IR 05000298/1987005

Insp Rept 50-298/87-05 on 870209-12.Violation Re Failure to Perform Manipulations on Plant Controls Will Be Considered Unresolved Item,Per Commission Policy.Major Areas Inspected: Operator & Requalification Training Programs

ML20212G463
Person / Time
Site:	Cooper
Issue date:	02/27/1987
From:	Harrell P, Hunter D, Jaudon J, William Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212G442	List: IR 05000298/1987005 ML20212G436
References
50-298-87-05, 50-298-87-5, NUDOCS 8703050352
Download: ML20212G463 (8)

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, APDENDIX l

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

' . NRC Inspection Report: 50-298/87-05 License: DPR-46 Docket: 50-298 Licensee: Nebraska Public Power District P. O. Box 499

. Columbus, NE 68601 Facility Name: Cooper Nuclear Station Inspection At: Cooper Nuclear Station, Brownville, Nebraska Inspection Conducted: February 9-12, 1987 Inspectors: _ M W.B.~ Jones,RysidentInspector 2- 23 $fl Date

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.Q or ResToent Inspector Date Approved:

_ d R. Hunter, Chief Project Section B,

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Inspection Sunanary Inspection Conducted February 9-12, 1987 (Report 50-298/87-05)

Areas Inspected: Routine, unannounced inspection of the licensed operator and requaltrication training program and the nonlicensed staff training progra Results: Withinthetwoareasinspected,onepotentialviolation(failureto perform manipulations on plant controls, paragraph 3) was identified. In accordance with Comission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147), this potential violation will be treated as an unresolved item.

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DETAILS Persons Contacted Licensee Personnel

• Horn, Division Manager of Nuclear Operations

• Drier, Training Program Development Supervisor

• J. Dutton, Training Manager

• J. Meacham, Senior Manager, Technical Support

• T. Sander, R0/SP0 Instructor NRC Personnel

• D. DuBois, Senior Resident Inspector, Cooper Nuclear Station

• P. Harrell, Senior Resident Inspector, Fort Calhoun Station

• Jones, Resident Inspector, River Bend Station

• E. Plettner, Resident Inspector, Cooper Nuclear Station

• Denotes those present during the exit interview on February 12, 198 The NRC inspectors also contacted other plant personnel during this inspectio . Licensed Operator Initial Training The NRC inspectors reviewed the initial licensed operator training program to verify that the program being implemented by the licensee complied with the licensee's NRC-approved training program and 10 CFR Part 5 During performance of this review, the NRC inspectors verified that the following program elements were properly implemented by the license . Lectures required by the licensee's NRC-approved training program were attended

. Simulator training center certification of training was completed

. Required time onshift was performed

. Records were maintained by the training department to document participation by each licensing candidate in the above activitie Based on the review performed by the NRC inspectors, it appeared that the licensee was implementing an effective Itcensed operator initial training progra During 1986, all individuals put up for examination by the licensee passed their initial examination to obtain their operator licens No violations or deviations were. identifie .

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3. Licensed Operator Requalification Program The NRC inspectors reviewed the licensed operator requalification program to verify that the program being implemented by the licensee complied with the licensee's NRC-approved training program and 10 CFR Part 55. During performance of this review, the NRC inspectors verified that the following program elements were implemented by the licensee:

. Preplanned lectures required by the licensee's NRC-approved training program were given to the operating staff in each 2 year requalification progra . All licensed personnel reviewed emergency and abnormal operating procedures annuall . Documentation was available to indicate that operations and staff supervision personnel (licensed individuals not assigned to an operations crew) reviewed facility design changes, procedure changes, facility license changes, and abnormal and emergency operating procedure . All licensed individuals who failed the annual written examination were placed in an accelerated requalification progra . All licensed individuals who scored low in any particular category were required to attend appropriate lecture . All licensed individuals received on-the-job training as specified by the licensee's NRC-approved training progra . Each licensed operator completed an annual requalification examination prepared by the licensee or the NRC,

, Records were maintained by the training department to document participation by each licensed operator in the above activitie The licensee's NRC-approved training program was established by the licensee in a letter to the NRC dated October 1, 1980. The program was later amended by a letter dated June 1, 1981, to upgrade the training program to include training for mitigation of core damage. The requirements in the above letters were provided by the licensee in Section 3.4 of Volume XIII to the Updated Safety Analysis Report (USAR).

This USAR section provides the requirements for maintaining a training program that complies with the NRC-approved program. The NRC inspectors reviewed the requirements stated in the USAR versus the requirements made in letters sent to the NRC. No problems were noted between the program requirements provided in the USAR and the requirements of the NRC-approved program. The NRC inspectors also verified that the USAR requirements were being properly implemented in the current training progra . . . .

During review of implementation of the program, the NRC inspectors noted that the licensee had not implemented all the requirements established by the program. Paragraph 3.a of Appendix A to 10 CFR Part 55 requires that on-the-job training be provided that includes manipulation of plant controls. Section 3.4.1.2.8 of Volume XIII of the USAR, dated July 22, 1984, states that the control manipulations listed in Table XIII-4-1 are acceptable for meeting the reactivity control manipulations required by 10 CFR Part 55. Table XIII-4-1 states that the loss of instrument air and the loss of service water be included as required manipulations. However, the licensee has not included these two activities as manipulations in their training program. The failure to include the loss of instrument air and the loss of service water as manipulations is a potential violation of 10 CFR Part 55. This potential violation is considered to be an unresolved ite (298/8705-01)

In discussions with licensee personnel, it was determined that the simulator used by the licensee is not capable of simulating the two manipulations. The licensee has instituted a program of individual self study for these manipulations as a substitute for actual hands-o performance on the simulator. However, the licensee has not submitted a revision of the training program to the NRC for approval of this s substitution. Licensee personnel stated the revision to the training program would be submitted to the NRC in March 198 The NRC inspectors also reviewed the 1985 (Audit 85-01) and 1986 (Audit 86-07) training audits performed by the onsite quality assurance (QA) grou This review indicated that Audit 85-01 had noted that the training department was not timely in taking corrective actions in response to QA findings. Audit 86-07 determined that the training department had taken appropriate ccrrective action to ensure responses were timely and adequately addressed the identified problem areas. No other major problems were identified in the audit Although the NRC inspectors did not attend any training classes, the NRC inspectors reviewed selected lesson plans used for classroom instructio The lesson plans included nuclear pressure relief and core spray system The review was performed to verify the technical content was accurate and the lesson plan material adequately covered the subject. No problems were noted during the revie The licensee is currently in the process of receiving accreditation from the Institute of Nuclear Power Operations (INPO). The licensee made a presentation to the INPO Board of Accreditation in December 1986; however, due to management changes made in the licensee's training organization in November 1986, the INPO Board opted to wait until May 1987 to evaluate the training program for possible accreditation. The delay was established to allow the training program to function under the new management organization prior to the Board making a final decision on program accreditatio ,

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Based on the results of review performed by the NRC inspectors, it appears that the licensee was implementing an effective training program. The pass rate for the requalification examinations administered by the licensee and the NRC for 1986 was 100 percen No violations or deviations were identifie . Nonlicensed Staff Training The NRC inspectors reviewed the nonlicensed staff training program to verify the program was being implemented in accordance with the requirements of Technical Specification 6.1.4, ANSI 18.1, and Section 3.3.3 of Volume XIII to tha USAR. The review included examination of training records, discussions with personnel, and a review of the training material used in the classroom. The review also included verification that personnel within specific disciplines had reviewed surveillance tests, equipment repair procedures, system operating procedures, and emergency and abnormal operating procedures, as appropriat The NRC inspectors reviewed the qualifications and training of personnel within the disciplines listed below. The number in parenthesis indicates the number of training records reviewe . Shift technical advisors (7)

. Electricians (6)

. Chemistry technicians (5)

. Instrumentation and control technicians (5) .

. Mechanics (7)

Based on the review performed by the NRC inspectors, it appeared that the individuals working in the disciplines identified above are receiving appropriate training. This determination was based on review of the functions and responsibilities performed by the individual within the selected discipline. In one case, the training record for an individual employed less than 6 months was reviewed and it appeared that the initial training provided to the individual was adequate for his assigned dutie In Septemoer 1986 the licensee submitted a self-evaluation report to INP0 for review. INPO is presently expected to visit the site to review the seven categories of nonlicensed operator training for possible accreditation in June 198 No violations or deviations were identifie . .- . . -- - _ _ - - - - . _ -

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,. Inspector Observations l During review of documentation and discussions with licensee personnel, l the NRC inspectors made the following observations:

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. As allowed by the licensee's NRC-approved training program, one licensed individual was exempted from taking the requalification l examination in 1986 as the individual prepared the licensee's l requalification examination. However, the individual's training file l

did not contain any documentation addressing the reason for exemption from taking the examination. Licensee personnel stated l documentation would be provided in the individual's training flie, i

l . A program had'not been established to ensure that an individuals

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scoring between 70 and 80 percent in the same category in successive years received individualized training in the category. Licensee i personnel stated that such a program was under development and would j be added to the overall training program in the near futur . Training records for the current year's activities were stored in a file cabinet that did not have a one-hour fire rating. Licensee

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personnel stated that the records would be moved to an appropriate storage cabine . If an individual scores between 70 and 80 percent in a category, the licensee does not provide additional specific instruction in the category during the following requalification training year. The ifcensee requires only that the individual attend whatever classes have been scheduled. Typically, one or two classes are given in a category during the following requalification training yea . The licensee has not updated the USAR or NRC-approved training program to reflect the organizational changes made in the training department in November 198 The licensee stated the USAR would be updated during the next scheduled revision. As previously stated, i the NRC-approved training program is scheduled to be updated in March 1987.

, The observations listed above are not violations, deviations, or

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unresolved items. These items were noted for licensee consideration for program improvement and do not have a specific regulatory requiremen . Unresolved Item An unresolved item is a matter that requires additional information for determination whether it is acceptable, a violation, or a deviation. One unresolved item is discussed in paragraph 3 of this repor Item Subject 298/8705-01 Failure to provide control manipulations l

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, Exit Interview -

~The NRC inspectors met with Mr. G. R. Horn (Division Manager of Nuclear Operations) and other members of the licensee staff at the end of this inspection. At this meeting, the NRC inspector summarized the scope of

the inspection and the findings.

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