ML19354D990

Insp Rept 50-298/89-38 on 891204-08.No Violations or Deviations Noted.Major Areas Inspected:Training & Qualification Effectiveness

ML19354D990
Person / Time
Site:	Cooper
Issue date:	01/05/1990
From:	Gagliardo J, Mccoy M, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19354D989	List: ML19354D988 ML19354D990
References
50-298-89-38, NUDOCS 9001250148
Download: ML19354D990 (7)

See also: IR 05000298/1989038

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-298/89-38

Operating License: DPR-46

Docket: 50-298

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Licensee: NebraskaPublicPowerDistrict(NPPD)

P.O. Box 499

Columbus, Nebraska 68602-0499

facility Name: CooperNuclearStation(CNS)

Inspection At: CNS

Inspection Conducted: December 4-8, 1989

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Inspectors:

. B. Vickrey, Reactor

pector, Operational

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Progt ms Section, D

sion of Reactor Safety

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Human Factors Analyst, Procedures

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.(C.McyoyIngSection,HumanFactors

and Tiain

Assessment Branch, Division of Licensee

Performance and Quality Evaluation

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Approved:

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g. E. Q4911ardo, Chief, Operational Programs

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Secti%n, Division of Reactor Safety

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Inspection Sumsry

Inspection Conducted December 4-8, 1989 (Report 50-298/89-38)

Areas Inspected: Routine, unannounced inspection of training and qualification

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effectiveness,

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Results: Within the crea inspected, no violations or deviations were identified.

The licensee had a schedule for' establishing a training tracking system and for

the simulator installation / operability. Training department procedures and

instructions had been recently updated and revised.. Observed classroom

presentations exhibited a high level of instructor technical knowledge and

excellent presentation methods.

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The training department was not fully' staffed, and the operations training

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supervisor position was filled with a temporary assignment. The understaffed

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condition raised concerns about the training department's recruiting ability

and the tireliness of their filling vacant positions. This is important for

staffing future proposed positions to support sinulator installation / operability.

The understaffed condition and the poor communications between the plant and

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the training department's management had contributed to the low instructor

morale noted by the inspectors,

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DETAILS

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Personnel Contacted

NPPD

• R. D. Black, Operations Supervisor

• L. E. Bray, Regulatory Compliance Specialist

• S. L. Bray, Operations Quality Assurance Supervisor

• R. Brungardt, Operations Nanager

• J. W. Dutton, Training Manager

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• G. R. Horn, Division Manager Nuclear Operations

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'J. M. Meacham, Senior Manager of Operations

• S. M. peterson, Senior Manager, Technical Support

• G. R. Smith, Licensing Supervisor

• Denotes those attending the management exit meeting on December 8. 1989.

Other licensee personnel were contacted during the inspection.

2.

Training and Qualifications Effectiveness (41500)

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This area was inspected using portions of the guidance in NUREG-1220.

In

evaluating the strengths or weaknesses of the licensee's-training program,

emphasis was not directed toward any particular aren eucciated with

previously identified problems. However, industry evei.h training and the .

implementation of a training tracking system were eu ow.ibecause of

previous concerns identified in these areas. The te5 W M on. activities

also focused on concerns raised previously with ress M to management

attention to, and involvement in, the area of training. _Other areas ,

selected were selected based on their availability in the scheduled

training at the time of the inspection,-and the inspectors' background-

and knowledge in the subject areas.

Inspection activities included:

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A tour of the training facilities and control room;

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'A review of selected. training department procedures;

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An_ auditing of training presentations and a review of the associated

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training material;

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A review of the programs and projections for completion of training

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department improvements; and

Interviews with training department supervisors, instructors, and

students.

2.1 Tour of the Training Facilities < and Control Room

A training department tour was conducted to evaluate the. instructional-

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settings and training aids available for training pur)oses. The classroom

settings were generally in satisfactory condition wit 1 respec.t to

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instructional aids and student facilities. The facilities included

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chemistry and instrument and control laboratories, but there were no

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formal laboratories for mechanical or electrical training. The lack of

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mechanical and electrical laboratories was obvious in that several of

passageways)gaidswerestoredatvariouslocations(including

their trainin throughout the facility. Discussions with instructors over

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this inconvenience indicated that efforts were underway to improve the

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nechanical and electrical training areas. This subject was addressed to

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the training department manager as an area in which improvements are

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needed.

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During the control room tour there were no evolutions taking place other

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than normal watchstanding activities. Visitors and activities were

controlled to minimize distraction or interference with the watchstanders

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at their stations. General cleanliness of the plant was good, and the.

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operators were attentive to their watch stations.

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2.2 Review of Selected Training Department Procedures

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During the course of the inspection, the inspectors made reference to, and

reviewed portions of, the following training department procedures (NTPs):

NTP: 01, Nuclear Training Department Procedures, Revision 3

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NTP: 02, Training Program Descriptions, Revision 4

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NTP: 03, Certification, Revision 5

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NTP: 04, Alternative Completion of Training Requirements, Revision 2.

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NTP: 05. Training Course Approval, Revision 2

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NTP: 06, Remedial Training, Revision 4

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NTP: 07, Training Work Request, Revision 3

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NTP: 08, Instructor Qualification, Revision 4

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These procedures had been recently updated and revised. Of particular

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interest to the inspectors was the apparent success of NTP-07, " Training

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Work Request." The system described by this procedure used a multicopy

form in which the originator maintained a copy, but also received two

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feedback copies during the processing of the request. The first feedback

was provided after the initial evaluation and the second feedback after

completion of the revision. This positive form of feedback to the

originator seems to be a good system to encourage participation from the

licensee in making continued improvements in the training program,

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2.3 Audit of Training Presentations and the Review of Associated Training

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Material

Portions or all of three courses were audited by the inspectors. These

courses included:

Industry Events No. INTO 23

Control Rod Drive tiechanism No. COR-002-05

Nuclear Pressure Relief System No. COR-002-16

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During the industry events trainino, the inspectors noted that several of

the events may not have been related to the reactor design and could have

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been deleted from formal classroom training. These events could have

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been covered in a reading file or equivalent; their formal coverage

seemed to distract the interest of the students und prevented the instructor

from devoting time and em)hasis to more significant events that would have

been of more interest. Ttis observation was brought to the attention of

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the training manager who initiated a training wor ( request to evaluate and

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upgrade the methods used in screening and the subsequent training on

industry events. During the review of instructor qyalifications, it was

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noted by the inspectors that the industry events course curriculum require-

ments for instructor qualification appeared to be in conflict with the

qualification of the contract instructor used to teach the course. This

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observation was brought to the attention of the licensee. The concern was

not that the instructor did not possess the qualifications to instruct the

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course, but that the curriculum requirements did not specify the qualifica-

tions that the instructor should possess.

The inspectors' observations of the above classes su> ported their

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evaluation that instructors were well qualified and sad good presentation

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methods. During the presentation of the nuclear pressure relief system,

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the instructor entered several items in the presentation data log. These

items included notes to followup on student questions, information to be

distributed to previous crews that had received this instruction, and the

changes needed in the course material. The inspector noted that the

student test handout had been revised five times since 1986 while the

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Instructor Guide was only Revision 1.

The failure to maintain the

Instructor Guide current resulted in outdated figure numbers, and in one

instance, a value different from the student handout. These differences

were pointed out to the instructor by the inspector.

2.4 Review of Progress and Projections for Completion of Training Department

Improvements

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The inspectors reviewed the licensee's program and projections in the area

of developing and implementing a training tracking system and the

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simulator installation and operation. The tracking system was currently

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scheduled to be complete and usable sometime in April 1990. The simulator

was scheduled for arrival in January or February 1990, and was scheduled

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for startup in May or June 1990. The inspectors were concerned with the

number of training department vacancies, which raised a question as to

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whether or not the training department plans could be supported to meet

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the above schedules. The inspector questioned licensee representatives

regarding the adequacy of the present and future manning schedules to

support their goals.

2.5 Interviews with Training Department Supervisors, Instructors, and Students

Interviews were conducted with two reactor operators, two senior reactor

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operators (SR0s), three SRO instructors, the Program Development Supervisor,

the Operations Training Supervisor and the Nuclear Training Manager. The

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operators interviewed indicated that the instructors for the licensed

operator classes were generally excellent.

In addition, the operators

were satisfied with the quality and quantity of the instructional materials

used in the classroom.

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Operators and instructors reported that the training department was under-

staffed. The majority of the individuals interviewed indicated that there

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was a reluctance from the operators in the plant to become instructors

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because of the operators' perceptions of weak training management and low

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instructor morale. This difficulty in recruiting operators into the

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training department may effect the training department's future needs for

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instructors with plant experience.

Furthermore, the position of Operations

Training Supervisor had not been permanently filled. This position had

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been held by several individuals in the past few years, and as a result,

the instructors reported that feelings of instability and a lack of

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consistent supervision had been created among the operations instructors.

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Finally, the projected staffing needs for the simulator a)peared to be

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unrealistic. The instructors questioned the adequacy of saving only three

instructors scheduled by the training management and_ indicated that more

simulator instructors would probably be needed to meet the requirements of

the expected class needs.

The operators and instructors interviewed indicated that there was poor

communication between the plant manager and the training manager. The

majority of individuals interviewed stated that information flow between

plant staff and the training staff was good at the student / operator and

instructor level, but was weak at the management level. The operators and

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instructors indicated that this poor interfacing between the plant and

training department had resulted in minimal flow of information at the

management level. This a> parent poor communication had led to reported

feelings of uncertainty tsat information was communicated effectively and

in a timely manner at the upper management level. Furthermore, the

instructors noted that the consnunication was weak within the training

department between the training management and the supervisors / instructors,

andamongthedivisionswithinthetrainingdepartment(i.e., operations,

maintenance,instrumentandcontrol).

In addition to the poor. communication

and staffing issues, the instructors interviewed reported low satisfaction

with the level of involvement of training management. The majority of

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instructors noted a lack of support and concern from training management

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and indicated that training management provided an insufficient amount of

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involvement, guidance, and participation in daily staff activities. These

issues had led to reported low instructor morale within the operations

training department. This low morale within the training department had

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also been perceived by the operators and was given as one of the reasons

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for their reluctance to become instructors.

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The concerns indicated by the instructors and operators interviewed

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heightened the questions that have been raised regarding an apparent lack

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ofmanagementoversight(atthecorporatelevel)forthetrainingfunction.

The NRC's concerns in this area have been long standing, beginning with

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NRC Inspection Report 50-298/82-36. More recently, the NRC letter of

October 16, 1989, identified a number of concerns in the operator

requalification program which nearly caused this program to receive an

" unsatisfactory" rating.

In NRC Inspection Reports 50-298/88-24 and

50-298/89-33, the NRC documented dissatisfaction with the licensee's

failure to correct training related issues effectively.

Licensee management needs to evaluate the overall adequacy of the training

function and the training program's ability to meet management's expecta-

tions. This evaluation should include all aspects of training, including

non-licensed training, and it should critically seek to identify the root

cause(s) of the concerns and take the actions necessary to correct them.

No violations or deviations were identified in the review of this program

area.

3.

Exit Interview'

The inspectors met with the licensee representatives (denoted in

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paragraph 1) on December 8, 1989. The inspectors summarized the

inspection purpose, scope, and findings. The licensee acknowledged the

comments and did not identify any specific proprietary information to the

inspectors. An NRC resident inspector was present at the exit meeting.

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