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Insp Rept 50-298/96-16 on 961202-12.Violations Noted. Major Areas Inspected:Operations & Plant Support
	ML20133C880
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Site:	Cooper
Issue date:	01/02/1997
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ENCLOSURE 1

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV !

Docket No.: 50-298

License No.: DPR-46

Report No.: 50-298/96-16

Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: Nebraska Public Power District

141415th Street

Columbus, Nebraska

Dates: December 2 12,1996

Inspectors: Thomas Meadows, Lead inspector

Howard Bundy, Reactor Engineer

Ryan Lantz, Reactor Engineer

Mary Miller, Senior Resident inspector

Approved By: John L. Pellet, Chief, Operations Branch, DRS

ATTACHMENTS:

Attachment 1: Supplemental Information

Attachment 2: Simulation Facility Report

9701000132 970102

PDR ADOCK 05000298

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EXECUTIVE SUMMARY

Cooper Nuclear Station

NRC Inspection Report 50-298/96-16

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This inspection assessed the licensed operator requalification program to determine '

whether the program incorporated appropriate requirements for evaluating operators'

mastery of training objectives in accordance with 10 CFR 55.59(c). The assessment

included an evaluation of the program's controls to assure a systems approach to training

and evaluation of operating crew performance during annual requalification examinations.

This included review of the facility documents, observation of operating and staff crews

during dynamic simulator scenarios and plant walkthroughs, and an assessment of the

examination evaluators' effectiveness in conducting and evaluating examinations. The '

inspection also included an evaluation of the plant referenced dynamic simulator used to

conduct the examinations and the reference documentation used to produce the i

examinations and some extended control room observations. I

Operations

Overall, the licensed operator requalification training program effectively

implemented a systems approach to training and maintained the condition of

licenses. However, the inspectors observed some recurring performance

deficiencies in crew command, control, communication, and procedure usage skills

during abnormal emergency operations. The inspectors identified an apparent

weakness in the program's ability to effectively maintain operator performance at

expected levels so that previously identified performance deficiencies and

weaknesses do not reappear. (Sections 04.1,05.1,05.2,05.3,05.4,05.5).

Licensed operators displayed good communication skills, teamwork, plant system

knowledge, and ownership of plant equipment, with the exception of two crew

failures noted during the simulator evaluations (Sections 01.1, 04.1, F8.1).

Annual requalification examinations were comprehensive and discriminated at the

appropriate level (Section 05.1).

The licensed operator requalification f acility evaluators administered the

examinations professionally and in accordance with accepted industry practices

(Section 05.2).

The licensee's training department was responsive to feedback and revised the

training program as appropriate (Section 05.3).

Plant Suocort

Plant housekeeping was good (Section F8.1).

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Report Details

1. Operations

01 Conduct of Operations

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01.1 Observations of Operator Performance '

a. Insoection Scope (71715)

Using the guidance of Inspection Procedure 71715, " Sustained Control Room and

Plant Observation," the inspectors observed activities in the control room during

normal plant operations. The inspectors compared the observed performance with

expected performance as described in facility policies and procedures. Between

December 9 and 12,1996, the inspector observed three different shift crews for

continuous periods ranging from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The inspector observed three crew I

turnovers and approxirnately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of control room operations involving power

operations.

b. Observations and Findinas

The inspector noted that the individual operator turnover briefings were thorough

and detailed, and that both the oncoming and offgoing operators were alert and i

diligent in providing a professional turnover. Post-relief crew briefs were thorough

and comprehensive with each member of the crew providing a status of activities

and equipment for their areas.

The inspector observed consistently good and effective communications in

accordance with management expectations. Operator communications were clear

and unambiguous, and communication support equipment appeared reliable and

adequate. Communications outside the control room were generally formal and

consistently effective.

Control room conduct was formal. The shift supervisor was closely involved in shift

operations. Access to the control room was formally controlled and noise levels

were maintained low and non-distracting to the control board operators. The

licensed senior operator maintained a professional environment in the control room,

which was noteworthy due to the impending startup and increased activity in the

plant and the control room.

Operators routinely exhibited good self checking and peer checking when

manipulating controls. The inspector observed that the operators performed peer

checks on the designated components.

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c. Conclusions

The inspector concluded that operators exhibited good communication, command

and control, annunciator response, procedure usage, self checking and peer

checking.

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04 Operator Knowledge and Performance l

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04.1 Operator Performance on Annual Reaualification Examinations i

a. Insnection Scone (71001)

The inspectors observed the performance of two shift crews during their annual j

requalification evaluations. Each crew was composed of five active licensed I

operators and one shift technical engineer. This Licensed Operator Requalification

Cycle 96-20 began on November 11,1996, and ended on December 20,1996. l

The cycle consisted of an annual operating examination, that included simulator !

dynamic performance evaluations and five job performance measures for each

licensed operator. Also included was a written examination for each operator,

consisting of a simulator static examination and an open reference examination,

it was the conclusion of a two-year licensed operator requalification program.

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b. Observations and Findinas

Six of eight crews passed all portions of their evaluations. Two crews f ailed the

dynamic simulator evaluation.

The causes for the failures were primarily performance deficiencies in crew

command, control, communication, and procedure usage skills. On December 4-9,

1996, the inspectors observed the dynamic simulator, job performance measures,

and written evaluations for two crews. One of these crews failed, which brought

the total crew failures for this cycle up to two. Two individuals on this crew were

also f ailed, one by missing an individual critical task, and the other on performance

competencies. The licensee evaluators expressed concerns that one of the licensed

reactor operators that was failed on individual competencies may not be competent

to continue to perform license duties and removed the individual from shift for

further evaluation. The licensee's remediation actions are discussed further in

Section 05.4.b below.

Operator performance in the simulator was consistent with that observed in the

control room with the exception of formal communication practices. During

stressful simulator scenario conditions, formal communications would break down

at times. This weakness was most obvious in the two crews that f ailed, but also

apparent, to a lesser degree, in the other six crews evaluated during this cycle.

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The licensee's staff acknowledged that crew communications weaknesses had been

identified and improvements incorporated into the training program through ,

feedback process. !

c. Conclusions

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The inspectors concluded that, with the exception of two crew failures, which were

primarily caused by performance deficiencies in crew command, control

communication, and procedure usage, the licensed operators exhibited good

knowledge and ability during the requalification examinations.

After the formal remediation and re-examination of the two failed crews were

completed, the inspectors also concluded that all operators had demonstrated an

adequate ability to continue licensed duties with the exception of one reactor

operator who had been failed on competencies.

05 Operator Training and Qualification

05.1 Review of Reaualification Examinations

a. Inspection Scope (71001)

The inspectors performed a review of the annual requalification examinations,

including operating tests and biennial written examination, to evaluate general

quality, construction, and difficulty level. The inspectors also reviewed the

methodology for developing the requalification examinations.

b. Observations and Findinas

The operating examinations consisted of job performance measures and dynamic

simulator scenarios.

The facility utilized the General Electric Owner's Group template evaluation

scenarios as guidance in the development of the scenarios used for the

requalification examinations. The scanarios followed the guidelines of

NUREG 1021," Operator Licensing Examiner Standards," Revision 7, Supplement 1,

in complexity and quantitative event requirements. The scenarios were written with

clear objectives, expected operator actions, and critical task identification and

evaluation criteria.

The job performance measures were adequate in scope and depth, and covered a

broad range of topics as required by the training program and the regulations.

Generally, critical steps were appropriately identified, although the inspectors

identified three job performance measures that contained one to two steps

important to successful task completion that were not annotated as critical steps.

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The inspectors noted that many of the job performance measures required

significantly more time for the applicants to complete than was indicated as the

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validation time for the task. One task in particular, Job Performance

Measure 201-004," Operate the CRD System to Bring the Reactor Critical," showed

a validation time of 15 minutes. Each of the three licensees observed performing

the task required approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to complete the task, not counting procedure

review prior to beginning rod withdrawal. The inspectors determined that an

inadequate time validation was done on this job performance measure, and this

ultimately impacted the remaining schedule for job performance measures.

Additionally, expectations for the method to complete this task appeared to be

unclear. Each applicant utilized continuous rod withdrawal control differently, from

not at all to the maximum allowed by procedure. During the crew oebrief of

examination results by management and the other evaluators, these expectations

were not clarified, even though the use of continuous rod withdrawal was

addressed. The inspector noted that plant engineering encouraged the use of

continuous rod withdrawal to minimize challenge to the control rod drive system

during startups. The licensee staff acknowledged that the Job Performance l

Measure 201-004 needed re-evaluatic") and that management expectations of the l

use of continuous rod withdrawal control needed to be cbnfied and consistently ;

communicated to engineering, training, and operations. !

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The inspectors determined that the written examinations were of the appropriate

breadth of coverage and depth of knowledge, and of particularly effective

discriminating value.

However, the examination development program, NTP 4.2, " Test item and

Examination Development," Revision 0, was vague with respect to examination

question repeatability criteria. Steps 5.3 - 5.3.3 gave several alternatives to ensure

no compromise of examinations in a given program year or cycle, as follows:

". . no examinations will be repeated, with a minimum of 25% of the

questions different from any other examination."

". . . sufficient time elapse between examinations to preclude compromise."

The inspector noted that the wording is vague enough to allow more than

50 percent repeat on successive examinations, and that proposed Week 5 and 6 i

written examinations for this year's annual examinations were identical, with the !

exception of two to three questions, to the Weeks 1 and 2 examinations,

respectively.

When questioned as to how examination security would be preserved, the licensee

stated that a procedure change request would be submitted to specify a time period

of 1 month as sufficient time to preclude compromise. The inspectors determined

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that examination security measures were being followed in accordance with

program requirements and appeared adequate to reasonably prevent physical

compromise of an examination. No compromise events were known or suspected ;

to have occurred during this requalification program cycle. !

c. Conclusions

The inspectors concluded that the examinations were well constructed, challenging,

and discriminated at the appropriate level. The written examination section of the

examination development procedure was interpretive, which presented a potential

challenge to examination security.

The licensee acknowledged that they needed to clarify their written examination

development procedure guidance to preclude a potential challenge to examination

security.

05.2 Examination Administration

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a. Insoection Scoce (71001) !

The inspectors observed the administration of all aspects of the requalification

examinations to determine the evaluators' abilities to administer an examination and

assess adequate performance through measurable criteria. The inspectors also

noted the fidelity of the plant simulator to support training and examination

administration. The insoectors observed two operations shift crews, of five

licensed operators each, during conduct of the dynamic simulator scenarios and job

performance measure evaluations. Five licensed operator requalification training

evaluators and one operations management evaluator were observed participating in

one or more aspects of administering the examinations, including pre-examination

briefings, observations of operator performance, individual and group evaluations of

observations, techniques for job performance measure cuing, and final evaluation

documentation.

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b. Observations and Findinas

The evaluators conducted the examinations professionally, and thoroughly

, documented observations for later evaluation. Job performance measure cues were

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A formal method of evaluation was used that reviewed crew and individual critical

tasks following the scenario observations, and then competencies for the crew and

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for individuals when appropriate. During the simulator evaluations the inspectors

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noted that the evaluator staff was particularly effective in identifying and proper!y

categorizing operator performance deficiencies and weaknesses. The inspectors

also observed strong operations staff participation. The post-scenario examination

evaluation caucuses were well organized and efficient with the evaluation team

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reaching a crisp, accurate consensus on performance results in a timely manner.

This minimized overall crew stress. The inspectors observed that the crews held

independent self-critical caucuses, led by their shift supervisors, who were also

involved with developing remediation plans, when necessary. The inspectors also

observed that shift supervisor ownership for crew and individual performance was a

management expectation and was apparent in most cases.

The inspectors noted that the performance of the simulator in supporting the

examination process was good.

c. Conclusions

The facility evaluators administered the examinations professionally and in

accordance with industry standards. The facility evaluators effectively identified

deficiencies or weaknesses in the trainees to feedback into the training program.

05.3 Review of Trainino Feedback System

a. Insoection Scoce (71001)

The inspectors verified the methods and effectiveness of the licensed operator

requalification training program feedback system.

b. Observations and Findinos

During interviews, licensed operators and training management described several I

methods for providing feedback on the licensed operator requalification training j

program. The inspectors noted that these methods were appropriately covered in ;

training department procedures and guidelines. Written requests could be made

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with either the training feedback form or training work request form. A response a

could be requested if the training feedback form was used and was required if the j

training work request form was used. At the beginning of a training week the shift j

supervisor and training instructor would discuss the areas for training emphasis l

during the week. At the end of the training week the shift supervisor would present ;

all written feedback and any other feedback to the training instructor. The other '

crew members also participated in this debriefing. The training instructor then

summarizcd all the feedback. Training feedback was also accepted by training j

instructors and management in any other format. A combined monthly report of j

student feedback was then issued to training supervisors and lead instructors. This

feedback, together with management field observations, management training I

observations, and other data was reviewed monthly by an operations training

coordination committee, and quarterly by a training effectiveness review committee.

A management training effectiveness review committee consisting of senior facility

managers met semi-annually.

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The operators interviewed expressed satisfaction with the training feedback l

program. After reviewing student feedback summaries and committee reports, the

inspectors concluded that training issues ware being properly identified and

addressed by management.

The inspectors reviewed the condition reports listed in Attachment 2 to determine if

appropriate corrective action training had been planned and implemented. The

inspectors found that it was difficult to determine if appropriate training had been

performed in many instances by reaoing the condition report. Selected training

issues identified in the condition reports were discussed with operators during

interviews. The inspectors determined that the operators had received appropriate

training on the issues presented.

c. Conclusions

Operations personnel utilized several diverse and effective methods for providing

feedback to the licensed operator requalification training program. The training

department, with involvement by senior management through participation in

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training effectiveness review committees, responded to the training feedback l

provided.

05.4 Review of Remedial Trainina Proaram

a. inspection Scope (71001)

The inspectors assessed the adequacy of the effectiveness of the remedial training ,

conducted during this requalification cycle and the training planned for the next l

cycle to ensure that it addressed operator or crew performance weaknesses,

b. Observations end Findinas

With respect to failures of Crews B and F (February 1996), D (November 1996),

and a second failure for F (December 1996) during Requalification Training

Cycle 96-20, the inspectors identified recurring performance deficiencies in crew

command, control, communication, and procedure usage skills. The inspectors

identified an apparent weakness in the program's ability to effectively maintain ;

operator performance at expected levels so that previously identified performance i

deficiencies and weaknesses did not reappear. Furthermore, the inspectors )

assessed that Crew F's second failure was due to some of the same performance

deficiencies identified in the February evaluation.

! Although some crews performed well, others were marginal, or required extensive

remedial training. Crew performance across the different shifts appeared

inconsistent at times. It was apparent that the licensee's corrective actions have

not always been effective for all crews to maintain operator performance at

expected levels so that previously identified performance deficiencies and

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weaknesses did not reappear. The inspectors requested that the licensee provide ;

any documented root causes and intended corrective actions regarding this issue.

The inspectors also requested a copy of the final Requalification Training i

Cycle 96-20 Completion Report. The licensee's staff acknowledged this issue and

the request for additional documentation.

The inspectors also observed Crew F's short-term remedial training process on

December 4-8,1996, and remediation examination on December 9,1996. The

inspectors determined that the short-term remedial training was intensive and

effective. Cre u F's improved performance supported the licensee's decision to j

return it to licensed shift duties as scheduled. However, the inspectors shared the l

lisensee's concerns that the licer. sed reactor operator who failed on individual

competencies may not be competent to continue to perform license duties. The

inspectors requested that the NRC be kept informed of the final remedial disposition

of this operator before returning him to licensed duties, or of a decision to terminate

the license. The licensee's staff acknowledged this request.

c. Conclusions

The remedial training program was adequate. Short-term remedial training was

intensive and offective. However, recurring performance deficiencies in crew

command, control, communication, and procedure usage skills indicate that the l

licensee's corrective actions have not been effective for all crews to maintain l

operator performance at expected levels so that previously identified performance I

deficiencies and weaknesses did not reappear.

05.5 Review of Conformance with Ooerator License Conditions:

a. insoection Scone (71001)

The inspectors evaluated the adequacy of the requalification program's compliance

with Subpart C, Medical Requirements and 10 CFR 55.53, license conditions. The

inspectors interviewed operators and training management, and examined the

licensee's records to determine compliance for conditions to maintain an active

operator license, reactivation of licenses, and medical fitness. Approximately

10 percent of the records were reviewed.

b. Observations and Findinas

Operator license conditions were being accurately identified and tracked. License

i conditions were complied with in the samp!s selected.

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c. Conclusions

The inspectors concluded that the licensee accurately tracked, maintained, and

controlled the .:onditions of operator licenses and reactivation of inactive licenses in

accordance with Subpart C,' Medical Requirements, and 10 CFR 55.53, License

Conditions.

08 Miscellaneous Operations issues

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08.1 Review of the Uodated Final Safety Analysis Reoort Commitments

A recent discovery of a licensee operating their facility in a manner contrary to the

. Updated Final Safety Analysis Report description highlighted the need for a special

focused review that compares plant practices, procedures, and/or parameters to the

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. Updated Final Safety Analysis Report descriptions. While performing the inspection

discussed in this report, the inspectors reviewed the applicable portions of the

Updated Final Safety Analysis Report that related to the areas inspected. The

inspectors verified that the Updated Final Safety Analysis Report section for

licensed operator replacement and requalification training was consistent with the

observed plant practices and procedures.

IV. Plant Support

F8 Miscellaneous Fire Protection issues

F8.1 General Comments

The inspectors observed general plant housekeeping incident to administration of

the in-plant job performance section of the operating test. The f acility was

reasonably clean, welllighted, and the floors were clear and free from debris. The 1

operators were conscientious to note discrepancies and inform the main control i

room.

V. Manaaement Meetinas !

X1 Exit Meeting Summary

The examiners presented the inspection results to members of the licensee

management at the conclusion of the inspection on December 12,1996. The

licensee acknowledge the findings presented.

The licensee did not identify as proprietary any information or materials examined

during the inspection.

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ATTACHMENT 1

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee !

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R. Creason, Senior Operations Training Specialist

R. Gardner, Operations Manager 1

B. Houston, Licensing Manager

S. Jobe, Operations Training Programs Supervisor

M. Peckham, Plant Manager

D. Shallenberger, Lead Licensed instructor, Requalification

A. Shiever, Nuclear Training Manager i

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S. Smalifoot, Shift Supervisor

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NRC

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C. Skinner, Resident inspector I

DOCUMENTS REVIEWED

Procedures Reviewed !

Directive 54, " Management Overview of Training ar.d Evaluation Activities,"

Revision 6

Directive 47, " Training Effectiveness Review Committee," Revision 8 i

Directive 7, " Management Field Observation," Revision 7

NTG 317, " Shift Crew Training Assessment," Revision 3

NTP 6.2, " Evaluation of Program Effectiveness," Revision O

NTG 308, " Training Impact," Revision 04.00

NTG 328, " Operations industry Events," Revision 01.00

NTP 1.1, " Training Work Request," Revision 0

SKLO12-06-01," Simulator Discrepancies and Design Changes," Lesson Plan

NTP 4.2, " Test item and Examination Development," Revision O

SOP 2.2.28, "Feedwater System Starup and Shutdown," Rev;sion 58.1

CNS Operations Directive 2, "CNS Communication," Revision 12

NTG 323," Development of Licensed Operator bqualification Evaluation Scenarios"

NTG 315, " Licensed Personnel Requalifit,c n Training"

NTP 5.3, " Student Remediation"

NTG 317," Shift Crew Training Assessment"

NTP 6.2, " Evaluation of Program Effectiveness"

NTP 08, " Instructor Qualifications"

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Condition Reports and Licensee Event Reports

CR 96-0478, dated May 9,1996 i

CR 96-0766, dated September 3,1996 )

CR 96-0849, dated September 25,1996 l

CR 96-0765, dated August 30,1996 i

CR 96-0356, dated April 13,1996

CR 96-0553, dated June 11,1996 j

CR 96-0180, dated February 28,1996 i

CR 96-0832, dated September 20,1996 )

LER 96-05, Revision 0 ;

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Memoranda and Other Reoorts

NTM96011," Management Training Effectiveness Review Committee, May 29, June 5,

June 13,1996," from John H. Mueller, dated June 26,1996 1

NTM96018," Management Training Effectiveness Review Committee Meeting Minutes - !

July 29,1996," from Philip D. Graham, dated October 17,1996

"MTERC Meeting - September 25,1996," from Philip D. Graham, dated October 29,1996

OPS 96027,"First Quarter TERC Meeting - March 22,1996," from R. L. Garner to J.T.

Herron, dated April 12,1996 l

OPS 96034, "Second Quarter TERC Meeting - June 21,1996," R. L. Gardner to J. T.

Herron, dated July 15,1996

NTG-315, Attachment B, "CNS Licensed Operator Requal Topic Survey," R. R. Carlson,

dated August 19,1996

NTG-315, Attachment B, "CNS Licensed Operator Requal Topic Survey," R. R. Carlson,

dated August 19,1996

NTD960628," Operations and Operations Traihing Coordination Meeting," S. J. Jobe to D.

W. VanDerKamp, dated September 11,1996

NTD960708," Operations and Operations Training Cocrdination Meeting," S. J. Jobe to D.

W. VanDerKamp, dated November 1,1996

NTD960308,"Requal End-of Cycle Completion Report: 96-12," A. R. Shiever to R. L.

Gardner, dated June 6,1996

NTD960684,"Requal End of Cycle Completion Report: 96-15." A. R. Shiever to R. L. j

Gardner," dated October 4,1996 l

"CNS Directive 7 Field Observations - Monthly Report," R. A. Sessons to J. H. Mueller,

dated July 12,1996

NTD960709," Student Feedback Report for September 1996," Ralph Drier to Training

Manager, Training Supervisors & Training Leads," dated October 28,1996

NTM96044," Directive 54, Training Activity Observation Report - September & Third

Quarter 1996," A. R. Shiever to NPG Managers, Supervisors and Training Lead

Instructors, dated October 28,1996

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NTM96036," Directive 54, Training Activity Observation Report - August 1996," A. R. l

Shiever to NPG Managers and Supervisor, Nuclear Training Lead Instructors, dated

September 20,1996

NTD960578," Industry Events Survey Results and Recommendations," D. Shallenberger/L. ,

Monroe to D. VanDerKamp, dated August 22,1996

ML20133C880

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