ML17055D948
| ML17055D948 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/08/1988 |
| From: | Gallo R, Lange D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055D947 | List: |
| References | |
| 50-220-88-10, NUDOCS 8806230010 | |
| Download: ML17055D948 (24) | |
See also: IR 05000220/1988010
Text
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3.
The
apparent
lack of effectiveness
for the licensee's
quality assurance
program
to identify deficiencies
in training
program
documentation
and
compliance.
The
above
unresolved
items will
be
reviewed
in conjunction
with the
facility licensee
response,to
Confirmatory Action Letter 88-13.
0
DETAILS
PERSONS
CONTACTED .
NIAGARA MOHAWK POWER
CORPORATION
'R. Abbott, Station Supt. Unit 2
- J. Aldrich, Tech. Assistant,
Unit
1
M. Biamonte, Training Supervisor
C. Cary, Training Supervisor
M. Goldych, Assistant
Supt. Training-Nuclear
M. Hedrick, Training Supervisor
"T. Lempges,
Vice President-General
Nuclear
- C. Mangan,
Senior
Vice President
- T. Perkins,
General
Superintendent
- R. Randall,
OPS Supt. Unit
1
- T. Roman, Station Superintendent,
Unit
1
- R. Sanaker,
Lead License Class Instructor
- R. Seifreid, Assistant
Supt. Training-Nuclear
D. Straka,
Supervisor of Operations,
Training-Unit 1
D. Wilcox, Training Supervisor
- J. Willis, General
Superintendent
- K. Zollitsch, Superintendent
Training-Nuclear
NEW YORK STATE
"P.
Eddy,
US
NUCLEAR REGULATORY COMMISSION
- R. Cook, Senior
Resident
Inspector
- R. Gallo, Operations
Branch Chief,
- J
~ Johnson,
Section
2C Chief,
- D. Lange,
BWR Section Chief,
- T. Lumb, Senior Operations
Engineer,
"W. Schmidt,
Resident
Inspector
The inspector also held discussions
with other licensed
and
non licensed
personnel
during the course of the inspection.
"Denotes
those present at the exit meeting
on March 25,
1988.
INSPECTION OF LICENSED OPERATOR RETRAINING AND CONTINUING TRAINING,
2.1
Backcaround:
An inspection
conducted
in February,
1988 (inspection
report 50-220/88-05) identified deficiencies
in the documentation
of
licensed operator requalification training.
During a subsequent
0
telephone
conversation
between
the
NRC and facility licensee
management,
the licensee
committed to correcting the documentation
problems'he
NMP Training Department
conducted
an audit of the
licensed operator training files between
March
1 and March 11,
1988.
The inspector
reviewed the results of the audit conducted
by the
Training Department.
This review included inspection of individual
training files and interviews with training department
personnel.
The inspector also reviewed Nuclear Training Procedure
(NTP-11),
Rev. 4, which describes
the Licensed Operator Retraining
and
Continuing Training Program for compliance with 10 CFR 55.59.
2.2
Ins ection Findin s:
The results of the
NMP Training Department
audit are outlined in Attachment
A to this report.
The audit
covered the training records for the
1987 requalification period
conducted
from June,
1987 through February,
1988.
The outline
documents training that was missed for Cycles
2 through 8, whether
or not the Station Superintendent
was notified of the missed
training, whether or not the missed training was noted
as
an
exception
on the operator's
license
renewal application
(NRC Form
398,
Personal
gualification Statement),
and the date the missed
training was made-up.
The audit, identified thirty-nine (39) licensed
personnel
that had
not completed
the required continuous cycle training for portions of
cycles
2 through 8.
NTP-ll, Section 3.5,
Program Participation,
requires that each license holder "fully complete all required
training for each requalification cycle".
Missed training should
be
completed prior to the
end of the next cycle'and in all cases,
shall
be completed prior to the
end of the annual requalification period.
The end of the
NMP-1 annual requalification period was cycle 9, held
'n
February,
1988 (upon completion of the comprehensive
written
examination).
The incomplete training of licensed operators
and
senior operators
is an apparent violation of 10 CFR 55.59(a)(1)
which
requires that each licensee
(licensed operator)
successfu'lly
complete
a requalification program developed
by the facility licensee.
(220/88-10-01)
Approximately
50% of the training that was missed
was not identified
to the Station Superintendent.
This was determined to be
an apparent
deviation from NTP-11, Section 3.5 which requires that the Station
Superintendent
be notified in all cases
when requalification training
is missed.'220/88-10-02)
The fact that
no action
was taken to assure
that the missed training
was completed,
as required in those
cases that were identified to the
Station Superintendent,
indicates
an apparent
lack of management
attention to the requalification training program.
In addition, the
license holders identified with missed training in
many cases
were
key managers
and supervisors.
Deficiencies in
management
involvement in assuring requalification training program
effectiveness
and compliance is an unresolved
item.
(220/88-10-03)
The missed training was not noted
on
NRC Form 398 for any of the
delinquent license holders
who had submitted
a license
renewal
application since
May 26,
1987.
Facility licensee
management
must
certify on the Personal
qualification Statement
(NRC Form 398) that
the licensed operator
has
met all the requirements
of the
requalification program.
NRC Form 398 allows for exceptions
to
be noted
on the form, but none were noted for the thirteen (13)
cases
where training was incomplete at the time of license
renewal
application submittal.
The impact of these
omissions
on the license
renewal application is an unresolved
item.
(220/88-10-04)
The facility licensee'
method for documenting
and tracking
requalification program requirements,
to support the conditions of
license
and for use in completing license
renewal applications,
appeared
to be backlogged
and fragmented.
Documentation
was being
retrieved
from 3
. 4 sources,
therefore deficiencies (i.e. missed
training) were not being identified.
This documentation- problem
had
been identified during
a Safety
Review Audit Board
(SRAB) inspection
conducted
in Apri1,
1987,
however,
no violations had been identified
or corrective action taken.
The effectiveness
of the quality
assurance
program to identify deficiences
in training program
effectiveness
and compliance is an unresolved
item.
(220/88-10-05)
The inspector identified an area of weakness,
in the requalification
program,
based
on discussions
with training department
personnel.
The development of a Systems
Approach to Training (SAT), for licensed
operator continuing training,
has not been
implemented.
Specific job
tasks analysis
(JTA), learning objectives
and job performance
measures
have not been
developed
to address
the content for a
continuing training program for licensed operators.
Until this is
complete
and certified to the
NRC, the requalification program must
meet the requirements
of 10 CFR 55.59 (c).
Emphasis is needed
on
implementing the
SAT program to assure
that the training being
conducted is job performance
related
and encompasses
the necessary
performance
feedback
and industry events
associated
with safe
operation at the facility.
3.
Ins ection of Outa
e Modification Trainin
3.1
~Back round:
The inspector
reviewed
the materials to be used for
training non-licensed
personnel
on modifications
made during the
current refueling outage.
This training is scheduled
to be
conducted prior to restart of Nine Mile Point Unit 1.
The inspector
also interviewed training department
personnel
involved in
development
and administration of the outage modification training.
3.2
Ins ection Findin s:
The result of the interviews with training
department
personnel
indicated that the planned training
on outage
modifications would be adequate
and effective.
The training
materials
were found to be of adequate
quality for training of
non-licensed
personnel.
4.
~Ei
fI
The management
was informed of the purpose
and
scope of the inspection at
the entrance
interview.
The finding of the inspection
were periodically
discussed
with station
management
throughout the inspection period
and
were
summarized
at the exit meeting
on Parch
25,
1988.
0
OPERATIONS
PERSONNEL
RO/
Name
Train1ng
N1ssed
Station
Supt.
Notif 1 ed
Except ons
Date
Makeup
Noted on
Training
398
Renewal
Com leted
Cycle
4
9/87 - Cont.
Trng.
Y
Cycle
6 - ll/87 - Cont. Trng.
N'
N/A
Cycle
6 ll/87 Cont. Trng. N'/A
Cycle
4 9/87 - Cont. Trng,
Cycle
6 11/87
Cont.
Trng.
Y
N'
N
N/A
Cycle
4 9/87
Cont. Trng.
Cycle
7 12/87 - Cont. Trng.
N/A
3/20/88
Cycle
4 -
9/87 - Cont.
Trng.
N/A
3/9/88
Cycle
7 12/87
Cont.
Trng.
N>>
N/A
3/20/88
'
Cycle
4
9/87
Cont.
Trng.
N/A
3/19/88
Cycle
4 9/87 - Cont.
Trng.
Y
L1c.
Ren.
Requirements
Y
3/22/88
3/22/88
- Notif1ed on 3/24/88 per
NHP Memo. F.C.
33026
Page
1 of'
OPERATIONS
PERSONNEL
RO/
Name
Training
Missed
Stat1on
Supt.
Not1f 1 ed
Excepthes
Date
Makeup
Noted on
Tra1ning
398
Renewal
Com leted
Cycle
6 11/87 - Cont.
Trng.
N*
N/A
3/20/88
Cycle 4 -
9/87 - Cont. Trng.
N/A
3/19/88
Cycle g,-.ll/87 - Cont. Trng.
N/A
3/20/88
Cycle
7 12/87 - Cont. Trng.
3/19/88
Cycle
7 12/87 - Cont. Trng.
N/A
3/20/88
Cycle
4 9/87
Cont.
Trng.
- Simulator**
Cycle 2
Cycle 3-
Cycle 6
Cycle 8
6/87 Remediation
7/87 - Remediat1on
ll/87 - Cont.
Trng.
2/88
Cont.
Trng.
N/A
N/A
N/A
N/A
3/21/88-3/22/88
3/21/88-3/22/88'/21/88
3/21/88
Cycle
5 - 10/87 - Simulator"
N/A
Cycle
2
6/87 -'Heat Transfer
Y
Cycle
7
12/87 - Cont.
Trng.
N'.
, N/A
3/21/88
3/19/88
Cycle
4 -
9/87 - Cont.
Trng.
RO
Cycle
3 -
7/87 - Simulator'*
Cycle
6 - 11/87 - Cont,
Trng.
Cycle
4 9/87 - Cont. Trng.
- S1mulator"
Cycle
7 - 12/87 - Cont.
Trng,
NO
Na
YN'/A
N/A
N/A
N/A
K/A
3/20/88
3/20/88
3/20/88
'ot
1 f1ed
on 3/24/SS
per
NMP Memo.
F,C,
33026
- 'h1s s1mulator
tra'Ining
1s in addition to those manipulations
required
by
IOCFR55.
Page
2 of
6
OPERATIONS
PERSONNEL
RO/
Name
Training
Missed
Station
Supt.
Notlfled
Exceptions
Date
Makeup
Noted on
Tralnlng
398 Renewal
Com leted
'ycle
7
12/87 - Cont.
Trng. N'/A
3/20/88
Cycle
3 7/87 Cont.
Trng.
N/A
'otlfled on 3/24/88 per
NMP Memo.
F.C.
33026
Page
3 of 6
NON-OPERATIONS
PERSONNEL
RO/
Name
Training
Hissed
Cycle
6 - 11/87 - Cont. Trng.
Cycle
7 12/87 - Cont. Trng.
Stat1on.
Supt.
Not1f i ed
N
N*
Exceptions
Date
Makeup
Noted on
Tra1n1ng
398 Renewal
Com leted
'/A
N/A
- Cycle 2 -
6/87 - Rx. Theory/
Heat Transfer
- Tech.
Specs.
Cycle
3 - 7/87 - Cont. Trng.
- Techn1cal
Specifications
Cycle
4 - 9/87 - Rx. Theory/
Heat Transfer
Cont. Trng.
Lic. Ren.
Reqmts.
Cycle
5 - 10/87 - Simulator'*
Cycle
6 11/87 - Cont. Trng.
Cycle
7 - 12/87 - Cont. Trng.
Y
Y
Y
N*
Y
Y
N'>>
N*
N
N
N
N
N
N
N
N
N/A
3/16/88
3/16/88
3/15/88
3/16/88
3/16/88
3/15/88
3/16/88
3/15/88
3/15/88
'
Cycle 4-
Cyc1 e 6-
Cyc1 e 7
Cyc 1 e 8-
9/87
Cont. Trng.
1 1 /87
Cont.
Trng.
12/87 - Cont. Trng.
2/88 - Simulator>>*
N*
N/A
N/A
N/A
N/A
3/23/88
3/23/88
3/23/88
50o
Cycle
6 - ll/87 - Cont.
Trng.
Cyc1 e
7
12/87
Cont.
Trng.
N/A
N/A
3/9/88
3/9/88
Cycle
6 - 11/87 - Cont.
Trng.
Cycle
7 - 12/87 - Cont. Trng.
Cycle
8 -
2/88 - Cont. Trng.
N/A
N/A
N/A
3/19/88
3/19/88
'otified on 3/24/88 per
NMP Memo.
F.C.
33026
This simulator tra1ning is in addit1on to those
man1pulations
required
by 10CFR55.
Page
4 of 6
'
RO/
Name
NON-OPERATIONS
PERSONNEL
Tralnlng
Station
Supt.
Hot 1 f1 ed
Cycle
4 9 87 - Llc. Renewal
Req.
Y
- Cont. Trng.
Y
- Slmulator*'*
Exceptions
Date Hakeup
Noted on
Training
398 Renewal
Com leted
N/A
3/10/88
N/A
3/10/88
K/A
3/15/88
Cycle
6 - ll/&7 - Cont. Trng.
Cycle
7 - 12/87 - Cont. Trng.
Cycle
8 -
2/88 - S1mulator**
N*
H/A
3/9/88
H/A
"
3/9/88
N/A
3/8/88
Cycle
5 - 10/87
Cycle
6 - ll/87
Cycle
7 - 12/87
Cycle
8 -
2/88
- Cont. Trng.
- Cont.
Trng.
- Cont. Trng.
- Cont. Trng.
Cycle
2 -
6/87 - Cont. Trng.
Cycle
4 -
9/87 - Rx.Theory/
Heat Transfer
Y
Y
N'*
N>>
N/A
N/A
N/A
H/A
H/A
N/A
3/15/88
3/15/88
3/15/88
3/15/88
3/15/88
.
s
Cycle
3 -
7/87 - Simulator'*
Cycle
3 -
7/87 - H.O.C.D.
Cycle
7 12/87
Cont.
Trng.
Cycle
8 -
2/88 - Cont.
Trng.
N*
N>>
N
N
N/A
N/A
3/14/88
Cycle 4-
Cycle 5-
Cycle 6
Cycle 7
9/87
Llc. Ren.
Req.
10/87 - Simulator'*
ll/87 - Cont.
Trng.
12/87 - Cont.
Trng.
N'*k'/A
N/A
N/A
N/A
3/22/88
3/22/88
3/22/88
Cycle 3
Cycle 6-
Cycle 7-
Cycle 8-
7/87 - H.O.C.D.
11/87 - Cont.
Trng.
12/87 - Cont.
Trng,
2/88 - Cont.
Trng.
- Simulator"
N'/A
N/A
N/A
N/A
N/A
3/8/88
3/8/88
3/8/88
3/8/88
3/8/88
'otified on 3/24/88 per
NHP Hemo.
F.C.
33026
" This simulator training ls ln addition to those manipulations
required
by 10CFR55.
Page
5 of
6
'
NON-OPERATIONS
PERSONNEL
RO/
Name
Tralnlng
M1ssed
Stat1on
Supt.
Not1f1 ed
Exceptions
Date
Makeup
Noted on
Tra1n1ng
398 Renewal
Com leted
'RO
Cyc
e
3 -
7/87
Cycle
6 - 11/87
Cycle 7 12/87
. N':.
Cycla 6~gl87
Cycle
7 - 12/87
- Cont.
-. Cont.
Trng.
Trng.
- Jf.
N*
'lPc'
Cont. Trpg.
- Cont. Trng.
N*
N>>
- Gen 5 Aux111aries
Y
N
3/23/88
N/A
3/23/88
N/A
3/23/88
N/A
N/A
Cycle
7 12/87 - Cont. Trng.
Cycle
8 -
2/88 - Cont. Trng.
N*N'/A
N/A
.3/21/88
3/21/88
Cycle
3 -
7/87
Gen L Aux111arles
Y
Cycle
5 - 10/87 - Tech.
Specs.
N'ycle
7 - 12/87
Cont. Trng.
N'
N/A
N/A
Cycle
3 7/87 - Cont. Trng.
Cycle
6 - ll/87 - Cont.
Trng.
Cycle
7 - 12/87 - Cont.
Trng.
Cycle
8 -
2/88 - Cont.
Trng.
- S1mulator"
N
N/A
N/A
N/A
N/A
3/8/88
- Not1f1ed on 3/24/88 per
NHP Memo. F.C.
33026
'* Th1s simulator tra1n1ng
1s
1n addltlon to those
man1pulat1ons
requ1red
by 10CFRSS.
Page
6 of
6
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'