documented and auditable programs and procedures in place to evaluate the effectiveness of the training program and to revise those programs as necessary.
Instructor critiques of the training are used for program evaluation.
Trainee critiques are also used for this purpose.
Feedback from supervisors is also used for program evaluation.
Trainees'n-the-job experience is now being solicited and used for program evaluation although the feedback loop is not yet complete due to the fact that NLOs did not have formal training programs on which to base their opinions with respect to program relevancy to on-the-job experience.
At present, internal and external audit finding are appropriately used for program evaluation.
However, more mechanisms for this type of feedback are in the process of being used or designed and the feedback mechanisms are in a transitional state.
Documented qualification requirements for the training staff exist that address subject matter and instructional skills.
Training staff members are evaluated by both their supervisors and instructional technologists
~
C
~'k
)e
l F
'l t
The D.
C.
Cook training organization seems to have the appropriate mechanisms and programs in place to allow it to develop a program that will meet the standards for INPO accreditation.
6.
ualit Assurance Oversi ht of Tr ainin Discussions were conducted with representatives of the licensee's guality Assurance organization to determine the extent to which that organization provided oversight of training.
Additionally, two completed audit reports for training were reviewed (QA 83-09 dated May 30, 1983 and gA 83-16 dated August 18, 1983).
As a result of these activities the following observations were made:
a ~
gA audits of training activities in the past, conducted on a biennial frequency, have been based on documentation of implementation of specific training procedures.
As such, prior audits have been somewhat limited in scope and have focused little on ongoing training activities.
b.
Past audits have identified some procedural inconsistencies, recordkeeping weaknesses, and failure to conduct certain retraining sessions as required; however, some the findings were not followed up in a timely manner.
c.
Until recently, the guality Assurance organization possessed little expertise in training.
d.
The licensee has recently changed the required audit frequency to annual and has changed the audit basis from specific procedure implementation to topical audit.
Based or these observations it is concluded that guality Assurance oversight of training has been somewhat lacking, but this has been recognized by the licensee and changes have been or are being made that will rectify this situation, The assessment Team Leader met with the licensee representatives denoted in Paragraph 1 throughout the assessment and on November 8, 1985, and summarized the scope and findings of the assessment.
It was noted that while certain areas had been identified were improvements could be made, in general the licensee was aware of these areas and had already initiated remedial action as part of their effort to attain INPO accreditation of their training programs.
A major strength identified by the assessment was the commitment of significant resources and talent by the licensee to effect improvements through a systematic approach to training.
The Assessment Team Leader also discussed the likely informational content of the inspection report with regard to documents or processes reviewed.
The licensee did not identify and of the information as proprietar h
~
~