IR 05000280/1984031
| ML20127E497 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 02/11/1985 |
| From: | Falconer D, Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127E402 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM 50-280-84-31, 50-281-84-31, 50-338-84-39, 50-339-84-39, NUDOCS 8505200101 | |
| Download: ML20127E497 (26) | |
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M00 UNITE"; STATES .
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. NUCLEAR RE!ULATORY COMMISSION
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" $ 101 MARIETTA STREET, #
ATLANTA. GEORGIA 30303
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Report Nos.: 50-280/84-31, 50-281/84-31, 50-338/84-39 and 50-339/84-39 Licensee: Virginia Electric and Power Company
' Richmond, VA 23261 Docket Nos.: 50-280, 50-281, 50-338 and 50-339 License Nos.: DPR-32, DPR-37 NFP-4 and NFP-7 Facility Name: Surry and North Anna Ihspection Conducte .I November 5-28, 1984 Team-Leader: .
D. Tal
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Date Signed Team Members: C. Christensen D. Stadler G. Troup Accompanying Personnel: A. Campbell, EG&G, Idaho P. Isaksen, EG&G, Idaho C. Vanderniet, EG&G,. Idaho Approved by: b' / [6 C.Julian,@ectionChief 'Dat( Signed Operational Programs Division of Reactor Safety SUMMARY Scope: .This special, announced inspection entailed 250 inspector-hours on site in the area of plant training program assessment at Surry and North Ann Results: Within the area inspected, one deviation was identified at the North Anna sit Deviation (338/84-39-07, 339/84-39-07): Failure To Provide Mariagement Training
.To Shift Technical Advisor PDR ADOCK 05000338 G PDR
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REPORT DETAILS Licensee Employees Contacted
- Dr. T. Williams, Manager of Power Training Services
- Dr. B. Shriver, Director of Nuclear Training
- R. Saunders, Station Manager, Surry
- E.-Harrell,. Station Manger, North Anna
- J. Bailey, Superintendent Nuclear Training, Surry
- L. Edmonds, Superintendent Nuclear Training, North Anna Other licensee employees contacted included managers, instructors, engineers, technicians, operators, mechanics, and other corporate and station employee 'NRC Resident Inspectors
- M. Branch, Senior Resident Inspector, North Anna
- D. Burke, Senior Resident Inspector, Surry M. Davis, Resident Inspector, Surry
- J. Luehman, Resident Inspector, North Anna
- Attended exit interview on November 9, 1984 at the Surry Site
- Attended exit interview on November 28, 1984 at the North Anna Site Exit Interview The inspection scope .and findings were summarized on November 9 and November 28, 1984, with those persons indicated in paragraph I above. The licensee acknowledged.the inspection findings as detailed belo . Licensee Action on Previous Enforcement Matters Not inspecte . Unresolved Items Unresolved items were not identified during this inspection . VEPC0 Training Assessment Plant training programs were assessed to determine their effectiveness in supporting licensed activities at the Surry and North Anna facilities. The assessment consisted of the review and evaluation of policy documents, implementing procedures and instructions, lesson plans, system descriptions, ;
training aids and reference ' manuals, and individual training record l
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Interviews with-training and plant staff constituted a major portion of this assessmen I
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The training assessment was divided into two segments: 'The Surry evaluation conducted by a six member inspection team during the period of November 5-9, 1984 as detailed in paragraph 6 of this repor The North Anna evaluation conducted by a' three member inspection team during the period of November 26-28, 1984 as detailed in paragraph 7 of this repor An evaluation of the licensee's co'rporate management of plant personnel training programs was conducted on November 7, 1984, at corporate head-quarter Corporate management of plant training programs is provided by the Power Training Services (PTS) Department. Surry and North Anna stations training superintendents report to PTS in the corporate organizational structur PTS is responsible for training program development, implementation and evaluation with the goals of providing trained personnel for the safe'and efficient operation of the North Anna and Surry Nuclear Station The inspector interviewed various PTS managers and supervisors. Training program administrative instructions, guidelines and procedures were reviewed to determine corporate involvement .n the development and evaluation of plant training program Proposed and developed program implementation plans and resource allotments were assessed to determine the licensee's intentions to improve overall plant personnel training program A commendable effort is currently underway to develop and implement performance based training programs at each. station. Significant corporate, as well as plant resources, have been directed towards the development of a systematic training methodology and workable performance based training programs. The development of the new performance based administrative-guidelines are near completio Individual program development and implementation at both Surry and North Anna are being aggressively pursue ; Another notable aspect of PTS is the program evaluation provided by the Nuclear Training Assessment (NTA) Grou NTA conducts assessment and evaluation of training programs, training staff and training administratio This self audit function is in addition to that normally provided by the individual plant QA/QC staff NTA . al so is responsible for tracking corporate and regulatory commitments, evaluating corrective actions and providing recommendations for program improvement The inspector reviewed a NTA audit, dated October 10, 1984, addressing a-June, 1984 SRO upgrade examination at the Surry Nuclear Station that an excessive number of candidates failed. The audit appeared to be an objective assessment of the occurrence. The root causes of the excessive failure rate were identified and comprehensive corrective actions recommende .
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Within the area of corporate training program administration, no violations or deviations were identifie : Surry Training Assessment The areas assessed at the Surry Nuclear Station included the following: Licensed Operator Training Non-licensed Operator Training ' Operational Experience Feedback Instructor Qualification General Employee Training QA/QC Inspector Training Shift Technical Advisor Training
- Support Engineer Training Maintenance Training Although several deficiencies were identified by the assessment team, overall plant training was determined to be adequate for-the support of safe plant operatio During the assessment period, the licensee was in the process of developing
.and implementing major upgrades and revisions to established plant training programs. These efforts were directed towards changing training methodology from the knowledge-based to performance-based programs necessary to achieve INP0 accreditation. The inspection team's assessment of specific training programs was based solely on the ' evaluation of the in place training programs and the licensee's future plans were only considered in the determination of overall program developmen Licensed Operator Training (1) Licensed Operator Requalification Training The Licensed Operator Requalification Program (LORP) at Surry is in transition to a performance based program as are most other-VEPC0 training programs. The inspectors reviewed the draft performance based requalification program, which has a proposed -
implementation date of January 1,1985, and noted several improve-ments over the original approved program. The new LORP will-require that all licensed personnel, including backup licensees and training staff, who are to maintain active NRC licenses will perform shift license duties at least five days per quarter. This requirement would satisfy. the intent of 10 CFR 55.31e and eliminate a noted deficiency in the present requalification program. The new LORP will require that the results of the annual requalification examinations be processed through a matrix to de'termine areas which should be emphasized in the following year's requalification schedule. This would satisfy the intent of 10 CFR 55 Appendix A and be an improvement over the present informal method in use. The proposed LORP also defines accelerated i
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requalification training to contain lectures or discussions along with guided self-stud Accelerated requalification under the present qualification program is primarily self-stud Accelerated requalification should be at least as good as requalification training and not consist of all'self-study. When approved, the revised requalification program should be submitted to the NRC for review and approva Implementation of the proposed LORP and its submittal to the NRC will be identified as Inspector Followup Item (280, 281/84-31-01).
Although interviews with licensed individuals indicated that requalification training had improved substantially in the past year, the inspectors noted a number of deficiencies and areas of concern in the current requalification program. The present program has no approved and up-to-date texts for systems trainin This deficiency is being resolved with new systems texts being written by a vendor. A review of these text drafts for three systems indicated that they are very detailed and should resolve the problem when complete The present requalification program has no apparent defined process for review, revision, and approval. The revised LORP will incorporate administrative controls for these area A review of the annual requalification examinations revealed that the same examination was utilized for all five shifts on-different dates in 1982 and 1983 although the exams were different for the two years. Several different examinations were utilized for the 1984 annual requalification. It was also noted that the same requalification cycle quiz is being given to all five shift Two quizzes for each cycle or a different quiz for each shift would ensure quiz intergrity. The requalification test question banks and answer keys were found by the inspectors to be stored in an unlockable file cabinet in an unlocked office in the training building. The licensee felt that the severity of this deficiency was tempered by several factors including the large number of questions, assembled tests being stored in the vault, and only 50%
to 60% of the questions on a given text being compiled from the banks. It was agreed, however, that the test bank and answer keys would be moved to a lockable file cabinet and kept locked. The security of requalification test banks will be reviewed at a later date and will be identified as Inspector Followup Item (280, 281/84-31-02).
(2) Replacement License Training
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System Training (Classroom): Overall, the classroom portion of the training program was very well structure The curriculum of the training program had a logical flow from one course into another and courses followed from one to the
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next -in a clearly defined format that was easily followed by the students and the training staff. Each course was divided into lessons that taught all the materials needed for the training of reactor operators and the training staff appeared to be quite knowledgeabl The Surry plant is currently in the process of having new texts developed that describe plant systems and operation A few of these texts were reviewed in a draft form and appeared well written. The rest of the texts were still in the developmental stages by the contractor hired by the Surry facility and were unavailable to the audit team. The Surry plant has established a review process for the new texts as they are released by the contractor which will ensure the technical correctness of the materia A parallel plan for t.te development of instructor lesson guides was also in place which will ensure a standardized format for lesson instructio This plan will further improve the quality of the classroom training program. A time schedule for the development of the lesson plans that follows the actual text development will aid the completion of both tasks and should be implemente System examination banks need to be developed that coincide with the new system texts. There was evidence that this was taking place, but a formal ~ plan should be implemented to ensure correspondence. These examination questions should be reviewed to ensure that all objectives are covered and that lesson plans are tied to several questions to ensure proper testing of the covered materia System Training (Simulator): The Surry plant simulator was well maintained and reflected most of the changes that had occurred to the control boards in the control room of the actual plant. The changes that were not reflected in the simulator have been scheduled to be done within one yea The method of training that is currently being used in the systems portion of the simulator gradually introduces the new operators to the simulator. The students are trained on the simulator after learning about a plant system. They locate the systems controls and perform basic system operation This method of training reenforces the classroom training that has been given, increasing the importance of the lessons to the operator Dv
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A method of reporting discrepancies that are found to exist in the simulator is specified in the Training Administration Guidelines Section 2.9. At present, the students are unaware that this reporting system is available. The availablity of this reporting system should be brought to the attention of each student during initial orientation to the simulator instructional perio Enlargements of the plant P& ids provided for the operators and instructors to use during simulator sessions would aid the instructors in checking that the operators have a clear understanding of how the controls effect the plant and further integrating the classroom portion of the training to that'of the simulato Fundamentals Training: The overall structure of the curric-ulum was well developed and included all the major topics that are required for a new reactor operator. Here, as in the system training, lesson plans are developed and break the major areas of study into teachable lesson The reactor physics course at present utilizes two different texts. This caused some confusion to the students because they were required to utilize both texts to find covered materia Questions in the fundamentals examination bank need to be tied to the objectives that are taught in the course. This will ensure all areas taught will be covered in the examination of the subjec A policy for the review and improvement of the instructor lesson plans needs to be enacted to' ensure the text is up-to-date and meeting the current training requirement This statement pertains to all the lesson plans used in the fundamentals are Training Administration Guidelines: The Training Administra-tion Guidelines Manual.(TAG) was found to be well written and easy to us The topics contained in the draft version 1 covered most of the areas of concern to the training depart-men This manual will prove to be of benefical use in the smooth operation of the training departmen Overall the R0/SR0 Course Program Cuide shows good direction and management containing well defined outlines of the R0/SR0 license course. The inspectors suggested the following improvements to the Program Guide:
(a) The Program Guide needs an introduction section that ties it to the TAG manua (b) A review and change procedure needs to be established to reflect current modifications to the progra _ . - - . _ , . - . . . . - - - ---.-.--.-.- -
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n (c) LThe manual should have a numbering system similar to the one
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'(d) ' The Appendices need a numbering system to tie them to the proper sections of the R0/SRO Course Program Guid ~(e) Appendix G needs'a date blank for the RO's initia ,
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(f) Students should not sign their own signatures on the
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Performance /Walkthrough blanks of the checkoff sheet .
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All of the individuals that were interviewed felt that the '
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training program had greatly improved in the last year. They felt that the classroom training time was well spent and that ' the . -
,' instructors were capable 'of providing good training. Utilizing
- the STA- in the simulator was identified as a good feature of the
- . shift retraining cycle The training center itself was very suitable to the process o learning. The new operator's training area provides a comfortable and quiet area for study and lectur Due to the training
- schedule, the inspectors were only able'to observe a small segment a of.the simulator in operation. The mood in the simulator room was one that- fostered learning. The operators functioned in an orderly. manner making. the definition of responsibilities ^ clearly , evident. The instructor was quite relaxed, had very good control of the students, and interacted well with them.
, Non-Licensed Operator Training n
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The Non-Licensed Operator Training Program is also -undergoing
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transition to a performance based . program. Non-Licensed z0perator Training 'is divided into - several areas including Basic ~ Systems
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j' Training, Academic Training, Watch Station Qualifications, and (~ Requalification Training.
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Basic Systems Training: This is an 80 hour9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> course designed to
introduce new hires to plant' systems prior to being assigned to '
normal duties. The course i s - designed for, and presented concurrently to, several different groups including operations ~,
' saintenance,and security. Interviews with non-licensed operators indicated that this course would be more effective, particularly for personnel with previous operating experience, . if it were' .
designed specifically for operators-and presented independent from-
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"other groups . A review of the training records of several non-licensed operators, hired .just before this course was implemented, indicated that no apparent effort was made to backfit these personnel into this systems course. This training could have proven beneficial even though the individuals had probably
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already completed some steps in their plant qualifications. A n
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review of the various texts utilized for systems training, as well
,~ as interviews with non-licensed operators, indicated that there was no up-to-date single text available for systems training. The Step Training Texts and the original system descriptions were out
- - of date, and simplified systems drawings were not available. As part of the transition to performance based training, VEPC0 has new systems books under development by a vendor. A brief review of two of these systems books indicated that they were very comprehensive, and that they contained simplified systems drawings. Due to the present lack of up-to-date systems training materials, the inspection team encourages distribution of these new texts as they are developed and approved, rather than waiting for the complete packag Academic Training: The Nuclear Control Room Operator (non-licensed) Development Program Guideline states that there are two step development programs in effect at Surry; one for personnel 1"/ hired before April 15, 1982, and the other for personnel hired
, after that date. The old program includes some academics. The new
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. program has had academics removed; in that, operations personnel x presently being hired, have had academics material in either
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Memphis State, Penn State, or the Navy. This academic training
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included such areas as mathematics, physics, chemistry, energy WL conversion, heat transfer, basic reactor principles, design, and operation of pressurized water reactors. In an effort to staff-up
, for a six shift operation, the operations group has deviated from hiring only Memphis State and Navy personnel, and started hiring
"off-the-street". These new operators, without previous academic
, and nuclear fundamentals training, are being placed directly into
"; the step qualification program which no longer contains academic
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areas. The licensee informed the inspectors that a new six month academic training program will be available for all new hires in s s- 1985. This course will include mathematics, physics, materials 1 - science, thermodynamics, heat transfer, fluid flow, reactor
theory, engineering mechanics, electrical theory, instrumentation and control, and radiation protection. It is essential that new operators hired during the interim period also receive this academic training, both to better understand the processes involved in their normal job functions, as well as to help prepare them for eventual entry into the license training program. This will be identified as Inspector Followup Item (280, 281/84-31-03).
- Watchstation Qualifications: The present Watchstation Qualifica-
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tion Program is 39 months in length, and is divided into six
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qualification step The program is primarily self-rtudy, self
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the systems and tasks which are within his or her area of respon-A sibility. Section 5.2.1, Part b of the Surry Nuclear Control Room Operator Program Guideline states that " systems within each step
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n have been reassigned between the two programs" (pre-April 1982
{ q. , -- and post-April 1982). A review of the changes indicated that the
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e ' academic items were removed and replaced with additional system Section 6.'1 allows new operators with either Memphis State or Navy training to enter the Qualification Program at the third or fourth
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step, respectivel The only requirement to demonstrate profi-ciency on all systems contained in Steps 1, 2, and 3 is the
<' completion of ' written tests. This bypasses three other profi-
'ciency demonstrations normally required on each system, including a verbal discussion with a licensed operator, a system walkthrough with a licensed operator, and an overall performance appraisal by a superviso The systems on the first three checklists are primarily the steam plant, and when combined with the practice of requiring completion of all three checklists along with the fourth
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checklist in the first six months of employment, could lead to an
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\' inadequate depth of knowledge on in plant equipment. This is very 7 .different from making an allowance for academic knowledge attained I through the Navy or Memphis State Training Program which is reasonable. A review of the new 59 month performance based
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Non-Licensed Operator Training Program indicated that in the future, systems qualifications may be accelerated, but - not bypassed, which is a definite improvement. As mentioned in the previous section, the performance based non-licensed operator training program will also contain a six month academic section, e and overall, should be far superior to the present progra .i
. A review of several of the training records for Watchstation Qualifications disclosed a number of minor discrepancies which should be resolved, and avoided in the future. An operators name
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and the date were not entered on the qualification signature page
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which could allow transferring of this qualification page to
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another operator. Several qualification cards did not contain the required Superintendent- of Operations signature, and some approved signatures were made with a rubber stamp. Illegible and single initials were entered in qualification check off items perhaps necessitating the establishment of a master initial versus name list. Finally large numbers of qualifications appeared to be signed off in a single day (63). Further discussien revealed that these qualifications were not accomplished in one day. There was only one date entry slot on the entire checklist and there should
.i have been a date slot next to each initial slot. Future qualifications should be signed off on a timely basis as complete Requalification Training (non-licensed): Requalification
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Training is normally scheduled four days out of each shift cycle, but the non-licensed operators attend only two days of .requali-
-fication. The remaining two days of each cycle, the non-licensed operators from each shift are utilized as a manpower pool to help support shift operation The two days of requalification time appeared to be utilized effectively with time devoted to a review
of important LERs, design changes, and system review All non-licensed operators interviewed felt that they need the four
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full days of requalification training each cycle, the same as licensed operators. This could be very beneficial, particularly if they were included in selected license requalification lectures and as observers in simulator requalification exercise The interviews also indicated that due to the time lapse ~between being hired as a non-licensed. operator and entering the license training program, even ex-Nuclear Navy personnel lost some of their skills in mathematics, physics, and reactor theory. This can lead to difficulty when initially entering license training, and inclusion of this type of . training in non-licensed requalification could also be very beneficia Miscellaneous Training: A review of several non-licensed operator training records and interviews indicated that General Employee Training and annual retraining were adequate and being conducted as required on a timely basis. Fire Brigade Training is an eight day state-certified course, and although the course was not reviewed, interviews indicated that it was well structured .and comprehensive. A recommended improvement in this area would be to add a section on the special precautions and techniques necessary in fighting potentially contaminated fires, since this did not'
appear to be included in this standard fire fighting trainin The one week Watchstanding Techniques Course is provided to newly hired operators to introduce operating philosophy, available source materials, procedures, print reading, and paperwork requirements. This course appeared to be adequate to meet its designed purpose, but as with Systems Training and Academic Training, there was no apparent effort to backfit individuals
' hired just prior to establishment of the course in 198 c. Real Time Training (Operational Experience Feedback)
Operational experience reports from extended sources such as the NRC, INPO, and vendors, as well _ as experience reports generated internally by Surry - or North Anna, are evaluated and distributed for review and necessary action -by a staff specialist from the Safety Evaluation and Control Group (SEC). The distribution list includes Operations, Maintenance, Technical Services, Training, and Plant Management, and nay be extended to other departments depending on applicabilit Operations: The Operations Superintendent is responsible for reviewing operational experience routed from the SEC, and for dissemination of the information to the shifts as necessary. The information, including design changes, LERs, SERs, I&E notices and bulletins is distributed as required reading to Operations personnel with a 60 day completion requirement. It was noted by the inspectors that Surry NRC Information Reports are disseminated as required reading which can be very beneficial in keeping operating personnel abreast of plant status. A review of current required reading indicated the reviews are being completed and signed-off as required. It was noted during this review that the
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non-licensed operators were no longer included on the required reading list for licensed operators, but were on a separate and much less inclusive list. This change was made because staff felt that much of the licensed required reading was not at the level of understanding for non-licensed operators. The inspectors suggested that the licensee should consider utilizing the STA or a shift SR0'
to provide training on operational experience, where the technical implications or application to the particular plant may not be readily apparen Maintenance and Instrument and Control (Technical Group): It appeared that both the Maintenance and Technical Groups were adequately dispersing the operational experience information received from the SEC. Documentation by the Maintenance Group was much more formal than the Technical Group. The inspectors were informed that this was primarily due to the much smaller number of personnel in the Technical Group. The inspectors recommended that the distribution and completion of operational experience to the Technical Group be made more formal to ensure that it reaches all required personnel and to make the documentation readily auditable'.
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Training: The incorporation of operational experience into applicable training programs' at Surry has been very informal and undocumented in the past. A review of lesson plans for the past year did not indicate the incorporation of operational experience, even though this subject is specifically listed in the requalification program for annual lecture The instructors could remember informally discussing some of LERs, and design changes to the fire protection syste In an effort to improve this situation, the Superintendent - Nuclear Training at Surry has established a Program Change Coordinator to route information as necessary to applicable instructors. Two Training Administrative Guidelines (TAGS) to help ensure that design changes and information notices are routed to the Program Change Coordinator and subsequently incorporated into appropriate -training courses have recently been developed. This effort needs to be further upgraded to include all operational experience, including LERs, which may require training beyond required reading, including classroom or simulator training ' as applicable. A portion of the annual requalification lecture series and ' simulator training should be devoted to operational experience, and appropriate lesson plans developed to ensure uniformity of the trainin In addition, to ensure meeting the intent' of NUREG-0737, Item 1.C.5 Part 7, a program should be established to provide a periodic internal audit to ensure that the operational experience
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feedback program functions effectively at all levels and in all group Instructor Qualifications
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The Instructor Certification Program is presently in transition to a
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performance based program as are many of the training programs at Surry. - The certification method utilized in the past consisted of an
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informal checklist of seven items. A review of these checklists for-instructors who teach operator licensing and requalification classes, indicated that they were completed as required. In conducting the review, and'in observation of classroom activities, it was noted that certain instructors who were not SR0 licensed were teaching certain balance-of plant (B0P) systems and design changes to designated BOP'and safety-related systems. A review of the qualifications of two instructors indicated one' had twenty years Nuclear Navy experience, had attended SRO license training, but had not yet achieved an SRO license, while the other had been R0 licensed on the Surry Plant. . Enclosure I, Section 2d of Harold Denton's Letter of March 28, 1980, on Qualifications of Reactor Operators states " Training center and facility-instructors who teach. systems, integrated responses, transient and simulator courses shall demonstrate their competence to the NRC by-successful completion of a senior reactor operator examination." Surry Technical Specification 6.1.B.3 requires meeting or exceeding the recommendations of this letter. In order to ensure compliance with this Technical Specification and the NRC Letter, it is recommended that the licensee minimize the utilization of non-SR0 licensed instructors in teaching systems and design changes. The teaching of systems by non-licensed instructors should be limited to balance-of plant-(non-safety related) systems in which the instructor has demonstrated experience and in-depth knowledge, and should never include integrated operations or simulator trainin Design changes taught by non-licensed instructors should be limited to minor changes which do not substantially affect the capability of safety related systems t ~
perform their intended function, or changes which do not affect the-integrated safe operation of the plan It was . also noted during the inspection that there had been no formally established method for the auditing and evaluating of instructor performance on a regular basis by the training organization in the pas There had been no' such evaluations performed and documented in the past six months. In addition, student evaluation sheets were being utilized in only a very few of the classes taugh ~
In order to ensure that a high standard of instruction is maintained, it is recommended that these periodic evaluations be conducted by
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training staff and that student evaluation forms be utilized and-reviewed for all classe The inspectors also reviewed the new instructor certification program being implemented by VEPC0 at Surry and North Anna. This program is performance based and is divided into two sections, a seven day full-time classroom basic instructor certification, and a two year -
self-study and evaluation master instructor certification module. Both
- of these courses appear to be very comprehensive and should be much more effective in developing high quality instructors with many diverse skills.
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Within the area of inspector qualification, no violations or deviations were identifie e. General Employee Training The Surry General Employee Training (GET) program consists of two days of instruction in the areas of Generic Radiological Protection, QA/QC, Radiological Site Specifics, Workers Rights, Security, Emergency Plan, Fire Protection, ' Safety, and Radiological Practical Factor The program also provides advanced GET, that expands the topics to include First Aid, Containment Entry and the ALARA program. Thegeneral Employee Retraining (GER) program consists of a one day session devoted primarily to ? ' ndensed review of those GET topics identified abov ,
All station employees are required to attend GER every 12 months. The inspector reviewed the licensees GET/GER implementing -procedure, Administrative Procedure 12, Qualification and Training. Detailed implementing instructions for the GET and GER programs are sppcified in Training - Administrative Guide (TAG) 4.2, Attendance Requirements for GET/GE TAG 4.2, Step 6.10.3.2 requires GET instructors to maintain a GET Failure File for the exams and certification forms of those employees who fail GET/GER until the employee returns for retraining. During a
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review of the GET Failure File, the inspector noted'several instances cf certification that a failed student had been issued a GET c i 'tification car The GET certification card indicates successful completion of GET and should not be issued to failing employees prior to the successful completion of GET/GER. Subsequent inquiry revealed that the certification cards were, in fact, not issued to failing employees. The general practice of GET ~ instructors is to complete GET/GER paperwork, prior to the completion of' GET/GER to expedite the documentation process. As a result, the block vertifying -that a certification card has been issued is pre-checked "Yes" - for all students; however, failing students are not issued the certification card and the -paperwork is not generally corrected to reflect this statu The . licensee indicated that this discrepancy would be correcte The QA/QC topic of GET/GER training was considered to need improvement for maintenance, operations and other station technical employees. The QA/QC topic is very general, with few specifics being provided. The
, licensee is presently . developing a QA/QC Enhancement Course that will provide more indepth instructions in QA/QC to selected plant personne The inspector considers that the implementation of the new QA/QC Enhancement Course will resolve this discrepancy. Implementations of the QA/QC Enhancement Course will be identified as Inspector Followup Item (280, 281/84-31-04).
The inspector also performed a review of selected personnel training records to verify that GET/GER training' had been provided to station
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personnel as required. Within the area of GET, no violations or deviations were identified Quality Assurance Auditor and Quality Control Inspector Training Quality Assurance (QA) auditor and Quality Control (QC) inspector training is the responsibility of the Quality Assurance Department. QA auditors receive initial QA department orientation in the form of-lectures and self-study to provide knowledge and understanding of
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ANSI N45.2, ANSI N45.2.12 and ' the audit implementing procedure In addition, on-the-job training is informally provided by the lead auditor. -QC inspectors receive initial indoctrination consisting of basic quality fundamental and QC instructions. QC inspectors are then entered into the QC Inspector Development Program which consists of six step Each inspector is required to complete an end of step test every six month Two failures of an end of step test results in removal from the program. Program development leads to the position of senior QC inspector in four years. Further training for QC inspectors -
and QA auditors consists of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant systems training provided by the plant training staff and the QA department. Other training is provided on an as needed basi The inspector interviewed several Quality Assurance Department personnel and reviewed selected QA training records, lesson plans, training materials and implementing procedures. During a review of QC inspector certification records, one QC inspector who did not perform a receipt inspection within the six-month proficiency demonstration interval was identified; however the interval had not exceeded the one year proficiency demonstration interval prescribed by the ANSI standard. The licensee committed to complete the required inspection prior to exceeding the one year interva In addition to the above, the inspector had the following comments concerning the QA Department training program:
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QA Department training instructors should receive the same instructor certifications required of the training center instructors
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The QA Department should be in the routing chain for all Power Services Assessment Group audit Within the area of QA Department training, no violations or deviations were identifie Shift Technical Advisor Training NUREG-0737,Section I.A.1.1 requires that the position of Shift Tech.nical Advisor (STA) be established and that a training and qualification program be maintaine The long-term STA training program was submitted to the NRC by VEPC0 letter, dated June 18, 198 *
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By letter dated January 6, 1982, the NRC responded that the STA training program "is acceptable in meeting the intent of guidelines set forth (by the NRC)."
A review of the training records, qualification / evaluation reports and requalification records of seven STAS indicated that they had been trained within the requirements of the program. The class schedule, training guide, and selected examinations for STA Class 84-1 were also reviewed. It was observed that while the topics covered were the same as in the training and qualification program submitted to the NRC, the time allotted to certain topics had been increased (such as materials from two to four days) or decreased (such as mathematics from nine to-two days). The total time for the program was the sam Licensee representatives stated that the time spent on the topics had been modified based on the experience and qualifications of the students, as well as the evaluations from previous classe In that the program had been accepted as meeting the " intent of the guide-lines", rather than a specific approval of the submitted program, the licensee concluded that adjustments could be made without formal NRC approval if the topics were still covered. This appears to be a valid evaluatio In reviewing the initial training and requalification training test records for the STAS it was observed that some scores on periodic examinations were less than 70%, although the cumulative averages were greater than 70% . The licensee representatives stated that a low score on a periodic examination was not considered to be significant since STAS in training must pass a comprehensive examination and qualified STAS must pass an annual requalification examinatio '
A test score of less than 70% indicates that the individual does not have a solid mastery of the material. A program or system should be formalized to assure that when a test score is less than an established level, remedial or supplemental training and counseling are provided and a re examination give The test score on the re-examination should be documented to demonstrate that the individual has a satisfactory mastery of the material. The establishment of a remedial program will be identified as Inspector Followup Item (280,281/84-31-05).
Within the area of STA training, no violations or deviations were identifie Support Engineer Training At present, there is no formal training program for engineers except for those to be qualified as Shift Technical Advisors. Plant Procedure ADM-12, " Qualification and Training", Section 3.4.2.e states that developmental programs for engineering personnel will be included in the training plan. Through discussions with plant training personnel, t _
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and a review! of the Surry Training Center Training Administrative Guidelines and Program Guidelines, it was determined that the developmental program does not exist. Quality Assurance Audit 83-03 of the training program identified this as a finding of "no documented evidence of developmental training program for engineering personnel".
The completion date for corrective action is being tracked as 12/31/8 Licensee representatives,-both plant and corporate stated that Engineer Training / Continuing Training Programs are currently in the development stage as a result of the QA audit. These programs are scheduled to be completed by April 1985. The programs will be implemented by July 1, 198 The draft training program covers a 12 month period and includes classroom, self-study and on-the-job training which is monitored by Job Performance Measures . (JPMs). In addition, the program includes attendance at the Plant Systems Course and a Technical Writing Cours In that the implementation date of this program is 1985, and.that there has been no developmental program for current staff members, ' the question of attendance in the program for current staff engineers should be addresse Licensee management acknowledged that criteria would be developed to determine which' engineers will be required to complete the program (either completely or partially) and which engineers will be exempted. Implementation of the engineering training program will be identified as Inspector Followup Item (280, 281/84-31-06). Maintenance Training Plant procedure ADM-12, Section 3.9.2 specifies that mechanics will be entered in the Power Section Mechanical Development Program (Revised),
and upon completion, will be transferred into the Mechanical Continuing Training Program in accordance with the Training Center Program Guide 16. ADM-12, Section 3.9.3 specifies that electricians will be entered
- into the Power Station Electrical Development Program (Revised), and
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upon completion, will be transferred into an Electrical Continuing Training Program in accordance with the Training Center Program Guide 1 Through a review of the Program Guides and discussions with training personnel, it was determined that neither of the revised development
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implemente Mechanics and electricians are presently in the
" original" development program (not the revised program).
A review of the " original" training programs showed that they include:
(1) formal, structured requirements (2) specific criteria for evaluation and advancement-t
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s (3) formal examination requirements (4) on-the-job training and evaluation .
(5) formal classroom training i All mechanics participate in the continuing training program, regardless of their statu Continuing training ~is scheduled around plant-outage The training is conducted using formal class outlines, training aids,- etc. Additionally, vendor-conducted courses have been utilized as part of the mechanics continuing trainin Since June 1984 there has not been an . instructor at the Surry Training Center for the Electricians Training Progra Recruitment of a qualified instructor is in progress. In the interim, the electricians have received training conducted by vendors which is classified as
"special training" but which also serves as " continuing training."
Plant Procedure ADM-12, Section 3.8.4 specifies the initial training and qualification program for new Nuclear Instrument Technicians as well as the continuing training program. The details of the two programs are contained in the Surry Train Center Program Guides 7 (Development) and 8 (Continuing). Both programs have been approved and implemente Through review of the Program Guides, training records and discussions with the training personnel it was determined that the development program includes:
(1) formal, structured requirements (2) specific criteria for evaluation and advancement (3) formal examination requirements (4) on-the-job training'and evaluation (5) vendor schools Program Guide 8 specifies that continuing training for the technicians will be _eight hours of instruction per quarter. From a review of the training schedules and records, and discussions with the training personnel _ it was determined that the quarterly training has consisted of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, and has included' use of the plant simulator for demon-stration purpose A licensee representative stated that a controlled study course (slides, sound track, training materials) has been procured and will be instituted in 1985 for technicians in both the development and
- continuing programs. Also, a review / revision of the Job Performance Measures will be conducted in 1985 to assure that they reflect current requirement Within the area of maintenance training, no violations or deviations were identifie . North Anna Training Assessment The North Anna assessment was a followup inspection to the Surry Assessment
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and was utilized to establish a basis for evaluating overall _ utility training. As such, the areas assessed included the following: Licensed Operator Training Non-Licensed Operator Training . Instructor Qualification General Employee Training Shift Technical Advisor Training . Support Engineer Training Maintenance Training Although deficiencies in several areas of plant training were identified, training was determined to be adequate to support continued plant operatio This assessment was based solely on the evaluation of in place training programs. It is important to note that major improvements to plant training
' programs _were being developed in efforts to achieve INP0 accreditation, Licensed Operator Training (1) Licensed Training: The results of the written section of a recent R0/SR0 hot license examination at North Anna indicates that deficiencies may exist in the License Training Program. There appeared to be no approved controlling license training program document. The training staff indicated that they were utilizing various sources for direction, including sections of the Surry License Training Program and INP0 guidelines. This lack of'a single defined program probably contributed significantly to the lack of complete success. The lack of current systems texts also appeared to be a contributing factor. New systems texts are under development by a vendor and should substantially aid future license classes. A review of lesson plans indicated that many were written in 1979 and have never been formally revise Numerous hand written changes were in the lesson plans, but_no date or approving signature or initials were included by each chang These lesson plans are under redevelopment with objectives and with question _ banks tied to the lesson plan objectives. These new lesson plans appear to be a substantial improvement and should enhance both license and requalification training. When the new Performance Based License Training Program is approved and implemented, along with the new systems texts and lesson plans, license training should greatly improve as well as the license examination results. This area will be reviewed in subsequent inspections and will be Inspector Followup Item (338, 339/84-39-01).
(2) Requalification Training: As at Surry, it has been acceptable in the past for licensed staff personnel to be exempted from an entire ~ year of requalification training based on annual requali-
) fication ' examination scores of greater than 80%. It appears that the intent of the new Licensed Operator Requalificat-ion Program t
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(LORP) is that all licensed individuals will attend requalifi-cation training, except where excluded from specific lectures per 10 CFR 55 Appendix A. In addition, the proposed LORP requires that all personnel, including training staff and backup licensees, who are to maintain their licenses active will spend at least five days per quarter on shift performing licensed duties. Under this prop'osed program, NRC licensed personnel who cannot meet this requirement will have their licenses declared inactiv The scheduled implementation of this revised LORP is presently January 1,1985. The implementation of the revised LORP, and the requirement to perform licensed duties to monitor an active license in accordance with 10 CFR 55.31e, will be examined during future inspections and will be Inspector Followup Item (338,339/84-39-02).
It was noted by the inspectors that although different annual requalification examinations were given to each shift, the same requalification cycle quiz is utilized for all five shifts. Since the shifts take the cycle quizzes on different dates, the possibility that questions might be passed on could be reduced by providing at least two different quizzes or a separate quiz for each shif A review of security for test question banks for License, Non-License, and Requalification Training, indicated that they were all stored in locked file cabinet It appeared that these file cabinets, which are located next to various training staff desks, also contained a r. umber of fully assembled tests. It is recommended that assembled tests be stored separately from test banks, preferably in the records vault or another high security are The North Anna Requalification Program requires that when an NRC licensed R0 or SRO is removed from licensed duties due to failure of the annual requalification exam that certain records be retained. Among the records listed for retention are the letter of removal from license duties, accelerated training completed, tests and answer keys, and letters of requalification and return to duty. Two files of individuals who had failed the annual requalification examination in 1982 were reviewed and found not to contain a record of removal from licensed duties. The licensee performed an extensive search for these records, but at the time of the exit meeting had not located them. Subsequent to the exit, the licensee conducted a review of control room logbook entries for the period involved which indicated that the operators had not stood the watch. The inspectors consider this to be an isolated case of training document misplacemen (3) Simulator Training: The inspector observed a makeup simulator class for three STAS and two licensed individuals. Although the group did not appear to be as organized as a shift unit, they reacted very well to a less than obvious casualty, and located the affected Technical Specification LCO in a reasonable length of I i
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tim Although the North Anna simulator is new, recent hot license examinations indicate the simulator training to be very effective. Much of this early success is probably due to the fact that licensed plant personnel were included in the operational acceptance testing of the simulator and also that the simulator requalification training utilizes the shifts as a functional unit including the STAS in their designed ' rol The inspectors verified that Anticipated Transient Without Scram (ATWS) training on the simulator had been provided to all five operating shift The inspectors recommended that this training be provided for all future license groups, as well as becoming one of the required requalification control manipulation b. Non-Licensed Operator Training As at Surry, the North Anna Non-Licensed Operator Training Program is undergoing transition to a performance based progra The basic systems training being utilized at the present time is very general and is presented concurrently to groups other than operators, including maintenance and security personnel. The inspectors observed that the systems course in progress was very large and was being taught in a small classroom which appeared overcrowded. Since the operators being hired at North Anna have Navy Nuclear experience, it would be benefi-cial to design this course for operators, and present it separately from the non-operating personnel. The inspectors noted that seven of nine recently hired non-licensed operators had not attended systems training due to manpower requirements of a recent plant outage. The backfit training of these seven operators will be inspected during a subsequent inspection and will be Inspector Followup Item (338,339/84-39-03)
There is no available up-to-date systems text for non-licensed operator training, as in the case of licensed operator training. The licensee indicated that the system texts presently under development by a vendor will be issued to licensed and non-licensed operators as each unit is complete As at Surry, the test pass criteria for non-licensed operator training courses is 70%, as opposed to 80% for licensed individuals. Since all non-licensed operators eventually enter license training, the transition might be less demanding, and the success rate possibly higher, if operators were accustomed to this 80% requiremen Unlike Surry, North Anna has never deleted the academic training from the first non-licensed operator qualification checklist These academic checklist items, however, were based on self-stud The new performance based non-licensed operator training program will include a six month introductory course which includes formal classroom academic training and should be far superior to the present program. As at Surry, the past practice has been to allow new hires with Navy experience or Memphis State Nuclear Fundamentals Training to by pass the
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first three in plant qualification steps. The only requirement was to
- pass the written examinations on the three steps, which did not ensure that the individuals were adequately trained on in plant locations and the operation of systems and equipment. ' The new performance based qualification will allow accelerated qualification by individuals with previous experience, but will require that proficiency be demonstrated on each step-checklist item through verbal discussion with a licensed
. operator, a system.walkthrough with a licensed operator, and an overall
. performance appraisal by a superviso .The inspectors noted that North Anna is in the process of adding a Training Coordinator to each shift which should greatly enhance the Non-Licensed Operator Watchstation Qualification Program. The Non-Licensed Operator Requalification Program was recently reinstituted following a shutdown from May to November, 1984 due to manpower requirements for plant operations The inclusion of the non-licensed operators as observers in licensed simulator training for eight hours each requalification cycle should prove very beneficial. In addition to the one- day of simulator observation, one day of the non-licensed operator four day requalification cycle is presently classroom instruc-tion and the other two days are self-study. When the instructor shortage is' resolved, it is recommended that more than one day of non-licensed operator requalification be utilized for classroom trainin Areas of training should be similar to license requalification training, but with emphasis on non-license operator responsibilities in those area It was noted by the inspectors that no remedial actions are taken when non-licensed operators fail their cycle qui To ensure that non-licensed operators maintain an acceptable level of knowledge in important requalification training areas, that they are encouraged to obtain maximum benefit from the time and effort expended, and that proper study habits are instilled for license training, some level of remedial action should be taken to upgrade deficient areas. Due to the time delay between being hired as a non-licensed operator and entry into license training, the skill levels attained in such areas as reactor theory, mathematics, physics, and chemistry can decay to the point where it hampers the ability of individuals to succeed in license training. Academic training should be included in the non-licensed requalification training to help maintain these skill levels attained in the Navy, Memphis State, or the VEPC0 six month introductory cours Instructor Qualifications The Instructor Certification Program at North Anna is presently in ,
transition to a performance based program as it is at Surry. The certification method utilized in the past consisted of training and evaluation by the Training Supervisor. All active instructors have been certified under this original program. The new Performance Based Instructor Certification Program consists of a seven day basic section, and a two year Master Instructor Certification Modul Based on a
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recent evaluation, which indicated that the experienced North Anna instructors already have the equivalent training contained in the seven day basic certification course, the licensee has elected to waive this trainin The instructors will all enter the two year Master Certification Program which is essentially self-study with performance based evaluations by training staff and supervision. The inspectors recommended that the video-taping / instructor evaluation section of the seven day certification course be retained and utilized for all staff instructors, as this could serve as a valuable tool in helping to upgrade instructor performance and confidenc This training' was not
. included in the original instructor certifications at North Anna. The licensee indicated that all staff instructors should begin the two year instructor certification course by January 1985. The progress of this new instructor certification program will be monitored during future inspections and will be Inspector Followup Item (338, 339/84-39-04).
All North Anna instructors teaching license classes and the simulator were SRO licensed except on The one exception was a former I&C technician who recently joined the training staff, and who is limited to teaching Instrumentation and Control. The use of non-SR0 certified or licensed instructors should be limited to non-safety related systems in which the instructor has demonstrated expertise, and should never include integrated plant operation or simulator training. This does not preclude the use of subject experts without a SRO license as guest lecturers in their area of expertis It was noted by the inspectors that the SRO licensed instructors had not been assigned to licensed duties on shift since becoming instructors. These instructors cannot stand shift duties until the requirements of 10 CFR 55.31e are met. The licensee has proposed that effective January 1,1985 all personnel, including staff instructors and backup licensees, who are to maintain active NRC licenses must spend five days per quarter on shift performing licensed duties. NRC licensed personnel who cannot meet this proposed requirement would have their licenses officially declared inactiv The implementation of this proposal will be monitored during subsequent inspections and will be Inspector Followup Item (338, 339/84-39-05).
North Anna has an established form for performing instructor evalua-tions and several completed evaluation forms were reviewed by the inspectors. The forms appeared to be adequate in scope for evaluating instructor performance and providing feedback to the instructors and included a section for instructor response to the evaluatio The licensee indicated that these evaluations will be performed on a regular basis under the new instructor certification program by both training staff personnel and training supervisors. Student evaluation sheets were not being distributed to all classes and the training staff indicated that there was a lack of response by trainees when they were distributed. The inspector recommended that they be utilized for all classes, and that constructive response could be encouraged by requiring that all students complete the evaluations, performing an
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adequate review of the responses, and. finally by giving timely feedback to the students of actions taken on concerns and recommendation General Employee Training The' North Anna GET program consists of classroom instruction in company policy, station contingency procedures, station access ~ control and security, radiol gical health and safety, use of protective clothing and equipment, industrial safety and fire protection, QA/QC, and station familiarization. All regular station employees receive General
- Employee retraining annually (12 months). Employees who fail to attend GER within the 12 month period or who fail to achieve a passing score on the recertification exam are denied access to the plan GET -is procedurally controlled by ADM-2.3, General Employee Trainin program. The inspector reviewed ADM-2.3 and the GET lesson plan Selected personnel training records were reviewed to determine if GER
.was being completed at least every 12 months for station employees. On January 1,1985, the licensee plans to implement a revised GET/GER program. Review of the new GET/GER program will be identified as an Inspector Followup Item (338, 339/84-39-06).
Within the-area of GET, no violations or deviations were identifie Shift Technical Advisor Training The North Anna STA Training program was outlined by VEPC0 letter dated June 18, 1981 and accepted by the NRC letter dated January 25, 198 'A review was made of the 1983 and 1984 class training records, two STA training records, lesson plans and the STA training program dated October 20, 1982. -The review of the 1984 class training records revealed that the STA class was combined with the R0 training clas The combined class covered the required topics specified by the STA training plan with the exception of Management training. Management training for STAS was committed to by the VEPC0 letter dated June 18, 1981. The inspector informed licensee management that the lack of management training is a deviation from North Anna's STA training program (Deviation 50-338/84-39-07,50-339/84-39-07). .The licensee informed the ' inspection team that management training would be conducted for the 1984 STA class by January 20, 198 On completion of initial training and certification, the STAS are enrolled in the Licensed Operator Requalification Program. A compart-son of these two programs revealed that the grading criterion is differen The initial training requires a passing grade of 70%, but i; once an STA is in requalificaiton training the passing grade is 80%.
! It is recommended that the minimum grading criterion for initial training be 80%, so that the student becomes accustom to the higher
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The overall training program for STA's appears adequate and should provide the training needed to perform the function of ST f. Support Engineer Training Program Like Surry, North Anna has no formal training program for engineers. A new engineer will receive General Employee Training and may receive a 40-hour basic plant systems cours The licensee stated that an Engineer Training / Continuing Training Program is under developmen This program is scheduled for completion and implementation by the middle of 1985. The concern as outlined in the Surry section for backfitting training for existing staff engineers also applies for North Ann Implementation of the engineer training programs will be identified as Inspector Followup Item (338, 339/84-39-08)
g. Maintenance Training A review of Power Station Mechanical Development Program and Power Station Electrician Development Program was conducted. These programs are in a transition phase. As of January 1984, all new hires were placed in the revised Development Program. The old program is still applicable for personnel hired before January 198 The old development program is 63 months in length and consists of 11 separate step The basic program is on-the-job training for approximately six months in each step. During this time the trainee-has text books to study and homework to hand in to the station training department. At the end of each step, the trainees' foreman completes a work appraisal (practical factors) and personnel evaluation form on the traine Then the training department administers the end-of-step examinatio The revised development program is 56 months long and is divided into nine steps. The revised program incorporates classroom training in basic skills training (10 week course) and electrical or mechanical intermediate skills training (10 weeks). Also each step is divided into module training sections, which are in one-month interval On completion of a module, the trainee is given a written tes The trainee must pass all module tests in a step with a grade of 70% or better before he is advanced to the next step. The revised program is an improvement over the older program in that the training department and maintenance foremen will be able to track the program and progress of a trainee on a monthly basis instead of every six month North Anna has established a training laboratory for maintenace training. This lab will improve the knowledge level of maintenance personnel by giving them hands-on training with equipment that is similar to plant equipment.All maintenance personnel participate in the station continuing training program. This training is conducted using formal class training, laboratory training, and vendor-conducted
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trainin The revised development program and the continuing training program appear adequate to meet the needs of the maintenance personne The Nuclear Instrument Technician Development Program is a 48 month program divided into eight six-month steps. The program is structured similar to the maintenance development programs. To complete a step, a trainee-is given text books with homework assignments to hand'in to the training departmen He must also perform a set'of practical factors and take an end-of-step examinatio After the trainee has successfully completed all eight steps, he is certified a technicia .The re-training program consist of 12 topics (minimum) to be given over a two year perio At the completion of the two year cycle, an examination is administered which the technician must pass with a grade of at least 70% or he will be retested. The Nuclear Instrument foreman keeps track of trainee practical factors completion by use of a
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computer data system. This allows the foreman to maintain an accurate status of trainee progress and also allows the training department to maintain _a pr~ ogress record on the trainee. It is recommended that the other maintenance departments develop a similar tracking system for their trainee Within the area of maintenance training, no violations or deviations.were identifie _-