IR 05000267/1987027

Insp Rept 50-267/87-27 on 871005-09.One Potential Violation Noted.Major Areas Inspected:Licensed Operator Requalification Program & Nonlicensed Staff Training

ML20236L224
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/27/1987
From:	Jaudon J, William Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236L216	List: IR 05000267/1987027 ML20236L213
References
50-267-87-27, NUDOCS 8711100214
Download: ML20236L224 (8)

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i e i APPENDIX U. S. NUCLEAR REGULATORY C0FDtISSION

REGION IV

NRC Inspection Report: 50-267/87-27 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC)

Facility Name: Fort St. Vrain Nuclear Generating Station Inspection At: Fort St. Vrain (FSV) Nuclear Generating Station, Platteville, Colorado Inspection Conducted: October 5 through 9, 1987 Inspector , b 01;_ Q - 102i-0 W. B. Jones, Resident Insphctor Date I

River Bend Station

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s l -2-Inspection Summary Inspection Conducted October 5-9, 1987 (Report 50-267/87-27)

Areas Inspected: Routine, unannounced inspection of licensed operator requalification program and.nonlicensed staff trainin Results: Within the two areas' inspected, one potential violation was ;

identified (failure to correct a training program deficiency within a timely manner, paragraph 4).

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DETAILS" Persons Contacted

• F. J. Borst, Support Services Manager

• H. L. Brey, Nuclear Licensing and Fuel Manager

• C. H. Fuller, Station Manager

. *R. O. Hooper, Technical Training Supervisor L. Hutchins, Training Instructor R. Molar, Training Instructor

• F. Moore . Quality Assurance Technical Supervisor

• J.'Novachek,' Technical / Administrative Services Manager

• A. Purnell, Licensing Specialist

• E. Rivera, Operations Training Supervisor

• R..Sargent, Assistant to Vice President Operations R. Shay, Training Instructor

• D. G. Seymour, Quality Assurance Engineer M. Smith, Training Instructor

• L. R. Sutton, Supervisor, Quality Assurance Auditingj

• J. Switzer, Training Support Supervisor

• T. F. Tomlinson,- Manager, Quality Assurance

• D. Warenbourg, Manager, Nuclear Engineering

• S. R. Willford, Superintendent of Training-

• R. O. Williams, Vice President Nuclear Operations The NRC inspector also interviewed additional'11censee personnel during the inspection perio l

• Denotes those persons that attended the exit interview conducted on .

October 9,1987. The NRC Resident Inspector, P. M. Michaud also: attended-the' exit interview, Licensed Operator Requalification Program -

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The NRC inspector 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 the performance of this review, the NRC inspector verified that the-following program elements were. implemented by the licensee:

Preplanned lectures required by the licensee's NRC-approved training program have been given to the: operating. staff and are scheduled-throughout the remainder ~of the 2-year requalification progra *

Training lectures included review of station systems and technical .

specifications.

, All licensed personnel reviewed emergency procedures annuall ,.

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Documentation was available to indicate that operations and staff supervisor (licensed individuals not assigned to an cperations crew)

reviewed facility design changes, procedure changes, facility license i changes, and emergency procedure The required control manipulations were' performed within the required annual and biannual cycl All licensed individuals who failed the annual requalification examination were placed in an accelerated requalification progra All licensed were individuals required to attend' who scored 'low appropriate in any p(articular lecture category Each licensed individual must attend 80 percent of all lectures and all missed lecture material, including weekly examination, must be made up.)'

All licensed individuals received on-the-job trainin '

Each licensed operator completed an annual requalification examination prepared by the licensee or the NRC staf Records were maintained by the training department to document participation by each licensed operator in the above activitie The licensee has established a lesson schedule for the remainder of the j licensed operator requalification cycle. The NRC ins)ector reviewed the Emergency Procedure (EP) lesson plans, which are taug1t on an annual ]-

basis. Revisions to the EP were found with the applicable EP lesson plan for incorporation into the next lesson. The licensee presently conducts seminars on a regular basis to provide a mechanism for identifying a revision to procedures, design changes or plant events to the licensed and' j nonlicensed operators in a timely manne The NRC inspector reviewed the licensee's program for incorporation-of _

Significant Operating Event Reports (SOERs), Licensee Event-Reports (LERs), NRC Information Notices and other' event-related reports into the training program. This program is established in Training Management Procedure TMP-4.1, " Training Program Evaluation." This j,

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procedure implements the Training Development Request (TDR) program. A TDR is assigned to each SOER, LER, Information Notice and other event reports for review of applicability to the training program. A TDR may also be written by an individual in the plant to request that training in a-particular area be revised or develope Review of the TDR log revealed that there are open TDRs dating back'to early 1986 when the program was first implemented. This was discussed with licensee management. During .,

the discussion, the licensee indicated that a change to the present TDR 4 program may be necessary to gain control of the backlog of TDRs. The  ;

reduction of the TDR backlog and any changes to the present program is an open item pending additional review by the NRC inspector (267/8727-01);

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-5-The licensee's annual requalification examinations were reviewed by the NRC staff for the type and difficulty of questions prior to the licensee giving the examination. The NRC inspector subsequently reviewed the accelerated requalification examination for the two individuals that

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Grading practices were also reviewed and found to be consistent throughout the examinations reviewed. The initial pass rate for the requalification examination administered by the licensee was 8 out of 9 for senior reactor operators and 12 out of 13 for reactor operators. Each of the individuals that failed the initial requalification examination was placed in an accelerated, requalification program and subsequently passed the accelerated requalification examination. The licensee has. established a program for evaluating individual scores and the overall scores of each section of the requalification examination to determine if there was a ,

deficiency in the operators understanding of the material or if the !

questions were inappropriate. Evidence of this program being implemented !

was found in Interoffice Memorandum PPC-87-2056 which indicated that 1 Section 4 of the reactor operator examination and the corresponding l Section 7 of the senior reactor operator examination had a deficiency in !

operator understanding. As a result, material covered in the two sections !

alone will be taught during the first or second rotation 'of requalification year which began in October 198 The NRC inspector reviewed the control manipulations matrix sheets and noted ti at each licensed operator had completed the required annual control manipulations for the June 1986 through June 1987 requalification year. The licensed operators appear to be making sufficient progress to complete the required biannual and annual control manipulations within the remainder of the June 1987 through June 1988 requalification cycle. The NRC inspector noted that the licensee maintains an informal program for tracking licensed operators that complete the control manipulations. The licensee is reviewing this program to determine if any further controls are neede No violations or deviations were identified in area of the inspectio . Nonlicensed Staff Training The NRC inspector reviewed the nonlicensed staff training program to j verify the program was being implemented ~in accordance with the licensee's i NRC approved training program and to evaluate the effectiveness of the training program. The review included examination of training records, discussions with personnel, review of selected-training material used in-the classroom, and training facilities _ available to each departmen The licensee is presently developing lesson plans for the nonlicensed staff and modifying the existing lesson plans to strengthen training programs. Changes to the existing lesson plans are accomplished using th same TD% program described in paragraph 2.o# this report. A similar

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i-6-backlog of TDRs was noted for the nonlicensed staff training progra !

Monitoring of this backlog is considered an open item (267/8727-01) I pending NRC inspector review of licensee _ action to reduce the backlo The NRC inspector reviewed changes that are being made to the i Instrumentation and Control (I&C) technician training program to determine the extent of changes to the program and what methods are being used to' i incorporate . training. requests into the lecture materials that 'are being I developed... The I&C instructors have issued job surveys to each of the I&C '

technicians requesting the technicians to describe each of the tasks that they perform and requesting that they determine, based on their ' i experience, the difficulty and at what frequency they must perform each .i given task.. The' input from this survey has been analyzed to assist in

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i determining what lectures will be given during the.next cycle and what I additional training material must be developed. This program appears to l have been implemented effectively and it is providing essential feedback j to the instructors on what tasks additional training may be neede '

The NRC inspector also reviewed the use of waivers for training requirements. when an individual demonstrates proficiency in a subject area-for waiving training requirements based on a lesson plan not having been developed or presented, or for a piece of equipment being out of service so that the task can not be performed. In the case of an individual demonstrating proficiency in a subject area, waivers were being granted based on the recommendation of an individual not certified as an on-the-job training instructor observing the applicable job. performance measure. Waivers granted because of lesson plans not having been developed or presented or equipment out of service for an extended time were not being tracked to determine if the waiver can be withdrawn'and the-training requirement completed. The' licensee is presently undergoing a major reorganization of the training department and is reviewing the training program to determine what changes should be made. -The use of waivers is an open item pending additional review by the NRC. inspector (267/8727-02). The licensee has committed to audit the. process of waiving training during their January 1988 Quality Assurance (QA) audit of the l training organization as identified by licensee commitment number QDC-13 The NRC inspector noted that training instructors and supervisory i personnel with which discussions were held, expressed the desire 4 to provide both operations and other plant staff personnel. with the ,

training they needed to perform their jobs in~ a proficient ~ manner. The lecture materials that have been and that are being developed appear to identify the needs of the differe'nt plant personnel. Evidence of the desire to present material which had been adequately reviewed and prepared-for presentation was observed.

l No violations or deviations were identified in this area of the:

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The NRC inspector reviewed Licensee QA Audit Report TRQL-87-02, " Training i and Qualification of Plant Staff Personnel to ANSI N18.1-1971 and Regulatory Guide 1.8 (Revision 1-R)," issued on March 20, 1987. During the performance of this audit, the licensee identified that a training program has not been established for managers, supervisors and professional / technical I persennel as required by Section 5.3 of ANSI N18.1-1971. This finding is I identified as Quality Discrepancy Report (QDR)87-013 and was issued against the training department on March 10, 1987. The NRC inspector  ;

reviewed the subsequent. correspondence between the training department and 1 the QA organization. The original commitment date to have completed the I required corrective action was' July 22, 1987. This date was not met, nor was the subsequent date of August 31, 1987, met. The date for having '

completed the corrective action has been moved to December 31, 1987. Thi failure to initiate corrective action to correct the above training program deficiency within a timely manner is an unresolved item (267/8727-03). ;

5. Status of INP0 Training Accreditation  ;

The licensee has received INP0 accreditation for the licensed and nonlicensed operator training programs. The licensec is preparing for the INP0 accreditation v'isit in December 1987 for the following training programs:

technical advisor 4 instrumentation and control technician j

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electrical maintenance personnel j mechanical maintenance personnel radiological protection personnel chemistry technicians I onsite technical staff and managers The licensee expects to receive accreditation for training programs by ;

June 198 . Unresolved Item An unresolved item is one about which additional information is required-in order to determine if it is acceptable, a deviation, or a violatio There is one unresolved item in this-report:

Paragraph Item N Subject 4 267/8727-03 Timely Response to QA Finding Which Identified a Deficiency in the Training Program

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-Exit and Inspection Interview An' exit interview was conducted on October 9,1987,:with:the licensee's i representatives (identified in paragraph 1). ; During this interview, th l}

NRC inspector reviewed,the scope and findings of the inspection.

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