ML17055D945
| ML17055D945 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/16/1988 |
| From: | Crescenzo F, Lange D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055D944 | List: |
| References | |
| 50-220-88-11, CAL-88-13, NUDOCS 8806230005 | |
| Download: ML17055D945 (14) | |
See also: IR 05000220/1988011
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No. 50-220/88-11
Docket
No. 50-220
License
No.
Licensee:
Nia ara
Mohawk Power Cor oration
301 Plainfield Road
S racuse
New York 13212
Facility Name:
Nine Mile Point
Unit
1
Inpection at:
Scriba
Inspection
Conducted:
A ril 11-15
1988
Inspector:
Frank J.
Crescenzo,
Senior Resident
Inspector
Shoreham
Nuclear
Power Station
Division of Reactor Projects
date
Approved by:
David J.
Lange, Chief
Boiling Mater Reactor
Section'perations
Branch, Division of Reactor Safety
date
Ins ection
Summar
Inspection
on April 11-15,
1988
( Inspection
Report
No.
50-220/88-11)
Areas Ins ected:
A special,
unannounced
safety inspection
was conducted
to
review the facility's licensed
Operator
and Senior Operator requalification
programs.
This inspection
was focused
on the licensee's
actions
in response
to
Confirmatory Action Letter (CAL) 88-13,
dated
March 28,
1988.
Additionally,
inspections
were conducted of the programmatic
changes
and the guality
Assurance
programs
associated
with licensed operator training programs.
The
inspection consisted of a review of training records,
programmatic
changes,
and
interviews with personnel.
Results:
No violations were identified.
The licensee
had completed
most of
the remedial
actions
necessary
to comply with commitments
made in Confirmatory
Action Letter
(CAL) 88-13.
The licensee's
proposed
actions to prevent
recurrence
of previously identified problems
were found to be programmatically
adequate;
however,
senior
management
attention will be required to ensure
proper implementation of these actions.
8806230005 8806l6
8'DR
ADOCK 05000220
9
DETAILS
1.0
Persons
Contacted:
Ni ara
Mohawk Power Cor oration
J. Willis, General
Superintendent
- R. Abbott, Station Superintendent,
Unit 2
- T. Roman,
Station Superintendent,
Unit
1
- K. Zollitsch, Superintendent,
Training
~B. Blanda, Assistant Operations
Superintendent,
Unit
1
- H. Barrett, Assistant Operations
Superintendent,
Unit
1
- R. Seifried, Assistant Superintendent,
Training
- C. Beckham,
Manager, Quality Assurance,
Operations
"M. Boyle,
Compliance
and Verification
"D. Straka,
Supervisor,
Operations Training
"G. Weimer, Supervisor,
Operations
Training
"D. Johnson,
Corporate Audits
- S. Agarwal,
Lead Licensing Engineer
"T. Egan,
Licensing Engineer
B. Connally, Quality Assurance
New York State
- P. Eddy,
US Nuclear
Re viator
Commission
"W. Cook, Senior Resident
Inspector,
Nine Mile Point
"W. Schmidt,
Resident
Inspector,
Nine Mile Point,
- Denotes those present at the exit meeting
on April 1S,
1988
2.0
Ins ection
of
the
licensee's
actions
in
res
onse
to
Confirmator
Action Letter 88-13.
Confirmatory Action Letter
(CAL) 88-13
documented
commitments
made
by the
licensee
which were to be completed prior to restart of the Nine Mile Unit
1 facility.
These
included the following:
a.
Completion of all requalificat,ion training for Unit
1 personnel
required for the last
24 month requalification cycle.
b. Licensee verification that those individuals who renewed licenses
since
May 26,
1987
had completed all training documented
on
NRC
Form 398 submittals.
c.
Licensee verification that the Unit 2- requalification
program is
in compliance with station
and
NRC requirements.
The inspector
reviewed training records for all individuals identified as
requiring
additional
training.
These
persons
were
identified
by
the
facility licensee
during
an
audit
of the
training
records
which
was
conducted
as
discussed
in Inspection
Report
50-220/88-10.
The
inspector
reviewed several
selected training files to further verify completeness
of
the training program
and to verify the accuracy of the facility licensee's
audit
results.
The
materials
presented
in
the
makeup
sessions
were
reviewed
and interviews
were
conducted
with persons
who
received
makeup
training to determine
the effectiveness
of the training received.
2.1
Ins ection
Findin s:
The results
of the training file review
revealed
that
the
licensee
has
essentially
completed
the
requalification training
program
requirements
described
in
88-13
and
NRC Inspection
Report 50-220/88-10.
As of April
15,
1988,
two individuals
had
not
completed
the
required
retraining
identified
as
necessary
to
comply
with
requalification
program
completion
requirements.
Of these
two,
one will no longer maintain
a license
and the other is scheduled
to
complete
the retraining
by April 22,
1988.
The
status
of
these individuals was
made
known to senior station
management
as
required
by Nuclear Training Procedure
(NTP-ll),
It
was
noted
by
the
inspector
that
the majority of training
missed
was
in
the
"Continuing
Training"
area.
The material
presented
in this training consisted
of
reviews
of pertinent
industry or stations
events
and other general
topics that cannot
be fit into
specific
requalification
lectures.
Significant
industry
events
which
have
specific
applicability
to
a
particular
system
or
topic
are
usually
addressed
in
other
requalification lessons
as applicable.
A review of lesson
plans
and training attendance
forms indicated
that Continuing Training sessions
usually last
one
to
two
and
one-half
hours.
Most of the licensed
personnel
requiring makeup
training
had
missed
one,
two or three
of these
sessions.
The
training
was not completed
as required prior to the
end of the
requalification
period.
Also,
some
individuals
had
missed
additional
classroom
or simulator
sessions.
It was also
noted
that
a
few .individuals
were
more
delinquent
in training
than
others.
These
individuals
had
been
maintaining
licenses
for
both the
Nine Mile facilities or were filling staff positions.
The
inspector
was
informed
by the
General
Superintendent
that
these
double licenses
would no longer be maintained.
The inspector
also
reviewed
the training files for several
Unit
2
licensed
operators.
No discrepancies
were
noted during this
review.
The
licensee
completed
an
audit
of all
licensed
operator
training
. files
and
concluded
that
the
Unit
2
requalification
program
was
in
compliance
with
station
requirements.
2.2
Conclusions:
The results of interviews, with licensed
personnel
who
had received retraining,
indicated that the retraining
was
adequate
and effective.
The persons
who were interviewed stated
that they
had
been
adequately
retrained
and
in
some
instances
described
the
makeup
training
as
of better
quality than
the
normal
cycle
training.
The
materials
presented
during
these
makeup
sessions
were also
reviewed
and
found to
be of adequate
quality.
As
noted
above,
the
majority
of
these
materials
consisted
of Licensee
Event Reports
and industry event materials
from various
sources.
3.0
Review of the Licensee's
ro osed
ro rammatic
im rovements
The
inspector
reviewed
the
licensee's
proposed
improvements
to
the
training
and
qualification
programs.
These
improvements
were
to
be
formalized by changes
to NTP-11, the development
of procedures
to control
completion of
NRC
Form 398,
and the establishment
of programs
to improve
the overall quality of the requalification
program.
The
inspector
also
discussed
the
proposed
changes
with senior training staff members
and the
General
Superintendent.
3.1
Ins ection
Findin s:
The
inspector
found the
proposed
changes
to
NTP-'ll
to
be
adequate
to
assure
future
compliance
with
station
and
NRC requirements.
This finding
was
made with the
assumption
that
the
changes
would
be
properly
implemented
and
management
oversight
would continue
beyond
the
implementation
stages.
The
proposed
changes will emphasize
the definition of required
training documentation
and will clearly describe
actions
to
be
initiated
for
those
persons
delinquent
in
training
status.'equired
training in this context wi 1 1
be defined
as that which
is
necessary
to
comply with
10CFRSS
licensed
operator
requal-
ification programs.
By clearly defining those
lessons
which are
required,
the licensee
intends
to eliminate confusion
as to the
definition of
a "complete
program."
Licensed
personnel
receive
training
on
a variety of topics
during requalification cycles
and
much
of this training
may
not
be
required
for
license.
requalification.
Previously,
because
Continuing
Training
was
integrated
into the requalification
program, it was
not
always
clear to the
persons
involved what
was required
to
be
made" up,
if missed.
As a result
makeup training was,
in
some
instances,
not
given
the
proper
emphasis
by
station
personnel
and
management.
With the
proposed
changes, it should
be clear
to
those
involved,
which training lessons
are
required
to
be
made
up,
when missed.
The licensee
further intends
to upgrade
the process
by which it
documents
training
received
and overall
program
status.
This
process
has already
been
improved
upon by the addition of status
check
sheets
to
document
requalification status.
These
sheets
are
in all licensed
operator training journals
and are
used
to
document
the
completion
of
each
cycle of the requalification
program.
Mien
an individual completes
the required
core cycle,
a
training
supervisor
will
sign
the
check
sheet
indicating
completion
of
the
cycle
and
will
provide
comments,
if
applicable,
to aid auditors.
All the required training for each
cycle
must
be
completed
prior to signoff,
and all
the
cycles
must
be
signed off to consider
the requalification
program for
an individual
as
complete.
The licensee
eventually
intends
'to
implement
a
computerized
records
management
system;
however,
these
plans
were
preliminary,
and
did
not
allow
adequate
assessment
by the inspector..
Along with the
improved
documentation,
the
proposed
revision
to NTP-ll will require that the status
of the
licensed
operator
requalification
program
be reported to senior site management
at
the completion of each
cycle.
Those
persons
who
miss training
or otherwise
do not complete
a regularly scheduled
cycle will be
held
accountable
to
the
General
Superintendent.
The
General
Superintendent
wi 11
not
be
given
authority
to
dismiss
an
individual from the training but must ensure
the makeup training
is completed.
Previously,
persons
were allowed to miss training
provided the applicable station superintendent
was notified.
In
many
instances
following station
superintendent
notification,
sufficient actions
were not taken
to ensure
makeup training
was
completed.
In
other
instances,
the
missed
training
was
not
reported
as required
(see
NRC Inspection
Report
50-220/88-10).
These
instances
indicated
that
increased
management
attention
would
be
necessary
to
ensure
future
compliance
with
program
requirements.
Additionally, NTP-11 will specifically state
that those
license
holders
who do not complete
the required training
by the
end of
the requalification
period
be
removed
from licensed
duties
and
that this action
be reported to the
NRC.
A
new
procedure
wi 11
be
developed
to specify
the
methods
by
which the
licensee will prepare
and
submit
NRC
Form '398.
Key
attributes
to
be included
in the
procedure
were discussed
with
licensee
management.
These will include
specific definitions
and
instructions
for preparing
the
form
in
an
accurate
and
consistent
manner.'lso,
an
independent
verification of each
submittal will be required
by a training department staff person
and
a final independent
check will be performed
by the facility
licensee's
Nuclear
Compliance
and Verification group prior
to
'
submittal.
The
inspector
found
these
proposed
actions
to
be
adequate if properly
implemented.
The inspector
also
requested
the
licensee
to
provide
additional
training
to
each
license
holder
on
his
responsibilities
with respect
to
complete
and
accurate
submittals of these
forms.
3.2
4.0
Review of
The
licensee
intends
to
formulate
methods
to
improve
the
Licensed Operator requalification program.
These actions
are
in
response
to the
perception
by licensed
personnel
that
much of
the requalification
program is repetitive
and is not effective
in training
the operator
to perform job-related activities.
To
combat this perception,
the licensee
has
proposed
to form a task
group,
comprised
equally of training
and operations
personnel,
to discuss
ways to improve the
scope
and quality of the training
provided to licensed
operators.
Recommendations
resulting
from
these
discussions
will
be
presented
to
the
General
Superintendent
for action.
The effectiveness
of this task force
could
not
be
assessed
by
the
inspector,
however,
improved
communication
between
operations
and
training
personnel
was
viewed
as
a necessary
component
to
improve the overall
quality
of the requalfication
program.
Conclusion:
In
summary,
the
licensee's
corrective
actions
appear
appropriate.
A complete
assessment
of their effective-
ness
cannot
be
made until after implementation.
The inspector
noted that all of the
improvements
discussed
involve
increased
management
attention
to
training
program
effectiveness
and
compliance.
As
such,
a
continued
commitment
on
the
part
of
senior
management will be required to ensure
proper
and adequate
implementations
ualit
Assurance
ro rams related to trainin
The inspector
reviewed
the licensee's
quality Assurance
program to. assess
its effectiveness
in revealing previous,
or future breakdowns,
in training
program
effectiveness
and
compliance.
The
review included
previous
and
ongoing guality Assurance
audits of the training department
and interviews
with equality Assurance
personnel.
4.1
Ins ection
Findin s:
The
inspector
reviewed
Niagara
Mohawk
audit report ¹SY-RG-IN-87006 which documented
findings resulting
from an audit conducted
in April 1987.
The report
updated
two
previously
identified
"recommendations"
concerning
inadequate
documentation
of
requalification
training
received.
These
concerns
were closed
by the inclusion into training journals, of
~ requalification
"Summary Sheets,"
designed
to identify specific
topics
covered
in each training session.
These
sheets
are
not
the newly implemented
status
check sheets
discussed
in section
3
above.
These findings indicate that records
management
problems
had
been previously identified at Nine Mile Point.
At the
time
of
the
audit
stringent
requalification
program
attendance
requirements
were
not
in effect.
These
requirements
did
not
become effective until implementation of the
10CFR55 rule change
.
in May 1987.
Because
of this,
the inspector
determined
that it
was
a reasonable
conclusion
on the part of the licensee's
audit
group that
program
attendance
requirements
were
being
complied
with.
Concurrent
with the
inspectors
review of the training program,
the
facility
licensee
was
conducting
an
in-depth
guality
Assurance
audit
of
the
training
programs.
The
inspector
reviewed
the
scope
of the
audit
and
discussed
the preliminary
findings with the guality Assurance
team
leader
and. department
manager.
The
inspector
found
the
scope
to
be
extensive
and
thorough.
One
example
was
the
complete
review of all licensed
operator training files for compliance
with station
procedures,
which
resulted
in
the
auditors
checking
approximately
2500
attributes.
The audit findings were mostly minor in nature
but
sufficient
to
warrant training
department
action.
In several
instances,
the training
department
had
responded
to the audit
findings
and
had
incorporated
the
corrective
actions
in
the
NTP-11
changes
discussed
in
section
3
above.
The
licensee
committed
to
providing
the final results 'of this
most
recent
audit
to the
NRC for review.
Additionally,
the
licensee
has
committed
to
conducting
an
additional
audit
of
the
training
department
in
six
months.
The
normal
frequency
of training
audits
is yearly.
The 'licensee
also
committed to providing the
results of this future audit to the
NRC for review.
M
Management
was
informed
of the
purpose
and
scope
of the
inspection
at
the entrance
interview.
The findings of the inspection
were periodically
discussed
with station
management
throughout
the
inspection
period
and
were summarized at the exit meeting
on April 15,
1988.
Attendees
at
the exit meeting
are listed in section
1.0 of this report.