IR 05000245/1993028
| ML20058F372 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/16/1993 |
| From: | Conte R, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058F364 | List: |
| References | |
| 50-245-93-28, 50-336-93-23, 50-336-93-28, 50-423-93-25, 50-423-93-28, NUDOCS 9312080090 | |
| Download: ML20058F372 (39) | |
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U.S. NUCLEAR REGULhTORY COMMISSION
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REGION I
REPORT NOS:
50-245/93-28, 50-336/93-23, 50-423/93-25 FACILITY DOCKET NOS:
50-245, 50-336, 50-423 FACILITY LICENSE NOS:
DPR-21, DRP-65, NPF-49 LICENSEE:
Northeast Nuclear Energy Company P.O. Box 270 Hartford, CT. 06141-0270 FACILITY:
Millstone Units 1,2 and 3 INSPECTION AT:
Waterford, CT. and Region I Office INSPECTION DATES:
October 4-8 and November 1-4, 1993 INSPECTORS:
J. H. Williams, Senior Operations Engineer S. L. Hansell, Operations Engineer 0[f3 INSPECTOR:
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/. H. Williams, Sr. Operations Engineer Date WR Section, Operations Branch, DRS
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APPROVED BY:
Richard J. Conte,JIfiicf Date BWR Section, Operations Branch, DRS
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i INSPECTION SUMM ARY: Inspection conducted October 4-8 and November 1-4, 1993 (Inspection Report Nos. 50-245/93-28, 50-336/93-23, 50-423/93-25)
AREAS IN_SPECTED: A regional initiative safety inspection was conducted of the Millstone l
l Unit I licen.ed operator requalification training (LORT) program by observing facility
administered examinations and reviewing examination matedals.
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In addition, facility commitments and certain open items for all 3 units were reviewed and discussed with appropriate personnel to determine their current status. Those items that were
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still open were evaluated to assess their effect on a licensed operator requalification training (LORT) program satisfactory determination at Unit 1.
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RESULTS: Based on this inspection the training and evaluation oflicensed operators is adequate to assure safe plant operations.
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i The facility administered annual requalification examination was challenging and objective.
l Improvements were noted in the operator performance standards and examination materials.
j The renewed emphasis on training and higher standards has resulted in improved operator
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and plant performance.
A number of facility commitments and open items that affect a satisfactory LORT program determination were found to be satisfied and closed in this report. Residual open issues are i
summarized in Section 2.2.
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DETAILS 1.0 INTRODUCTION in September 1991 and again in September 1992, the NRC found the licensed operator requalification training program at Millstone 1 to be unsatisfactory. As a result, Region I
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initiated additional inspections of the Licensed Operator Requalification Training (LORT)
program to assure high quality training of licensed operators with respect to continued safe plant operations. (See Attachment 1)
The licensee provided corrective actions associated with the 1991 and 1992 unsatisfactory LORT program determinations and the NUREG-1220 training inspection (93-80). These corrective actions were discussed in numerous facility letters identified in Attachments 3 and
4 and in letters dated September 3,1993, and October 19, 1993. Additional corrective actions were provided in the enforcement conference on July 1,1993 (EA No.93-130) and the response to the subsequent notice of violation by a letter dated October 19, 1993.
The purpose of this inspection was to review corrective actions and determine if those
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remaining open had any bearing on an LORT program satisfactory determination and (2)
review the LORT annual examinations given by the facility to determine if they met NRC examiner standards.
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2.0 SUMMARY OF MAJOR FINDINGS / CONCLUSIONS
2.1 Examinations and Evaluations (Section 3)
All portions of the exams administered the week of October 4th met the NRC
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examiner standards, Revision '.
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The scenarios were challenging and required the crews to make safety significant e
decisions.
The facility evaluators were objective, provided good assessments of operator e
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During the walk-through portion of the exam, the operators displayed a consistent use
of the "self-check" practice when performing steps in the procedure.
Written exam questions were at a higher level of knowledge compared to the 1991 e
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annual exam.
The emphasis on training and higher standards has resulted in improved operator e
performance.
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2.2 Corrective Actions (Section 4)
A number of corrective actions and other open items are closed and discussed in this report.
The corrective actions associated with the LORT program that remain open are:
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Unresolved item No. 245/336/423//93-80--01: Adequacy of facility policy for conducting LORT on a continuous basis (section 4.2.1)
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Deviation No. 245/93-80-03: Actions to improve the quality and tracking of
commitments (4.2.3)
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Inspector Follow Item (IFI) No. 245/336/423//93-80-09: Establish control measures
to address training on important or significant events, procedure changes, or license j
amendments when an immediate need occurs. Also, for Unit 2, assurance that the LORT for active and inactive licensed operators is the same (section 4.2.9).
IFI No. 245/93-28-01: Train instructors and training management in leadership skills
and techniques needed to influence the behavior and performance of others (section
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e IFl No. 336/423//93-28-02: Use of advanced training techniques at Units 2 and 3 (section 4.2.16).
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IFI No. 245/93-2.8-03: Training procedure changes (section 4.2.20)
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- IFI No. 245/93-28-04: Organizational commitments (section 4.2.21)
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IFI No. 245/93-28-05: Provide assurance that the minimum acceptable knowledge
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level of operators will not be lowered by use of CWT (section 4.2.25).
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IFI No. 245/91-26-01: Residual item - provide assurance that the minimum crew composition will include 3 ROs (section 4.2.26).
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Violation No. 245/93-04-01: Failure to audit Unit I LORT program (section 4.2.27).
These open items, in a number of cases, involve Units 2 and 3 rather than Unit 1. The open
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items applicable to Unit I are not significant enough to adversely affect a satisfactory LORT
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program determination.
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3.0 OBSERVATIONS OF EXAMLNATION AND EVALUATIONS
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3.1 Scope The scope of this inspection was to perform an independent review of the licensed operator requalification annual examination process. The review included observations of the dynamic simulator scenarios, job performance measures (JPMs), and written exams administered to operating and staff crews. The inspection focused on the facility evaluators' performance,
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quality of examination material and performance of the licensed operators. The facility's exam materials were compared to the NRC examiner standards (NUREG 1021, Revision 7).
A list of the simulator scenarios, JPMs, and written exam identifiers is provided in Attachment 2 of this report.
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3.2.1 Dynamic Simulator Scenarios
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Two simulator scenarios for the operating crew and one for the staff crew were observed.
The scenarios were challenging and required the crews to make safety-significant decisions.
The scenarios met NRC examiner standards criteria for quality and quantity of equipment malfunctions, procedure use and crew critical tasks.
Overall, the crews' performances were good, and all critical tasks were accomplished I
satisfactorily. There was one isolated case of a senior reactor operator (SRO) transitionmg down the wrong leg of an emergency operating procedure. The SRO's action did not impact
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the safe operation of the plant during the simulated plant event. The operators frequently
checked their control panels and backed up each others' actions during the scenarios. The (
operators displayed good teamwork skills.
The facility evaluators administering the examinations included the Operations Manager and l
training department personnel. The evaluators were objective, provided good assessments of
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operator performance, and were professional throughout the exam process. After each simulator scenario, the evaluators conducted a thorough critique of operator performance.
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The crew and individual evaluations were examples of how the facility holds the operators to l
high standards of performance.
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i The simulator scenarios used during the week of October 4th were comparable to the ones
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administered during the NRC examination of September 13 - 17, 1993. A review of all the
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scenarios administered for the 1993 annual exams indicated that they were consistent with NRC examiner standards.
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3.2.2 Job Performance Measures (JPMs)
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The JPMs used for the examination covered both normal and emergency tasks. The format
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and content of each JPM met the NRC examiner standards for quality and appropriate critical
tasks.
The operators followed plant procedures associated with the JPMs and executed all critical steps correctly. There were three JPMs performed using the plant simulator and two JPMs simulated in the plant. The operators displayed a consistent use of the"self-check" practice
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when performing steps in the procedure.
The facility evaluators provided the proper amount of feedback to the operators without aiding the operators' ability to complete the JPM successfully. The JPMs were well coordinated and operators did not impact each other during the exam.
I The JPMs used the week of October 4th were comparable to those administered in prior
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1993 exams. The selection of the JPMs used for the exam was appropriate for the training administered.
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3.2.3 Static Simulator and Written Examinations The inspector observed the static simulator exam given to the operating crew. The exam was administered on a frozen simulator after a major transient occurred. The confidence weighted test (CWT) method was used for the static and written exams. CWT exam
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questions have three distractors compared to four distractors used on NRC-administered exams. The facility had not completed grading of the written exams at the time of the exit.
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The exam questions met the criteria in the NRC examiner standards with the exception of differences due to CWT methodology. The exam questions were written at a higher level of
knowledge compared to the 1991 annual exam. This was the result of the facility's effort to upgrade-the written exam bank. Written exam questions were appropriate for the sample plan.
To reduce the chance of exam compromise, each operator had his own copy of the reference material and a proctor was available for the entire exam.
3.3 Conclusions All portions of the exams administered the week of October 4th were comparable to the examinations administered by the NRC.
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The facility administered annual requalification examination was challcnging and objective.
Improvements introduced by the Project Team were evident in the higher operator performance standards and better examination materials. The emphasis on training and higher standards has resulted in improved operator performance.
4.0 CORRECTIVE ACTIONS 4.1 Scope Selective corrective actions associated with the 1991 and 1992 unsatisfactory requalification i
program determinations and the NUREG-1220 training inspection were reviewed. These corrective actions were discussed in numerous facility letters identified in Attachments 3 and 4 and in letters dated September 3,1993, and October 19, 1993. Additional corrective actions were described at the enforcement conference (EC) on July 1,1993 and restated in the reply to notice of violation dated October 19, 1993. These corrective actions were discussed at a meeting with the licensee on August 4,1993, and documented in NRC Inspection Report No. 50-245/93-25, Attachment 4, as training commitments. Items identified with EC numbers relate to corrective actions from the enforcement conference. A
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review was conducted to determine how each open item affected a satisfactory determination for the Unit 1 LORT program.
j 4.2 Findings 4.2.1 10 PEN) Unresolved item No. 245/336/423//93-80-01: Corporate Poliev For Conductine LORT On A Continuous Basis The adequacy of the facility policy for conducting license operator requalification training (LORT) on a continuous basis as required by 10 CFR 55.59(c)(1) is being reviewed within the NRC. The stated policy is to conduct a minimum of 12 cycles (6 week periods for each cycle) in a two year period. The Operator Licensing Branch of NRR is reviewing the adequacy of this policy. This item was not specifically reviewed during this inspection and is listed here for completeness. The open item does not adversely affect LORT program
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satisfactory determination, since 12 or more of a possible 17 cycles in a two-year period are dedicated to licensed operator training.
4.2.2 (CLOSED) Violation No. 245/336//93-80-02: Failure of Some Licensed Operators to Attend or Make Un LORT Trainine by the End of the LORT Cycle.
This violation applied to Units 1 and 2. The Notice of Violation was issued September 20,1993, and the facility responded by letter dated October 19,1993. The
i licensee provided corrective actions at the July 1,1993 enforcement conference and in their October letter. They certified compliance with the regulations as of April 1993 for Unit I and as of June 1993 for Unit 2 in their October letter. These corrective actions are discussed J
below.
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Licensed operators who were delinquent in their 1991/1992 LORT program attendance have completed the LORT program requirements. This item was reviewed in the NUREG-122.0 inspection (93-80).
Facility management clarified their policy on LORT program attendance and established a 12-wcek time limit to make up missed training. Provisions regarding the timeliness for makeup of missed simulator training were also established. A training program
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implementing procedure (TPIP) common to all LORT programs was developed and contains i
appropriate attendance requirements. The inspector reviewed this procedure (NTM 3.080, dated September 27,1993) to verify that it included the requirements.
In addition, the Millstone Station Vice President's memorandum to all licensed operators expresses strong support for the necessity of attending LORT.
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Also, the licensee committed at the enforcement conference to track LORT attendance in matrix form and to provide the matrices to each unit director and operations manager on a monthly basis (EC-21). Operator Training Branch Instruction (OTBI)-18 requires attendance information to be included in the monthly report described by OTBI-5. OTBI-5 was revised to include unit directors and operations managers on the distribution list for these monthly
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reports. The inspector reviewed several copies of the monthly report for the attendance matrix and distribution to verify implementation of the corrective action.
This item is closed.
4.2.3 (OPEN) Deviation No. 245/83-80-03: Deviations from Commitments Three deviations from 1991 corrective actions were described in NRC Inspection Report (IR)
93-80. Two of these deviations were: formalize policy of management observations of j
simulator performance, and develop written standards of performance. Both issues involved -
not meeting commitment dates. The commitments were met at a later date as described in 93-80.
The third deviation related to a commitment to video tape routine training. The facility letter J
dated April 27,1993, indicated that videotaping was to be used for remediation and j
evaluation sessions. The specific deviations described in IR 93-80 have been satisfied. The
facility letter of October 19, 1993, describes additional corrective actions for meeting future commitments. These actions include: (1) improving the quality of commitments; (2)
improving the procedural tracking of commitments; and (3) periodic management review of the status of LORT commitments,
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These corrective actions are considered enhancements to the program and are not directly related to a satisfactory LORT program determination. However, this area remains open pending NRC staff verification of these actions. The licensee also reported that a new system will be operational by November 1,1994, under the Performance Improvement Program.
4.2.4 (CLOSED) Unresolved Item No. 245/93-80-04: Revise LORT Exam Bank The facility committed in letters dated 11/8/91 and 12/7/92 to revise the LORT exam question bank to address use of higher cognitive level questions. This item was unresolved pending NRC review of the exam bank. Approximately 300 of the 702 total questions were reviewed in this inspection. The questicns met the NRC examiner standards criteria contained in ES-602 and were written to a higher cognitive level. Three minor errors were noted and brought to the attention of training personnel. No errors were noted in questions used on the exam for this inspection week. The facility has developed an acceptable exam bank with higher cognitive level questions.
Additionally, the licensee committed to review, revise, or develop 150 written examination questions per year as specified in NRC Examiner Standard ES-601 and have at least 350 acceptable questions per type by December 7,1993 (EC-27). The questions reviewed met the criteria in ES-602 and were written to the comprehension or analysis level of knowledge.
This item is closed.
4.2.5 (CLOSED) Unresolved Item No. 245/93-80-05: Revise TPIP To Address Hich Level Of Operator Proficiency By letter dated 11/8/91, the facility committed to revise the training program implementing procedure (TPIP) to address a high level of operator proficiency. NTM 3.028 was revised to meet this commitment; however, the NUREG-1220 inspection (IR 93-80) concluded that the changes made were not effective based upon the fact that a second unsatisfactory requalification program determination occurred. The item was unresolved pending an effectiveness review of the additional changes made to NTM 3.028.
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NRC effectiveness reviews included the mid-year facility examinations (IR 93-15), the NRC quarterly training inspections (IR 93-04 and IR 93-17), J.e NRC-administered requalification examination (IR 93-25), and this inspection. Based upon these reviews, this item is closed.
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4.2.6 (CLOSED) Inspector Follow Item (IFD No. 245/93-80-06: Simulator Evaluation Criteria A facility commitment made by letter dated 11/8/91 was to develop and convey simulator evaluation criteria to operations training personnel. The criteria were to define the standards
l and expectations of operations management. Inspection Report 93-80 indicated that, for weekly evaluations, the criteria were not clearly defined for individual performance in a crew setting with respect to actions taken for unsatisfactory or unsafe performance.
OTBI-20, Rev. 2, contains the standards and expectations of operations management. It also
contains evaluation criteria and defines unsatisfactory performance. NTM 3.080, LORT Program Implementing Procedure, section 6.4.9, requires any individual who is unsatisfactory on a Progress Review (weekly exam) to be removed from licensed duties and
complete all actions specified in his individualized training program prior to resuming licensed duties. NTM 3.080 is the new common LORT program procedure that replaced
NTM 3.028.
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An enforcement conference commitment was to revise simulator training and evaluation tools
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to provide specific standards and expectations of operations management (EC-29). Revised OTBI-14, section 6.4, contains specific simulator scenario guidance that meets or exceeds the
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NRC examiner standards criteria. All simulator exercise guides in the simulator scenario bank were updated to the new criteria contained in OTBI-14. OTBI-20 was revised to
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include standards and expectations of operat'.ons management for dynamic simulator training.
Based upon the review of the revised procedures, this item is closed.
4.2.7 (CLOSED) IFI No. 245/93-80-07: Pass / Fail Criteria For Simulator Evaluations l
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The facility committed by letter dated 11/8/91 to develop definitive criteria to be used during
examinations to determine success or failure of individuals and crews. Procedure NTM
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3.028 was revised to require remediation if a weekly simulator evaluation is unsatisfactory, l
but did not require removal from licensed duties. During the NUREG-1220 inspection, the
facility committed to revise NTM 3.028 to require operators assessed as unsatisfactory or
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unsafe to be remediated and reexamined before returning to licensed duties.
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Another enforcement conference commitment was to revise NTM 3.028 to require that
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operators assessed as unsatisfactory or unsafe be prohibited from returning to licensed duties.
until remedial training and reexamination can be completed (EC-30). NTM 3.080 requires that operators assessed as unsatisfactory or unsafe be remediated and satisfactorily retested -
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This item is closed.
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4.2.8 (CLOSED) Violation No. 336/423//93-10-08: Failure To Conduct Audits Of Ooerator Trainine Procrams For Unit : 2 and 3
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This was a violation of "iRC requirements associded with failure to conduct audits of operator training programs as required. This item. number applies to MP2 and MP3 and not
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MP1, since a previous violation (see section 4.2.27) was cited for Unit 1. The licensee provided corrective actions at the July 1,1993, enforcement conference and in their letters of April 5,1993, and October 19, 1993. The October 19, 1993, letter certifies compliance vrith
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applicable regulations. These actions are discussed below.
Audits for the Units 2 and 3 LORT programs have been completed.
The letter dated October 19,1993, describes a corrective action to revise the appropriate procedure. Also, the NNECo procedere for audits (NEO-3.01), was revised to require
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audits of the operator training and requalification programs at least once every two years (EC-13).
At the enforcement conference, the licensee committed to conduct cross unit evaluations of operator training programs (one operator training program will be audited quarterly) (EC-10). Based upon a review of the 3rd-quaner self-assessment dated 9/8/93, precedure NTDD-
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I 26, "Self-Assessments," dated 9/1/93, the planning outline for the 4th quarter assessment, and discussions with training management, this commitment is being met.
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In addition, the licensee committed to assess the QSD audit matrix to see if any other
deficiencies exist regarding insufHcient audits of other organizations (EC-23). The QSD audit matrix was assessed and revised to eliminate noted deficiencies.
This item is closed.
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4.2.9 (OPEN) IFI No. 245/336/423//93-80-09: Proeram Weaknesses Three program weaknesses were identified as common to all three units. In addition, MP2 and MP3 each had one individual weakness described. The facility letter dated 9/3/93, responded to the described weaknesses.
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Common Weaknes es (OPEN) Trainine on an immediate Need Basis Control measures did not address how training for important or significant events, procedure changes, and license amendments is given when an immediate need occurs. Programmatic
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i changes, in distinction to changes in the Document Acknowledgement System (DAS), to address this issue are being developed and planned for implementation by
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December 1,1993. As an interim measure, the Station VP has issued guidance to improve
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the effectiveness of the DAS process. The DAS process is used to route selective important information to the operators. The item will remain open and will be reviewed when licensee
actions are cor.'pleted.
l This weakness did not directly contribute to the unsatisfactery performance at Unit 1. This j
open item does not adversely affect a satisfactory LORT program determination.
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(CLOSED) Root Cause Analysis
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Control measures did not address when a root cause analysis for major training deficiencies
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is to be conducted and the extent of such an analysis. Procedure NEO 2.38, " Nuclear l
Assessment Program," dated June 27,1993, establishes thresholds for conducting a root
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cause analysis and provides guidance on the analysis. This item is closed.
(CIX) SED) Examination Ouestion Repeatability
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Control measures did not address the number of examination questions previously used during LORT from being used again on annual or biennial written examinations. NTM
3.080, section 6.4.5.6, addresses question repeatability. The requirement includes review of i
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of, mated test items is no greater than the fraction of the entire exam bank used during the LORT program. For exaraple, if 10 percent of the question bank is used during LORT, then i
the repeated questions on the exam would be no greater than 10 percent. This item is
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closed.
MILLSTONE UNIT 2 Weakness (OPEN) LI)RT For Active versus Inactive Licenwd Operators
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The MP2 LORT program distinguished training for active versus inactive licensed operators.
I Two examples of this practice were described in IR 93-80. One involved training for
refueling and the other involved shutdown risk management procedure implementation. The l
facility committed to more carefully assess the appropriateness of including items selected to
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meet specific plant needs within the LORT program. This item is open pending review of
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the effectiveness of the actions taken. This is a Unit 2 item and does not affect a Unit 1
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E satisfactory LORT program determination.
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MILLSTONE UNIT 3 Weakness
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MILLSTONE UNIT 3 Weakness (CLOSED) Freauency of Evaluation of Operator Proficiency
l There was no programmatic requirement for MP3 to assess operator proficiency in a written l
i form more frequently than annually. NTM 3.080 requires periodic written examinations.
Paragraph 6.4.3 of NTM 3.080 states that progress exams shall be given each training week.
Paragraph 6.4.4 requires written exams at least twice each calendar year. This item is
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4.2.10 (CLOSED) SOER 92-01 Evaluation For Units 2 and 3 The facility committed to assess the contents of SOER 92-01 regarding self-checking for
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training on the other Millstoae units in the letter of 12/7/92. This item was discussed in section 7.7 of IR 93-80 for MPl. The facility has developed the " STAR" (Stop-Think-Act-Review) program for self-checking at Millstone. This program appears to be well developed i
and carefully planned. The facility has provided training on the " STAR" program and plans
'1 to provide training on self-checking to all workers at the Millstone site. This item is closed.
July 1.1993. Enforcement Conference Commitments as Documented in Insocction Report No. 245/93-25. Atladuntnt 4 4.2.11 (OPEN) IFI No. 245/93-28-01: Leadershio Traininn The facility committed to train instructors and training management in leadership skills and techniques needed to influence the behavior and performance of others (EC-1).* Three pilot courses have been conducted. This training has been given to approximately twenty individuals; however, only one MP1 instructor has been trained to date. This item is open until the training is given to MP1 training management and selected instructors. Training personnel have performed adequately during all NRC evaluations after the first program failure in 1991.
This open item is considered a long-term enhancement which does not adversely affect an LORT program satisfactory determination.
4.2.12 (CLOSED) Conduct Workshops l
The facility committed to conduct workshops for operations managers and supervisors of l-operator training in the following areas: lessons learned from the Project Team, leadership, feedback, TPCC role, standardization, and evaluation (EC-2).
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reviewed, and the workshop was discussed with training management. Based upon the review and discussion, this commitment was met and the item is closed.
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4.2.13 (CLOSED) Shift Suoervisor input To Individualized Simulator Trainine-l The facility committed to provide expanded, individualized simulator training, based upon shift supervisor input, to strengthen crew performance (EC-3). The commitment is to be
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proceduralized so that it will be identified as necessary input to the LORT curriculum.
Based upon discussions with training management, shift supervisor input is provided each i
six-week cycle. NTM 3.080, section 6.2.2.6, addresses shift supervisor input for planning
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topics for the next two year LORT cycle. This item is closed.
j 4.2.14 (CLOSED) Common Conduct Of Operations Procedure The facility was to implement the Millstone Station Conduct of Operation Procedure (EC-4).
The common Millstone conduct of operations procedure (OP 276/2276/3276, Rev 1) was implemented on July 19, 1993.
The facility was to complete initial discussions between operations management and their
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crews regarding the implementation of the conduct of operations procedure (EC-5).
Discussions between operations management and their crews were completed as documented i
in memoranda from each unit manager to the Station VP.
This item is closed.
4.2.15 (CLOSED) Remediate Students ( Applicable to MPl) Remediate students in LORT who score below 90 percent (EC-6)-
Millstone Unit I uses con 5dence weighted testing (CWT). NTM 3.080 section 6.4.2.4,
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requires students who score below 90 percent on a CWT be remediated. Students who score less than 80 percent are removed from licensed duties until remediated and score at least 90 percent on a retest. This item is closed.
4.2.16 (OPEN) IFI No. 336/423//93-28-02: Advanced Trainine Techniones The facility committed to conduct diagnostic testing on all units (EC-7). As of October 1,1993, CWT or diagnostic testing had been conducted on about 20 percent of the MP2 licensees. Plans call for diagnostic testing on MP2, MP3, and Connecticut Yankee during the fourth quarter of 1993.
The facility committed to implement Advanced Training Classrooms (ATC) on the other units (EC-8). The ATCs have been implemented for operakr training at MP2. Plans call for implementing the ATCs at MP3 during the fourth quarter of 1993 ano at Connecticut Yankee in the first quarter of 1994.
These actions apply to Units 2 and 3. These actions have already been implemented at Unit 1. This item is open until actions are completed and reviewed for Units 2 and 3.
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i 4.2.17 (CIASED) INPO Assist Insoection l
An INPO assist inspection will be conducted on MP1 (EC-9). A six-person INPO team conducted the assist visit during the week of July 12th. Among other things, the team -
reviewed the cognitive level of the written exam bank and found it to be satisfactory. This item is closed.
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4.2.18 (CIASED) Industry Practice The facility committed to benchmark training programs through visits to other utilities (EC-11). The facility has visited several other plants to find ways to improve their program. For example, training and operations personnel visited and/or evaluated training programs at Vermont Yankee and Diablo Canyon. In addition, personnel from Philadelphia Electric and
Pennsylvania Power and Light conducted simulator evaluations and provided assessments of the MP1 LORT program.
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The facility committed to establish greater participation in industry forums (EC-12). The facility has looked outside of its own organization for ways to improve and has established and/or maintained participation in industry forums. In addition to attending industry meetings and workshops relating to training, personnel have participated in several INPO evaluations of other utilities.
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This item is closed.
4.2.19 (CLOSED) Annual Perfornmnce Evaluations A shift supervisor's annual performance evaluation will be tied, in part, to the LORT performance of his crew (EC-14). By memorandum dated 7/13/93, the Station VP directed the unit operations managers to ensure each shift supervisor's annual performance review specifically addresses the training performance of his assigned crew. The Station VP noted that a fundamental element of each shift supervisor's responsibility is the performance of his
crew.
An instructor's annual performance evaluation will be tied, in part, to the LORT performance of his assigned crew (MP1 only) (EC-15). A memorandum to the MP1 instructors dated 7/26/93, describes training management's expectation regarding the mentoring responsibilities. The memo notes that mentoring responsibilities will be tied to the
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annual performance review.
This item is closed.
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4.2.20 (OPEN) IFI No. 245/93-28-03: Trainine Procedure Chances
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Training performance will be monitored periodically at the executive vice president level l
(EC-16). The facility's plans for management reviews are undergoing change.
The Nuclear Training Manual (NTM) will be revised to more effectively and efficiently implement training (EC-18). A draft of the revised NTM was undergoing licensee review at the time of this inspection. Based upon discussions with the licensee, this action will not be i
completed until the end of the year.
Operator Training Branch Instructions (OTBis) will be revised to more effectively and efficiently implement training (EC-19). This activity is being conducted along with the NTM revision.
I The LORT TPIPs will be revised to specify implementation of management observation of
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training, including guidance regarding what to look for during the observations and the
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frequency for conducting observations (EC-22). The facility has scheduled this item to be completed by December 22,1993.
Continue management observation of operator training in accordance with OTBI-13, Rev 0,
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l until the TPIPs are revised to provide requirements and guidance (EC-31). This item is scheduled to be completed by the licensee by December 22,1993.
This item is open until the actions are completed and reviewed by NRC staff. This open item provides long term enhancements to the program and does not adversely affect a satisfactory LORT program determination.
j 4.2.21 (OPEN) IFI No. 245/93-28-04: Oreanizational Commitments l
There will be a six-month overlap for the newly-appointed supervisor of operator training for MP1 with the final phase of the Project Team (EC-17). The overlap is planned through February 1994, starting in July 1993.
After the Project Team is disbanded, the Operator Training Branch (OTB) will not revert to the previous organizational structure (EC-20). The proposed OTB organizational changes were under facility management review at the time of this inspection.
i The licensee committed to maintain the Project Team in place at MP1 until at least the end of 1993 (EC-26).
This item is open until actions are completed and reviewed by NRC staff. This open item does not adversely affect the satisfactory LORT program determination, since the interim organization established in November 1992 was effective in producing substoatial program improvements (Inspection Report Nos. 245/93-80, 93-25, this report).
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4.2.22 (CLOSED) Mentor Procram l
Continue the implementation of the mentor system at MP1 (EC-24). The mentor program appears to be an effective program based upon the results of the recent examinations. The commitment is being met and this item is closed.
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4.2.23 (CLOSED) (ke of CWT for Unit 1 The facility committed to continue the use of CWT as input into LORT program design at MP1 (EC-25). It has been MP1 policy to use CWT for all written evaluations administered by the facility. Procedure NTM 3.0S0 has been revised to allow the use of CWT.
Discussions with Unit 1 training management indicate they plan to continue the present policy. This item is closed.
4.2.24 (CLOSED) Operations Involvement In Trajtline Evaluations The facility committed to maintain operations involvement during weekly simulator evaluations to reinforce standards and support training objectives (EC-28) and conduct crew evaluations weekly during simulator requalification training. P:ocedure NTM 3.080,
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requires operations involvement in weekly simulator evaluations. This item is closed.
4.2.25 (OPEN) IFI No. 245/93-28-05: Meanine Of CWT Scores Below 90 Percent The CWT method penalizes students who guess on answers and provides insight into the students' knowledge level. However, the method of scoring also allows a student with 6 correct answers on a 10-question test to score 91 percent on the test and a student with only 2 correct answers on the ten-question test could score 81.5 percent using the CWT method of scoring.
The relationship between the test scores of CWT and a standard multiple choice testing is not known at the lower end of the passing range (below 90%). Therefore, the equivalency of the scores used to determine minimum acceptable knowledge level is unknown. This item is open until there is assurance that the minimum acceptable knowledge level has not been lowered by use of CWT. The licensee indicated at the exit meeting that they would try to better define this relationship.
CWT has been effective in diagnosing licensed operator weaknesses, which led to positive results during the 1993 requalification cycle. This open item does not adversely affect a satisfactory LORT program determinatio.
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4.2.26 (OPEN) Unresolved Item No. 245/91-26-01: Short-Term and IAne-Term Corrective Actions - Minimum Shift Crew Composition
i By letter dated November 8,1991, the licensee committed to 17 short-term and 18 long-term corrective actions. This item was unresolved pending verification of the long term actions and the effectiveness of the completed short-term actions. These 35 items and the associated
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NRC inspections activities are listed in Attachment 3. Three of the long-term actions dealt with shift crew composition, items 2111.1,2 V.llI, and 2 VI.11 in Attachment 3.
The facility informed the NRC at a later date that they would operate with the revised crew composition administratively controlled and would not process an amendment to Technical i
Specifications as originally described. Facility letters of February 25,1993, and
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May 20,1993, commit to a reassessment of shift composition with another letter to be submitted by February 28,1994.
This issue is under review in NRC and is open until the results of the licensee reassessment
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are completed and reviewed by NRC. Because of the actions already taken by the licensee and confined by administrative controls and inspection, the open item does not adversely affect a satisfactory LORT program determination.
4.2.27 (OPEN) Violation No. 245/93-04-01: Failure to Audit Unit 1 Operator Trainine Programs NRC Inspection Report No. 245/93-04 identified a failure to perform audits of the Unit 1 operator training programs every two years as required by Technical Specification 6.5.3.7(b). Northeast Utilities letter dated April 5,1993, provided corrective actions that are discussed below.
An audit of the Unit 1 operator training program was completed. This audit (Audit No.
A21062) was reviewed in NRC Inspection Report No. 245/93-80, section 6.5.
Audit procedures were revised to direct that operator training programs be audited at least once every two years. Other programs, such as Health Physics and Maintenance will also be audited at least once every two years also. Procedure NEO-3.01 was revised to require the audits.
The licensee stated that the Notice of Violation and the facility reply w::re to be discussed at the next regularly scheduled meeting of the Nuclear Review Board chairpersons to heighten their awareness of the need to direct Quality Services Department resources where needed.
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r This action has not been verified as completed by the NRC staff. The item remains open until the action is verified as completed. This open item does not adversely affect a satisfactory LORT program determination.
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4.3 Summary of Conclusions
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A sizeable number of commitments were found to be satisfied. Those remaining open commitments, in general, relate to items that are still being worked on and in a number of cases involve MP2 and MP3 rather than MPl. The open items applicable to Unit 1 are not
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significant factors in the MP1 LORT program satisfactory determination. Attachments 3 and 4 provide a historical listing of the commitments from 1991 and 1992 and their present status.
5.0 EXIT MEETING
An exit meeting was conducted at the Nuclear Training Center on October 8,1993. The inspector discussed the findings of the inspection with those individuals identified below.
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Northeast Nuclear Enerev Company M. Brown, Nuclear Training Manager J. Gionet, Engineer, Quality Services Department P. Przekop, Unit 1 Operations Manager l
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C. Tabone, Operator Training Supervisor R. Schmidtknecht, Shift Supervisor
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R. Heidecker, Supervisor Operator Training B. Ruth, Manager, Operator Training
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D. Harris, Licensing Engineer U. S. Nuclear Reculatory Commission J. H. Williams, Senior Operations Engineer S. Hansell, Operations Engineer
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K. Kolaczyk, Resident Inspector j
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Attachments:
1. Recent Millstone Unit 1 Inspection and Examination History l
2. Examination Materials 3. 1991 Corrective Actions Summary Table 4.
1992 Corrective Actions Summary Table
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ATTACIIMENT 1 RECENT MILLSTONE UNIT 1 INSPECTION AND EXAMINATION IIISTORY
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litm Date
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SLLBJECT 1.
10/3/91 (N/A)
Confirmatory Action Letter 1-91-015 2.
10/29/91 91-17 Requal Program Evaluation
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3.
12/19/91 91-26 Operational Evaluations 4.
3/13/92 92-05 Requal Training all Units 5.
4/29/92 92-11 Requal Retakes
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6.
7/13/92 92-14 Operator Roundsheets 7.
10/9/92 (N/A)
Confirmatory Action Letter 1-92-014 8.
11/2/92 92-23 Requal Program Evaluation
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12/29/92 92-31 Quarterly Inspection 10.
12/31/92 92-32 Requal Retakes ll.
2/24/93 93-04 Quarterly Inspection
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12.
2/24/93 93-06 Requal Retakes j
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4/6/93 93-07 Requal Retakes r
14.
6/7/93 93-80 NUREG-1220 Training Inspection (and Quarterly Inspection)
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7/1/93 93-15 Quarterly Inspection (mid-year exams)
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8/11/93 93-17 Quarterly Inspection and EOPs 17.
9/21/93 EA 93-130 Notice of Violation and Proposed CP 18.
10/7/93 93-25 Requal Program Evaluation 19.
N/A 93-28 Quarterly Inspection and Open Items 1-
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L ATI'ACIIMENT 2 i
EXAMINATION MATERIALS
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Simulator Scenarios:
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1. ATWS/ Loss of 14D Electrical Bus, LOR SES-11, Rev. 3
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2. Steam Line Break in the Turbine Building, LOR SES-28, Rev. 2 3. Unisolable RWCU Leak into Secondary Containment, LOR SES-27, Rev. 3 Job Performance Measures 1. Diesel Manual Start Locally, 070-502-04-01, Rev. 6
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2. Initiate Drywell Spray, 409-208-04-01, Rev.5 3. Recirculation Pump Start Rx Critical, 017-503-01-01, Rev. 6
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4. Alternate Method of Control Rod Insertion, 530-501-05-01, Rev. 2
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5. Restore Station Auxiliary Power to the RSST Following an LNP, 151-200-04-01, Rev.6 j
Written Examinations:
Static: 12rge Steam I.ine Break, SSE 13, Rev.0 (RO-930057)
Written: RO Exam 930058 SRO Exam 930059
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NITACIIMENT 3 1991 - MILLSTONE UNIT 1 CORRECTIVE ACTION SUMMARY A. Licensee Lxtter of November 8,1991, Attachment 1 (CAL 1-91-015 action closed in NRC letter of December 19, 1991, Report No. 91-26)
NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES 1.A.1 Develop or improve performance standards Performance-oriented review (POR)
during 1991 Op Eval.
245/93-80, section 7.15, closed I.A.2 Convey improved performance standards to all licensed POR during 1991 Op Eval.
personnel 245/93-80, section 7.15, closed I.A.3 Utilize human behavior specialist to assist in the behavior POR during 1991 Op Eval, changes to support improved standards.
245/93-80, section 7.16, closed II. A.1 Management simulator observation frequency 245/93-80, section 7.29, deviation (93-80-03 in part)
Closed in 93-28, section 4.2.3
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES.
II.A.2 Establish policy for the frequency of management observation 245/93-80, section 7.29, deviation of simulator performance.
(93-80-03 in part)
Closed in 93-28, section 4.2.3 III.A Operations management support of training objectives POR during 1991 OP Eval.
245/93-80, section 7.26, closed Ill.B.1 Develop evaluation criteria that define the standards and POR during 1991 OP Eval.
expectations of Operations Management
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245/93-80, section 7.18, open (93-80-06)
Closed in 93-28, section 4.2.6 Ill.B.2 Convey simulator evaluation criteria to all operator training Review of scenario bank included in personnel ER 245/92-23.
245/93-80, section 7.18, open (93-80-06)
Closed in 93-28, section 4.2.6
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III.C.1 Reinforce strategies for utilizing simulator capabilities 245/93-80, section 7.19, closed 22-
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES III.C.2 Utilize video tapes in routine training sessions Evident in 1991 Op eval and in 1992 requal exam.
245/93-80, section 7.20, deviation (93-804)3 in part)
Closed in 93-28, section 4.2.3 III.D.1 Raise the complexity of scenarios and obseive, evaluate, and POR in 1991 OP eval and observed in determine additional licensed operator needs. Add third RO 1992 exam.
and make hardware mods 245/93-80, section 7.25, closed Ill.D.2 Develop and utilize advanced scenarios 245/92-23 reviewed simulator exam bank and noted some weaknesses.
245/93-80, section 7.25, closed IV.A Evaluate and make changes to procedures to remove known Partial during 1991 Op Eval.
interpretation problems.
245/93-80, section 7.31, closed IV.B Review EOP Rules of Usage and Change as necessary 245/93-80, section 7.21, closed Reviewed in 245/93-17, section 6, closed.
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES
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IV.C Increase personnel awareness of operating philosophy changes 245/93-80, section 7.22, closed and potential impacts IV.D.1 Develop definitive criteria for examinations Evident in 1991 Op Eval - Facility Evaluator Performance good in 1992 Requal Exams.
245/93-80, section 7.23, open (93-80-07)
Closed in 93-28, section 4.2.7 IV.D.2 Ensure all personnel are aware of the criteria 245/93-80, section 7.24, closed
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B. Licensee Letter of November 8,1991, Attachment 2 NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES 2.1.1 Incorporate advanced simulator scenarios into licensed 245/93-80, section 7.25, closed Training operator training programs prior to use (Updated 12/7/92 -
Completed initially but will be routinely reassessed)
2.1.2 Update NRC examination bank mater:als to present NRC 245/92-23 indicates item is still open.
standards by October 31,1992. (Updated 12/7/92 - Still ongoing)
245/93-80, section 7.9, unresolved (93-80-04)
Closed in 93-28, section 4.2.4 2.11.1 Review assess and change as necessary the Training Plan 245/93-80, section 7.33, unresolved Implementing Procedure to ensure that a high level of (93-80-05)
proficiency is maintained by Jan 31,1992 (Updated 12/7/92 -
Completed initially but additional revisions planned)
Closed in 93-28, section 4.2.5 2.II.2 Conduct crew evaluations weekly during simulator 245/93-80, section 7.26, closed requalification. (Updated 12/7/92 Completed)
2.III.1 Upgrade the 2 crews to the new standards with 3 ROs Evident by the shift roster, plant
(Updated 12/7/92 Completed)
operations procedures and NRC inspections and examinations.
93-28 section 4.2.26, unresolved Item No. 245/91-26-01, open
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES 2.111.2 Complete 1991 annual requal exams (Revised 12/7/92 245/93-80, section 7.28, closed Completed)
2.111.3 Assess staff license need and retrain those remaining (Revised 245/93-80, section 7.27, closed
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12/7/92 Completed)
2.111.4 Complete 1991 annual requal exams for staff licenses 245/93-80, section 7.28, closed (Revised 12/7/92 Completed)
2.111.5 Complete and implement training plans for the failures by Individual plans submitted 1/31/91 (Revised 12/7/92 Completed)
Last of failures in 1991 given retake -
exams 245/92-11, closed 2.III.6
' Review negative training on simulator and complete by 245/93-80, section 7.34, closed 1/31/93. (Revised 12/7/92 Completed)
2.111.7 Assess the need for requal training during refueling outages 245/93-80, section 7.35, closed with a policy out by 1/31/92 (Revised 12/7/92 Completed placed additional controls)
2.IV.I Formalize policy for management observation of simulator 245/93-80, section 7.29, deviation Standards performance by 2/28/92 (Revised 12/7/92 Completed)
(93-80-03 in part)
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Closed in 93-28, section 4.2.3
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES 2.IV.II Develop written standards of performance for all NU umts by 245/93-80, section 7.30, deviation 2/28/92 (Revised 12/7/92 Completed initially common (93-804)3 in part)
standards to be issued to all units)
Closed in 93-28, section 4.2.3 2.V.I Evaluate EOPs are optimum from a human factors standpoint Reviewed in 245/93-17 section 4, Procedures by 1/31/92. (Revised 12/7/92 new schedule for EOPs in closed 12/2/92 letter)
2.V.II Procedure reviews and changes by 11/30/92 (Revised 12/7/92 245/93-80, section 7.31, closed Completed)
2.V.III Process a license amendment to have 3 ROs on shift by See also 2.III.1,245/93-28, 1/31/92 (Revised 12/7/92 still an open issue with NRC)
section 4.2.26, open 2.VI.I Increase attention given to human factors during implementation 245/93-80, section 7.32, closed of plant mods or procedure changes (Revised 12/7/92 Completed in procedure NEO 5.25)
2.VI.II Add additional SRO to shift (Revised 12/7/92 authorized but See 2.V.III stillin early stages of development)
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1991 - MILLSTONE UNIT 1 CORRECTIVE ACTIONS C. Licensee Letter of January 31,1992 NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES (Numbers in parentheses relate to previous items)
1. A (2.11.1)
Revise Requal Training Program Implementing Procedure 245/93-80, section 7.33, unresolved (TPIP) by 1/31/92 (Revised 12/7/92 Additional changes are (93-80-05)
required)
Closed in 93-28, section 4.2.5 1.B(2.111.6)
Continue to monitor training and evaluations to assure high Duplicate to item 2.11.1 operator proficiency and revise training program content as Closed in 93-28, section 4.2.5 necessary 2. A (2.III.6)
Revise simulator to allow individual control rod insertion by Evident by scenarios conducted 8/31/92 during 1992 requal examination.
Reviewed in 93-25, Closed 2.B Instructors seek out negative training items 245/93-80, section 7.34, closed 3 (2.IIL7)
Requal training program during refueling (See 2.III.7)
Duplicate to item 2.III.7, closed in 93-80, section 7.35
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ATTACIISIENT 4 1992 - AllLLSTONE UNIT 1 CORRECTIVE ACTIONS A. October 7,1992, Exit meeting NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES (Numbers in parentheses relate to later items)
A.1 (C.4)
Use revised flowchart method to develop written 245/93-80, section 7.9, closed examinations.
Verified use in 245/92-27
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Identify weaknesses in examinations and factor into LORT See C.5 below training program.
A.3 (C.2)
Provide necessary remediation to those who failed.
Remediation plans submitted; See C.2.
One operator license terminated, 9 of 14 passed retake exams. Retakes in 245/92-27,92-32,93-06 and 93-07 245/93-80, section 7.3, closed A.4 Continue reanalysis of MP1 job task analysis.
245/93-80, section 7.10, closed A5 Review existing training and examination materials against 245/93-80, section 7.10, closed -
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new learning objectives.
NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES A.6 SLSmit letters for those operators that failed at the SRO level Ixtters submitted 10/28/92 and and prform RO functions.
11/25/92, closed
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1992 - MILLSTONE UNIT 1 CORRECTIVE ACTIONS B. Licensee Letter of October 8,1992 NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES B.1(C.1)
Remove operators who failed from licensed duties.
No specific inspection required-Licensee Program requirement-Closed B.2 Establish Justification for Continued Operation.
CAL 1-92-014 issued (ER 245/92-23), closed B.3 (C.6)
Perform root cause analysis for failure.
Facility completed on 12/3/92 and documented in licensee Ictier 12/7/92 Inspection 92-32 closed B.4 Student counseling was initiated 245/93-80, section 7.2, closed
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1992 - MILLSTONE UNIT 1 CORRECTIVE ACTIONS C. CAL 1-92-014 NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES C.1 (B.1)
Restrict from licensed duties those operators who failed requal No specific inspection required-examinations.
Licensee Program requirement-Closed C.2 (A.3)
Submit remediation plans as they are developed.
245/93-80, section 7.3, closed C.3 Inform the NRC staff on a weekly basis of subsequent Weekly calls completed, closed failures. Ensure staffing levels include third RO.
C.4 (A.1)
Construct the 1992 written examinations using the process Verified use in 245/92-27 developed for the 10/2/92 requal exam.
245/93-80, section 7.9, closed C.5 (A.2)
Identify generic operator weaknesses for the 1992 exam Reviewed in 245/93-80 (D. A.4)
period and provide retraining to operators by end of the second cycle of requal. (A.2 and D.A.4)
Effectiveness reviews in retake exams and program eval 245/92-27,92-32, 93-06,93-07 and 93-25 Closed C.6 (B.3)
Meet with NRC staff to discuss root causes for these Facility presented on 12/3/92 and weaknesses in C.5 and corrective actions.
Documented in ltr of 12/7/92 Inspection 92-32, closed C.7 Submit long-term and short-term corrective actions by Facility completed in 12/7/92 and 12/7/92.
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1992 - MILLSTONE UNIT 1 CORRECTIVE ACTIONS D. LICENSEE LETTER of 12/7/92 NUMIIER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES D. A.1 Establish a project team In place based on inspection observations.
Staffing levels reviewed in inspection 93-04.
245/93-80, section 7.8, closed D. A.2 Submit operator remediation plans (from A.3 and C.2)
Plans were submitted for 14 failures.
One license was terminated (retakes in 92-27,92-32,93-06 and 93-07)
Closed D.A.3 Provide specific training on the four failed JPMs by the end 245/93-80, section 7.4, closed of the first LOR cycle in 1993.
D. A.4 Provide training on the system generic deficiencies during the Reviewed in 93-80 first LOR cycle in 1993.
Effectiveness noted in retake exams and program evaluation 245/92-27, 92-32, 934)6,93-07, and 93-25 closed
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ooe NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES D.A.5 Use the Advanced Training Classroom starting the first cycle Verified in inspection 245/93-04 in 1993 Reviewed in 245/93-80, closed 245/93-80, section 3.4, closed D. A.6 Inplant systems training during the first I.OR cycle in 1993 245/93-80, section 7.5, closed D. A.7 Use confidence weighted testing as input into requal training 245/93-80, section 7.6, closed design.
D.A.8 Train on INPO SOER 92-1 in the first cycle in 1993.
245/93-80, section 7.7, closed D.B.1 Keep project team through the recovery period of approx 1 245/93-80. section 7.8
year.
93-28, section 4.2.21, open D.B.2 Upgrade examination materials to meet NUREG-1021 245/92-27, closed including use of NRC-reviewed written examination question tool (from A.1 and C.4).
245/93-80, section 7.9, Unresolved 245/93-80-04 Closed in 93-28, section 4.2.4 D.B.3 Revise Unit 1 Job Task Analysis (from A.5).
245/93-80, section 7.10, closed l
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NUMBER CORRECTIVE ACTION NRC INSPECTION ACTIVITIES D.B.4 Restructure LOR training to include formal JPM training.
245/93-80, section 7.11, closed D.B.5 Devise simulator exercise guides, as necessary to include 245/93-80, section 7.12, closed additional instructional strategies and standards.
D.B.6 Conduct periodic independent review of Millstone 1 LOR 245/93-80. section 7.13 training.
93-28, section 4.2.27, open D.B.7 Reassess licensed operator performance in third quarter of 245/93-15, 93-17, 93-25, 93-28, 1993, closed D.B.8 Complete EOP training on new flowcharts by July 1,1993.
245/93-17 sections 2 and 3, closed D.C. I.a Apply effective training strategies to Unit 2,3 and Haddam 245/93-28, section 4.2.16, open Neck.
D.C.1.b Assess contents of SOER 92-1 for training on other units Closed in 93-28, section 4.2.10 D.C.2.a Develop operator training branch instruction to apply to all 245/93-80, section 7.14, closed units.
D.C.2.b Perform independent periodic review of LOR training on all 245/93-80, section 7.13, closed (See units.
also D.B.6
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