ML20003E393
| ML20003E393 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/05/1981 |
| From: | Aneshansley M, Gagliardo J, Hunnicutt D, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003E390 | List: |
| References | |
| 50-285-81-02, 50-285-81-2, NUDOCS 8104030311 | |
| Download: ML20003E393 (10) | |
See also: IR 05000285/1981002
Text
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U. S. NUCLEA;< REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
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Report No. 50-285/81-02
License No. DPR-40
Cocket No. 50-285
Licensee:
Omaha Public Power District
1623 Harney Street
Omaha, Nebraska 68012
Facility Name:
Fort Calhoun Station, Unit 1
Inspection at:
Fort Calhoun Station, Blair, Nebraska
Inspection conducted:
January 12-15, 1981
Inspectors
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M. I. Aneshansley, Reactor Inspector
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L. A. Yandell, Reactor Inspector
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Reviewed b :
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, J. E. Gagli~ardo, Chief
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Nuclear Support Section
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Approved by:
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D. M. Hunnicutt, Chief
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Reactor Projects Secticn No. 2
Inspection Summary
Insoection conducted during the oeriod of January 12-15. 1921 (Recort No.
-50-285/81-02)
Areas Inspected:
Routine, unannounced inspection of the Tests and Experiments
Program,. Training and Requalification Training.- The inspction involved forty-
eight (48) inspector. hours on-site by two NRC inspectors.
Results: Within the three areas inspected . four violations were identified
as follows:
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(1) Test and Experiments Program, (Failure to follow reporting require-
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ments of 10 CFR 50.59, paragraph 2).
(2) Training, (Fa".e to follow commitments made in the training program,
paragraph 3).
(3) Requalification Training, (Failure to meet r2 qualification require-
ments, paragraph 4).
(4) Requalification Training, (Failure to provide records of activities
affecting quality, paragraph 4).
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DETAILS
1.
Persons Contacted
- W. Jones, Division Manager, Production Operations
- F. Thurtell, Division Manager, Environmental and Regulatory Affairs
- R. Andrews, Section Manager, Operations
- K. Morris, Manager, Administrative Services.
- G. Peterson, Supervisor, Maintenance (also acting Manager, FCS)
- T. Patterson, Licensing Administrator
J. Gass, Training Supervisor
M. McEwan, Training Coordinator
T. Chapman, Health Physicist
A. Richard, Plant Engineer
The inspectors also talked with and interviewed other licensee employees
including craftsmen, engineers and office personnel.
2.
Tests and Experiments Program
The inspector reviewed Ft. Calhoun Station Procedure G-3, Special Proce-
dures and Special Order No. 20 to verify that the licensee has established
a program to (1) handle requests for performing plant tests and experiments,
(2) ensure that tests and experiments are performed using approved written
procedures, (3) verify that all proposed test and experiments are reviewed
to determine whether they are described in the FSAR, (4) verify that a
written safety evaluation pursuant to 10 CFR 50.59 is done for those tests
and experiments not described in the FSAR, and (5) ensure that all tests
and experiments conducted pursuant to 10 CFR 50.59 are formally reported
to the NRC in a timely manner.
The following special procedures were reviewed;
Procedure
Title
Date Performed
Containment Purge Supply and
7/13/79
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Exhaust Penetrations (M-88 &
M-87) Type C Leak Rate Test
Variable Tavg. Test Using
8/27/79
Center CEA
Leak Test of Primary Coolant
6/5/80
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System
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Performance of Ultrasonic
1/6/80
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Examination and/or Liquid
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Penetrant Examination on Welds
in Stagnant, Oxygenated and
Borated-Systems
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SP-RCS-TEMP-1,
RCS Temperature Rise with
4/9/80
Shutdown Cuoling Securec
Excore Detector Symmetric
8/20/80
Offset Recalibration
The inspector reviewed the monthly reports from August 1979 through
September 1980 that contained periodic reports of tests and experiments.
Section (2)(b) of 10 CFR 50.59 requires that holders of a license provide
a report to the appropriate NRC Regional Office on the performance of any
" tests or experiments not described in the safety analysis report," and
that this report contain "a brief description of such . . . tests and
experiments, including a summary of the safety evaluation of each."
Contrary to the above, the licensee failed to provide a summary of the
safety evaluation done on each test and experiment.
This is an apparent
violation for failure to meet the reporting requirements of 10 CFR 50.59.
(8102-01).
3.
Training
The inspector reviewed program elements and records of the licensee's general
training and retraining program for employees and contractors.
Based on
the. Ft. Calhoun Station Training Manual, this review addressed the areas of
(1) General Employee Training (radiation protection, site security, emer-
gency plan / fire drills, first aid, safety meetings, and QA/QC), (2) De-
partment Training, (annual lectures and on-the-job training), (3) Emergency
Duty Officer and Emergency Monitoring Team Training, and (4) Fire Brigade
Training.
In addition, the inspector interviewed several members of the
plant staff regarding the training they've received and reviewed the Site
Security and Radiation Protection Training Report dated January 6, 1981.
As a result of these reviews, the inspector determined that the licensee
had failed to meet the following commitments made in the Training Manual.
a.
Section B.2.1 requires "an annual refresher training session and an
examination" in radiation protection, but contrary to the above,
approximately 250 OPPD personnel, holding current badges for the
Ft. Calhoun Station, haim gone more than one year without this
training.
b.
Section B.2.1 requires that those perso nel "who have security
classifications which allow unescorted access to the Ft. Calhoun
Station" be given " Site Security refresher training each calendar
year in order to maintain their classification." Contrary to the
above,-approximately 375 OPPD personnel holding current badges for
the Ft. Calhoun Station failed to undergo refresher training in 1980.
c.
Section B.2.4 requires that the licensee schedule and conduct " quart-
erly fire drills involving the entire plant staff." Contrary to the
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above, Ft. Calhoun Station had no plant-wide fire drills scheduled
for 1980, and had only one fire incident that involved the entire
plant staff that was recorded for training purposes.
d.
Section B.2.8 requires that "an annual schedule detailing General
Training and Retraining, Departmental Training and Retraining and
special training events" be prepared and " published each December
for the following year." The inspector reviewed the schedule for
Departmental Training and Retraining, and special training events
that was recently published for 1981, but contrary to the above,
no annual schedule for General Training and Retraining had been
issued.
e.
Sections C.4.1.1 and C.4.2.1 require the licensee to schedule
"approximately 30 haars of lecture" each year for the Mechanical
and Electrical crafts, respectively.
Contrary to the above, no
schedule for this type training was issued for 1980.
f.
Sectionr C.4.1.1 and C.4.2.1 require that craftsmen " attend an
annual secture series censisting of topics from the following:
Appropriate Technical Topics
Plant Systems and Components
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Administrative Precedures
Technical Specifications
Changes to Facility Design
Changes to the Facility License
Quality Assurance and Control"
Contrary to the above, a review of selected training records of five
craftsmen and interviews by the inspector indicated that craftsmen
had not been attending required departmental training lectures.
Specifically, the inspector determined that (1) all but one crafts-
men were overdue for Radiation Protection refresher training, and
(2) none of the craftsmen had the required 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of departmental
lecture training.
Note:
Two of the individuals interviewed had no entries for de-
partmental training, but it was determineo that they had
attended some lectures.
The problem seems two-fold:
first,
that craftsmen were not getting the required 30. hours de-
partmental training; and second, that proper records were
.not being kept on the lectures they did attend.
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g.
Section D.2.1 requires that persons selected as Emergency Duty
Officers be " instructed in the entire Emergency Plan," be given an
" examination prepared by the Supervisor-Chemistry and Radiation
Protection," and demonstrate their " ability to perform the duties
of EDO under drill conditions" as documented on "an Emergency Duty
Officer Training Checklist."
In addition, Section D.2.5.2 requires
that the Supervisor-Chemistry and Radiation Protection (C&RP) prepare
"an examination on the Emergency Plan for Emergency Duty Officer
training." Contrary to the above, three licensee personnel were
identified by position on Figure V.1 of the FCS Emergency Plan as
Emergency Duty Officers but had not received the training as out-
lined above.
The licensee pointed out that these individuals were
not considered E00's at present and that Figure V.1 reflects
qualifications to be obtained as part of a specific position.
The
inspector stated that when requesting a list of qualified ED0's from
the licensee, Figure V.1 from the Emergency Plan had been given to
him.
This remains a matter of confusion because no other list of
qualified ED0's exists in the plant files.
In addition, the Supervisor -
C&RP has not prepared an examination on the Emergency Plan for EDO
training.
This is an apparent violation for failure to follow commitments made
in the Ft. Calhoun Station Training Program.
(8102-02).
The inspector expressed concern with the licensee at the overall
weakness of the geniral employee training.
One item of concern
identified was the apparent unfamiliarity of plant personnel with
the training program and its published requirements.
Much of this
stems fron the fact that only three copies of the Training Manual
are available et the Ft. Calhoun site, and the document is not in
general circulation.
A second item of concern resulted from the
review of Ft. Calhoun Station QA audit report 23-80 dated July 23,
1980, that identified items to be corrected, but were still present
at the time of this inspection.
The inspector had the opportunity to review the department training
schedules for 1981, and to sit in on one of the system lectures.
It
appears that the 1981 program will be capable of meeting the require-
ments for departmental training as set forth in Section C of the
Training Manual.
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Licensed Ooerator Recualification Training
The purpose of this inspection was to determine that the licensed operator
requalification training program was effective and in conformance with
regulatory requirements.
The inspector reviewed all aspects of the requali-
fication program for calendar year 1980 including the annual examination,
results and evaluation.
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a.
Annual R0 and SRO Requalification Examination
A review of the annual requalification examination indicated that the
following subjects were covered on the SR0 examination:
(1) Reactor Theory
(2)
Radioactive Material Handling, Disposal and Hazards
(3) Specific Operating Characteristics
(4) Fuel Eandling and Core Parameters
(5) Administrative Procedures, Conditions and Limitations
The Ft. Calhoun Technical Specification 5.4.1 requires that the re-
qualification program meet or exceed the requirements of 10 CFR 55,
Appendix A.
10 CFR 55, Appendix A, requires that the operator and
senior operator written examination cover the following subjects:
(1) Theory and Principles of Operation
(2) General and Specifih Operating Char
teristics
(3) Plant Instrumentation and Control Sy
as
(4) Plant Protection Systems
(5) Engineered Safety Systems
(6) Normal, Abnormal and Emergency Operating
ocedures
(7) Radiation Control and Safety
(8) Technical Specification
(9) Applicable portions of 10 CFR
The failure to include all subjects in 'he annual examination for SR0s
is an apparent violation against Technical Specification 5.4.1 and
(8102-03)
10 CFR 55, Appendix A, further requires that the requalification pro-
gram include written examinations which determine-licensed operators'
and senior operators' knowledge of subjects covered in the requali-
fication program and provide a basis for evaluating their knowledge
of abnormal and emergency procedures.
This has been implemented by
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Fort Calhoun in their training manual which states, "Following the
examination, a report will be issued summarizing weak topical areas
and a list of those personnel, if any, who fail the examination.
In
addition, indivfauals who score less than 80% in particular categories
will be required to attend the appropriate lectures.
Periodic written
quizzes will be given to all lecture participants to evaluate their
knowledge on topics covered by these lectures." The inspector
determined that the report on the 1980 requalification exam had not
been prepared.
The licensee's failure to provide the report of
the evaluation of the examination is another example of the apparent
violation against the requirements of the requalification program.
Further, one licensed operator scored less than 80% on the annual
examination (Radiation Safety and Control Section), did not attend
any retraining in this area and was not reexamined in this area
as required.
This is Enother example of the apparent violation on
tne failure to meet the requirements of the requalification program.
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The inspector reviewed the results of examinations given to several
SR0s and R0s and was concerned that these examinations had not been
graded in a professional manner.
There seened to be an inconsistency
in the acceptance criteria (exam key) and the responses given by
the operators.
This apparent lack of " attention-to-detail" in the grading of the
examinations is considered an unresolved item (8102-04).
The in-
spector will provide copies of the examinations, exnmination keys
and the responses to NRC headquarters and ask that they be reviewed
and further guidance provided.
The inspector determined that only one version of the R0 and SRO
examination was given.
In the case of the SRO, it required approxi-
mately six weeks to administer the examination to all personnel.
In
the case of the R0 examination it required approximately 12 weeks
to administer the examination.
The licensee had taken no special
precautions to prevent the examination from being compromised.
This
will be identified as an open item (open item 8102-05) and the
methods utilized to prevent compromising examinations will be dis-
cussed with the licensee in a future inspection.
On-the-job training- 10 CFR, Part 55, paragraph 3, requires the requali-
fication program to include on-the-job training so that:
(1) "Each licensed operator and senior operator is cognizant of
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facility design changes, procedure changes, and facility
license changes, and
(2) "Each licensed operator and senior operator reviews the contents
of all abnormal and emergency procedures on a regularly scheduled
basis:"
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The inspector reviewed individual training records, shift training
packages and lesson plans in an effort to determine that these
requirements had been met.
It was determined that the licensee had
not developed a method to ensure that all licensed operators and senior
operators review the contents of all abnormal and emergency procedures
on a regular basis and that the reviews had not been conducted.
The
failure to conduct these procedure reviews on a regularly scheduled
basis is another example of the apparent violation of the requalifi-
cation program requirements.
Through discussions with the training coordinator, the inspector deter-
mined that the licensed operators and senior operators were cognizant
of facility design changes, procedure changes and license amendments.
This was accomplished through training sessions, " night orders,"
operations superintendent memos and shift training.
Howe' er, there
was no documentation that all licensed operators and senior opera-
tors had been made cognizant of procedure changes and facility
license changes 48, 49, 50, 51, 52 and 53.
Technical Specification 5.10.2 states, "The following records shall be retained for the
duration of the Facility Operating License:
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Records of Quality Assurance Activities required by the QA
Manual"
Quality Assurance Procedure (QAP) #7, paragraph 3.1, states, " Records
shall be retained that furnish evidence of activities affecting
quality." Paragraph 3.3 states, "The records listed in Appendix A
(to QAP #7) shall be accumulated and handled in a controlled manner.
Appendix A (to QAP #7) lists records of individual plant staff members
qualification, experience, training and retraining as a quality assurance
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record.
The licensee's failure to maintain records that document
licensed operators cognizant of procedure changes, facility design
changes and facility license changes is an apparent violation.
(8102-06)
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During the audit, the inspector identified several errors in the
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licensee's training records.
These are listed below:
(1) The Operations Requalification Summary sheet contained in ten
individual training records had not been cc>aleted.
Spaces
which indicate position title, license erfective date, type
license and requalification examination results had not been
completed for.1980.
(2) -Shift training packages 80-02, 80-07-2, 80-07-4 and 80-5-2 had
not been signed by the shift supervisor.
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(3) Six drill evaluation forms contained in shift training package
80-08-1 had not been sigr:ed.
(4) Three drill evaluations contained in shift training package
80-08-2 were carbon copies, i.e., the evaluation of three opera-
tors responses were carbon copies with different names at the
top.
10 CFR 55, Appendix A, paragraph 4.c. states, "The requaiification
program shall include systematic observation and evaluation of the
performance of licensed operators and senior operators by supervisors
and/or training staff members including evaluation of actions taken
or to be taken during actual or simulated abnormal and emergency
conditions.
The inspector discussed these evaluations with the acting plant manager
and it was determined that the annual company performance evaluation,
drill evaluations and simulator repor's were used to conduct these
evaluations.
However, a review of the drill evaluations indicated
that an evaluation of the performance of seven licensed operators
had not been conducted.
Further, the report issued by Combustion
Engineering merely stated that the OPPD personnel had attended the
simulator and had performed ten reactivity manipulations.
The
report did not contain an evaluation of operator performance and/or
competancy.
The licensee's failure to systematically evaluate the
performance and competency of licensed operators is another example
of the failure to meet the requirements of the requalification program.
5.
Exit Interview
An exit interview was conducted on January 15, 1981, with those OPPO
personnel denoted in paragraph 1 of this report to summarize the scope
of the inspection and the finidings.
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