ML20237A401
| ML20237A401 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/11/1987 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8712140452 | |
| Download: ML20237A401 (2) | |
See also: IR 05000285/1987013
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In Reply Refer To:
DEC i i 1987
Docket:
50-285/87-13
Omaha Public Power District
ATTN:
R. L. Andrews, Division Manager-
Nuclear Production
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1623 Harney Street
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Omaha, Nebraska 68102
Gentlemen:
Thank you for your letter of November 19, 1987, that provided an
update to your previous reponse, dated July 30, 1987, to our letter and Notice
of Violation dated June 30, 1987. We have reviewed your reply and find it
responsive to the concerns raised. We will review the implementation of your
corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
Sincerely,
OrlMnal signed W
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L. J. Callan, Director
Division of Reactor Projects
cc:
W. G. Cates, Manager
Fort Calhoun Station
P. C. Box 399
,
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
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1333 New Hampshire Avenue, NW
Washingtori, DC 20036
Kansas Radiation Control Program Director
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Nebraska Radiation Control Program Director
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Omaha Public Power District
1623 Harney Omaha. Nebrasha 68102
402iS36 4000
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November 19, 1987
LIC-87-676
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NOV 2 3 l987
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
References:
1. Docket No. 50-285
2. Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews)
- lated June 30, 1987
3. Letter from 0 PPD (R. L. Andrews) to NRC (J. E. Gagliardo)
dated July 30, 1987 (LIC-87-543)
Gentlemen:
SUBJECT:
Updated Response to NRC Inspection Report 50-285/87-13
The subject Inspection Report contained three (3) unresolved items and several
concerns related to the licensed operator requalification training program.
Please find attached an update to OPPD's response en the unresolved items
presented in Reference 3, and the current status of concerns identified during
the inspection.
If you have any questions, please contact us.
Sincerely
AW
R. L. Andrews
Division Manager
Nuclear Production
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LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Ave., N.W.
Washington, DC 20036
R. D. Martin, NRC Regional Administrator
Anthony Bournia, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
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Attachment 1
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Unresolved Item (VRI) 285/8624-01
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Related to establishing an effective training records program to document
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completion of training activities.
A discussion of the follow-up performed on
URI 285/8624-01 was provided in paragraph 2 of the NRC Inspection Report
50-285/87-10. The follow-up inspection indicated that the licensee had just
recently initiated actions to establish an auditable record system.
Response:
As of October 1, 1987, the following training programs are being tracked by
OPTIM. Although the program is not in the "p~roduction mode" on OPPD's main
frame computer, it is functional and producing training records for those
programs:
1987 Licensed Operator Requal Training
a
1987 Requal Simulator Training
a
Licensed Duty (56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> per quarter)
a
R0 Program
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SR0 Program (Beginning September 14,1987)
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Accelerated Requal Training
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TONA (Equipment Operator Nuclear / Auxiliary)
a
Therefore, OPPD believes this item is now resolved.
Unresolved item (VRI) 285/8624-02
Related to not providing on-the-job training for all aspects of plant opera-
tions by failing to give classroom lectures for the Loss of Instrument Air and
the Loss of Shutdown Cooling. A discussion of this item was provided in
paragraph 2 of Inspection Report 50-285/87-10.
The follow-up inspection
indicated that no corrective actions had been initiated in providing these
classroom lectures since the problem was initially identified in August,1986.
Response:
Training on the Abnormal Operating Procedures for loss of Instrument Air and
Loss of Shutdown Cooling was conducted during the second and third requali-
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fication rotations of 1987, respectively.
All licensed operators, and some
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licensed staff members, have received this training.
Licensed staff members
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who did not attend formal training completed review of the Abnormal Operating
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Procedures by self-study and successfully passed quizzes to demonstrate mastery
of the material. As of October 22, 1987, training of all licensed individuals
was complete with the exception of one (1) individual who has yet to take and
pass the quiz.
Unresolved Item (VRI) 285/8624-03
Related to providing a pre-planned lecture series on E0P's.
This item was
discussed in paragraph 2 of NRC Inspection Report 50-285/87-13.
The follow-up
inspection indicated that some E0P's were discussed during simulator training
given in the early part of 1987, but trairing on all E0P's had not been
provided.
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Attachment 1 (Continued)
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ResDonse:
All licensed individuals received training on at least six (6) of the seven (7)
E0P's during simulator training the first quarter of 1987. This training con-
sisted of classroom sessions and/or practical sessions on the simulator floor.
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Twenty-five (25) licensed individuals received training on E0P-02, " Electrical
Emergency," during the 1987 simulator training. However, ten (10) individuals
(7 operators and 3 staff members) did not.
Nine (9) of these individuals have
since received training on E0P-02.
The tenth has been waived since he instruc-
ted on E0P-02 at the simulator.
OPPD believes this item is now resolved.
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Attachment 2
Concerns
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During the subject inspection a number of concerns were identified by the NRC
inspector.
Each concern is listed below, followed by OPPD's response.
Concern a.:
Approximately 75 percent of the training staff is composed of contractor
personnel.
These contractor personnel taught approximately 85 percent of
the classes given from September 1986 through March 1987. Although most of
the contractor personnel have received licenses as operators at other
plants or have held instructor certifications; none of these instructors
have had any operating experience at FCS. Without actual operating experi-
ence at the FCS, the classroom lectures could not include a description of
actual plant operating experiences.
This type of information would enhance
the overall knowledge level of the operators attending classroom lectures.
Licensee personnel stated that efforts were initiated in the recent past to
add instructors to the training staff that currently hold operating
licenses at the FCS.
This effort will begin in July 1987.
Resoonse:
OPPD is committed to the use of qualified instructors in the conduct of
licensed operator requalification training.
New contract instructors are
hired only after their resume's have been thoroughly reviewed and appro-
priate references have been contacted. A procedure for certification of
instructors does exist and is described in the " Training Administrative
Manu al . " Since the time of the audit, two (2) SR0 licensed individuals
have been transferred from Operations to Training. The knowledge and
experience of these individuals will significantly enhance the quality of
training which is conducted.
In order to provide further quality, efforts
are now made to have a SR0 licensed training staff member attend the first
week of each licensed operator requalification training rotation. This
individual helps to ensure that the technical content of each lecture is
correct.
Concern b.:
The licensee had not established a method for certification of contract
instructors to teach plant systems.
Without a certification program, the
level of knowledge of contract instructors was not determined for a
specific area prior to allowing the contractor to provide training in that
area.
Licensee personnel stated that instructors were interviewed by the
Supervisor - Station Training prior to being allowed to teach and have been
evaluated for the technical content of their lectures twice each year.
Based on the results of these evaluations, it was felt additional certifica-
tion was not required.
Licensee personnel stated that they would consider
giving each instructor a check out on the individual systems they teach to
verify their technical knowledge is adequate.
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' Attachment 2 (Continued)
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Response:
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A certification process is described in the " Training Administrative
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Manual . " The technical quality of lesson plans has been further enhanced
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by the assignment of " system experts" in Training.
This scheme assigns a
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number of specific lesson plans to each individual instructor.
Each
instructor is then responsible for the content of his assigned lesson
pl ans .
Quality of training is enhanced due to the fact that the instructor
feels ownership for his lesson plans and also due to the fact that each
instructor has a limited scope of material over which he is expected to
develop expertise.
Concern c.:
A review of 15 lesson plans indicated that 9 of the lesson plans were
prepared by a contractor and approved by a licensee employee with no
operating experience at any nuclear plant. The review also indicated that
no operating personnel-at the FCS had reviewed the lesson plans.
Licensee personnel stated that the lesson plans previously unreviewed by
licensed personnel would be rereviewed by appropriated personnel in the
near future.
Response:
In November 1986, training instructors were assigned licensed operator
lesson plans for upgrade and maintenance based upon each instructors
expertise.
Forty-eight-(48) safety significant system lesson plans were identified by
the OPPD Training Department to be upgraded.
By April of 1987, these
lesson plans were upgraded, reviewed by an SR0 from the operations
department, and reviewed by an SR0 from the training staff.
Reactor theory
and thermal hydraulics lesson plans have been upgraded and reviewed by an
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SRO.
All instructors have been notified by a memo dated October 26, 1987
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that the source document must be used when teacning on the Operating
Manual, Technical Specifications, USAR, or Code of Federal Regulations.
Revision Request (RR) forins are being issued to upgrade lesson plans on a
regular basis, to ensure the remainder of the lesson plans are upgraded,
and to incorporate industry events.
The revision request form is a vehicle
used to upgrade material and is described in the " Training Administrative
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Manual." The RR forms are used to document that any changes made are
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properly reviewed and approved.
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Concern d.:
Lesson plans for Sections 1 and 2 (Safety Limits and Limiting Conditions
for Operations) of the TS, the auxiliary feedwater system, and the E0Ps
were reviewed for technical content.
The results of the review indicated
that the lessonylans contained technically incorrect information,
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appropriate information had not been included, and typographical errors
affecting the technical meaning of the information were not uncommon.
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Attachment 2 (continued)
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Licensee personnel stated that the lesson plans were in the process of
being reviewed. No time frame was given as to when the reviews would be
complete.
Response:
The licensed operator requalification lesson plans for E0Ps and Technical
Specifications have been discussed in depth. The most appropriate format
for instruction in these areas has not been established in detail.
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Improved E0P and Technical Specification lesson plans will be completed by
the end of 1987.
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Concern e.:
Lesson plans had not been completed for Sections 4 and 5 (Design Features
and Administrative Controls) of the TS.
Without an approved lesson plan,
no. learning objectives were established and no assurance was made that the
licensed operators received in-depth instruction needed to perform their
assigned duties.
Licensee personnel stated that the lecture given on Sections 4 and 5 of the
TS was given using the TS manual as the lesson plan.
These personnel
stated that they felt lectures given from the TS manual were adequate.
Resoonse:
The improved Technical Specification lesson plan discussed in Concern (d)
will provide for instruction in Sections 4 and 5 where appropriate.
Concern f.:
The licensee established a formal program for maintaining lesson plans
up-to-date in April 1987.
Prior to this time, it was the individual
instructor's responsibility to ensure that the lesson plan contained the
latest information. As discussed in paragraph 6.d above, a review per-
formed on three (3) lesson plans indicated that the information contained
in the lesson plans was incomplete or inaccurate. These lesson plan
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inadequacies were due, in part, to the lesson plans not being updated with
the 1atest information.
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Licensee personnel stated that the lesson plans that had become outdated
would be reviewed and brought up-to-date. No date was specified as to when
the updating of the lesson plans would be completed.
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Response:
In November 1986, training instructors were assigned licensed operator
lesson plans for upgrade and maintenance based upon their expertise.
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Attachment 2 (Continued).
Forty-eight (48) safety significant system lesson plans were identified by
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the OPPD Training Department to be upgraded.
By April of 1987, these
lesson plans were upgraded, reviewed by an SR0 from the operations depart-
ment, and reviewed by an SR0 from the training staff.
Reactor theory and
thermal hydraulics lesson plans have been upgraded and reviewed by an SRO.
All instructors have been notified by a memo dated October 26,.1987.that
the source document must be used when teaching on the Operating Manual,
Technical Specifications, USAR, or Code of Federal Regulations.
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The program initiated in April 1987 requires review and updating of lesson
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plans as new material becomes available and provides assurance this up-
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dating has occurred prior to use of the lesson plan in the class room.
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Revision Request (RR) forms are being issued to upgrade lesson plans on a
regular basis, to ensure the remainder of the lesson plans are upgraded,
and to incorporate industry events. The revision request' form is a vehicle
used to upgrade material and is described in the " Training Administrative
Manual." The RR forms are used to document that any changes made are
properly reviewed and approved.
OPPD postulates thct this program will bring and maintain lesson plans
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up-to-date.
Upgrading of lesson plans is a continuous process.
The goal
of this process is to assure a lesson plan is up-to-date prior to its use
in instruction.
Concern a.:
The licensee did not maintain an as-given training schedule. The schedule
was issued at the beginning of the week to notify appropriate individuals -
of the classes to be taught.
If, for some reason, the class was resche-
duled or the class was cancelled, no changed were made to the schedule to
reflect the actual as-given training.
Without this information, the
licensee can not establish that the training required by 10 CFR Part 55 and
the licensee's NRC approved training program was provided.
Licensee personnel stated that this concern would be reviewed and, if
appropriate, actions would be taken to establish a program to maintain an
as-given training schedule.
Resoonse:
Regulations require documentation exist to demonstrate that individuals
have received all training required by the licensee's licensed operator
requalification training program.
Presently, two systems are being used to
accomplish this objective: the OPTIM system, and a computerized tracking
system which is updated by operations training personnel on a P.C.
Using
these systems, it is possible to establish at any time, an individuals
status relative to the training program requirements. Although an as-given
training schedule can be obtained from these records, it is not utilized
since the item of interest is the individual's record relative to the
program's requirements.
Therefore, OPPD believes the current (1987)
records meet the requirements of 10 CFR Part 55 and our training program.
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Attachment 2 (Continued)
Concern h.:
The NRC inspector interviewed onshift licensed operators to verify that the
training records actually reflected the training received by each indivi-
dual.
During discussions with licensed personnel, it was determined that
the classroom attendance sheets for a lecture given on special topics in
March, April, and May 1987 had been completed, but approximately 1 month
after the attendance sheet was signed, individuals received a letter stat-
ing that the individual had missed the classroom lecture. There appeared
to be a discrepancy as to whether or not the training records correctly
reflected the individual's attendance at the lecture on special topics.
By
the end of this inspection period, the licensee had not established the
reason for the apparent discrepancy. This item remains open pending a re-
view of the discrepancy by the licensee and a follow-up review by the NRC
inspector.
(285/8713-05)
Besponse:
It is OPPD's position that the apparent discrepancy in training records was
an isolated incident which occurred during the transition to the new
records system.
The present training records system routes the completed
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attendance sheets through the appropriate training supervisor and then to a
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temporary storage location.
In the case in question, the completed
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attendance sheet became temporarily misplaced after leaving the training
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supervisor.
It is important to note that this incident did not indicate an
individual had attended a class that he had not actually attended.
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The subject inspection report also included a list of comments derived from
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Shift Supervisor, Senior Reactor Operators, and Reactor Operators. These
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comments are listed below, followed by OPPD's responses.
Comment 1:
The drawings and diagrams given as training handouts during lectures were
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unreadable.
Response:
At the request of the Training Department, a consultant reviewed the
drawings and diagrams c.ontained in the licensed operator lesson plans.
Only a very small percentage were found to be unreadable or illegible.
OPPD is upgrading drawings as the need is identified.
Comment 2:
The reference material in the training library was out of date because the
changes to the procedures were not incorporated in a timely manner.
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Response:
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OPPD presumes- t is comment is in reference to the Fort Calhoun Operating
Manual.
An fofficial copy" of applicable portions of the Operating Manual
now resides in the training library.
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Attachment 2 (Continued)
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Comment 3:
Material presented in classroom lectures was not detailed enough to provide
the instruction needed to operate the plant.
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Resoonse:
Classroom lectures were never intended to provide all knowledge and
abilities necessary for operation of the plant. On-the-job training is a
necessary and integral segment in the training program for every one of the
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different watch stations.
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Comment 4:
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Instructors were late for class and not prepared due to last minute changes
in the training schedule.
Resoonse:
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This, indeed, was occasionally a problem in the past.
However, this
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problem has been almost completely eliminated by the designation of " system
experts" and by the use of a one month. "look-ahead" training schedule.
Last minute reassignments are normally only needed in the event of sudden
illness or other unexpected absence on the part of an instructor.
Comment 5:
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Training material did not contain plant operating experience.
Response:
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This was a problem in the past. The " Training Administrative Manual" now
contains a procedure for incorporation of in-house and industry operating
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experience into training.
This procedure is being implemented and works
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well.
Comment 6:
Management has been told of concerns listed above but no apparent action
has been taken.
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Resoonse:
It is emphasized that there are very few instant cures to problems which
may exist in training. Most effective remedies take significant time and
effort to develop.
However, management is aggressively pursuing excellence
in all areas of operator training.
In order to enhance communications with
operating crews, regular meetings are now being held between Training and
the Shift Supervisors.
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