IR 05000315/1988025

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Insp Repts 50-315/88-25 & 50-316/88-29 on 881031-1104.No Violations or Deviations Noted.Major Areas Inspected: Licensed Operator Requalification Training,Including Evaluation of Commitments to Improve Program
ML17325B066
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/14/1988
From: Burdick T, Damon D, Hopkins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17325B065 List:
References
RTR-NUREG-1021 50-315-88-25, 50-316-88-29, NUDOCS 8812190340
Download: ML17325B066 (24)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-315/88025(DRS)

No. 50-316/88029(DRS)

Docket Nos.

50-315; 50-316 Licensee:

Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Licenses No.

DPR-58; No.

DPR-74 Facility Name:

D.

C.

Cook Nuclear Power Station, Units 1 and

Inspection At:

Bridgman, MI 49106 Inspection Conducted:

October 31 through November 4, 1988 Inspectors:

J.

A. Hopkins

~ P.

/A~I~>

a,te D. J.

Damon

~(A5QC Approved By:

T.

M. Burdick, Chief Operator Licensing Section

iQiqle ate 1 ~ r'f/~~

ate Ins ection Summar Ins ection on October 31 throu h November 4 1988 Re orts No. 50-315/88025(DRS)

reas ns ecte

pecial unannounced inspection by region based license examiners inspectors in the area of licensed operator requalification.training.

This included evaluation of the status of the commitments made by the licensee to improve their requalification program and the progress they are making in implementing the new requalification examination process.

Selected portions of Modules 30703, 41701 and 92701 were used as guidance during this inspection.

Results:

The licensee is fully meeting their commitments to improve the Feequa Tfication Training Program and has made significant progress towards fully implementing the new requalification examination process outlined in NUREG-1021, ES-601.

No violations or deviations were identified.

8812190340 881214 PDR ADOCK 05000315

PDC

>r

Details 1.

Persons Contacted Indiana Michi an Power Com an

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G.

  • A. A.

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Smith, Jr., Plant Manager Blind, Assistant Plant Manager Rutkowski, Assistant Plant Manager Gibson, Assistant Plant Manager Matthais, Administrative Superintendent Gillespie, Operations Training Supervisor Barker, AEPSC equality Assurance Senior Auditor Svensson, Licensing Activities Coordinator Baker, Operations Superintendent Simms, Station Superintendent Cooper, Requalification Program Administrator Arent, Operations Training Specialist General Ph sics T. Antonacci, Contract Examiner D. Hoffman, Contract Examiner D. Duquette, Contract Examiner V. Madison, Contract Examiner US NRC

"B.

L. Jorgensen, Senior Resident Inspector

"Denotes personnel present at November 4, 1988 exit meeting.

The inspectors also contacted other licensee staff members during the course of the inspection.

2.

Followu on Previous Ins ection Findin s a.

(Closed)

0 en Item 315/87027-01 OLS) and 316/87027-01(OLS:

The Requa s fscatlon rasn~ng rogram roce ure,

-

-

. TRN.104, Revision 1, allowed personnel to miss lectures and make them up by either passing the quiz or by personal consultation with instructors.

The instructors revealed that at times, significant periods of time were taken up with personal consultation by individuals who had missed lectures and subsequently failed the quizzes.

The licensee indicated that a new draft of the Requalification Training Program Procedure would limit the number and type of lectures that could be missed.

A review of the draft procedure revealed subject area lectures that could be missed, provided the periodic examination on the subject was passed.

Since some of these lecture topics were in previously identified areas of poor performance on requalification examination, the inspectors recommended that these lectures be changed from optional to mandatory attendance.

In a November 5, 1987 letter to the NRC, the licensee committed to full participation in the Requalification Program by mandatory lecture attendance and completion of related quizzes by all Licensees.

Missed lectures would be made up by individual presentation by the instructor or viewing the video taped lecture.

This would be documented in the individual s training record.

The inspectors reviewed the draft of 12-PMP-2070.TRN. 104, Revision 2,

"Licensed Operator Requalification Training Program,"

(LORP), to evaluate the attendance policy for lectures.

Section 4.5 of the LORP requires attendance at all scheduled lectures or allows presenting the lecture or viewing a video tape of the lecture to satisfy the requirement.

A grace period of two requalification periods (six weeks per period) exists 'to make up missed lectures.

The inspectors reviewed the attendance records for one crew over three requalification periods and determined that there was 100K attendance or documented make up of lectures.

(Closed)

0 en Item 315/87027-02 OLS) and 316/87027-02(OLS:.

The

)nspectors were concerne a t e po en la or tralnlng the SROs at the RO level existed.

The licensee committed to review this area to determine if it was a programmatic deficiency.

In a November 5, 1987 letter to the NRC, the licensee outlined the steps they would take to bring the training up to the SRO level.

These steps included:

~

Increasing scope of Read-it packages (see Paragraph 2.c).

~

Acquisition of a site specific simulator.

~

Increased emphasis on EOP bases.

~

Two Requalification Instructors attended an industry sponsored Teaching Workshop (September 1987).

In a January 22, 1988 letter. to the NRC the licensee stated their additional planned corrective actions to bring the training up to the SRO level.

This included additional emphasis in weak areas identified from previous examinations and mandatory lecture attendance (see Paragraph 2.a.).

The inspectors reviewed a sample of the lesson plans from Requalification Cycle 13 (September 1987 through January 1989)

and determined that most of the lesson plans were at the SRO level.

(Interviews with licensed operators in the requalification program agreed with the inspectors evaluation.)

The licensee was told to continue with the process for all of the requalification lesson plans.

(Closed 0 en Item 315/87027-03(OLS)

and 316/87027-03(OLS:

Required reading, common y referre to as ea -1t pac ages, e p ensure the operators maintain familiarity with changes in plant design, systems,

and procedures.

The inspectors were concerned that there was no evaluation of the required reading process.

The licensee committed to develop a method of testing the "read-it" packages.

In a November 5, 1987 letter to the NRC, the licensee outlined the steps they would take to incorporate the "read-it" packages into the requalification training program.

These steps included:

~

Classroom presentation of plant modifications and LERs.

~

Periodic quizzes of the material covered in the "read-it" packages.

The inspectors reviewed a sample of the lesson plans and weekly quizzes from Cycle 13 and determined that the "Read-it" packages had been incorporated into the requalification training program through formal presentation with study objectives and evaluation on the weekly quizzes.

(Interviews with licensed operators in the requalification program agreed with the inspectors evaluation.)

3.

Re uglification Pro ram Im rovement In October 1987, regional based inspectors were sent to the D.

C.

Cook plant to conduct a performance based inspection of the Requalification Training Program to determine the root cause of the unsatisfactory results from the previous two requalification examinations (both in Requalification Cycle 12).

The inspectors identified thirteen areas of

'concern, three of which were classified as OPEN ITEMS (see Paragraphs 2.a.,

2.b, 2. c).

The licensee made several commitments to improve the Regualification Training Program and outlined the steps to accomplish this during the exit meeting, in a November 5, 1987 letter to the NRC, and in a January 22, 1988 letter to the NRC.

On October 31, 1988, regional-based inspectqqs were sent to evaluate the status of the commitments made by the licensee.

The inspectors reviewed the schedule for Requalification Cycle 13, 'selected lesson plans and weekly quizzes, a sample of the attendance records, the draft of 12-PMP-2070. TRN. 104, Revision 2, "Licensed Operator Requalification Training Program,"

(LORP), arid interviewed several training staff members and licensed operators participating in the requalification program.

8elow is a summary of the areas of concern (without the OPEN ITEMS), the commitments to improve the requalification pro~ram made by the licensee, and the inspectors'valuation of the licensee s progress in implementing these improvements.

'a 0 Trainin Week Schedule In October 1987, the inspectors determined that the licensee allowed the individual operating crews in the requalification training week to choose between a four ten-hour day or five eight-hour day schedule.

(Most crews selected four ten-hour days).

The inspectors major concern was that the last two hours of the day were nonproductive.

The licensee committed to modify the requalification training week to five eight-hour days.

The inspectors reviewed the Cycle 13 requalification training schedule, and attendance records and determined that the program was scheduled around five eight-hour days (except for weeks with a holiday).

Additionally, personnel interviewed felt the five day schedule was more effective.

Instructor Contact Time In October 1987, the inspectors were concerned that the SROs were not receiving adequate formal training time to maintain their knowledge at a sufficiently high level.

The licensee committed to increasing the lecture time in Cycle 13.

The inspectors reviewed the lecture schedule for Cycle 13 and determined that there was approximately 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of formal lecture.

Additionally the LORP, Section 4.l.l.c, commits the licensee to provide a minimum of 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> of lecture during each Requalification Cycle.

Finally, the training schedule for Cycle 14 projects approximately 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of formal lecture.

Personnel interviewed stated that the increased formal lecture time was well received.

Non-Structured Trainin Time In October 1987, the inspectors reviewed Cycle 12 requalification schedule and found that during a training week, approximately ten hours per week were spent in formal, lecture and four to eight hours spent in operations meeting, shift meeting, or other non-licensed training.

This left approximately twenty hours of non-structured training time for self-study.

The inspectors recommended that the licensee review the non-structured training time to determine if it was being used effectively.

The inspectors reviewed Requalification Cycle 13 training schedule and the projected schedule for Cycle 14 and determined that almost all of the requalification training week was structured (see Paragraph 3.b for. additional. information).

Personnel interviewed indicated.a need for some self-study time.

Weaknesses in S ecific Areas Hased on the results of requalification examinations in Requalification Cycle 12, the inspectors determined that the level of knowledge in the areas of system design, plant instrumentation and control, and thermodynamics were degraded.

In a November 5, 1987 letter. to the NRC, the licensee outlined a series of steps to address this concern.'hese steps included:

Increased attention to plant instrumentation and control operations during simulator training in Cycle 13.

Increased lecture time during Cycle 13 in identified weak areas.

Two Requalification Instructors attended an industry sponsored Teaching Workshop (September 1987).

The inspectors reviewed Requalification Cycle 13 training schedule and determined that the licensee had incorporated the proposed steps into their requalitication training program.

The effectiveness of the licensee's increased training in the identified areas will be evaluated during the Cycle 13 annual requalification examination (administered November 7 through December 8, 1988).

~Staffin In October 1987, the inspectors found that the designated requalification staff was insufficient to meet the training needs of the licensed operators in the requalification program and the administrative demands of the program itself.

The licensee committed to increasing the Requalification Training Staff to three and to reduce the number of non-shift and non-operational licenses.

In a November 5, 1987 letter to the NRC, the licensee again committed to reduce the number of staff licenses and strictly control the number of licenses assigned outside of the Operations Department.

The licensee committed to expand the Training Staff by one.

Additionally, the licensee stated that after site specific simulator testing was completed, the effective number of instructors dedicated to requalification would be raised to six.

The inspectors reviewed the licensee's Operational Training Organizational Chart and determined that there was an Operations Section Supervisor, a Requalification Program Administrator, six requalification instructors, and one simulator operator.

The inspectors reviewed the licensee's staffing and determined that the number of non-operations individuals licensed was reduced, which included the removal of all the training instructor licenses.

Simulator Trainin Prior to May 1988, simulator..requalification training was provided once a year for a one week period at a non-site specific simulator.

The inspectors noted to the licensee that a fully utilized simulator could markedly improve the* requalification training program in the areas of normal and abnormal integrated operations.

The licensee committed to increase simulator training to greater than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per year.

(The licensee was in the process of.procuring a

site-specific simulator scheduled to be operational in May 1988.)

The inspectors reviewed Requalification Cycle 13 training scheduled and determined that the licensee had provided 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of non-site specific simulator training and approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per period over four periods) of site-specific simulator training.

Requalification Cycle 14 projected approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per period over six periods) of site-specific simulator trainin g.

In section 4.5.B.2 of the LORP, the licensee committed to a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of site-specific simulator training in each Requalification Cycle.

Personnel interviews revealed that the operating crews enthusiastically endorse the site-specific simulator as the greatest asset of the training department.

ualit of Learnin Ob ectives/Test uestions In October 1987, the inspectors found that a large number of the Learning Objectives and test questions were at the simple recall level.

The inspectors also determined that weekly quiz questions did not have realistically assigned point values for the required level of response.

The licensee agreed to review the concern.

In a November 5, 1987 letter to the NRC, the licensee stated that the examination preparation and review process were being revised using NUREG 1021, "Operator Licensing Examiner Standards,"

as a

guide.

The licensee also stated that one requalification instructor had been sent to an industry sponsored examination development course in September 1987.

This instructor would conduct a training seminar for the rest of the Operations Training Staff.

In a January 22, 1988 letter to the NRC, the licensee stated that the training seminar for the Operations Training Staff had been given.

The inspectors reviewed a sample of the Cycle 13 lesson plan learning objectives and weekly quiz questions.

The'inspectors determined that although the licensee had made improvements in the quality of quiz questioning, they needed to continue their effort to get, away from "recall" and "list" questions.

h.

Examination Gradin In October 1987, the inspectors reviewed the licensee's grading and post examination quality review for two Cycle 12 annual requalification examinations and a sample of the weekly quizzes.

The inspectors found deficiencies such as subjective grading, errors in grading, and poor post examination reviews.

The licensee committed to more training for the Operations Training Staff in this area (see Paragraph 3.g.).

The inspectors reviewed a sample of Cycle 13 weekly quizzes and determined that the quality of the grading of the weekly quizzes was acceptable.

The inspectors noted a need for more consistency between different graders and a need to specify partial credit on the answer key (to help improve consistency).

Examination Feedback In October 1987, personnel interviewed expressed a need to obtain their quiz results in a timely manner.

The inspectors found that

obtaining quiz results was not a scheduled activity and was left up to the individual.

The licensee committed to implement a quiz feedback mechanism into the requalification training program.

In a November 5, 1987 letter to the NRC, the licensee stated that weekly quizzes would be reviewed immediately after the quiz, and that a detailed review of the quiz would be scheduled in the next requalification period.

The inspectors reviewed Cycle 13 schedule and determined that the weekly quizzes were being reviewed immediately after each quiz and during the next training period.

j.

Examination Securit In October 1987, the inspectors reviewed Cycle 12 weekly quizzes and annual examinations and found a significant amount of duplication between successive weekly'uizzes and between annual examinations.

The licensee's Requalification.Training Program allowed. as much as 80 percent duplication.

The licensee planned to develop an examination bank to reduce the potential f'r compromise.

In a November 5, 1987 letter to the NRC, the licensee stated that as more high quality questions were developed, (see paragraph 3. g.),

the size of the examination bank would increase.

This, in conjunction with the projected use of a computerized examination bank, would reduce the duplication.

In a January. 22, 1988 letter to the NRC, the licensee stated that to reduce the potential for compromise as measured by the number of duplicate questions used on subsequent exam'inations, a goal of 50 percent non-duplicate questions was established for Cycle 13.

The inspectors reviewed a sample of the weekly quizzes for Cycle 13 and determined that the licensee was making significant progress in reducing question duplication on subsequent weekly quizzes.

The inspectors found that the duplication averaged a little above 50 percent.

(A high of 65 percent and a low of 45 percent.)

4.

Re uglification Examination Process On July 22, 1988 in a letter from the NRC to Indiana Michigan Power Company (AEP), the NRC notified AEP of their intention to administer requalification examinations to the licensed operators at D.

C.

Cook Station during the week of October 31, 1988.

These examinations were to follow the guidance contained in NUREG-1021, Revision 5, "Operator Licensing Examiner Standard,"

section 601(ES-601).

The letter further outlined materials to be submitted to the NRC 60 days prior to the examination.

In a September 1,

1988 letter to the NRC, the licensee stated that the examination materials requested were enclosed, to the extent that they were able to develop them in the available time.

The materials consisted of:

~

59 Open-Reference Written questions

~

12 Job Performance Measures (JPM)

3 Dynamic Simulator Scenarios The licensee further stated that they were concerned that the amount of material available was insufficient to generate an annual requalification examination for October 31, 1988, and were considering an extension request regarding the timing of. submitting the materials.

The licensee projected that they could provide:

~

110 Open-Referenced Written questions

~

35 JPMs

~

10 Dynamic Simulator Scenarios by mid-September 1988.

Due to the accelerated schedule for developing examination materials, the licensee was concerned about the quality of the examination process.

They proposed a hybrid process for the Cycle 13 requalification examination as outlined below:

Open-Reference Written Examination with an objective of no more than 50 percent question duplication.

Dynamic Simulator Examination.

Operating Examinations (Walk-Through) using the methodology in ES-301 and 302, (replacement examinations).

(The licensee stated that they had insufficient experience or resources to develop and validate sufficient JPMs for examination in October 1988.)

Region III examiners reviewed the materials sent and determined that the number of test items were insufficient to administer a comprehensive NRC requalification examination.

In a September 9, 1988 letter to the licensee, the NRC stated the reasons for delaying the administration of requalification examinations and informed them that no future examination date had been scheduled.

The letter also contained comments on the examination material previously submitted as outlined below:

Open-Reference Written questions - too many yes/no or multiple choice questions and a high percentage of simple "look-up" type questions.

JPMs submitted were all related to the control room.

At least 40 percent need to be outside of the control room.

The dynamic scenarios all represented catastrophic failures.

Any instrument or component failures were only run coincident with the major failure.

On October 31, 1988, regional based examiners/inspectors went to D.

C.

Cook to review the licensee s requalification examination materials and methodology during the first week of Cycle 13 annual requalification examinations.

The inspectors evaluated the examination process using the guidance in NUREG-1021, Revision 5, section 601(ES-601),

"Administration of NRC Requalification Program Evaluation."

Specific comments on the dynamic simulator, open-referenced written, and walkthrough portions of the examination were shared with the licensee's training staff to ensure a clear understanding of the problems encountered by the inspectors.

The following paragraphs address each of the three portions of the examinations and the inspectors findings'.

a.

D namic Simulator Scenarios The licensee evaluated four crews over a two day period.

Each dynamic simulator examination consisted of two scenarios which were both used in the morning and afternoon sessions on each respective day'.

The licensee had five approved scenarios with two more undergoing quality review and validation.

The dynamic simulator examination materials and process used by the licensee were generally of good 'quality and conformed with ES-601.

The licensee has integrated instrument and component failures into the scenarios which improved the overall quality of the scenarios.

The following is a list of the concerns identified by the inspectors.

(1)

Examination Briefing - The licensee conducted a briefing which explained the rules and procedures of the s'imulator examination and then conducted a shift turnover to define the condition of the plant.

Next, the candidates performed a control board walkdown and again received a shift turnover.

The inspectors determined that the examination briefing should be separate from the shift turnover in order to more closely simulate a

turnover in the control room.

(2)

Time Critical Behavior - ES-601 requires that each scenario have at least one time dependant crew response.

None of the approved scenarios had a time dependent response.

The licensee committed to review this standard and submit their proposal for incorporating it into their program.

b.

0 en-Reference Written Examination The open-reference portion of the examination consists of two distinct parts; the Static Simulator (part A) and the Limits and

>i',

Controls section (part B).

The inspectors reviewed the open-reference examination to evaluate the licensee's progress in reducing the percentage of yes/no or multiple choice questions and "look-up" type questions.

The inspectors determined that the quality of the questions had improved and generally conformed to ES-601.

Part B of the examination was administered to 15 candidates in a classroom setting.

The licensee supplied only six sets of reference material.

Twelve candidates did not complete that portion of the examination.

The licensee reviewed the situation to determine the root cause of the problem and possible solutions.

The licensee found:

(1)

not enough reference material for 15 candidates, (2)

reference material not well maintained (e. g., missing tabs and indices),

(3)

reference material not well organized in the classroom, (4)

time validation did not duplicate examination conditions.

The inspectors agreed with the licensee's evaluation and told the licensee that ES-601 requires that each candidate have their own reference.

The licensee is continuing their evaluation to determine appropriate corrective actions.

c.

0 eratin Examinations The licensee conducted operating examinations on 15 candidates using the methodology outlined in ES-301 and ES-302 (replacement examinations).

The inspectors monitored a sample of the examinations with no problems noted.

The licensee was informed that future requalification examinations should follow the standards in ES-601 to be suitable for NRC use.

5.

Exit Interview The inspectors met with licensee representatives (paragraph 1) at the conclusion of the inspection on Nov'ember 4, 1988, and summarized the scope and findings of the inspection activities.

The licensee acknowledged the inspectors'tatements.

The inspectors also discussed the likely informational content of the.inspection report with regard to documents or processes reviewed during the inspection.

The licensee did not identify any such documents or processes as proprietar RIII REPORT/LETTER TRAVELLER Total daYs to issue:

Licensee:,,

INDIANAMICHIGAN 1%M& OGMPANY 1 RIVERSIDE 1MZA COLUMBUS, OH 43216 Facility(s):

D. C.

COOK NUCLEAR HM&SZAPION URIS 1 AND 2 License No(s):

DPR-58; DPR-74 Draft Completion Date:

Initial'yping:

Received Start End

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Start End Date Hailed:

Date Received:

Review Process **

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