ML17290A630
| ML17290A630 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/16/1993 |
| From: | Morrill P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A626 | List: |
| References | |
| 50-397-93-15, NUDOCS 9309290165 | |
| Download: ML17290A630 (33) | |
See also: IR 05000397/1993015
Text
~ ~
'
U. S.
NUCLEAR REGULATORY CONNISS ION
REGION V
Report Number:
50-397/93-15
Docket Number:
50-397
License
Number:
Licensee:
Washington Public Power Supply System
P. 0.
Box 968
3000 George Washington
Way
Richland, Washington
99352
Facility Name:
Washington Public Power Supply System
Nuclear
Reactor Facility, Unit 2 (WNP-2)
Inspection at:
WNP-2 site near Richland,
Inspection
Conducted:
Dune 28,
1993 - July 2,
1993
Inspectors:
T. Burdick, Region III, Team Leader
P. Norrill, Region
V (June
30 - Duly 2,
1993)
T. Sundsmo,
Region
V
D. Lynch,
NRR (contractor)
D. Schultz,
NRR (contractor)
Approved by:
P.
D.
N rr)
,
C se
Operations
Section
ate
~Sunmar
Ins ection on Dune
28 to Jul
2
1993
Ins ection
Re ort No. 50-397 93-15
Areas
Ins ected:
This announced
inspection,
using the methods of NUREG 1220,
Tr aining Review
Criteria and Procedures,
Revision
1,
as described in Inspection
Procedure
41500, Training and gualification Effectiveness,
examined the licensee's
implementation of a systems
approach to training (SAT).
The inspectors
focused
on:
Non-licensed operator
and chemistry technician training programs
Licensed operator training programs
management
corrective actions
Training department staffing
9309290165
930816
ADOCK 05000377
Q
PDR .'..
Results
General
conclusions
and
S ecific Findin s:
The inspection
team found that training was being conducted
using
a systems
approach to training (SAT).
However, training staffing was insufficient
without extensive
overtime to accommodate
the current training workload along
with ongoing program accreditation
commitments, training personnel
turnover,
and management
changes.
This appeared
to have led to prioritization of work
in which immediate
needs
superseded
long range tasks.
(Sections 3.c.(l),
4.c.(6)
and 5.b.)
management
used quality assurance
and other internal audits to identify
training program problems.
However, the corrective action tracking and
follow-up were not always effective.
(Section 4.c.(1))
Line management
has demonstrated
increased
involvement in the licensed
operator requalification program.
However, there
was little indication that
other training programs
received significant line management
attention.
(Sections 2.c.(l) through 2.c.(4))
The inspectors
observed that operator
performance of Emergency Operating
Procedures
(EOPs)
and evaluation techniques
used
by the training department
evaluators
had significantly improved over the last two years.
(Section 3.b.)
Summar
of Violations and Deviations:
The licensee failed to maintain
a continuous
two year requalification training
plan for the current two year training cycle (1993-94) contrary to 10 CFR 55.59(c). 1.
Neither the 1991-92 nor the 1993-94 two-year plans were approved
by licensee
management.
Contrary to the licensee's
procedures,
a planned
deviation from the
1993-94 plan was not reviewed by the Plant Operations
Committee.
(Section 3.c.(l))
The licensee failed to initiate a plant evaluation report to track and
document
an audit finding in January
1993 which identified the lack of an
approved operator requalification training program for the periods
1991-92
and
1993-94
as required
by the procedure
and contrary to
Criteria XVI. (Section 4.c. (1))
Summar
of 0 en Items:
No open items were identified or closed in this report.
2
Details
Persons
Contacted:
Licensee
Contacts:
A. L. Oxsen
- J. V. Parrish
- G. C. Sorensen
- J. C. Gearhart
- J. Swailes
+J.
M. Baker
- J. D. Cantrell
- G. 0. Smith
- W. D. Schaefer
- J. Engbarth
- D. L. King
T. Love
D. Werlau
- D. A. Bennett
- L. D. Norrison
- R. G. Devall
- S. Bruce
- P. N. Taylor
T. Dezember
L. Mayne
Deputy Nanaging Directot
Assistant
Nanaging Director, Operations
Regulatory
Programs
Hanager/Supply
System
Director, guality Assurance
Plant Nanager
Nuclear Training Nanager
Acting Nuclear Training Nanager
Operations Division Hanager
Operations
Hanager
Administrative Auditor
Operations. Training Development
Nanager
Chemistry Nanager
HP/Chemistry/GET
Hanager
Chemistry Supervisor,
Operations
Supervisor,
Radwaste
Processing
guality Assurance
Engineer
Lead Requalification Simulator Training Specialist
Operations
Liaison
Support Shift Supervisor
Chemistry Operations
Supervisor
Additional licensee
managers,
supervisors,
trainers,
and employees
were
intet viewed during the course of this inspection.
NRC Contacts:
R. Barr
Senior Resident
Inspector
- D. L. Proulx
Resident
Inspector
J.
M. Clifford
Project Manager,
MNP-2,
- Denotes individuals present at the exit meeting.
Non-licensed
0 erator
and Chemistr
Technician Trainin
Pro rams
41500
a ~
~Sco
e
An inspection of the
MNP-2 Non-licensed
Operator
and Chemistry
Technician Training Programs
was conducted
from June
28 to July 2,
1993.
The training inspection
was conducted in accordance
with
the guidance of NUREG 1220, Revision l.
Interviews were conducted with a sample of sixteen licensee
personnel
including managers,
supervisors,
trainers,
operators,
and chemistry technicians.
A sample of records
were reviewed
and
direct observation of ongoing training was conducted
during
a
control
room simulator session for equipment operators.
This
simulator training focused
on diesel
generator electrical
operations.
~Summar
The inspectors
concluded that both programs
were conducted
using
a
systems
approach to training.
No violations or deviations
were
identified in these
areas.
Weaknesses
identified were:
0
Nanagement
did not communicate
performance
expectations
directly to non-licensed
employees.
o
management
did not appear to be actively involved in non-
licensed training programs.
o
There was
no formal feedback
process
to non-licensed
personnel
that assured
closure of recommendations
from
students.
One strength
observed
was the training matrix recently developed
for equipment operators
providing
a two year detailed plan for
continuing training.
Evaluation Details
(1)
Procedural
Compliance
and Self-Checking
Both equipment operator instructors
and equipment operators
(EOs) indicated that the training on policies
and management
expectations
associated
with procedural
compliance, self-
checking,
and configuration management
were difficult to
accomplish.
One instructor interviewed felt that the
emphasis
given to these subjects
by senior
management
attendance
at the training sessions
for licensed operators
was good, but the lack of such senior managers
at similar
training for non-licensed
operators
was detrimental.
Three
instructors interviewed felt that these topics were
among
the weakest
areas of training for non-licensed
operators.
Based
upon the interviews
and the examination of
EO training
(Section 2.c.(2)), the inspectors
concluded that procedural
compliance
and self-checking
needed
greater
emphasis
to non-
licensed operators.
The presence
of senior managers
during
training of licensed operators
appeared
to have improved
training effectiveness.
Similar involvement of line
management
in
EO training on self-checking
and procedural
compliance
appeared
appropriate.
The Operations
Hanager
responded
to the inspectors'oncerns
by stating that he would attempt to provide more face-to-
face communications with equipment operators
during
tr aining.
l
'l
f
,
)I
0
Equipment Operator Training Program
The inspectors
found no Operations
Department
involvement in
the establishment
or modi,fication of Equipment Operator
training.
The Nuclear Training Program
(Technical Training
manual,
TTN 1.0., Section 3.0,
Program Requirements),
prescribed that, "line management
is ultimately responsible
for the overall quality of their training programs ....",
and that "Line management
ownership in training is defined
as taking an active role in the content
and conduct of their
training programs."
TTN 1.0, Section 3.0,
Program
Requirements,
paragraph
3. 1, Line management,
requires line
management
ownership in training of the organization's
employees.
Further, line and training management
were
required to continuously monitor the conduct of training to
assess
quality and provide guidance
and direction for
continuing training activities.
The inspectors
stated that
although this facility procedure
was not
a regulatory
requirement, line management
should address
the deficiency.
The inspectors
reviewed the Equipment Operator Training
Natrix that specified each,cycle's
training content,
training announcements,
and interviewed Equipment Operator
Training Specialists.
The inspectors
noted
a Training
Department strength in that
EO training specialists
had
recently prepared
a complete
EO Training Natrix for a two
year cycle.
This matrix identified priority subjects to be
taught
on
a continuing basis',
and married the seven
week
training cycle of the
EOs with the seven
week cycle of the
SROs/ROs.
This permitted training of the crews together
as
much as possible.
The matrix addressed
appropriate
systems
and administrative requirements,
and promoted parallel
systems training to both groups.
Prior to the start of each
training cycle, the Training Department
prepared
an
announcement
to the Operations
Department
concerning the
content of the subsequent
cycle, location, dates,
etc.
Based
upon the inspector's
interviews, the
EOs considered
the course to be good.
However,
as described
above,
the inspector
found that
Operations
had not provided input for the course content to
assure
the department's
needs
were fulfilled.
As
a
consequence,
the curriculum was constructed
based only on
trainer experience.
The inspectors
concluded that the implementation of the
equipment operator
(EO) training program by the Training
Department
was
a strength.
At the
same time, the inspectors
concluded the Operations
Department
should
become
more
actively involved in developing
and managing the training of
its employees.
0
,W
The licensee
stated that they will consider periodic
operations
and training staff meetings to discuss
curriculum issues similar to periodic meetings
on
SRO/RO
issues.
(3)
Equipment Operator Errors
The inspectors
observed that'everal
events related to
clearances,
valve status,
and breaker lineups
had recently
occurred
due to improper Equipment Operator
(EO)
performance.
For example:
o
5/6/93,
PER 293-0507
Danger tags
were incorrectly
hung
on DG2-SN8 breaker
and
associated
fuses
instead of
SNB-DG2.
0
5/12/93,
PER 293-0570
o
6/18/93,
PER 293-0900
Valve EDR-V-158B was
inadvertently opened
instead
of EDR-Y-159B, improperly
transferring tank EDR-TK-4B
contents to a condensate
storage tank.
Valves CRD-V-102/1031,
V-
103/1031,
and V-105/1031 were
found closed
when they were
supposed to be open.
They
were not properly positioned
during performance of
hydraulic control unit lineup
in accordance
with PPN 2.2.1.
The inspectors
reviewed procedural
adherence
and clearance
order training received
by the equipment operators to
determine if the training provided was adequate.
EO Initial
Training in
EO applicable
procedures
was
a self-paced
module.
The module specifically addressed
the subjects of
procedural
adherence,
including when procedures
had to be
physically present during task performance,
and the
principles of "self-checking"
and its associated
"STAR" Stop, Think, Act, and Review.
EO Initial Training
also included
a four hour classroom
course
on
"EO Good
Practices"
which focused
on "Conduct of Operations".
A
section of the instruction specifically addressed
"Procedure
Compliance";
a learning objective specifically addressed
the
subject of verification techniques
to be used
when specified
by valve and breaker line-up checklists.
Similar subjects
were present in the
EO continuing training
curriculum,
and included specific subjects
such
as
82-EBB-
0
0501-LP,
Danger
Tag Clearance
Orders,
which included
learning objectives
such as,
"State the requirements
for
independent verification ....", "Describe
how to perform an
, independent verification", "...a simultaneous verification",
etc.
Based
on the content of the training materials
and lesson
plans
used to train EOs, the inspectors
determined that
materials
were adequate
to convey the requirements
to the
trainees.
Student evaluations
adequately tested retention.
The inspectors
found that training was adequate prior to the
time the
EOs entered the work environment.
As a consequence,
the inspectors
concluded that recent
(1992
- 1993)
EO errors in valve and breaker
alignments did not
appear to be related to inadequate training conducted
by the
Training Department.
Chemistry Technician Self-Checking
Self'-checking principles
had
been taught to the chemistry
technicians.
The inspectors
found that
a requirement
for
self-checking
was not included in Administrative Procedure
1.3.58,
Conduct of Chemistry.
It was stated
by the
Chemistry Supervisor that in the conduct of chemistry
procedures,
verbatim compliance
was required in order to
obtain proper results,
and that through the use of such
quality'control
processes
such
as blind standards
and
independent
checks,
the quality of the results
was assured.
The inspectors
observed that support of self-checking
principles
by chemistry management
for the implementation of
procedures
appeared
appropriate to ensure
a uniform approach
by the technicians.
This issue
was discussed
with the new (two months tenure)
Chemistry Hanager,
who indicated that she would evaluate the
concern.
Feedback to Equipment Operators
and Chemistry Technicians
The inspectors'eview
of course critique documents for
licensed operator,
equipment operator,
and chemistry
technician training identified that the operators
frequently
made constructive
comments with regard to the training
program.
However,
no formal mechanism existed to feedback
to the operator
making the suggestion
the disposition of the
suggestion.
Some feedback
was
made
by discussions
or
meetings following training cycles.
The inspectors
observed
that
a more formal feedback
mechanism
may encourage
additional constructive criticism of the training program by
the operators.
3.
Licensed
0 erator Trainin
Pro ram
41500
~
~
a ~
~Sco
e
Evaluation of the licensed
operator training program was performed
by review of training program documentation
and records,
interviews with the licensee's
staff,
and direct observation of
simulator training.
Interviews with approximately
15 members of
the licensee's staff from the Operations
and Training Department,
both management
and operators,
were conducted following the
guidelines of NUREG-1220, Training Review Criteria and Procedures,
Revision 1.
Training department
documentation
reviewed
by the
inspectors
included:
0
0
0
0
0
The licensed operator task lists
Checklists for required
annual training
Draft two year training plans for 1991-92
and 1993-94,
Selected
lesson plans,
Requalification training attendance
records
(record of
actual training),
Weekly requalification training feedback
forms from licensed
operators
and Training Update System
(TUS) requests
for
training,
Recent licensee
audits
and self assessments
of the training
department,
Training department
procedures
and memoranda
documenting
program implementation,
and
Graded examinations
taken
by the initial license class.
b.
~Summer
The inspectors
concluded that the licensed operator training
program was being conducted in a systematic
manner.
Significant
programmatic
weaknesses
that were identified during this
inspection included:
e
o
Implementation of draft (unapproved)
two year training
plans,
o
Changes to the draft training plans without appropriate
management
reviews,
o
Ineffective tracking of, and adherence
to identified program
requirements
and commitments,
and
o
Training department staffing levels that appeared
insufficient to perform the work that had
been assigned
to
the department
(Section 5).
The inspectors
observed that, notwithstanding these
weaknesses,
operator
performance of Emergency Operating
Procedures
(EOPs)
and
evaluation techniques
used
by the training department
evaluators
had significantly improved over the last two years.
J
I
Evaluati on Details
(2)
Licensed Operator Requalification
Program Approval
The inspectors
observed that Technical Training Manual
5.3.2,
IV.C.4, WNP-2 Licensed Operator Requalification
Program Description, required
an approved
two year program
plan in accordance
with LTI 4.8,
Licensed
Operator
Requalification Training Cycle Content.
At the end of June
1993, there
was
no two year training plan in place for the
training cycle which started in January
1993.
Licensee
procedures
did not state
who was responsible for plan
approval.
A draft two year plan had been prepared in April
1993.
However, at the beginning of the
NRC inspection
no
plan had
been finalized or approved.
The approved
two year
plan would define the licensed operator requalification
(LORg) program.
The lack of an approved
two year plan was also
an audit
finding identified by United Energy Services
Corporation in
January
1993, with a commitment
by the Training Department
to issue the plan by March 1993.
During the first three
months of the 1993-94 two year period (training cycles
93-1
and 93-2), the training performed did not correspond to the
material
present
in the draft plan.
Failure to maintain
a
continuous requalification program is
a violation of 10 CFR 55.59(c). 1. (Violation 50-397/93-15-01).
The licensee
acknowledged that the plan had not been
approved,
and provided the inspectors with a revised,
approved,
two year training plan prior to the Exit Meeting.
Licensee
personnel
also committed to establish
administrative procedures
to provide for requalification
plan review and approval.
Unapproved
Changes to the Licensed Operator Requalification
Training Program
The inspectors
observed that Technical Training Manual
(TTM)
procedure 5.3.2,
WNP-2 Licensed Operator Requalification
Program Description, required that revisions to the licensed
operator requalification program must
be approved
by the
Plant Operations
Committee
(POC).
The inspectors
found that
the
POC had not approved the two year plan, or deviations
from the plan (such
as the training conducted in training
cycles
93-1 and 93-2).
The inspectors
stated that this was
a weakness
in the licensee's
awareness
of management
requirements
for operator training.
The licensee
representatives
acknowledged
the
NRC observation.
(3)
Selection
and Tracking of Training Topics
The licensee
used
a task list as
a check-off to ensure all
the essential
items planned for operator requalification
training were accomplished.
However, the inspectors
observed that no formal evaluation
was performed for the
importance of tasks
on the task list.
Selection of tasks
for annual training was
based
on the professional
judgement
of the people developing the task list.
The inspectors
examined records of completed training to
check whether the program
p'ian had
been
implemented.
The
inspectors
compared
actual training conducted in 1991
and
1992, to the training that was scheduled.
Review of the
draft 1993-1994
Two Year Training Plan identified that
Emergency Operating
Procedure
(EOP) training for Revision
4
(Phase II) was substituted for the draft plan topics in
cycles
93-1
and 93-2 without any provisions to include those
topics at
a latet
date.
For Training Cycle 93-3, the
following generic fundamentals
were scheduled to be taught
either
by lecture or in the simulator:
o
Reactor kinetics
and neutron
sources,
o
Fission product poisons,
and
o
Reactor operational
physics during start-up.
There
was no documentation that documented that these topics
had
been included in either lecture or simulator training
sessions.
A similar comparison for the period October 4, 1991-
December 3,
1992 (1991-1992
Two Year Training Plan)
identified the following deficiencies:
o
The plan had
been promulgated,
but similar to the
1993-94 plan, there
was no record that it had
been
approved in a formal manner .
o
The following classroom topics were scheduled to be
presented,
but the records of the Training Cycles
completed did not document that the material
was
presented:
Control Air System
(CAS)
Containment
Instrument Air (CIA)
- Containment Nitrogen
(CN)
There was
no documentation
available to show that
these topics
had
been rescheduled.
The licensee
concurred that the training topics identified
above were neither conducted
as scheduled
nor rescheduled
8
during the 1991-92 training cycle.
However, these topics
were scheduled
in the 1993-94 training plans.
The inspectors
concluded that the method
used to select
training topics for the two year plan,
and the program's
administrative controls to ensure that the plan was .properly
implemented did not always ensure consistent,
systematic
program implementation.
Training Attendance
The inspectors
examined
documentation of licensed operator
plans
and attendance
at requalification training to
determine if personnel
were consistently receiving planned
training.
The examination
was performed
by (1) selecting
a
sample of individual training plan items which were listed
in training cycle schedules,
(2) reviewing lesson
plans to
determine if the planned
items were taught,
(3) checking
attendance
sheets to verify individual attendance
at regular
and make-up training for these
items,
and (4) checking
qualifications of instructors
and trainees for accuracy in
the licensee's
data
base.
No discrepancies
were noted.
However, the licensees'racking
system
was complex and
hindered retrieval of information.
Licensee
personnel
acknowledged
the inspector's criticism of the tracking
system.
Scenario guality
Simulator scenarios
properly listed expectations
and
performance criteria for crews undergoing training,
including emergency classifications.
The inspectors
reviewed several
Licensed Operator/STA Requalification
and
Training Simulator Scenarios
and concluded that the
,
scenarios
were constructed
in accordance
with the
Simulator Scenario
Development Guideline
and
Licensed Operator
Examiner's
Standards.
One scenario required the Shift Hanager
(SRO) -to make
an
Unusual
Event emergency declaration
and
(as conditions
deteriorated)
a subsequent
Alert declaration.
At the proper
points in the scenario,
the proper classifications
were
called for in accordance
with PPH 13. 1. 1,
(EPIP) Classifying
the Emergency.
This appeared
to be
a very effective method
to exercise
emergency
event classification.
Simulator Scenario
Observation
Simulator training appeared
to be conducted
in an effective
manner,
and to have led to significant improvements in
operator
performance.
Observation of training and
evaluation scenarios
identified that operator
communications
U
0
and control were good, evaluation of operator actions
was
thorough
and accurate,
and management
involvement was both
dynamic
and positive.
The inspector
observed
a decision
by
the Operations
Liaison. and Operations
Nanager that the
selected
evaluation scenario
was too similar to the warm-up
scenario
run previously.
This resulted in substitution of
another scenario that effectively tested the week's training
topics,
but was sufficiently different so that evaluation of
operator actions
was objective.
Nana
ement Corrective Action for Identified Deficiencies
a ~
b.
C.
~Sco
e
A selection of previous
1992
and
1993 guality Assurance
and other
audit findings were reviewed for adequacy of corrective action,
tracking,
and completion.
~Summar
While most areas
reviewed indicated adequate
management
control,
corrective actions for one identified training program problem was
ineffective.
The licensee did not take effective corrective
action to identify or comply with its licensed operator
requalification program requirement to approve the two-year
training schedules.
Out of ten audits reviewed, the adequacy of one audit dealing with
training on industry events
was questioned,
in that it appeared
a
more complete audit would have
made further follow-up by the
Training Department
unnecessary.
Two examples of documentation
changes
which should
have
been
made
for industry events training were identified.
Evaluation Details
(1)
Tracking of Special
Audit Findings For Requalification
The lack of a two year licensed operator requalification
training plan was identified during
a special
internal audit
in January,
1993.
A report by United Energy Services
Corporation
(UESC),
Update Report on Technical Training
Effectiveness
Review, dated January
27,
1993,
page 7,
identified that,
over
a year earlier, the previous
UESC
training review report (item ¹ 2.3. 1) had identified that
an
approved
two year training plan for licensed operators
did
not exist for 1991-92
and that during the current audit
there
was
no approved
two year plan for 1993-94.
In response
to this audit finding, licensee
personnel
stated
that the Training Department
had agreed to have the 1993-94
10
0
0
0
plan in place by March,
1993.
A draft plan was prepared
in
April 1993, but was not approved
by licensee
management.
The inspectors
reviewed the requirements
of TTM 5.3.2,
Licensed Operator
Requalification
Program,
and determined
that
a two year plan was required to be implemented in
accordance
with TTM 5.3.2,
IV.C.4.
The plan was approved
for implementation
on July 2,
1993, after the
NRC identified
this issue.
RNP-2 Administrative Procedure
PPM 1.3. 15, Plant Problems-
Plant Problem Reports,
stated in part that
PPM 1.3. 15 was
written to meet
10 CFR 50 Appendix B, Criterion XV and XVI.
PPM 1.3.15 also stated that
a Problem Evaluation Report
(PER)
was
a document
used to formally communicate the
existence of a plant problem to plant management
for action.
- It could be initiated by anyone
knowledgeable of an existing
or potential plant problem which requires resolution....
The
PER was the first level of problem evaluation
and corrective
action.
The failure to prepare
a
PER to document the lack
of an approved
plan for 1993-94, is, a violation of 10 CFR 50, Appendix B, Criterion XVI.
(Violation 50-397/93-15-03).
gA Audit Finding Training Attendance of Non-licensed
Personnel
In 1992 the Licensee
had identified poor attendance
at non-
licensed engineering staff training.
To determine if there
was
a training attendance
problem with licensed operators
the inspector interviewed management
and reviewed records
for all licensed staff members'ttendance
at
requalification training during the
1992
and
1993 calendar
years.
No significant evidence of absences
were identified.
The inspector
concluded that licensed operator training
attendance
was not
a problem.
gA Audit Finding Instructor Refresher Training
In 1992 refresher training was not planned
and scheduled for
simulator instructors
due to the transfer of the responsible
instructor.
The Training Department
rescheduled this
activity to begin in March 1993
and to be completed
by July
1,
1993.
The inspector interviewed the Manager, Training
and Engineering Support
and reviewed training records.
The
inspector
determined that refresher training was completed
as of July 1, '1993 for simulator instructors.
gA Audit Finding Written Examination Grading
Errors in licensee written exam grading were identified by
the licensee
both in the licensed
operator initial and
requalification training programs.
A sampling of 1993
0
0
examinations
from both programs
were regraded
by the
inspector with no discrepancies
identified.
gA Audit Finding - Industry Events Training
In June
1993
a licensee audit of Operating
Event Reviews
(OERs)
found that numerous Significant Operating
Event
Reports
(SOERs)
were not being properly trained upon.
Based
on the Dune
1993 audit and previous
NRC findings related to
licensee training on industry events,
the inspectors
examined the adequacy of the licensee's
OER program
management
and the training given to the operators.
The inspectors
examined training and processing of Operating
Event Reviews
(OERs)
based
on
a sample of OERs that appeared
most safety significant, to determine if training action
on
the items
was adequate.
Licensed Training Instruction (LTI)
2. 1, Training Update System Tracking Procedure,
provided the
methodology for processing
outside
documents
received
by
training, including
GER items.
Other items ..reviewed
by the
inspector
included plant modifications,
procedure
changes,
and instrument set-point
changes.
Each item examined that
received
a "Needs Analysis" by a training specialist
was
documented
on an appropriate
form which included the
required action.
Although the licensee
was properly administering
and
training on the
OERs examined,
the inspectors
observed
two
errors which were discussed
with the licensee.
The
inspectors
observed that the Nuclear Boiler Instrumentation
system description
was not revised or referenced to reflect
the adverse affect of non-condensable
gasses
on level
indication.
The up-date lecture lesson
plan 82-ROT-0193-Ll
for this topic appeared
incomplete in that it did not
provide clear questions
and answers to verify operator
comprehension.
Although extensive training of this topic
was documented,
the inspectors
concluded that the two
documents
described
above were not complete.
The inspector
observed that the June
1993 audit of the
training department
concerning
OERs stated that numerous
were not being presented
to the appropriate
audience
in accordance
with Training Department instructions.
The
inspectors
performed
an assessment
of whether applicable
tr ainees
had attended
OER training,
and found by sampling
that the trainees
had actually attended
the training.
To
verify the training on OERs, the inspector
reviewed
SOER 88-
1, Instrument Air System Failures,
Needs Analysis Actions
and found that the first lesson
plan was prepared in Duly
1989
and delivered in subsequent
training cycles.
The
subject material
was
moved into the system lesson,
Control
and Service Air System
(82-EAS-2701-LP,
dated 3/15/93),
and
12
appeared
on the current cycle schedule
for the appropriate
audience.
The
NRC inspectors
questioned
why the audit had
concluded that appropriate
industry events training had not
,
been given when it had
been given.
Licensee quality
assurance
and training personnel
stated that the audit had
concluded with the adverse finding due to the time needed
for additional research
by the training department to
determine if the training had
been given.
Based
on the inspections
described
above, the inspectors
concluded that the Operational
Event Review
(OER) program
and implementation
were adequate.
Facility Identified Changes
to the Task List
Approximately 180 self-identified,
new tasks for reactor
operators
and senior reactor operators
had recently
been
identified by the licensee.
The Training and Engineering
Support
group performed
a
training program evaluation of the licensee's
reactor
operators,
senior reactor operators,
and continuing training
for licensed
personnel
in late
1992.
A conclusion of that
report was that task identification and task analysis
was
not being formally performed
and that
a disparity existed
between required tasks
and tasks to which the operators
were
trained.
As a consequence
of the finding the licensee
embarked
on
a task identification program.
For reactor
operators
approximately 300 new tasks
were identified.
Many
(120) of the added tasks (to an existing list of 736) were
duplications in some way.
These tasks
were evaluated,
documented
and deleted.
The resulting
new task list was
published
as Revision
21 on 22 April 1993.
Of the approximate
180 added tasks,
70 tasks
were totally
new, confirming the conclusion of the program evaluation.
Many of these tasks
were routine operations
or
administrative items, but some were accident or emergency
tasks
such
as
{R0-0759-A-RRC), Operate
Reactor Recirculation
System in Single
Loop from both
Pumps in Fast,
or (RO-0982-
A-MS), Manually Open Safety Relief Valves.
Other tasks
could be accident precursors if improperly performed
such
as
{R0-0882-N-FPC), Drain Fuel
Pool Cooling System.
Similar
task issues
were found in the
SRO task list.
The inspectors
observed
simulator training 'conducted
on
operation of the recirculation system in single loop from
both
pumps in fast
(new task) in a session
on July 1,
1993.
While this task did not have all data fields {such as
frequency,
reference,
or setting
(method) for performing the
training) incorporated in the new task list, training was
being conducted.
13
i
The inspectors
also observed that
a new task concerning
local operation of the diesel
generators
was being taught to
equipment operators
in simulator training.
The inspectors
were told by license instructors that all of the safety
significant items from the newly added tasks
were being
covered.
As noted above,
the task analysis
information data fields
such
as frequency,
reference,
or setting
(method) for
performing the training on the
180 new tasks
was generally
not available.
As a consequence
of adding the newly
identified tasks,
the "master" database
of RO and
SRO tasks
contained
a significant number of absent
data fields.
While
the inspectors
did not find any new tasks
which were
incorrectly scheduled
or had
an inappropriate
methodology,
they observed that lack of complete data fields in the task
lists placed additional
burden
on the training instructors
and developers.
Based
on current training department
staffing levels, training on the added tasks
may not be
complete until the end of the 1993-1994 training cycle.
When questioned
by the inspectors
regarding the training
priority of the new tasks,
the licensee
agreed to review the
listing of new tasks
and prioritize them such that high,
priority tasks will be incorporated into training promptly.
Completion of task analyses
and incorporation of all new
tasks
were scheduled to be completed during the 1993-94
training cycle.
5.
Trainin
De artment Staffin
and Oversi ht
~Sco
e
An evaluation of the Training Department operations training
staffing and effectiveness
of management
oversight
was conducted
by reviewing supply system records
and by conducting interviews
with management
and working level personnel.
The records
reviewed
included cost expenditures,
budget reviews,
personnel
qualification reports,
new hire reports,
organization charts,
and
internal transfer documentation.
b.
~Summar
The inspectors
concluded that the Training Department
was
understaffed
by several
people.
Licensee
management
stated that
the Training Department
had staffing problems in 1991 and
1992,
but had difficultyrecruiting qualified personnel.
During the
last six months the licensee
had
begun to recruit and hire
necessary
personnel.
Current staffing appeared
acceptable.
Staffing levels were not increased to account for high turn-over
rates
or for high overtime levels.
Twenty-eight people
had left
0
the department
since
1991 (about
50% annual turnover).
Training
department
overtime had averaged
20%.
The shortage of qualified trainers
and developers
may have
had
an
adverse
impact on the licensee's ability to complete activities
such
as the timely submittal of operator license
renewal
requests,
the completion of the two year training plans,
or the tracking of
deferred training.
(Sections 3.c.(l), 3.c.(2),
and 3.c.(3))
(c)
Evaluation Details
Late Submittal of License
Renewal
Requests
During this inspection,
the licensee
overlooked submitting
a
timely request for license
renewal for,8 operators.
The
NRC
did not receive the request for renewals thirty days before
expiration,
and called the facility to determine if they had
been sent.
The facility reported that they had not been
tracking renewals for operators'icenses.
After completion
of this inspection,
the facility submitted the renewal
applications.
Region
V processed
the renewals
before the
licenses
expired.
During the inspection the inspectors
pointed out that this example demonstrated
the need for the
Supply System to establish
and maintain more adequate
management
controls in the training area.
(2)
(3)
Organization
Changes
The inspector
observed that over the last two years at least
four major changes
occurred in the licensed operator
training staff and/or management.
The organization
was
reorganized three times
and there were three different
Training Managers.
The individuals responsible for
operations liaison, initial operator training,
and
requalification training were changed
during the last year.
The current organization
combined requalification
and
initial training into one group and established
a training
program development
group.
This organization also
eliminated
one level of supervision which existed prior to
January
1993.
The inspector
concluded that the organization
appeared
to provide better focus
on specific tasks.
Overtime
Based
on
a review of resource
expenditure
documents,
the
inspector
determined that for the last year the licensed
operator training personnel
average
overtime was slightly
more than
20%.
Generally the overtime appeared
evenly
distributed over the period examined.
The inspector
concluded that this was
an indicator that resources
were
insufficient for the tasks
assigned.
15
(4)
Staff Turn-over
The inspector
examined individual work assignments
for
operator training administration
and development.
Based
on
the licensee's
staffing plans, the Operator Training branch
had twelve instructor/evaluator
positions,
an operation
liaison,
an STA coordinator,
and
a branch manager.
One of
the twelve instructors
was scheduled to go to INPO in August
1993 for two years,
one was going to become the
coordinator,
one worked on the new simulator project,
and
'ne
was assigned
to train equipment operators.
Five of the
fifteen people in the branch were hired in 1993.
The
Operations Training Development
branch
had five developer
positions,
one administrative position,
and the branch
manager.
One developer
was involved with the
new simulator.
Three of the seven
people in the branch were hired in 1993.
Over the last two years
approximately twenty-eight
individuals left the operator training organization.
Since
the organization
had twenty eight positions, this was
an
average of 50% turnover each year.
In response
to these observations,
the licensee
stated that
they had hired an additional instructor who would arrive in
August,
had brought in two'contractor instructors,
and were
planning to ask for two more contractors to work in program
development.
Until January
1993, the Supply System
had
difficultyrecruiting qualified personnel
for the training
department.'ecent
recruiting efforts were much more
successful.
The inspector
concluded that the licensee's staff turn-over
was higher than normal
and that staffing levels were not
increased to account for the high turn-over.
Follow-u
of Prior Ins ection Concerns
50-397 92-27
a ~
0 erations
Liaison
In September
1992,
an
NRC inspector
found that the operations
liaison staff person
was not certified as
a training evaluator,
even though
he conducted evaluations.
This was not consistent
with the standards
imposed
on the other training staff evaluators.
During the current inspection the inspector
found that the
operations
liaison was
a qualified evaluator.
The person filling
this position was required to complete
a training course
(approximately one week)
and training qualification equivalent to
that required of other training instructors.
Direct observation-
of the Operations
Liaison in simulator training and evaluation
roles identified that
he was capable of performing both roles
effectively.
This issue is closed.
16
b.
Consistenc
of Initial and
Re ualification Trainin
In September
1992,
an
NRC inspector
found that there
was
no
process to ensure that the training and evaluation skills
developed for the operator requalification program instructors
were transferred to the initial operator
program instructors.
In the current inspection the inspector
found that all instructors
for both initial and requalification programs
had
been
assigned
to
one work group.
Placing instructors in one work group facilitated
both initial and requalification training programs
sharing lessons
learned.
This issue is closed.
Exit Neetin
30702
The inspectors
met with licensee representatives
(denoted in Paragraph
1) at the conclusion of the inspection
on Duly 2,
1993.
The inspection
team summarized
the scope
and findings of the inspection activities.
The licensee
acknowledged
the inspection findings.
The team also
discussed
the likely informational content of the inspection report with
regard to documents
or processes
reviewed by the team during the
inspection.
The licensee
did not identify any such
documents
or
processes
as proprietary.
17
e
1
0