IR 05000247/1986026

Insp Rept 50-247/86-26 on 860826-28.Major Areas Inspected: Requalification & Initial Licensing Training Programs for Licensed Operators.No Tracking Sys for Assuring Compliance w/10CFR55.31(e) Requirements

ML20207K042
Person / Time
Site:	Indian Point, 05000000
Issue date:	09/22/1986
From:	Dudley N, Keller R, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207K023	List: IR 05000247/1986026 ML20207K019
References
FOIA-86-893 50-247-86-26, NUDOCS 8701090195
Download: ML20207K042 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-26

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Docket N .

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License N ORP-26  %.

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Licensee: Consolidated Edison Company of New York, In Broadway and Bleakley Avenue Buchanan, New York 100511

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- Facility Name: Indian Point - Unit 2 Inspection Conducted: August 26-28, 1986 ,,

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Inspectors: i '4 P /7"Ib N. F. Oudley,/Le Reactor Engineer date

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f- Reviewed by: _ _

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. t R. M. K le{, Chief,-ProjectsSection1C ate ,

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Approved by: _

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Harty~B. Kfster, Chief '

da't e Projects Branch No. 1

. - -e j Inspection Summary: The requalification and initial licensing training pro-grams provide adequate training and evaluation for licensed operators and licensed operator candidates. Tha administrative control systems which were evaluated did not fully support the requirements of the Trainir.9 Administrative Directive The training staffing available can support either a requalifica-tion or an initial licensing training program but not bot There is no tracking system for assuring compliance with the 10 CFR 55.31(e)

requirement for a certification to the NRC prior to reinstating a licensed operator to shift wor (

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f 8701090195 070106 /

PDR FOIA PDR ORADER86-893

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DETAILS Scope:

An unannounced inspection of the licensed operator initial and requalification programs was conducted. This review involved verification of the program's conformance to the requirements of 10 CFR 55 and to the licensee's training program implementing procedures. The inspection included a review of the following documents:

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Training Administrative Directives (TRAD)

- Senior Reactor Operator (SRO) Upgrade training program schedule

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- Salected Systen Descriptions and Lesson Plans

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SR0 Upgrade training program lesson plans

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- Selected individuals' training records

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Requalification' Training Program Instructions ,

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Requalification Program ~~ Schedule for 1985 and 1986'

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Requalification Program attenda.nce records _

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Annual Requalification Examination and Results . --

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Requalification program l'esson plans

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Instructor Certification and Observation records

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Simulator Evaluations

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LER and Plant Modification Tracking Syste Trainee and Supervisory feedback forms In addition, interviews were held with selected licensed personne Findings:

The most recent Senior Reactor Operator (SRO) upgrade traf,ing program provided the basis for the initial training program inspection. Generally, the conduct of and instruction provided by this program was deemed adequate to meet estab-lished standards. The licensee was successful in screening less than satis-factory candidates. The candidates were required to be evaluated on two separate and distinct audit examinations to determine whether a candidate should sit for the NRC administered operator license examination ..

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While conduct and instruction of the SR0 upgrade program is considered satis-factory, attention to administrative details was lackin There was no Master Schedule that accurately reflected the candidates progress through the training

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program or indicated changes to the course sequence. The schedule which was l

provided was incomplete and inaccurate.

O As a result of the INPO accreditation process, new Training Administrative ~

Directives (TRAD) were developed. However, there still existed a previous revision of the TRADs which governed the conduct of training for the SR0 i upgrade class. Listed below are instances where the TRADs in effect were not followed as require Two SRO Upgrade candidates had an unsatisfactory Transient and

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Accident Analysis Quiz grade and no trainee remediation form was

• . completed as required by TRAD-7 Section 21 and Station Administrative Order (SAO) 502 Section Individual question grades were lined out and changed without the

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grader initialing the changes.

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No attendance records were kept for the SRO. Upgrade p'6 Fam 9 as ,

required by TRAD-5 Revision Corrected answers were received by the training department, from a candidate who failed a weekly quiz. However, there was no indica-

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tion, that anyone had reviewed the candidate's wor The licensed operator requalification program was also reviewed. The requali-

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fication prograin underwent a major revision in January, of 1985. This revision appears to be a significant improvement o(pr the previous program as determined i

by a review of the course content scheduled for the 1986 Requalification Train-

ing Program and by interviews with licensed operators. The implementation of the trai-ning prc.' am was formalized by the Training Program Description for Licensed Operator Requalification, Rev. O, dated June 23, 1986, which included an attachment of ..mplifying Implement ing Guidelines (IG). The following dis-crepancies in the requalification program were identified:

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The IG requires all licensed operators to wttend all requalification lectures; the instructors used for the first cycle of 1986 did not

. attend any lectures,,nor was there any documentation to justify their 1 absenc The instructors did not participate in the cycle 1 and 2

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examinations and there was no documentation to justify their missing

the examinations.

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Three individuals missed lectures during the first cycle of 198 No absentee forms were submitted nor were the lectures made up as required by the I ,

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The IG states that, "all instructors will be SR0 licensed or instruc-tor certified", exceptions to this requirement are allowed with justification. Contrary to this requirement, an R0 licensed indivi-dual was used as an instructor in the simulator and subsequently his cycle simulator examination was waived. No justification could be located for these action The IG states that, "any operator who receives between 70% and 80% on a cycle exam must review the material and rewrite the answers to those questions missed". One instance was found where the candidate was allowed to answer additional questions to raise his grade above 80%, .

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without any justification or explanation of the action. All other failures reviewed had the test rewritten but there was no documenta-tion of an instructor revie The IG states that " operators who receive less than 80% on the annual examination must undergo an oral examination by the training depart-

. ment before the next cycle". Of six failufes of the annual wrfiten

! examination, no orals were complete The IG requisgg_ reactivity manipulation to+be completed in accordance with~10 CFR.55 ApptHdix Plant walkthroughs are not adequate t , meet th~is requirement. There is n'o method to tsqgk the number of reactivity manipulations conducted on the plant and simulator. Veri-

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fication that the reactivity manipulations were completed is compli-cated by the fact that some scheduled simulator scenarios were con-ducted as walkthroughs$and no records were found which identified the sessions which were conducted as walkthrough . The IG requires an operator who has failed2 the annual requalification

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program to complete an upgrading program. The content and extent of

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the upgrading program is not documented in the individual training

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Even though some annual requalification oral examination documentation strongly recommended remedial actions for some licensed operators who passed the oral examinations, no actions were taken on these recommendations. No feedback was provided to operators on individual areas of weaknesses identified by the annual requalification written examinatio less an examiration failure occureds.;.Results of evaluations should be ommunicated to individuals so that their weaknesses can be strengthene Training material is available for all plant systems, reactor theory, fluid flow and thermo-dynamics. Some of these systen descriptions and lesson plans were reviewed for format and content. The material was well structured, well written, and provided sufficient detail to provide adequate training informa-tio ._

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All instructors have completed a certification program and have been evaluated in accordance with the TRAD The instructor evaluations are comprehensive and provide a method for controlling the quality of classroom training. Instruc-tors have been scheduled to conduct continuous class training for extended periods of tim One instructor taught 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of direct contact instruction over two weeks. Another instructor taught 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of direct contact instruc-tion over a three week period. Best practices would suggest fewer consecutive direct contact hours for instructor There are five training staff positions for licensed instructors, of which four positions are filled. This number of licensed instructors is adequate to con-duct either a requalification or an initial licensing training program. If both programs are to be conducted concurrently, additional training staff will be require A computerized data base has recently been established to track SER's and NRC Notices and Letters which may contain information which needs to be incorporated into the training programs. A second data base has been established to track plant modifications which may require changes to system descriptions and lesson plans. The tracking system has identified necessary course content changes but

! none of there. changes have been incorpqrated in the training material. These ,

data base control systems appear to be adequate to monitor required changes to

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the training piFogra ,

From discussions with an operator, it was identified thothe operator had been assigned to di. rect the activities of licensed operators after a period of over four months of*not performing this duty. .It was unclear whether proper certi-fication had been made to the NRC in accordance with 10 CFR 55.31(e). An extensive review was made by the NRC in this area as part of strike coverage preparation in June,1986 and is documented in Inspection Report No. 50-247/86-1 At that time the licensee did not have a clear understanding of the require-ments of 10 CFR 55.31(e). Additional inspections will be conducted to verify

. compliance with this requirement.

Conclusion:

The initial training and requalification programs provide adequate training and are supported by.well written training mat.erial . The training implementing procedures have been recently issued and are undergoing revision. There are many instances where the administrative control systems do not adeMely sup- .

port the requirements in the implementing procedures. For example, the dect * 4 sion on whether an operator may return to watch standing duties after an annual requalification examination failure is not documente Simulator training has been integrated into the training programs. However, simulator reliability is questionabl Interviewed operators stated that walkthroughs were used when the simulator malfunctione ._

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A tracking system does not exist for assuring that licensed operators assigned to direct the licensed activities of licensed operators or manipulate the controls of the facility meet the requirements of 10 CFR 55.31(e).

Personnel Present At Exit Interview:

NRC Personnel:

N. Oudley -

Lead Reactor Engineer (Examiner)

B. Norris -

Reactor Engineer (Examiner)

S. Barber -

Reactor Engineer (Examiner)

P. Kelley -

IP-2 Resident Inspector Facility Personnel:

M. Selman -

Vice President Nuclear Power M. Blatt -

Vice President Staff, Nuclear Power W. Kejsler -

Senior Operator Instructor A. Budnick -

General Manager - Administrative Services A. Ciorgio -

Manager - Nuclear Training E. Perry -

Principal QA Engineer J. Koutouzis -

Operator Training Administrator

. J. Basile -

General Manager - NPG Summary of Comments Made~ at Exit:- -

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The inspector summarized the scope of the inspection.and evaluated the training -

programs as adequate for training and evaluating operators and operator candi-ate The following specific areas of concerns were presente _

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The decisions on returning operators to watchstanding duties follow-ing failures of the annual requalification examinations have not been forma 11y T cumente ,= -

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Operators are not provided feed back on individual weaknesses identi-fled on the annual requalification examination unless a failure occur l

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There is no system for tracking whether an operator has operated the l facility four months prior to assuming shif t responsibilities in accordance with the requirements of 10 CFR 55.31(e). i

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The unavailability of the simulator due to malfunctions has required some planned simulator scenarios to be conducted as walkthrough One operator felt that the simulator control board was at least one year behind modifications made to the main control roo Class size for requalification training varies from five to twenty l people as a result of scheduling problems. The larger class sizes I detract from effective classroom and simulator trainin *

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Some administrative controls are not conducted in accordance with the

required implementing procedures. The details of these items have been discussed with the training staf ,

The facility staf f stated that they recognized the need for developing a better method for ensuring compliance with the requirements of 10 CFR 55.31(e), and J that efforts were underway to re-evaluate their staffing needs and proficiency requirement P

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