NLS8600198, Responds to NRC Re Violations Noted in Insp Rept 50-298/86-06.Corrective Actions:Training Dept Instructions Revised & Written Exams Will Be Administered Following Requalification Lectures

Responds to NRC Re Violations Noted in Insp Rept 50-298/86-06.Corrective Actions:Training Dept Instructions Revised & Written Exams Will Be Administered Following Requalification Lectures

ML20199J079
Person / Time
Site:	Cooper
Issue date:	06/09/1986
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20199J060	List: IR 05000298/1986006 NLS8600198, Responds to NRC Re Violations Noted in Insp Rept 50-298/86-06.Corrective Actions:Training Dept Instructions Revised & Written Exams Will Be Administered Following Requalification Lectures
References
NLS8600198, NUDOCS 8607080116
Download: ML20199J079 (4)

Text

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I h Nebraska Public Power District NLS8600198

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June 9,1986 bk MI3E t U. S. Nuclear Regulatory Commission Jl

_d Region IV l 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Attention: Mr. James E. Gagliardo, Chief Reactor Project Branch

Subject:

Licensed Operator & Senior Operator Requalification Training Program

Reference:

1) Letter J. E. Gagliardo to J. M. Pilant dated May 19,1986, " Request for Additional Information"

2) Letter J. M. Pilant to J. E. Gagliardo dated April 24,1986, "NPPD Response to Inspection Report 50-298/86-06"

3) Letter J. E. Gagliardo to J. M. Pilant dated March 7,1986, "NRC Inspection Report 50-298/86-06" This letter is written in response to your letter to us dated May 19, 1986 (Reference if wherein you requested further information be provided regarding our Licensed Operator and Senior Operator Requalification Training Program. Our response to each of the specific concerns is contained in the following paragraphs.

Concern Examinations had not yet been given to the two individuals associated with lecture material presented which was related to specific sections of the 1984 requalification examinations on which they had scored less than 80% correct.

Response

The two individuals in question were examined by virtue of the 1985 annual requalification examination in all areas, 8607080116 DR 860627 ADOCK 05000297 PDR klh% - - - - - - - -

Mr. Jamts E. GagH rdo Ptgs 2 June 9,1986 including those areas covered in sections of the 1984 annual requalification examination in which they had scored less than 80% correct. One individual scored less than 80% on the same section of the examination in which he had previously scored less than 80% in the 1984 examination.

With the exception that mandatory attendance at all lectures provided during the 1985-1986 Requalification Program cycle covering material associated with that specific section of the examination has been required of this individual, we believe that no further corrective action associated with the 1984 annual written examination for either of the two (2) individuals remains to be taken.

Concern Clarify more specifically the increased emphasis on administration of the written examination than " administered consistent with standard practice" as stated in Reference 2.

Response i 1

Subsequent to the inspection conducted for which a Notice of Violation (Reference 3) was written, direction was provided by the Training Manager to Training Department supervision to administer written examinations when lectures associated with requalification topics are conducted. This action has been implemented. In addition, a change to Training Department Instructions has been initiated  :

addressing this concern. As a minimum, the Training l Department Instructions will be revised by June 30, 1986,  ;

to ensure examinations are administered covering: '

a) Lecture material presented which is related to an examination category, i b) Plant abnormal and/or emergency procedures.

c) Other lecture material presented which is considered to be appropriate for examination by the Operations Training Supervisor or his designee.

It should be noted that during the incremental requalification program cycle in which the annual examination is administered, no separate written examination i (quiz) will be administered covering materials presented.

In large measure, the material presented during that particular cycle encompasses an overall review of topical areas and subject matter considered to be appropriate for a comprehensive examination. Questions pertaining to the subject matter presented will be included in at least one, if not more than one, of the annual examinations which are prepared. Note that in this legard, three (3) separate RO and SRO examinations have been prepared for the 1986

Mr. Jc. mss E. Gigliardo P gs 3 June 9,1986 annual requalification examination cycle. These examinations will be administered on three separate dates during the time frame extending from June 2 through July 11.

Concern Identify program revisions to be made to the Licensed Operator and Senior Operator Requalification Training Program more specific than the response in Reference 2,

" revise ... to more clearly delineate requirements". In that regard you specified, "the program revision should specify the maximum acceptable time from the completion of a lecture until the material covered by that lecture is covered in an examination".

Response

With respect to written examinations (quizzes) administered during the course of the requalification program, the Training Department Instructions will be revised by June 30, 1986, to require examinations to be administered during the training cycle week in which the lecture material is presented. As previously noted, no separate examination will be given during the requalification cycle in which the annual examination is administered. In the event that an individual is not present when the quiz is to be administered, the quiz is to be made up prior to completion of the next incremental requalification program cycle. Note that these incremental cycles are now six (6) weeks in length to account for an Operations Department six (6) week rotating shift schedule.

In Reference 2, we indicated that we planned on delineating more specifically the requirements of our Licensed Operator and Senior Operator Requalification Training Program in a future submittal to the NRC. Presently, all of our Operator Training Programs, including the Requalification Program, are being evaluated by INPO in preparation for accreditation. The INPO Accreditation Field Team visit will be completed during the week of June 2. Consequently, we believe that any further delineation (clarification) of program requirements, save for the above should be deferred until completion of INPO's evaluation. We trust that you will find this to be a prudent course of action on our part and one that is consistent with program development in a systematic, organized fashion. We continue to anticipate full INPO accreditation of our Operator Training Programs during the fall of 1986.

Consequently, we believe submittal of our revised program description to the NRC by December,1986 to be a realistic ,

goal. '

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1 Mr. Jem:s E. G:gliardo Pag 3 4 June 9,1986 j 1

If you should require further information regarding our Licensed l Operator and Senior Operator Requalification Training Program,  ;

please contact us. '

Sincerely, J. M. Pilant Technical Staff Manager Nuclear Power Group JMP:DLR:eaj/lb/lk9/4(9B)

~-

GENERAL OFFICE Nebraska Public Power District * "?EtEM0%*0S#s*0^ea^"*"

S CNSS860300 April 24,1986 i 1

gy - 51985 2

Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV

. 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to Inspection Report 50-298/86-06

Dear Mr. Gagliardo:

This letter is written in response to your letter dated March 7, 1986, transmitting Inspection Report 50-298/86-06. Therein you indicated that one of our activities was in violation of NRC requirements.

Following is a statement of the violation and our response in accordance with 10CFR2.201.

Statement of Violation Failure to Follow the Requalification Training Plan 10 CFR Part 50.4(1-1), states, in part, "Notwithstanding the 3

provisions of 50.59, the licensee shall not, except as specifically authorized by the Commission, make a change in an approved operator requalification program by which the scope, time allotted for the program for frequency in conducting different parts of the program is decreased." The licensee's approved requalification training program requires that individuals who score less than 80% correct on a section of the annual requalification examination, attend lectures pertinent to that section and that written examinations covering the lecture material presented be given.

Contrary to the above, two individuals who had scored less than 80% on specific sections of the 1984 requalification examination were not given written examinations as required by the approved requalification training plan after lectures, which they were required to attend because of low scores on the annual l requalification examination.

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. Mr. J. E. Gagliardo April 24,1986 Page 2 This is a Severity Level IV violation (Supplement I.D)

(50-298/8606-02).

Reason for Alleged Violation This alleged violation was discussed at length during the course of the Inspection. The problem was clearly due to a difference in interpretation of our approved Operator and Senior Operator Requalification Program description. In Section III,

" EVALUATION", paragraph B, the requirement is stated as follows: - -

" Written examinations shall be given covering material presented in the requalification program lecture series."

. We do not believe that this statement should be interpreted to mean that a written examination is to be administered after each lecture. Hence, the reason for this alleged violation is due to a difference in interpretation of requirements specified in the CNS program. However, we do recognize that as a matter of standard practice, written examinations (quizzes) administered after a series of lectures is an expected evaluation method of training program effectiveness. In these instances cited, this was not done.

Corrective Steps Taken and Results Achieved While we do not believe that our Licensed Operator Training Program requirements were violated, we do recognize that in these cases cited, the normal sequence of exam administration was not followed. To date, increased emphasis has been taken to insure that written examinations (quizzes) are administered consistent with standard practice.

Corrective Steps Taken to Avoid Further Violation It is our intent to continue administering quizzes covering lecture material presented subsequent to the lecture series conducted. However, recognizing that the approved program as written lends itself to misinterpretation, the District intends to revise the existing Program description to more clearly delineate requirements.

Date When Full Compliance Will Be Achieved CNS is in full compliance with our stated Program requirements.

l Resubmittal of the Program description to clarify requirements shall be completed no later than 60 days after receipt of accreditation of these programs. This action is expected to be completed prior to December,1986.

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. Mr. J. E. G glirrdo April 24,1986 Page 3 Should you have any questions regarding this response, please contact me.

Sincerely ,

M J. M. Pflant Technical Staff Manager Nuclear Power Group JMP:DLR:JVS:dmr24/4(Y1)

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