IR 05000498/1988031
| ML20196L416 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/30/1988 |
| From: | Gagliardo J, Greg Pick, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20196L413 | List: |
| References | |
| 50-498-88-31, 50-499-88-31, NUDOCS 8807070453 | |
| Download: ML20196L416 (14) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-498/88-31 Operating License:
NPF-76 50-499/88-31 Construction Permit:
CPPR-129 Dockets:
50-498 50-499 Licensee:
Houston I.ighting & Power Company (HL&P)
P.O. Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project (STP), Units 1 and 2 Inspection At:
Bay City, Matagorda County, Texas InspectionConductep:
May 2-6 and 16-20, 1988 lh' N
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Inspectors:
G. A. Pick, Reactor Inspector, Operational Date
"Frog ms Section,. Division of Reactor Safety
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B'. Vickfey, Reacter Inspector, Operational Date P ogrgmf Section, Division of Reactor Safety M
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j Approved:
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s r f. Ga[ ljiardo, Chief, Operational Programs Da;e S6ctiord, Division of Reactor Safety Inspection Summary Inspection Conducted May 2-6 and 16-20, 1988 (Report 50-498/88-31; and 50-499/88-31)
Areas Inspected:
Routine, unannounced inspection of licensed operator training and nonlicensed staff training.
Results:
Within the two areas inspected, no violations or deviations were identified.
8807070453'88'0701 PDR ADOCK 05000498.
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DETAILS ~
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1.
P_ersons Contacted HL&P MP. Appleby, Training Manager
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LJ. Constantin, Supervisor, Operations Training
- B. Franta, Manager, Education and Administration
- J. Geiger, General Manager, Nuclear Assurance
.R. Graham, Senior Training Instructor.
- J. Green, Manager, Inspection and Surveillance
- S. Head,. Supervisor, Licensing
- 0. King,. Construction Manager
- J. Kubenka Manager, Staff Training
- E. Rosa',SlteManager'Ebasco)
- L. Weldon, Manager, Operations Training
- M. Wisenburg, Piant Superintendent, Unit 1 NRC
- J. Bess, Resident. Inspector
- D. Garrison, Resident Inspector
- J. Milhoan, Director, Division of Reactor Safety
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' *G. Pick, Reactor Inspector
- R. Vickrey, Reactor Inspector Other people cetitacted included operators, technicians, administrative personnel, and other training instructors.
- Denotes < those present during-the exit interview on May 20, 1988.
'2.
Followup on Previous Inspection Findings (Closed) Observation No. 15:
The licensee should reevaluate the practice of not logging equipment clearances by system.
The NRC inspector reviewed the South Texas Project Procedure OPGP03-20-0001, Revision 7, "Equipment Clearance," to determine if.the commitment made to change the wording of
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-the clearance procedure as described in NRC Inspection Report 50-498/88-17 was implemented.
The NRC inspector determined that the-requirements of Steps 5.2.1.d and.
5.2.1.g should ensure that all other systems affected (those which are part of the clearance boundary) by the clearance will be designated.
An additional concern was expressed by the NRC regarding the number of designated "acceptors," since everyone on the designated acceptor list may not have had the requirt.d specific technical expertise or system knowledge.
The licensee, in response, routed the list of designated acceptors to the department heads (e.g., manager plant operations) for
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They were to review the list and delete any unnecessary names.
Approximately 100 names were deleted for a revised total of designated acceptors of approximately 900.
This item is closed.
(0 pen) Observation No. 24 - The NRC inspector followed up on the comments made in NRC Inspection Report 50-498/88-17. The NRC inspector determined that the Technical Specification Management System (TSMS) software problems hvi been resolved, since the TSMS was operable and on-line on the prime computer.
There had been training conducted for the shift supervisors on the TSMS "Hypothetical Mode."
The NRC inspector commented at the exit meeting that this software would be an enhancement to the operating staff if all licensed operators were to be trained on TSMS operation and capabilities during a future requalification session.
The NRC inspector determined from the licensee that, although there was no estimated completion date, plans were being formulated to get a computer terminal in the simulator which will duplicate TSMS installed in the control room.
This observation remains open awaiting NRC verification of the system in operation.
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No violations or deviations were identified.
3.
Licensed Operator Training (41701)
The NRC inspector utilized the documents listed in Attachment 1 during conduct of the South Texas Project licensed operator training program inspection to obtain guidance for the program attributes in place.
a.
Licensed Operator Requalification Program - The inspection in this area was conducted to determine the effectiveness of the licensed operator requalification program.
The NRC inspector selected various operational events that occurred during startup.
These events may have been the result of deficient training or, as a result of the event, training was required as part of the conective action.
The South-Texas Project Licensee Event Reports (LERs) utilized to conduct the inspection and evaluate the South Texas Project licensed operator training program, are listed in Attachment 2.
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For the events reviewed, the NRC inspector checked records of selected individuals from both the operating staff and the training staff in order to determine if they attended training sessions related to the events. Each of the persons selected was licensed as either a senior reactor operator (SRO) or a reactor operator (RO).
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'The training received before the events consisted of that presented
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'in the Cold. License Training-Program.
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LTraining received by the licensed individuals,safter the events
o w'rred, resulted=in either teaching about the event ~in, lessons
learned or having licensed individuals read the LER-in."required
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. reading.'" Additionally, information from some events.resulted in_the development of a newslesson. plan or' alteration of~an existing: lesson plan. 'The training presented was' determined by the NRC inspector to be sufficient.
The.NRC inspector. verified lfor the individuals selected that:
they had attended the on-shift briefing; they had attended the 1987 requalification_ program lectures; they had conductedLall required control manipulations; they reviewed the required reading; and the-required procedure reviews and self-study were completed.
For-six of the individuals selected, the inspector reviewed their training records as documented on the Training Records Documentation System (TRDS).
The NRC inspector verified that.the TRDS had accurately documented attendance for each event selected.
The pass' rate for the 1987,requalification examination was that 48 of 50 SR0s and 4 of.4 R0s-who took the examination passed.
Two SR0s who had failed the 1987 requalification examination required accelerated requalification training.
The HRC inspector determined that the SR0s were removed from shift duties and placed in accelerated'requalification training.
This consisted of repeat attendance at cycle 707 requalificatio,n lectures and retake of the
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requalification. examination.- 'After passing the reexamination, the two SR0s were reassigned to licensed duties.
The NRC insper. tor interviewed'several licensed operators.
Operators
.who were interviewed expressed dissatisfaction with requalification training conducted outside of regularly scheduled training sessions, The operators interviewed perceived that this training was scheduled in this manner in order to meet licensee commitments to the NRC.
The licensed individuals who maintained an "active" license at South Texas Project were the five operating crews.
Reactor operations management did not maintain "active" licenses.
The method utilized to document an individual returning to "active" status involved the person doing parallel watchstanding for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in the position for which he will be assigned.
The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> includes a complete tour of the plant and all required shift turnover procedures.
The operations
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-division then sends a memorandum to the training department certifying that the individual has completed the parallel
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i-5-watchstanding requirements.
For the operating crews, there had been no tracking of hours on watch.
The 1987 requalification training cycle hours were allocated as follows:
Classroom 203.5 Simulator 51.0 Self-Study 89.5 Examination 15.0 This translates into 71 percent of the time the individuals were being instructed.
Four percent of the time was used for examina-tions, and 25 percent was self-study.
Self-study was utilized for completion of nequired reading and review of the material presented in class.
A job and task development project was being conducted as part of the South Texas Project accreditation effort.
There were 13 people dedicated to the job and task analysis development project.
The licensee estimates that they will request an accreditation board hearing around August 1989.
The licensee expects to be board accredited by December 1989.
In the areas reviewed related to the South
.as Project requalifice-tion program, the NRC inspector identified
, problems with the program effectiveness.
No violations or deviations were identified.
b.
Distribution of Licenses The licensee had 53 licensed operators with an additional 17 candidates who had completed their NRC R0 Hot License examinations.
The results of the license examination had.not been received at the close of the inspection.
The licenses were being utilized as listed below:
SR0s 49 - Total 8 - Nuclear Training 6 - Shift Technical Advisors (STA)
1 - Quality Assurance 3 - Reactor Operations Management 2 - Reactor Operations Support
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29 - On Shift R0s 4 - On Shift The breakdown was such that there were 29 plant operations personnel l
with SR0 licenses on shift, 2 training department SR0s on shift, and l
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'4 R0s'on shift for a total of 35 personnel on shift 'The six STAS were also on shift.
After the R0 candidate results'have.been received,'.the licensee indicated that he planned to place the majority of those-who pass with Unit 2 to aid in the testing and.startup activities.
There was at the time, a Hot License II class scheduled to be' examined by the NRC in November 1988.
There could be another 20 licensed operators at'the plant, giving an approximate total of 90 licensed individuals by November 1988.
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The licensee. appeared to have planned for enough operators to assure safe operation of both units; however, they did not appear to have sufficient reserve of individuals to. provide relief for the normal operating crews.
No violations or deviations were identified.
c.
Hot License' Training Program The NRC inspector reviewed the training that was presented to the South Texas Project Hot License I training class to determine its agreement with Sections 5.1 and 5.2 of ANSI /ANS 3.1-1981, "Selection, Qualification and Training of Personnel for Nuclear Power Plants."
.The Nuclear Training Department (NTD) informed the NRC inspector that
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this was the standard that thei program was designed around although they are committed to ANSI N1S.1-1971, "Selection and Training of Nuclear Power Plant Personnel."
The' training schedule for the Hot License I class included subjects'
which covered all the required areas.
Lesson plans were developed fer the required theory, mathematics, plant systems, transient and accident analysis, TS, plant procedures, teamwork, diagnostic training, health physics, and plant chemistry.
Lesson plans were developed for the simulator which included simulator exercises, scenarios, and practice sessions.
An on-the-job training program was developed.
The NRC inspector verified that an independent audit examination similar to an NRC licensing examination was given and the examination results reported to South Texas Project.
The South Texas Project Hot License Training Program as described in Procedure IP 8.8, Revision 1, "Licensed Operator Training Program,"
was in agreement with ANS 3.1-1981, Sections 5.1 and 5.2.
The simulator time scheduled appeared to provide sufficient familiarity for the Hot License I class.
The on-the-job training scheduled met the requirements.
The inspector reviewed the below selected lesson plans for technical content:
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~ Neutron: Kinetics LOT 101.06 LOT 102.39-Bernoulli's Equation L01102. 44.
Pump' Laws LOT 102.45 Pum,i Head LOT 102.51 Water Hammer LOT 501.08
' Constant Axial Offset Control LOT 504.47'
Natural Circulation Cooldown Without Letdown LOT 504.48 System Operating Procedures LOT 700.01 Lessons Learned From Events Each.of the lesson plans' reviewed had detailed instructions-for the.
instructor and sufficient technical content.
No violations or deviations were identified.
d.
Selected Topics The NRC inspector reviewed the Operator License Examination Report OL-87-02 and asked the licensee what corrective action was taken to prevent the operators' accident response, from being-inconsistent and unstructured as identified in the ceport during'a Mode 4 and/or Mode 5 loss Of coolant accident.
The inspector verified that emergency procedures for these contingencies were developed.
-The NRC inspector reviewed the training department mechanism for tracking commitments.
The process was described in Procedure NTP-109, Revision 1, "Licensing Commitment Management."
This training department procedure ensured that all commitments accepted by the training department will be tracked to completion.
The method of transmittal between the Training' Department and Support Licensing was specified.
Responsibilities within the Training Department were described and the documentation required to close an item was specified.
An area closely related to the commitment tracking was the feedback mechanism in place at the South Texas Project.
The initial screening of industry experience items (IE Bulletins, Generic Letters, SOERs, etc.), which are transformed into Operating Expirience Reports and Station Problem Reports, was conducted-by Support Licensing.
Both items were placed on Management Action Tracking System (MATS).
If action was accepted and/or assigned to the training department, then the training department would recreate the item by their cost code.
Upon completion of the Operating Experience Report, the training department retained a copy of the plan of action and closed the item on the MATS.
When the corrective action required by a Station Problem Report was completed, the necessary documentation was routed to Support Licensing for verification and closure.
One other area reviewed was instructor certification training.
This area was described in Procedures NTP-115, Revision 1, "Certification
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-8-of Instructors," and NTP-122, Revision'0, "Instructor Training Program." The NRC inspector verified through record review for three
.recently. hired contractors that they were certified by' Certification the licensee as instructors-in accordance with Procedure NTP-115,-
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of-Instructors," Step 6.3.3.
For each of the three individuals, the Provisional. Certification was based on observing a practice teaching session and by reviewing the individuals' experience as documented on their resumes. ~The certification was for.1 year.
At the time of the inspection, because of each contractors' training experience, there were no p ans to place them through an instructor training program, The NRC. inspector determined from discussions with the licensee that.
staff instructors were to be evaluated by their: respective training
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division manager and a' representative from the Education and Administration Division-to identify any weaknesses in either their instructional-ability or technical competency.
Instructors of licensed personnel were required 2to participate in the licensed operator requalification program.
From the personal TRDS training records of two instructors,.the NRC inspector determined that they had documentation of. participation in the 1987 requalification program and they had received' training on various instructional techniques.
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Trainir.;; Operational Readiness Fallowup Observation No. 2 - The NRC inspector' determined that licensee plans to resolve thiTconcern will be completed after all Plant Operations Review Committee (PORC) cembers and the alternates, who.have not had their training, co;aplete the training session scheduled in June 1988.
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The licensee was questicned on how they plan on training future employees who nay require this training and whether or not-they intend to conduct refresher training.
The' licensee responded that
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refresher training would be scheduled as the need for retraining is identified.
Observation No..E - The NRC inspector determined that the NTO was in the process of diveloping a detailed lesson plan on root cause analysis which will be more specific than and expands on the training being presented by the Independent Safety Engineering Group as discussed in NRC Inspection Report 50-498/88-17.
The lesson plan was to be based on various techniques which will be integrated.
The estimated completion date for the lesson plan development was August 1, 1988.
Observation No. 10 - In NRC Inspection Report 50-498/87-45, it is documented that "Mr. G. E. Vaughn indicated a commitment to integrate operations and training personnel in the future to increase cooperation."
In the licensee's response to observations made at the above exit meeting, the licensee states "HL&P management is developing a plan for rotating personnel between these two departments to provide cross training and a better mutual under-standing of each department's activities and responsibilities.
HL&P
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-9-will continue ~.to monitor this situation." The NRC inspector determined 1 rom discussions with the licensee that only one person.
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from operations had transferred to the training department.
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hired as an instructor and not rotated into the training ~ department.-
He had already left the training department at the time of the inspection.
Additionally, from discussions with' licensee personnel, the NRC inspector determined that after the_ pre'sent plan for rotating training instructors into.the plant for added operational experience expires in October 1988, there were no plans for any additional rotational assignments.
In summary, the'NRC inspector could not find evidence that there were any rotational assignments'from plant
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operations to the training department and there existed no plans to continue rotating individuals from' training department to plant operations after October 1988.
This is an open item (498;499/8831-01) awaiting subsequent inspection to datermine what actions have been taken by the licensee-to comply with the commitment contained in their response (ST-HL-AE-2298) dated July 15, 1987, to Observation 10.
The training dep'artment Procedure NTP-115, Revision 1, '! Certification of Instructors, Step 6.1.3.2 states, in part, that "Maintenance of technical competence for other certified instructors should include participation in continuing and special training programs that are provided in the technical areas for which certification is to be maintained....
They should also maintain familiarity with job requirements, plant changes, operating experiences, and technical
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specifications by periodically working or observing in their ~ area (s)
of technical specialty within the plant.
These activities should be documented using Attachment NTP-115-03 or a similar document."
A licensee representative state-that there were plans for operations instructors to be in the plant 'or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per month and approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.
It wa, his understanding that this amount
of time spent in the plant was a standard ir.dustry practice per year.
However, the procedure neither formalized a method to document the actual time spent nor required operations instructors to spend any specific amount of time in the plant.
-In response to an NRC comment (in NRC Inspection Report 50-498/88-01)
regarding no proceduralized method for the plant staff to provide quick feedback to the requalification training program, the licensee stated that the Operations Experience Feedback Form 8.9-4, located in IP 8.9, was used for this purpose. When plant operations determines that training would be required in a specific area, they could i
request training from the training department.
The Manager, i
Operations Training Division, informed the NRC inspector that, upon
completion of the training, the attendance sheets were to be returned l
to plant operations for verification that the training was completed.
This process was not prescribed by steps in the procedure, but relied on the guidance implied on the form to control the activity.
This process had been utilized on one occasion to date.
No violations or deviations were identified.
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44.
-Nonlicensed Staff Training (41400)
This inspection was performed to evaluate the effectiveness of the training programs for nonlicensed staff'in the areas of principal staff.
m^mbers, maintenance technicians, nonlicensed operators, technical staff members, quality control inspectors, and construction personnel.
The inspection' included interviews with staff, operators, maintenance technicians, and construction personnel to' determine if training was being provided for specific tasks assigned.
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The NRC inspector audited portions of two training c' asses.
Based on the course curriculum, training materials, instructor presentations, and
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classroom conduct observed, it appeared that the personn31 were receiving appropriate training.
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i The NRC incpector reviewed several personnel training records and found them to be properly stored,~ up-to-date, and accurate.
The documentation of these training records indicated that appropriate qualifications, experience, training, and retraining within the organization was being maintained.
Several lesson plans were reviewed for develop. ment and control.
The NRC inspector fotnd that the licensee's action item program had been making necessary changes and modifications to the lesson plans to incorporate lessons learned from events and/or activities.
To verify the adequacy of the training provided for craft, supervision, field engineerings and QC, the NRC inspector reviewed several of the licensee's weekly cable / termination "Teil Box Talk" courses.
The NRC inspector found that the licensee program covered problems, current changes, aad key issues.
The talks discussed root cause and the corrective action to prevent recurrence of identified r,roblems.
During the course of the inspection, the NRC inspector found the overhead hoist in Unit 2 Diesel Generator Room 22'to be-stored in an unsafe configuration.
Its hook was tied-off to electrical conduit with a safety i
belt and the chain was draped across safety-related cable trays and
supports.
This item was brought to the attention of the control room supervisor by the NRC.
The licensee stated corrective action would be taken; however, when the NRC inspector returned to the diesel generator room, he found.the hoist still not stored according to normal practice with the hook retracted.
Further investication found that the other Unit 2 Diesel Generator Hoists were not properly stored.
The NRC inspector interviewed several construction personnel and found that although there were no restrictions on the use of those hoists, they had not received any specific training by the licensee for their use or storage.
The NRC inspector reviewed the lesson plans for maintenance personnel training dealing with cranes and hoists for Unit 1 and found no specific instructions for the storage'of hoists.
This item was discussed with the
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To ensure that it was not overlooked, the instructor'made an'on-the-spot
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change to the ;1esson plans adding specific wordsj to' describe. how. to store L
hoists.
The NRC' inspector' disc'ussed the lack of training for construction personnel on use and storage of hoists with'the construction training i
personnel.
Construction training personnel agreed with the NRC inspector
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that there'was a need to train construction personnel in use of hoists and that training should cover new employees, existing employees, and some sort of periodic-refresher training.
This is considered'an open item (499/8831-02) pending the satisfactory implementation by the licensee of a training program for construction. personnel in these areas.
l The NRC inspector found that t.he licensee seemed to express a favorable attitude toward the continued development of their training programs.
The licensee's efforts to update cnd improve any areas'that seemed to be deficient was responsive. The review of procedures and other training dacumentation indicates that the licensee is progressing favorably in their efforts.to achieve INP0 accreditation within reasonable milestones.
No violations or deviations were identified in this area.
5.
Exit interview The inspection scope and findings were summarized with those individuals identified in paragraph 1.
The licensee did not identify as proprietary any information provided to or reviewed by the NRC inspector.
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Attacament 1 Documents Reviewed The NRC inspector utilized the below listed documents during conduct of the South Texas Project licensed operator training program inspection:
IP-1.45Q, Revision 1, "Station Problem Reporting," dated February 22, 1988 IP-2.2Q, Revision 3, "Operating Experience Review," dated November 17, 1987 IP-8.1, Revision 2, "Technical Advisory Councils," dated September 12, 1986 IP-8.3Q, Revision 1, "Training Interface," dated December 9, 1986 IP-8.4Q, Revision 0, "Training Records Documentation System," aated June 16, 1986 IP-8.7Q, Revision 0, "Cold License Training Program," dated July 27, 1987 IP-8.8, Revision 1, "Licensed Operator Training Program," dated September 12, 1986 IP-8.9, Revision 1, "Licensed Operator Requalification," dated March 5, 1988 IP-8.18, Revision 1, "Conduct of On-the-Job Training," dated March 11, 1986 NTP-104, Rovi.cion 1, "Training Program Specification," dated September 26, 1986 NTP-109, Revision 1, "Licensing Commitment Management," dated May 1,1988 NTP-111, Revision 3, "Lesson Plan-Development and Control," dated April 1, 1988 NTP-112, Revision 1, "Course / Instructor Evaluations," dated September 26, 1986 NTP-115, Revision 1, "Certification of Instructors," dated April 1,1988 NTP-122, Revision 0, "Instructor Training Program," dated March 1, 1988 NTP-123, Revision 0, "Senior Reactor Operator Certification," dated April 13, 1988 l
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-2-ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel" ANSI /ANS-3.1-1981, "Selection, Qualification and Training of Personnel for Nuclear Power Plants" Lesson Plan, "Introduction to Root Cause Analysis," dated January 18, 1988
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Attacment 2 Licensee Event Report The following South Texas-Project Licensee Event Reports (LERs) were utilized:
LER Number Subject Residual Heat Removal / Component Cooling Water-
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Water Hammer 87-012 Lockout of Cold Leg High Head Safety Injection (HHSI) Valves87-022 Inoperability of Two Toxic Gas Monitors Due to Failure to Switch From Summary Mode to Normal Operation.88-001 Reactor Coolant Pump (RCP) Started With a Secondary Temperature Greater Than 50 F Above The Primary Temoerature 88-002 Failure to Perform Local Leakage Rate Testing, (Fost Maintenance Test) on Containmer.t Isolation Valves88-003 Control Room Ventilation Actuation to hecirculation Mode Due to Improper Operator Action 88-005 Inadequate Surveillance Performed cn a Control Room Intake Air Radiation Monitor (F&ilure to Return to Normal)88-015 Technical Specification (TS) Violations, MSIV Inoperable 88-019 Prematurely Terminating an LC0 Requirement 88-020 ECW Screen Wash Booster Pump Mistakenly Declared Operable (Failure to Verify Test Acceptance Data)
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