IR 05000482/1987019

Insp Rept 50-482/87-19 on 870727-31.Potential Violation Noted.Major Areas Inspected:Licensed Operator Initial Training & Requalification Program

ML20237L004
Person / Time
Site:	Wolf Creek
Issue date:	08/11/1987
From:	Bruce Bartlett, Harrell P, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237K988	List: IR 05000482/1987019 ML20237K984
References
50-482-87-19, NUDOCS 8708200042
Download: ML20237L004 (10)

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~ APPENDIX f?g,' .g U. S. NUCLEAR REGULATORY COMMISSIO,'<[

REGION.IV

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}, ;. ~ w-i hj{'q q Inspection Report: 50-482/87-19 .,. - License: l YT;#4d t *

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Licensee: Wolf Creek Nuclear Operating: Corporation (WCNOC). Kj 4'Q

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P. O. Box 411  !

Burlington,' Kansas. 66839.

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Facility Name: WolfCreekGeneratingStathp)(WCGS@)- .,

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Inspection At: Wolf Creek Tite, Cof fey County, 8t gton, Kansas-

Inspection Conduc.ted: July' 27-31, ' 1987'-

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P. H..Harrell, Senior Resident React Date e 5'

Inspector,FprtCalhounStation 'f ,, (,<#

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Eh l B. L. Bartlett, RKident Inspector, . Date ., s 'TY,tN. ' #

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Approved:

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l 0. R. Hunter, Ch b)f, Project Section B, ' ;Drf,e '\*fp/

Reactor Projects Branch <> <C

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Inspection Summary '

L ' ){t. Inspection!Cmducted JuIy 27-31,~1987 (Report 50-482/87-19)

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Areas' Inspected: Routine, unannounced inspection including licensed operator J, ,

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initial training and requalification programs, and the nonlicensed staff training program, o < q

'Results: Withtf'Ah7,three arehs inspected, one potential violation'(failure to

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I n" . OR3Ili~NRC apprordi' prior to implementation of changes to the NRC-approve , requalification program that- degraced the program, paragraph' 3) was identified, g In<accordance with the Commission Policy Statement on Training and

,qualificationofNuclearPowerPlantPersonnel(50FR11147),thepotential i

violation will be treated as an unresolyed item.

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i DETAILS

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f Persons Contacted

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* Boyer, Plant Manager

• Chernoff, Licensing Engineer

• Estes, Superintendent of Operations

• Fehr, Superintendent, Licensee Training

• Flannigan, Acting Superintendent of Regulatory, Quality, and q Administrative Services 'l

• R. Grant, Vice' President, Quality il i

R. Guyer,-Supervisor, License Training

• C. Hoch, Quality Assurance Technologist

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R. Hubbard, Training Coordinator, License Requalification

! *W. Lindsay, Supervisor, Quality Systems

• 0. Maynard, Manager, Licensing ~ ..

• W. Mutz, Manager, Nuclear Plant Engineering Systems

• G. Pendergrass, Licensing Engineer

• F. Rhodes, Vice President, Nuclear Operations

• W. Rudolph, Manager, Quality Assurance I

• S. Sparks, Licensing Engineer

• J. Zell, Training Manager NRC Personnel

• J. Cummins, Senior Resident Reactor Inspector,' Wolf Creek Station

• Denotes personnel present at the exit intervie The NRC inspectors also contacted other plant personnel including operators, technicians, and administrative personne ; Licensed Operator Initial Training The NRC inspectors reviewed the initial licenced operator training program to verify that the program being implemented by the licensee complied with the licensee's established training program, as described in Procedure ADM 06-221, " Licensed Operator Initial Training Program,".and 10 CFR Part 55. This review was performed to verify that selected individuals that had recently received their initial licenses had completed the licensee's training program. During performance of this review the NRC inspectors verified that the following program elements >

were properly completed by each individual: i

. Lectures required by the licensee's training program were attende . Simulator training was complete . Required time on shift was performe . Simulator and cla'ssroom examinations were successfully. pass'e !

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The NRC inspectors verified that the licensee had maintained records to document participation by each licensing candidate in the above activitie Based on the review performed by the NRC inspectors, it appeared that the licensee was implementing an effective licensed operator initial training

! progra The licensee received accred.;ation from the Insti 'Jte of Nuclear Power Operations (INP0) for the initial operator training program in December 198 No violations or deviations were identifie . Licensed Operator Requalification Program The NRC inspectors reviewed the licensed operator requalification program l

to verify that the program being implemented by the licensee complied with the licensee's NRC-approved requalification training program and 10 CFR

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Part 55. During performance of this review, the NRC inspectors verified that the following program elements were implemented by the licensee:

. Preplanned lectures required by the licensee's NRC-approved training program were given to the operating staff in each 2-year requalification cycl . All licensed, onshift personnel reviewed emergency and abnormal operating procedures annuall . Documentation was available to indicate that nonshift licensed personnel reviewed facility design changes, procedure changes,

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facility license changes, and abnormal and emergency operating procedure . All licensed personnel received an annual oral and simulator examinatio ,

l . All licensed individuals who failed the annual written examination I were placed in an accelerated requalification program.

All licensed individuals who scored low in any particular category on

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the annual evaluation were required to attend the appropriate

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lecture .

All licensed individuals received on-the-job simulator training as specified by the licensee's NRC-approved training program.

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. Each licensed operator completed an annual requalification examination prepared by the licensee or the NR t i

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. Records were maintained by the training department to document I participation by each licensed operator in the above activitie The licensee's NRC-approved requalification program was established by the licensee's commitments contained in the Final Safety Analysis Report (FSAR) in effect'at the time the licensee received an operating license for the plant. The details of the commitments were provided in Section 13.2.2.1 of the FSA The NRC inspectors performed a review of the requalification training program currently used by the licensee,' as described in Procedure ADM 06-224, " Licensed Operator Requalification Training Program," Revision 5, dated June 19, 1987, against the requalification  ;

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program approved by the NR This review was performed to verify that l l revisions made by the licensee to the NRC-approved prog' ram had not degraded the requirements of the implemented program. During this review,  ;

the NRC inspectors noted one instance, described below, where the program i had been degrade Section 55.53(e) of 10 CFR Part 55, effective May 27, 1987, states, in part, that nonshift licensed individuals shall' actively perform the functions of an operator or senior operator on a minimum of seven 8-hour shifts per calendar quarter. The licensee implemented.this requirement in Section 6.2.5.2 of Procedure ADM 06-22 However, during implementatio of this requirement, the licensee also added to Section 6.2.5.2, that nonshift licensed individuals shall have a 1-month grace period;in which to make up any missed shifts. The licensee implemented a requirement which effectively allowed nonshift licensed individuals a total of 4 months to complete the shift requirements. This requirement was implemented prior to obtaining Commission approva Section 50.54(1-1) of 10 CFR Part 50 states, in part, that the licensee l may not, except as specifically authorized by the Commission, decrease the scope of the operator requalification arogram. The implementation of the requirement to allow 4 months for nonslift licensed individuals to l complete shift requirements is an apparent decrease in the scope of the requalification program. The failure to obtain Commission approval prior to implementation of a requirement that decreases the scope of the requalification program is a potential violation that will be considered an unresolveo ite (482/8719-01)

The NPC inspectors noted that the current calendar quarter is the first effec)'ve calendar quarter since the rule change to 10 CFR Part 55 was issw t For this reason, the license status for all nonshift licensed individuals was not affected. Licensee personnel stated that a procedure l change would be made to eliminate the 1-month grace perio During review of annual requalification examinations taken by licensed personnel in September 1986, the NRC inspectors noted that one individual had scored less than 80 percent overall on the examination. Section of Appendix A to 10 CFR Part 55 states, in part, that the requalification

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program shall include provisions for each licensed operator and senior l operator to participate in an accelerated requalification program where performance evaluations clearly indicate the need. In Section 6.5.1.2 of l Procedure ADM 06-224, Revision 4, dated December 3, 1985, the licensee 1 implemented this requirement by stating that any licensed individual scoring less that 80 percent overall on the written examination shall be ;

placed in the accelerated requalification program. No time limit was I specified as to when the individual should enter the accelerated l requalification program after it was determined that the individual {

required additional trainin The NRC inspectors reviewed control room logs and noted that the l individual that received less'than 80 percent overell on the examinatio +

was allowed to continue performing licensed duties after the licensee had determined that the individual had received an unsatisfactory grade.on the examination. In discussions with licensee management, it was established j that management policy allowed the individual to continue performing i licensed duties until a convenient time was established for removal of the l individual from shift dutie Licensee' management considered the  !

appropriate time to be when the individual entered his/her normally scheduled training shif Licensee management stated that this policy was l established to minimize perturbations on shift operations. The NRC inspectors informed licensee management that the intent of Section 4.e of Appendix A to 10 CFR Part 55 was' to ensure that individuals, identified as nending additional training, were promptly removed from licensed dutie Licensee management stated that the current policy would be reviewed for l consideration of promptly removing individuals from licensed duties when appropriate. This item remains open pending a review of the licensee's action on this item. (482/8719-02)

During a review to verify that all licensed individuals had completed all required reactivity manipulations, the NRC inspectors noted that the records for six of the ten individuals reviewed indicated that all ,

required manipulations had not been completed during the 1985 and 1986 requalification cycle Section 3.a of Appendix A to 10 CFR Part 55 states, in part, that the requalification program shall include on-the-job training so that each operator and senior operator performs control manipulations in any combination of reactor startups, reactor shutdowns, or other control manipulations that demonstrate skill and/or familiarity with reactivity l control system The licensee implemented this requirement by issuance of

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Procedure ADM 06-224, Revision 4, Attachment 1 for annual manipulations l and Attachment 2 for biennial manipulations. These attachments specified which manipulations were to be performed to demonstrate skill and/or familiarity with control system At the beginning of the current requalification cycle, the licensee instituted an informal program where the_ simulator-instructor tracks the

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i performance o'f each manipulation by each licensed individual. The NRC ,

inspectors reviewed.the log maintained by the simulator instructor. It

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appeared that the licensee had implemented a program that would ensure ,

that each licensed individual completed all required manipulations. It I appeared that the licensee had adequately addressed this item; therefore, '

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this item is considered closed and no further licensee action is required.

I During a review per formed by the NRC inspectors, it was noted that. records indicated that nine of ten licensed individuals had failed to review al emergency and off-normal procedures during 198 The records. indicated i that the nine individuals failed to review one or all of off-normal l Procedures OFN 00-017,00-018, 00-023,00-025, and 00-026. The reason ]

l that the individuals failed to review the procedures was that the signoff l sheet, used to document the completion of the procedures review, did not l list all the appropriate procedures.

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Section 3.d of Appendix A to 10 CFR Part 55 states, in part, that the  ;

requalification program shall include on-the-job training so that' each l

, licensed operator and senior operator reviews the contents of all abnormal'

! and emergency procedures on a regularly scheduled basi The licensee implemented this requirement by issuance of Procedure ADM 06-224, Revision 4. Section 6.2.4.1 of Procedure ADM 06-224 states, in part, that reactor and sen4r reactor operators shall review

. the contents of off normal and emergency procedures annually.

l Verifi':ation of review will be provided by signoff sheets (Attachment 3). j l Attachment 3 did not contain a listing of all the appropriate off-normal i l procedure l

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During followup on this item, the NRC inspectors noted that the licensee j had revised the signoff sheet for verification of procedures review in l

Revision 5 to Procedure ADM 06-224. The revised list, provided as i

Attachment 1 to the procedure, contained a listing of all the appropriate emergency and abnormal procedures. It appeared that the licensee had taken appropriate action to correct this problem; therefore, no additional licensee action is require On May 27, 1987, a rule change was issued by the NRC to 10 CFR Part 5 This rule change also affected portions of 10 CFR Part 5 ,

Section 55.53(g) of 10 CFR Part 55 and Section 50.74 of 10 CFR Part 50 established new requirements for notification of the Commission of licensed operator status changes. The NRC inspectors requested that the licensee provide the procedure that implemented the new reporting l requirements. The licensee stated that an implementing procedure had not l been developed and issued. The licensee stated that they would'use.the ]

regulations in 10 CFR Parts 50 and 55 as guidance.for issuance of the j appropriate notifications to the Commission. The NRC inspectors = expressed :

concern that regulations did not provide the level of detail and the  !

necessary guidance for the individuals that would encounter.the j information that required Commission notification. The licensee stated that a review for the need of an implementing procedure would be

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t performed. This item remains open pending aLfuture review to verify th'at, the licensee has~ notified'the Commission of any instantes required by the-regulations. (482/8719-03)

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The:NRC inspector reviewed the lesson plans. listed below to-verify thatt the lesson plans were technically correct and contained the appropriat ,' informatio umber Title LO-10-005-00 Residual Heat Removal 1 System,

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, LR-10-005-00 Residual Heat Removal, System 1 Review with a Loss of Shutdown -

' Cooling, Revision ~0 LO-14-061-00 Auxiliary.Feedwater System,

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Revision 2 LR-01-107-00 Davis-Besse Loss of' Main and >

l . Auxiliary Feedwater Events Revision 0

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During the review, the NRC inspectors noted minor errors in the 1esson plans. The licensee stated the errors would:be correcte During performance of.this portion of this: inspection, the NRC inspectors identified areas of concern. The licensee stated:the concerns would be reviewed and implemented, if appropriate. 'The" concerns are:as follows:

. Section 55.59(c)(2) states that preplanned lectures on the applicable-portions of Title 10, Chapter I, CFR shall be included in the requalification program. The NRC inspectors noted that the licensee-had only provided training nn.10 CFR Part 20. . The NRC inspectors suggested that 10.CFR Parts 2, 21, 50,'and 55'should'be included in-the lecture serie . In Procedure ADM 06-224, Revision 5, the licenseeLused."shall," ,

"should," and "may" to indicate'a requirement, a' recommendation, or permission, respectively. 'During review of the procedure', the NRC )

inspectors noted that "should" or'"may" were used in statementsjthat =

were requirements. Without the proper use of "shall," the statements

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did-not indicate the relative importance of the requirement. . The licensee stated that Procedure ADM 06-224 would be-reviewed.to ensure:

that'the use of "shall," "should," or "may" accurately reflected the-intent of each procedural statemen . The. rule' change made by the NRC to 10;CFR Part 55 on May 27, 1987, changed the frequency of the performance of the loss of essential-service water reactivity manipulation from bienniallto' annua '

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i Procedure ADM 06-224, Revision 5, had not been changed to reflect this requirement. The licensee stated a procedure change would be l- made to correct'this itemi

. Procedure ADM 06-224 stated that retraining was required for a nonshift licensed individual. if the individual did not perform licensed duties for a pe'riod'of 4 months. When the rule change was issued to 10 CFR Part 55, this requirement was deleted. Licensee-personnel stated Procedure ADM 06-224 would be revised to eliminate this statemen .

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. l The licensee received accreditation from the INP0 for the' shift supervisor I and control room operator training pr~ograms in December 198 . Nonlicensed Staff Training '

The NRC inspectors reviewed the nonlicensed staff training program to ' '. ,

verify the program was being implemented in accordance with the i requirements of the Technical Specifications and AN51 3.1-1978. The review included examination of training records' ard discussions with personnel. The review also included verification that selected personnel met the experience requirements-for the position held as' defined by ANSI 3.1-197 The NRC inspectors reviewed the following procedures to verify that the appropriate requirements had been implemente No problems were noted during this revie Numbcr Title

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l ADM 06-225 STA-Duty Call Technical Advisor Training A0M 06-211 Nonlicensed Operator Requalification Training ADM 05-110 Results Engineering Personnel Qualification and Training ADM 05-401 Reactor Engineering Personnel Qualification and i Training l ADM 01-102 Instrumentation and Control S;pervisor Duties and Responsibilities l I

ADM 01-011 Reactor Engineer Supervisor Duties and l Responsibilities ( ADM 01-044 Results Engineering Supervisor Duties and

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Responsibilities The licensee received accreditation from the INPO for the shift technical advisor and health physics technician training programs in December 1986.

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-10-l The INP0 will visit the site in the fall of 1987 co review the remaining training program Based on the review performed, it appeared that the licensee was I implementing effective training programs for nonlicensed staff personne No violations or deviations were ' identifie . Unresolved Item )

i An unresolved item.is a matter that requires additional information for-determination of whether it is acceptable, a. violation, or a deviatio An unresolved item.is discussed in paragraph 3 of this repor )

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482/8719-01 Degradation of the requalification- f training program without prio i Commission approval s

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i 6. Exit Meeting i l

The NRC inspectors met with Mr. G. D. Boyer, Plant Manager, and other {

members of the licensee staff at the end of this inspectio At this 1 meeting, the NRC inspectors summarized:the scope of the inspection and the 4 finding !

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