IR 05000322/1987014

Special Team Insp Rept 50-322/87-14 on 870622-26.No Violations Noted.Major Areas Inspected:Training & Qualification Program Effectiveness & Licensee Corrective Action Re Performance of Audit NB-86-01

ML20236J379
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/28/1987
From:	Cowgill C, Roxanne Summers NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236J359	List: IR 05000322/1987014 ML20236J356
References
50-322-87-14, NUDOCS 8708060158
Download: ML20236J379 (45)

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U.S. NUCLEAR REGULATORY COMMISSION

. REGION I Report N /87-14 Docket'N ' Licensee: Long Island O ghting Company Post Office Box 618 Wading River, New York 11792 Facility: Shoreham Nuclear Power Station Inspection At: ~ Wading River, New York Inspection Conducted: June 22-26,'1987

. Inspectors:

C. J. Cowgill, Chief, Reactor Projects

'.Section 10, Division of Reactor Projects (DRP), Region I-R. J. Summers Project Engineer, R7 actor Projects Section 28, DRP C. S. Marschall, Resident Inspector - Nine Mile Point Units 1 and 2, DRP l- R. Lo, Licensing Project Manager, Project Directorate I-2, NRR -

K. H. Gibson, Resident Inspector.- Salem Units 1 and 2, DRP W. Oliviera, Reactor Engineer, Quality Assurance Section, Division of Reactor Safety (DRS)

J. A. Prell, Reactor Engineer, Operational Programs Section, DRS Inspection Accompaniment: S. Sholly, New York State (Consultant) MHB Associates Reviewed By: k. L .be R. J.0 Summers, Project Engineer, Reactor OWW Q Ddte Pro ects Section 2B,

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Approved By: )

C. J J Cowgi Chief, Reactor Projects k 14d e

Section 1

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SUMMARY Special Team Inspection on June 22-26, 1987 (Inspection Report No. 50-322/87-14)

Areas Inspected: Special team inspection to evaluate training and qualifi-ation program effectiveness and review selected . licensee's corrective action resulting from the performance of LILCO audit NB-86-01/QS-86-0 Results: No unacceptable conditions were identified. The actions implemented by the licensee in response to NRC inspection report 50-322/86-03 and LILCO i audit NB-86-01/QS-86-03 were reviewed. It was determined that the licensee's training and qualification program had undergone a major revision to incorpor-ate the recently established training center and Office of Training. Licensee actions were determined to be effective and timely. Management involvement in establishing and implementing training program requirements was evident, and the knowledge level of individuals' was appropriate to their assigned duties. A review of the findings of LILCO audit NB-86-01/QS-86-03 showed that, at the time of the audit, weaknesses exi:,ted in procedural adherance and the licensee's training record management process; however, it was established that appropriate training had been conducted. The inspection involved 313 inspector hours by the Region I tea J I

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~ DETAILS Introduction In response to NRC inspection findings contained in NRC report 50-322/86-03 regarding the adequacy of radiochemistry technician training and performanc'e, 'LILCO performed a detailed. audit (NB-86-01/QS-86-03) of all station and corporate support staff training programs and necessary .

supporting documentation at Shoreham in April 1986. The licensee identi-fied a number of audit findings to senior corporate management as areas

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which required specific corrective action Subsequently, LILC0 initiated

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a program in July 1986 to address these and other audit. findings,.to

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l enhance oversight of the training and qualification program at Shoreham, and to support planned accreditation of' selected training programs by the Institute of Nuclear Power Operations (INPO). Purpose an.d Scope

.In accordance with NRC recommendations-contained-in the most recent

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Systematic Assessme'nt of Licensee Performance (SALP), dated November '24, 1986, Region I conducted a special inspection of LILC0 actions.. The objectives of the inspection were to: (1) ascertain whether the licensee had dedicated sufficient manegement attention to establishing adequate training for. personnel in required plant areas by assessing the adequacy and effectiveness of the licensee's corrective action program regarding the actions taken following the training and qualification audit of April

'1986; and (2) to assure that training programs were appropriate to the needs of the personnel by review of selected training programs, direct

- observation of work activities, and interviews of plant and training personne . Inspection Findings and Overall Assessment Following completion of the inspection and review of findings the NRC team concluded that the licensee had taken adequate corrective action for all findings included in the_ subject audits. Further, the team concluded that no violations of NRC regulations were identified as a result of the-inspection review The inspectors noted that at the time of the licensee audit in April 1986, there were inconsistencies-in the way the various station departments documented their training and also, a number of pro-cedural adherence problems. This led to an overall weakness in training record management and documentatio The NRC team established, however, that based on the followup of the April 1986 LILC0 audits sufficient records existed at the time of the audit to demonstrate that training required by NRC regulations had been conducte The NRC team noted that extensive licensee followup of the audit concerns had been performed, including quarterly audits of the training prcgram. In addition, periodic progress reports were provided to the Vice President-Nuclear regarding the closecut of individual audit finding l

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The NRC team review of selected department training programs indicated

l that the. programs met or exceeded regulatory requirements and that each had either been submitted for accreditation by INPO or was scheduled to be submitted by Septembcr 1987. During the review, the team noted that there  ;

was substantial support from senior licensee management and station j management in the training of employees. The NRC team also noted that  !

personne1 ~ interviewed were aware of training requirements and had suffi-cient knowledge to perform their task Finally, the team noted that the licensee was in the process of revising the method used to maintain official training records. The revised record management system, which will be a computer-based system maintained by the Office of Training, is scheduled for final implementation in August 1987. The licensee stated that a followup audit would be performed to ensure that all training records had been properly entered into the system. . This program is being implemented to correct previously identi- ,

fied weakness in training rect t managemen '

4. Review of LILC0 Actions for the April 1986 Audit'(NB-86-01/QS'-86-03) of Training and Qualification (T&Q) Programs In order to establish its scope and effectiveness the NRC inspection team conducted a review of the licensee's April 1986 audit findings and sub-sequent action The general program for the review consisted of record and procedure reviews, discussions with licensee staff and management, i comparison of licensee programs with NRC requirements, and inspector judgemen In general, the 35 audit findings could be categorized into three functional areas: records management,. internal procedure imple-mentation and maintenance, and integration of the Office of Training into the.T&Q Program. It was determined that in response to the-35 audit findings the licensee had completed all corrective actions in a timely manner. Quality Assurance (QA) review of the corrective actions was evident and, in addition, QA audit and surveillance activities associated with the development and implementation of the new T&Q Program provided appropriate feedback to corporate management to assess timely implementatio In order to effect long-term corrective actions for the audit findings, the licensee established a Task Force that proposed a new T&Q Program in July 1986. The new program, which the licensee began implementing on trial basis in August 1986, is scheduled to be completed and fully imple-mented in August 1987. One objective of the program is to enable the

licensee to obtain INPO accreditation. The program incorporates the function of the new Office of Training, establishes the new office's interface with the technical divisions, and delineates the roles of the divisions in the training and qualification of personnel. The new, fully computerized program will centralize documentation of qualification re-quirements, training programs, training records and individual quali-fication files. Licensee management expects the new T&Q Program to correct the underlying causes of the majority of the subject audit findings: 'for example, inconsistency of procedures and policies, poor records - .- _ _ _ __ _ _ _ __ - _ _-___-_- _ _ _

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. maintenance and the lack of,adhncence to procedure The NRC team review

$ and assessment of each audit-finding and corrective action (s) is discussed

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in the following section c

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h Descripti4j; i

Training and qualification records for equipment operators (E0s) land health physics technicians (HPs) were not in accordance with QA h ual,.

Section 17, paragraph 17.3.2.b and station procedure (SP) 21.006.(1L

" Station Operator Training and Qualification Program". The station pro-cedure required each replacement E0 to complete the E0 qualification ,

requirements for a dhen area prior to being recommended for qualification ,;

in that area, but the' records did not show that this requirement had been 3 met.tA}so, certaip],HP. celebration work was performed by an unqualified individua ./

Licensee Corrective Action The licensee corrected the' deficiencies h the E0 and HP records, as well as the procedures, in a timely manner. QA verified the corrective actions,t which included:

p The operating' engineer countersigned the missing sign offs of all the E0 folders. Where queMions arose regarding performance of

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on-the-job-training, the'E0 was requalified by the watch enginee '. lhe requirement for the training section to sign the completed qualification guide was considered unnecessary according to INP0 g guidelines. The requirement was deleted from the implementation

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procedure and the qualification guid . The operations department will be more specific regarding whether-on-the-job training was conducted while the E0 was on shift wor .(

. The operations department determined that remedial acti.on was not necessary for the identified EOs in the licensed operator program whq'

had not yet completed all the EO qualification '

i HP technicians were qualified, and their records (which were missing during the audit) were being processed through the HP enginee ,

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< The foreman attested, in a memorandum, that the identified HP

' technician had performed calibration work under his supervision. QA sampled another 20 work records to assure that this was an iso'.ated cas NRC Evaluation '

The inspector verified the corrective action by reviewing the Training and-Qualification records of four E0's, an HP qualification card, applicable

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y n 7-changes to procedure SP 61.040.01, " Health Physics Technician, Selection, Training and Qualification," and the subsequent Nuclear Review Board (NRB)

Audit 87-02~. In verifying the corrective actions for Finding 1 regarding performance of on-the-job training (0JT), the inspector reviewed the qualification manuals for four EOs with the operating engineer. Each

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manual has over 25 qualification cards. Each card contains approximately

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25 to 50 tasks that are to be performed by the' E0 and signed off by an OJT evaluator. The completed card. is signed by the watch engineer after an

. evaluation of the E0's performance. The. inspector reviewed five cards-from each manual and noted that the missing signatures identified in the audit finding were countersigned by the operating engineer. Through later discussions with several E0s and OJT evaluators, the inspector determined that the E0s were qualified to perform their assigned task :The inspector. interviewed the HP engineer and-an HP foreman regarding.HP technicians not being qualified in a functional area until the area was signed off by the HP engineer. Both individuals were aware of this-requirement; however, they also noted that the procedure would allow an HP technician to qualify and perform specific tasks in the functional area prior to full qualificatio The inspector also observed an HP foreman conducting an onsite, phase 5, practical factor class on radioactive materials handling for HP technicians. The inspector determined that the HP technicians were qualified to perform their assigned task Implementation of the T&Q Program (that is, computerizing of the records)

is intended to ensure that T&Q records are maintained curren No violations were identifie .2 Audit Finding No. 2 g> f 1 Description I&C section and maintenance section personnel were qualified ~without ade-quate support g documentation for vendor provided training, on-the-job training and -opriate resumes, which were required by Station Procedure SP 41.011.01, "I&C Technician Qualification Program" and SP 31.001.01,

" Training and Qualification of Maintenance Personnel."

License Corrective Action The licensee corrected the deficient individual training'and qualification files. Actual records of vendor and licensee training were available but were not properly filed. These records were located and filed properly, but not all records of on-the-job training were available. The licensee

. revised the department training procedures to require more specific

.information to be documented for on-the-job trainin I NRC Evaluation The inspector verified that the licensee had revised the department train- 1 ing implementing procedures to provide more accurate records of actual

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training, including on-the-job trainin In addition, the' inspector .  !

reviewed a sample of I&C and maintenance section individual training files and found.that the re' quired records were now being maintained in accordance with. applicable licensee procedures. On-the-job training records'were now available to, document various performance-related trainin 'The~ inspector also' interviewed five maintenance class A-1 mechanics regarding their. on-the-job training. The mechanics all . stated that even though the documentation of on-t%-job training had not'been maintained '

pmiously, such training 1,,R in fact ,oerformed and us/ful-to their job

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pitt'ormance. 'The inspects concluddd that the audit finaing pertained to trafning records management atid not actual insufficihint or inadequate, t ra', n i ng . J No violations werd identffied, .

4.3 ' Audit Finding No. 3 Description i

Certification of personnel for their assigned positions was not in accord-ance with Station Procedure SP 12.'003.01, " Personnel Qualifications and Responsibilities". "

Licensee Correctiva Action

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I The deficiencies were correctei regarding current certifications-for performance engineers, I&C technicians, radwaste operators and HP techni-cians. .The-Division of Training issued guidance through a memorandum dated day 22, 1986, which now requires monthly meetings with Office of Nucinar Operations area representatives to confirm that qualification records are being maintained curren NRC Evaluation The inspector verified that radwaste operator certifications were current, performance engineers no longer need certification (per memorandum dated June 4,1987), and clarification of the high school diploma or equivalency

. requirement was included in SP. 12.003.01, Rev. 18. The reeded corrective adtions were completed in a timely manner. The inspector slso verified as determined thrcugh discussions with the lead EO Instructor, that monthly meetings were being conducted. The memoranda from the lead E0 instructor

,have provided operations management with the results of the instructor's complete verification of the operator personnel training records. The inspector concluded that since actual certifications were maintained, the audit findings were' administrative procedural problems associated with updating the formal individual qualification folder !

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4'. 4 Audit' Finding No. 4'

4 Description

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Station Procedure SP 21.006 01, " Station Operator Training and Qualifi-cation Program," Revision 5, paragraph 8.2.3.1, provided for waiving

• .. training requirements for equipment operators, but did not provide for wai.ving- training requirements for licensed operators. Contrary to this, the area qualification certificates for six operators licensed in 1985 coniained the waiver " Qualified by virtue of completion of the' cold

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license, training program."

Licensee Corrective Action The licensee evaluated the performance of the individuals involved'and determined that no remedial training was needed. The training and quali-fication procedure was revised to allow training to be waived, if  ;

appropriat NRC Evaluation j

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The inspector interviewed operating and training department personnel, reviewed past and current training and qualification programs, and

-. reviewed' operations personnel training and qualification files. It was

. learned that as ' systems were being turned over to the operating staff from

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, construction staff, these operators were provided on-the-job training and performed work as EOs. Based on this experience and the fact that these operators had detailed systems training as part of the cold license t

program, the operating engineer waived the EO qualification requirement ,

Further, the inspector determined that for the identified individuals, the requirement for completing the EO qualification record was implemented after the licensed operator training program had begun. The operations department training and qualification program specifically addressed waiving E0 requirements but did not address waiving licensed operator training requirement Therefore, these operators had not completed the EO qualification require-ments principally because of the evolution of the training and qualifi-cation' procedures and program over a period of tim Following a review of these operators' training folders, the inspector concluded that the ,

operators were appropriately trained on systems and procedures equivalent I to that which would be obtained through completion of the E0 qualification l requirement The operations training and qualification program has since been revised to allow waivers of this type. The inspector concluded that actual quali-fications were appropriate to tF ci rcumstances .

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4.5 Audit Finding No. 5 Description Qualification matrix charts were not being properly maintained nor dis-tributed in accordance with various station procedures for I&C, mainten-ance, and health physics personnel in that some matrices contained errors or omitted expiration dates, and some were not properly poste Licensee Corrective Action The licensee revised station training implementing procedures (SP 12.003.01 and SP 31.001.01) to include expiration dates where necessary on the qua'ification matrice Matrix errors were corrected, and distribution was made in accordance with the station procedure NRC Evaluation The inspector verified that the appropriate station procedures were re-vised to include expiration dates on the qualification matrix. The in-spectors reviewed the qualification matrices for fire protection personnel, computer technicians, HP technicians and I&C and maintenance personnel. The matrices were being properly maintained, except that since resolution of the audit findings, the maintenance department had revised their manually maintained qualification matrix again, so that it no longer ^

included the annual vision test expiration dates for individuals qualified as examiners (Level 1, 2 and 3), ine inspector reviewed a sample of the station mechanic personnel qualification files and determined all qualifications were up-to-date, including the annual vision test require-ments. The maintenance department was already using the Office of Training computer-based records management system to track these types of periodic requalification requirements for department personnel in lieu of tracking on the manual qualification matri In additien, monthly audits of the qualification files are being conducted by the maintenance foreman to assure that all qualifications are curren As a result of the inspector's concern that the new computer-based program has not been officially accepted as operational, the manual matrix was revised to once again include the expiration dates, where appropriat When the new T&Q Program is fully implemented, however, the manual quali-fication matrix will no longer be needed, since the qualification data will be readily available at all user locations through the computer-based syste The inspector concluded that personnel qualifications were being properly maintaine The records management problem identified in this audit finding was corrected, and final implementation of the computer-based T&Q records system should prevent future similar problem The finding did not indicate actual training or qualification inadequacie No violations were identifie _ _ _ _ - _ _ _ - _ - - - -

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Description

. Maintenance of Training and. Qualification (T&Q) folders is not in accordance with Station Procedure SP 12.014.02, " Training and Qualifica-tions Folders." Also, evidence of training required by NRC Bulletin 79-19, " Packaging of Low Level Radioactive Waste for Transportation and Burial" was not included'in individual radwaste' operator training folders; evidence of Boiling Water Reactor (BWR) Chemistry' training was not in-

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cluded in the HP supervisor's folder; and the training requirements for the HP engineer did not correlate with his experience recor Licensee Corrective Action The HP engineer's. folder was updated and the six affected radwaste operators' folders were revised to include current Bulletin 79-19 certifi-cations. The Quality Assurance department verified that SP 12.014.02 was adequately replaced by Training Division Implementing Procedure (TDIP)

2-02,." Maintenance of Non-Computerized Records of Trainees and Programs,"

in conjunction with implementation of the new T&Q Progra NRC-Evaluation Through discussions with the HP supervisor, the inspector verified that based on the' individual's background and his position assignment, the HP engineer was not required to participate in the BWR chemistry cours This fact was later confirmed through discussions with the chemistry department hea Updated (Final) Safety Analysis Report (USAR) paragraph 13.2.1.2.2.1 concerning selection for participating in the BWR chemistry course is based on individual background and expected position assignmen The inspector verified that the radwaste operator folders did contain current Bulletin 79-19 certifications, as well as other required qualifi-cation data. Based on the reviews of qualification folders for this and other audit findings, the inspector has determined that the official training records are being maintained in accordance with the current procedures. Also, sufficient evidence was available at this time of the audit to demonstrate that appropriate training was complete No violations were identifie .7 Audit Finding No. 7

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Description L Resumes or employment applications were ; updated or maintained in

accordance with internal guidance in the Vice President-Nuclear memo-L randum, VPN 086-48, dated March 3, 1986. ____________J

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Licensee Corrective Action The resumes of four operations personnel, two radiochemistry personnel,.

and three radwaste operators were updated. Resumes for the instrument and control (I&C) engineer-in-training and the compliance engineer were added to their respective personnel files. The USAR (paragraph 13.2.6.3) was revised _to require a resume or employment experience, and qualifications  ;

be included in the personnel file, i NRC Evaluation The inspector verified that the radwaste operators and some of the EOs had resumes in their files. The ir spector also verified that paragraph 13.2.6.3 of the USAR was changed accordingly. The new T&Q program records management system will ensure that future qualification records will be-properly maintained so as to include a resume or employment experience, and appropriate qualifications. Although the findings indicated a failur to edhere to the licensee's internal policy, the inspector determined that actual personnel qualifications were maintaine No violations were identifie .8 Audit Finding No. 8 Description Eye examinations were not being administered on a yearly basis as required by Station Procedure SP 12.003.01, " Personnel Qualifications and Responsi-blities," and paragraph 3.2.1 of American National Standard ANSI N45.2.6-197 Licensee Corrective Action The licensee completed actions, including performing the eye examinations onsite, as well as revising SP 12.003.01 to incorporate the records 4 management elements of the new T&Q progra NRC Evaluation The inspector verified that the annual eye examinations were conducted and current for the radwaste operators and EOs. The inspector noted that the i subsequent quality assurance audit (QS 86-11) and LILCO deficiency report  !86-102 reported annual examinations not being current. These findings and deficiencies were also correcte The eye examination deficiencies were corrected expeditiously; however, the revision of SP 12.003.01 was delayed. This resulted in QA issuance of corrective action reports to management to make senior management aware  ;

that full, timely corrective action was not implemente The procedure )

was subsequently revised in November 1986 to incorporate various features i

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of'the new T&Q Program that should prevent recurrence of this records:

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management proble The inspector determined that the corrective actions '

were adequate; and, although the. procedure revision was delayed, QA was actively pursuing the' issue to assure completion of the required action There were no indications that individuals' qualifications were  ;

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N'o violations were identifie .9 Audit Finding No. 9 Description .

Contrary to ANSI N18.1-1971 requirements, LILCO auditors could not find documentary evidence that (1) a training program existed for management, supervisory and technical / professional personnel and (2) individuals who were assigned to the engineer-in-training (EIT) program had the benefit of a formal training program that would clearly identify responsibility, authority and acceptance criteri Licensee Corrective Action The licensee provided evidence that existing management courses met the ANSI N18.1-1971 requirements; and, a formalized EIT training program was implemente NRC Evaluation The inspectors reviewed licensee si e and corporate training records for supervisory personnel and determined that training was provided. The inspectors found documentary evidence that training programs for Shoreham first-level and second-level supervisors and division managers had been conducted. These training programs consisted of a six-day Basic Supervisory .vorkshop, a two-day Supervisory Skills Seminar, a five-day Supervisory Skills Followup Workshop for second-level supervisors and a ten-day Management Workshop for division level managers. It was noted, however, that Shoreham management participation in these programs was much more evident during the past two years than prior to receiving a low power-level license. These workshops and seminars were found to meet all regulatory requirements. Also the inspectors noted that, during the years 1984 and 1985, training had been significantly reduced because of financial constraint At the time of the April 1986 audit, the engineer-in-training (EIT)

program was only in its first year of implementation. No formal program description had been approved; however, appropriate management controls were placed on the EITs through direct supervision, and INPO recommended training was completed. The inspector interviewed various department management, Office of Training personnel and select EITs to determine that such controls and training were consistent with ANSI N18.1-1971 requirement _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The Office of Training is in the final stages of developing a formal technical staff and managers training program for. submission for INPO accreditation in September 1987. Technical training modules have been identified and are now being developed. The Office of Training is pre-paring these modules based on plant and INPO recommendations. As out-lined, this program will consist of three phase Phase I will be a three-month formal classroom training program for EITs. Phase 2 will consist of on-the-job training assignments in various plant section ~

This will'1ast for about one and one-half years, with each segment lasting about four months. fhase 3 will be for first-level and second-level supervisors and division manager It will consist of the training courses outlined previously that are presently given to supervisor Based on the considerations described, the. inspector determined that the previously established supervisory training programs did meet the established requirements. The licensee's corrective actions will, however, provide better oversight of the programs than was previously available. The inspector determined that based on the review of super-visory training records and a review of the technical qualifications of selected managers and supervisors, as well as selected personnel inter--

views, the licensee had at the time of the audit met all' regulatory requirement No violations were identifie .10 Audit Finding No. 10 Description Station training procedures were inaccurate in that they lacked informa-tion or contained inaccurate information, such as appropriate reference to the Nuclear Training Division and the appropriate titles of individuals responsible for training program implementatio Licensee Corrective Action The licensee corrected the discrepancies by incorporating new titles and k i

making reference changes, as appropriate, in the procedure NRC Evaluation The inspector reviewed the audit finding details and determined that the inaccuracies were editorial and that procedure revisions were required to make changes of titles of individuals responsible for implementation and changes or deletions of portions of procedures no longer applicable. The ,

inspector reviewed a sample of the licensee's corrective actions and j verified that the procedure revisions had been made to correct the stated i deficiencies. In July 1986, the licensee's Training and Qualification

, . Task Force addressed the preventive action by proposing a new T&Q Program for all plant staff and support organization Implementation of this program, while in a draft or trial form, was mandated by the Vice

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President for Nuclear Operatio- on August 8, 1986. As a result of the trial program, some revisions were made to achieve complete coordination of the effort and incorporation of the Office of Trainin Final imple-mentation is scheduled to occur by August 1987, and the revised program should prevent future inconsistencies among the station departmental procedures that were identified in this audit findin In conclusion, the inspector determined that this finding was administrative in nature and that neither the training nor qualifications of personnel were adversely affecte No violations were identifie .11 Audit Finding No. 11 Description Contrary to USAR Section 13.2, no objective evidence could be found to document the " individual study program" for I&C technician requalificatio Licensee Corrective Action The licensee revised the USAR to delete reference to the " individual study program."

NRC Evaluation The inspector determined that the " individual study program" referenced in the USAR was a very general description of a portion of the actual requal-ification progra In practice, this program consisted of required read-ing and group meetings (tailboard sessions) to provide feedback to the l technicians of plant and industry experience applicable to their work.

i Therefore the licensee's action to change the USAR to more appropriately describe the actual practice was acceptable, The finding was purely l administrative in nature and not indicative of an actual weakness in the i

training program for the I&C technician No violations were identifie .12 Audit Finding No. 12 Description Station training implementation procedures, SP 41.011.01 and SP C1.011.01, (which implement the training program for the I&C and computer section personnel) require personnel to participate in ongoing refresher trainin The refresher training is to be administered via classroom training, tailboard sessions, and the required reading program. Contrary to the procedures, there was no objective evidence that tailboard sessions were being conducted by the I&C and computer sections as require _ - _ _ _ _ _ _ _ _ . - .

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Licensee Corrective Actions The I&C and computer sections implemented methods for better documentation of.tailboard session NRC Evaluation The inspector-interviewed I&C and computer section personnel and reviewed applicable procedures and related documentation. The inspector determined that' prior to the audit, the section engineers periodically held section meetings that met the intent of tailboard meetings, in that safety and

. housekeeping. items were discussed. These meetings were not, however,.

consistently documented. The inspector verified that both groups are now conducting and documenting tailboard meeting This problem was consi-dered to' be an administrative error in implementing the' licensee's internal procedure. It was concluded, however, that the actual training was properly completed, i

No violations were identifie .13 Audit Finding No. 13 Description The clerical. staff of the Nuclear Training Division was incorrectly signing for designated supervisors on the qualification summary; and, the qualification summaries for some individuals were . incorrect because of clerical error Licensee Corrective Actions The clerical staff was retrained on proper documentation of training record ;

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The inspector reviewed applicable procedures and training record This

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finding was considered to be administrative in nature, in that the required information was recorded, but the methodology was in questio The inspector concluded that individual qualifications were accurate. The 1 corrective actions appear to have improved the accuracy and consistency of )

information transcribed onto the training records and should prevent {

-recurrenc I No violations were identifie .

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4.14 Audit Finding No. 14

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Description The training implementing procedure for the operations department, Station Procedure (SP) 21.006.01, revision 7, was found to be inadequate-for radwaste ' operators in that it did not (1) identify the frequency of refresher training or requalification training, (2) identify the method o training documentation, (2) contain provisions for relieving personnel from duty following an unsatisfactory evaluation of proficiency, (4)

identify use of the annual evaluation to determine the need for training or retraining, or (5) address training needs for radwaste operators hired before January 1, 198 Licensee Corrective Actions The audit response indicated that company training policy (NOC Policy 21)

requires each department to define, maintain current, and document the training needs of its organization, and that Station Procedure SP-21.006.01, revision 8, effective August 1986, establishes those requirements. In addition, SP 21.006.01, revision 8, specifies General i Employee Training (GET), respirator qualification, and training in the l requirements of NRC Bulletin 79-19, " Packaging of Low Level Radioactive l Waste for Transportation and Burial," for radwaste operators. The requirement for annual requalification in these areas is now specified in the individual training folder The response further indicated that a subsequent revision to SP 21.006.01-will also p.rovide (1) annual evaluations of licensed, equipment, and radwaste operators, (2) prompt disqualification and relief from duties of personnel found to be incompetent, and (3) identification'of recommendations to adjust training based on employee performanc Additionally, the response indicated that supporting documentation for qualification of radwaste operators qualified prior to January 1,1986 was also completed in response to the audit findin NRC Evaluation The inspector determined that the proposed revision to SP 21.006.01 (to be issued by September 1987) will specify the following: ( Qualification is required in General Employee Training, respiratory training, and NRC Bulletin 79-19. These qualifications expire  !

annuall . Documentation of training must be supplied to the Office of Training for retentio . Annual performance evaluations will be conducte . _ _ - - - _ _ _ _ _ _ _ _ - _ _ _ _ _ -

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B Unsatisfactory performance-evaluations will result in removal from dutie . Performance evaluations will be used as a basis for trainin . The requirements of the procedures apply to all radwaste operators,.

irrespective of hiring dat In addition, requalification training for equipment operators now includes ,

radwaste operator training in the present cycle by request of the opera-tions departmen In summary, although revision 7 to SP 21.006.01 did not specify certain requalification requirements, these requirements were established in other station procedure No individuals were identified that failed to meet specified criteri i No violations were identifie .15 Audit Finding No. 15-Description Contrary to Station Procedure SP 12.014.02, " Training and Qualification Folder," training performance evaluations for maintenance, modification, I&C, and computer personnel were not f;und in training and qualification folder Licensee Corrective Action

/ i The licensee formed a T&Q Task Force which proposed a new T&Q Program that replaces the " training performance evaluations" with a listing of perform-ance requirements that includes- identified needed skills and tasks asso-ciated with each job position (s) for each individua NRC Evaluation The inspector verified that the new T&Q Program, which is being phased in and should be fully implemented by August 1987, does change the individual T&Q folders to include the new performance requirements. Although the new T&Q Program is not yet fully implemented, this portion of the program has bee The inspector determined that the new performance requirements are much ,

more specific than the older subjective performance criteri Under the i new program, each department conducts a monthly audit of its T&Q folders to assure they are maintained curren The inspectors reviewed several ,

folders for the maintenance and I&C sections and verified that they were  !

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folders separate from the individual training and qualification folder The inspector determined that this audit finding does not represent either a- regulatory or safety concern. In addition, the corrective measures establish a more easily auditable and objective training performance _,

' record syste No violations were identifie .16 Audit Finding No. 16 Description There was no objective evidence that the Nuclear Emergency Preparedness Division had completed the required task lists for each individual or transmitted them.to the Nuclear Training Division, as required by Nuclear ,

Operations Support Division (N0SD) Procedure 17, " Training of NOSD l Personnel."  !

Licensee Corrective' Actions The Nuclear Emergency Preparedness Division developed task lists for all i personnel and transmitted them to the Nuclear Training Division prior.to completion'of the audit, u NRC Evaluation j The inspector reviewed Nuclear Emergency Preparedness Division personnel training files at ' random to confirm the presence of tasks lists. All files reviewed contained the task lists required by NOSD Procedure 1 .

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This audit finding was indicative of a problem in the management of i training records, in that records were not kept in the required-locatio !

It was not significant relative to the actual conduct of training or the qualification of personne No violations were identifie .17 Audit Finding No. 17 Description

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Contrary to internal policy, certain nuclear support organizations had not updated the official training record files by transmitting training records for various individuals to the Nuclear Training Divisio Licensee Corrective Action The training reccrds for the identified individuals were assembled and transmitted to the Nuclear Training Division prior to completion of the April 1986 audi ,

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'Although the official' training files are' maintained by the Office of-Training (formerly the Nuclear Training Division), each department also maintained personnel files that included the missing training record a This audit finding did not. indicate that specific individuals were not properly trained or that supporting evidence of training was not available i but',' rather, that this evidence of training was not' properly forwarded to the official . training file The licensee's corrective actions were prompt and effective. Partial implementation of the new T&Q Program has resulted in more frequent audits (monthly) of the official individual training files to assure that the records are being properly maintaine This audit finding was an administrative problem and the licensee's new T&Q Program should prevent recurrenc No violations were identifie .18 Audit Finding No. 18 Description NOSD Procedure.17 requires division managers to determine training requirements for each position in their division and the training needs of individuals assigned to positions. . No objective evidence existed that for the training matrices contained in NOSD personnel training folders, that the division managers made these determinations Also, no provision existed for the managers to substantiate the record by signature or initial and date to show evidence of their actions on'the needs matrices in the NOSD personnel' training folder Licensee Corrective Action In response to this finding, the licensee made a sammitment to revise NOSD Procedure 17 to include a provision for NOSD Division Managers to sign or initial and date the training needs form to substantiate and document their action NRC Evaluation The inspector reviewed NOSD Procedure 17, revision 3, to confirm that a provision for NOSD Division Managers to sign or initial and date the training-needs form has been include The inspector also selected NOSD personnel training files to review needs lists for division manager signa- l tures and dates. During this review, the inspector determined that needs lists were present in five of eleven folders and the Division Manager signature and date were present on each of the needs lists presen Documentation existed to indicate that the missing needs lists had been present during quarterly audits previously conducted by QA personnel. The division manager was able to produce duplicate needs lists, and the licen-see has made a commitment to insure that needs lists are present in all NOSD personnel training file .______ _____________

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The licensee stated that the loss of the needs lists may have been caused l 'by . transition to the computer-based training documentation system which combines the needs list and task list in a computer-based, Individual Position Specification, as detailed:in Appendix 2.3-I to NOSD Procedure 17, proposed revision 3A. This draft procedure, still under review at the p time of the NRC team inspection, was distributed to NOSD pe'rsonnel as a implementing guideline for use during transition to the new system of documentation. The licensee noted that the implementing' guideline may have caused removal of the missing needs lists as a result of a concerted effort to complete the transition to the new documentation syste Review of NOSD Procedure 17, proposed revision 3A, was completed during the inspection. The revised procedure will become effective in July 198 In addition, the licensee reviewed all NOSD personnel training folders to identify those folders requiring needs lists. The missing needs. lists-were supplied, and the inspector reviewed several training folders from-each of the divisions comprising NOSD to verify that all needs lists were '

presen In summary, the audit finding was indicative of a training documentation management problem that will be rectified with the completion of transition to the new computer-based documentation-syste The new system will document training requirements, completion of qualification, and expiration of periodic qualification, and the records will be easily accessible from multiple locations. The finding was not indicative of inadequacies in training or qualification of personnel. Licensee response to the audit-finding and corrective action to the inspector-identified discrepancy was considered acceptable No violations were identifie .19 Audit Finding No. 19 Description NOSD Procedure 17 requires that the Nuclear Training Division Manager ensure the maintenance of training records. A comparison of NOSD Pro-cedure Program Training File information with the information contained in the individual training folders for 6 of 12 Nuclear Licensing and Regulatory Affairs Division personnel revealed 11 discrepancie Licensee Corrective Action Prior to completion of the audit, the discrepancies were corrected by the l Nuclear Training Divisio NRC Evaluation The inspector compared the contents of NOSD Procedure Training File information with the contents of individual training folders for the following programs, and no discrepancies were identified: quality

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assurance: indoctrination, general employee training, and BWR

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familiarizatio This finding was representative of the training j documentation management problems identified in many of the audit findings, and was not indicative of a weakness in training or

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qualification of nuclear division personnel. Transition to the computer-based, Individual Position Specification-system should prevent recurrence-of these discrepancie No violations were identifie .20 Audit Finding No. 20  !

Description Purchasing Department Procedure QP-3 requires that the Purchasing Department Mana'ger, establish, in writing, minimum indoctrination and training: requirements and that the Purchasing Department Trainin Coordinator notify the Nuclear Procurement Division Manager of the completion of indoctrination and training of individual personne Contrary to the above requirements, there was no evidence that the specified personnel had' received training in accordance with the requirements of the Purchasing Department. buyer training. program, or that the Training Coordinator had notified the Nuclear Procurement Division

. Manager of.the completion of indoctrination and' training of individual personne Licensee Corrective Action i l

Prior to completion of the audit, the Purchasing Department Trainin Coordinator reviewed the status of personnel training and advised the Nuclear Procurement Division Manager of.the completion of indoctrination l and training of individual personne l NRC Evaluation The inspector reviewed the memorandum from the Purchasing Department i Training Coordinator to the Nuclear Procurement Division Manager for  !

completeness. In addition, training documentation was reviewed for  !

persons hired since the completion of the audit to confirm completion of l training and appropriate documentation. This finding was indicative of training documentation management difficulties and had no impact on actual training and personnel qualificatio Licensee response to the audit finding was considered to be acceptable, i

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4.21 Audit Finding No=. 21 Description Contrary 'to the Purchasing Department training procedure, quarterly pro-gress reports of the department's staff. training were not forwarded to the Nuclear: Training Divisio = Licensee' Corrective Action-The missing progress reports (third and fourth quarters of 1985 and the first' quarter of 1986) were forwarded to the Nuclear Training Division prior to completion the April 1986 audi NRC Evaluation The inspector determined that this finding was an administrative problem and did not indicate that training performed was inadequate. Department

'and individual training records were available. Subsequently,'the licensee changed the quarterly progress report'to an annual report:and

. recently decided- to eliminate the report entirely. The progress report is no longer necessary because the individual training records are being properly maintained. Full implementation of the new T&Q Program should prevent recurrence of'the proble No violations were identifie '4.22. Audit Finding No. 22 -!

Description NOSD Procedure 17 requires that this training program files contain a log o that records the dates and times for each occasion a training program is conducted. Contrary to this procedure, no such logs were'found in a series of NOSD procedural training program file Licensee Corrective Action Prior to completion of the audit, a log was developed by the Nuclear Training Division to meetthe above requiremen !

NRC Evaluation The inspector reviewed the log to confirm that it contained dates and i times for each training program conducted and was maintained current. The inspector determined that this was an administrative problem and not indicative of inadequate training. The inspector noted that the required dates were available in other licensee records. Licensee response to the audit' finding was considered to be acceptabl No violations were identifie !

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4.23 Audit Finding No. 23 Description Nuclear Training Division files did not include grade reporting sheets for various Nuclear Operations Support Division (N0SD) procedures training, as require Licensee Corrective Action The missing grade reporting sheets were located and placed in the Nuclear Training Department files prior to completion of the April 1986 audi NRC Evaluation The inspector determined that this finding was an administrative problem and did not indicate that actual individual training was inadequate. The missing records were available but were not properly filed. The licensee's corrective actions were prompt and effective. The inspector verified that the Office of Training (formerly the Nuclear Training Division) files'now retain'the required grade reporting. sheet No violations were identifie .24 Audit Finding No. 24'

Description-Contrary to company training policy (NOC Policy 21), the Nuclear Opera-tions Support Division (NOSD) training procedures did not require develop-ing annual training goals and objectives or quarterly training status report Licensee Corrective Action The licensee subsequently revised the company policy (NOC Policy 21) to .

delete the requirements for the various divisions, including NOSD, to l develop annual training goals and objectives and quarterly training status report NRC Evaluation {

The inspector determined that the audit finding did not indicate that i actual individual training was inadequate; however, company policy was not l heing properly implemented through various departmental procedures. The licensee subsequently concluded that the policy should be revised to .

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delete these requirements on the plant and support division The Office of Training was given the responsibility to develop such training goals and to report the status of efforts to meet those goal The inspector verified that NOC Policy 21 was appropriately revised to reflect the l actual division responsibilitie l

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Contrary to NOSD Procedure 17, paragraph 6.4.1.1, training instructors:

were'not. maintaining logs that record the dates and times a training program was conducted, grade' reporting sheets, copies of the written  ;

examination (s), topical. outlines, and lesson plan I l

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The subject files wera appropriately generated or updated. Preventive i actions were implemented to provide an internal audit of the applicable program file within 30 days following completion of a course. Th licensee is in the process of auditing the training program. files to assure completeness and consistenc NRC Evaluation The inspector reviewed the subject program files and interviewed records management personnel., The deficient files were completed with the required documentation. The~ Training staff has organizationally evolved from a Section .to an Office since the audit was performed, and three ,

different sets of procedures have been in riace over this period. The inspector verified that the program files referenced in the finding conform to current procedural requirements. The licensee's' corrective actions appear to be adequate, although the new program is not entirely implemented. The licensee is committed to properly maintaining the training files, and the inspector verified that procedures are in place to  :

accomplish the tas The inspector noted that the problems identified in the finding'were internal licensee requirements and that the required information existed in other location No violations were identifie .26 Audit Finding No. 26 Description Contrary to Nuclear Operations Support Division (NOSD) Procedure 17, paragraph 6.3.2, training program files for the instructor training pro-gram and storeroom personnel training did not have approved lesson plan In addition, the lesson plan for NOSD Procedure 11 training had not been approved by the Nuclear Training Division prior to training being give Licensee Corrective Actions New Nuclear Training Division guidance which required that approved lesson plans be used was issued to the instructors. Under the current

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l-procedures, lesson plans are no longer required for vendor supplied courses, if a detailed description of the course is supplie The NOSD Procedure 11 lesson plan was approve Program files were made to conform to current procedural requirement NRC Evaluation The inspector reviewed past and current training procedures, and training program files, and interviewed training and records management personne .The required storeroom and NOSD Procedure 11 lesson plans existed; however, they were not approved or filed in accordance with established procedures at the time of the audit. These program files have since been made to conform with procedural requirements. The instructor training program is vendor-supplied and no longer requires a lesson plan. A detailed course description and lesson materials were reviewed by the inspector. Current training procedures require that approved lesson plans be used,:except for vendor-supplied courses. Although the audit finding indicated a procedural adherence problem the inspector determined that the-lesson plans and program files now conform to current procedural requirement No violations were identifie .27 Audit Finding No. 27 i

Description Contrary to company training policy (NOC Policy 21), the Nuclear Training Division'had not developed an administrative training manual or procedures governing the implementation of the policy requirement Licensee Corrective Action The Nuclear Training Division (NTD) issued the administrative training manual and implementing procedures, which had been in draft form at the time of the audi NRC Evaluation The inspector verified that at the time of the audit, the Nuclear Training Division had developed the administrative training manual and implementing procedures, but these documents had not been issued. In addition, upon issuance, these NTD procedures appropriately implemented the company 4 training policy (NOC Policy 21). Subsequently, the NTO was changed to the Office of Training. The inspector verified that the new Office of Training procedures are in place, and they effectively implement the T&Q  !

program requirements of NOC Policy 21. Although the audit finding

. indicated that NTD implementing procedures were not in place, training practices in effect to implement the company policy were adequat No violations were identifie . _ _ _ _ _ _ _ - _ _ _ _ _ -

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4.28 Audit Finding No. 28 Description Contrary to Emergency Plan Implementing Procedure EPIP-5-4 the Nuclear Training Division files contained incomplete or inaccurate information concerning emergency preparedness training because the Nuclear Emergency Preparedness Division had not submitted completed records to the Nuclear Training Divisio Licensee Corrective Action Guidance was issued in the form of a memorandum signed by the Director of Training the Manager of the Nuclear Operations Support Department and the Vice President of Nuclear operations to document the responsibility of the Nuclear Emergency Preparedness Division to retain emergency preparedness training record In addition, the licensee issued a revision to EPIP-5-4 that gives responsibility for retaining emergency preparedness training records to the Nuclear Emergency Preparedness Division Directo NRC Evaluation This finding indicated a weakness in training records management and did not indicate or imply an actual weakness in the emergency response training of station personnel. The cause of this was a procedural inconsistency in the requirements for the maintenance of emergency training record Since actual training and qualifications were unaffected, the licensee response was considered acceptable. The use of a memorandum to effect a temporary change to a procedure, however, was considered inappropriate. This was determined to be an isolated incident and was brought to the attention of the license No violations were identifie .29 Audit Finding No. 29 l Description The Corporate Nuclear Training Administrative Manual was withdrawn from use on July 26, 1985, but the implementing procedures referenced in the Nuclear Organization Management Control Program Manual remained in effec Licensee Corrective Action l

The licensee deleted the obsolete implementing procedure NRC Evaluation The inspector verified that the obsolete training procedures were subse-quently deleted from the Nuclear Organization Management Control Program Manua Various elements of the new T&Q program were then implemented by

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the Vice President's memorandum in August 1986. This program should be fully implemented by August 1987. The inspector reviewed the new T&Q Program and Office of Training implementing procedures and determined that these actions provide sufficient management oversight of the training programs. At.the time of the audit, the company training policy had been recently revised to incorporate the new Nuclear Training Division. New implementing procedures were being phased in as the old procedures were being deleted. The fact that obsolete procedures had not been deleted during this time did not indicate that actual training and qualification programs were being improperly implemente No violations were identifie .30 Audit Finding No. 30 Description

. The Nuclear Engineering Department (NED) training implementing procedure referenced the deleted Corporate Nuclear Training Administration Manual as the governing company training policy instead of NOC Policy 2 Licensee Corrective Action'

NED revised the division training procedure to appropriately reference N0C Policy 21 and delete the. reference.to the obsolete Corporate Nuclear Training Administration Mar.ua .NRC Evaluation l The NED procedure revision was completed during the April 1986 audi The corrective actions were timely and effective ' The company training policy change that was implemented through issuance of NDC Policy 21, did not require any substantive changes at the NED divisional procedure level other than the change in reference. Therefore,'this audit finding was clearly only an administrative problem and did not indicate any problem with actual individual training in the NED organization. The inspector verified that the required procedure revision was mad No violations were identifie j 4.31 Audit Finding No. 31 i

Description '

Contrary to Nuclear Enginee-ing Department (NED) training implementing procedure NED 1.03, revision 1, the training needs matrix for 12 individuals were inaccurat .___ __ ___________- _-_-

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Licensee Corrective Action NED updated the individual training and qualification folders to correct

'the' identified deficiencies prior to completing the April 1986 audi NRC Evaluation The licensee's corrective action was promp NED personnel met the required qualifications for their position Therefore, this finding indicated a records management problem rather than that individuals failed to meet qualification _ criteri The inspector selected a sample of 20 individual qualification folders for NED personnel and verified that. the folders were current. Subsequent to this audit finding, the NED implementing procedure was revised to incorporate the requirements of the

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i new T&Q program, :The training and qualification' folders now include the computer-based tracking system printout of position requirements and individual qualification matrice This subsequent revision to the NED procedure should prevent recurrence of.this records management proble No violations were identifie .32 Audit Finding' No. 32 Description Objective evidence of training could not be found to prove that the Mechanic A-1 welding instructor had completed certain training require-ments'in accordance with the appropriate corporate training pro ~cedure Licensee Corrective Actions The licensee revised the welding instructor training procedure to include training schedule requirements controlled by the Welding Section Training Supervisor. In addition, the revised procedure requires that welding instructors be provided all required training and that certificates of completion of such training be verified and included in the individual i training f;1der I NRC Evaluation The inspector verified that the welding instructor training procedures (WI-R) were revised to include instructor training; that all welding ,

instructors had received all the required training; and that instructor "

training schedules were developed and maintaine The inspector also verified that instructors are only teaching courses for which they are currently qualifie In addition, it was determined that the mechanic A-1 i welcing instructor, whose training file was incomplete, was actually welder certified by both the American Society of Mechanical Engineers (ASME) and the American Welding Society (AWS). Also, the mechanics taught by this instructor were required to pass objective qualification tests that- demonstrated their welding skill, rather than being judged by a l

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' subjective assessment of the instructor regarding a student's abilitie Based on this review, it was determined that this audit finding and its resolution did not represent a regulatory or. safety concer No violations were identifie .33 Audit Finding No. 33 Description No objective evidence was found to prove that one of the mechanic A-1 i welding instructors had passed four of the welding-skill tests required by Production Training Procedure WI-R, " Procedure for Welding Instructor Requirements," Revision Licensee Corrective Action The mechanic A-1 welding instructor successfully completed the remaining four welding-skill test NRC Evaluation ihe licensee discovered this inadequacy in the welding instructor qualif-ications after the individual had taught his first welding class. As verified in Audit' Finding No. 32, the A-1 mechanics were required to demonstrate, through objective testing, that they.had acquired the necessary welding skills. Therefore, the actual training given was not inadequate as a result of the instructor not having demonstrated his  ;

welding-skill proficienc The. inspector reviewed the instructor  ;

welding-skill test results and verifie.d that all six skill tests were completed satisfactorily and also that the instructor was an ASME and AWS certified welder at the time of instructing his first cours The 4 inspector determined, based on the licensee's actions, that this probler, did not result in any inadequate welding training. Since the students adequately demonstrated their welding skills at completion of the course, their qualifications were vali The licensee has implemented additional ,

management oversight to assure that the instructors maintain appropriate l qualification No violations were identifie .34 Audit Findirq No. 34 Description Corporate training policy (NOC Policy 21, paragraph 4.2.6) identifies the  ;

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specific requirements that each' nuclear and nonnuclear department shall satisfy while implementing the training for their personne Contrary to the stated policy, the Information Systems Department (ISD) had not devel-oped a procedure for implementing the NOC Policy requirement ,

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Licensee Corrective Actions The ISD has-developed the subject procedures. NRC Evaluation The inspector reviewed the subject procedures and applicable training records, and interviewed ISD and computer section personnel. The nuclear systems designers report administratively to ISD and functionally to the computer engineer. The computer engineer directs the training and qualification activities. of these personnel. Computer section procedures delineate qualification requirements for personnel who work with nuclear computer system A review of the training' records indicated that the nuclear system designers were trained in.their areas of responsibility. The inspector determined that-the lack of procedures was an administrative oversight, in that ISD is a corporate entity and not routinely involved in nuclear procedures and programs. Training and qualification of personnel working on nuclear computer systems was procedurally controlled by the computer section procedures. The ISD procedure now incorporates these requirements. The inspector concluded that corrective. actions were adequate and complet l No violations were identifie .35 Audit Finding No. 35 Description Nuclear Operation Support Division (N0SD) training implementing procedure NOSD-17, Section 6.0, identifies specific requirements for generation of training-needs matrices and task lists for NDSD personnel. Contrary to this procedure training folders were found to be incomplete for 14 individuals from the Nuclear Training Division. In addition, the Emergency Preparedness Division training needs matrices did not contain '

written examination result .

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Licensee Corrective Actions Training files were made to conform to procedural requirements. The .

training-needs matrices and task lists are no longer required for training I personnel because they are not covered by NOSD procedures. The Office of i Training procedures do not require these documents for training personne l Subsequent to the audit, it was determined that Emergency Preparedness I Division training needs matrices do not require examination result j

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transferred from'a manual to a computer based system. Documents were missing during the April 1986 audit because records had been nulled'from files to be transferred to the new system. During this transition, both sets of documents are being' maintained until the computer system is fully accepted. The inspector determined that the licensee's corrective actions ')

are adequate for the transition period. Although this finding indicated a [

training records management problem, actual. qualifications of personnel i were appropriate for their positions. The_ procedural _ revisions made by 1 the licensee should prevent similar administrative problem No violations were identifie , Followup on Previous NRC Findings l

Violation 50-322/86-03-07(Closed). Violation of ANSI 18.1-1971 as committed to in Technical Specification 6.3.1, which requires a minimum of three years of related working experience _for technicians routinely per-forming both preventive and corrective maintenance on electronic equipment in the radiation _ monitoring system (RMS), including safety-related equip- i men The licensee assigned maintenance of the RMS to the computer

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section. ~The inspector reviewed training and qualification records for computer section technicians and determined that the experience of the technicians exceeds the requirements of ANSI 18.1-197 The inspector also reviewed a list of 20 deficiencies relative to the RMS, i including items identified by computer personnel during turnover of the l equipment from the chemistry group. The deficiencies consisted mostly of l drawing and hardware discrepancies that do not appear to be a result of a i lack of electronics knowledge by the chemistry personnel but, rather, inattention to detail. Corrective actions for deficiencies identified by _

the computer technicians during the turnover have been complete The. inspector selected a potentially safety-significant item from the'11st for detailed review. The item involved control room particulate / gas .

monitor, the drywell atmospheric monitor, and the low range plant vent i monitor. The alarm setpoints were not set conservatively because the

. computer default setpoints had not been update This deficiency was ,

identified by a radiochemistry technician during a functional test of the !

equipment. The computer section has since taken over this duty and has implemented procedural controls to ensure that default setpoints are up to date. The inspector reviewed the licensee's evaluation of this event and determined that there was no safety concer ;

The inspector determined that the computer technicians exceed ANSI experience requirements. Prior maintenance of the RMS by chemistry personnel does not appear to have degraded the operation of the syste Corrective actions for this item are adequate and complete. This violation is close ;

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- R_eview of Training and Qualification programs g The team reviewed a sample of training programs in an effort to assess-the implementation and effectiveness of the training. This review included the.following aspects: l Review of the USAR to determine the commitments for individual qual-ifications'and specialized training ~according to job function and reference to applicable industry standard . Review of the licensee's T&Q Program, Office of Training implementing.,

procedures, and selected department (s) training implementing procedure . -Interview of station management in each of.the selected departments, and the Office of Training to assess management involvement in the training program . Review of the methods for improving the training programs through  !

feedback mechanisms from within the station and through notifications of operating experience from the industr ; Interviews of department personnel about the effectiveness of the training received, including specialized and on-the-job training, j Observations of actions of a sample of work activities within the departments to assess the training effectiveness through actual job performanc '

The training programs for nonlicensed operators, I&C and maintenance technicians, as well as various plant support staff, including HP, fire protection, engineering and STA personnel were reviewed. In general, the training program elements exceeded the commitments in the USAR and, in all cases, met established regulatory requirements. Specific details on each area follow l 6.1 Nonlicensed Operator Training 6.1.1 Program Review The nonlicensed operator training (NLOT) program consists of task-based training that incorporates 16 weeks of formal classroom instructio The classroom training includes 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of instruction in mathematics and science fundamentals, 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on yard and control building systems, 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on turbine building systems, 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on reactor building systems, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> on radwaste building systems, and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on administrative and emergency procedure This NLOT program has been submitted to INP0 for accreditation and will be reviewed during an INP0 visit in October 198 The initial NLOT training program class was in progress during the period of'the inspection, with class completion expected in August 1987. The in -

spectors attended a portion of classroom training on the reactor building

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normal ventilation system (RBNVS) and reactor building standby ventilation @ t

+ system (RBSVS). Theysfound that the. instructor was well-informed andj

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professional, student handouts were detailed and easy to follow, and the, j'

students were encouraged to participate in the class. Inspectors also observed annuay fire brigade training at the Suffolk County Fire Scho .

Because currently qualiffed nonlicensed EOs have not had the benefit of thenewprogramforinitialitrainingofnonlicensedoperators,the licensee is including the initial training course curriculum in the present requalification cycle for nonlicensed EO The inspectors reviewed instructor qualifications'and found that the instructors currently being used in the nonlicensed operator training program are General Physics Corporation employees. The licensee is in the process of developing a cadre of LILCO instructors, however, who will be required to undergo an instructor qualification program. Instructors may

'be-technically qualified by one of the following methods: Achieving full E0 qualificatio . Developing instructional material for the subject area in which

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qualification is desire p 7 Completing a'self-study program in the desired area and passing the unit testt Attending' the class in the desired area and passing the unit' tes In addition, prospective instructors must complete two practice-teaching sessions in the intended subject area prior to being certifie The inspectors reviewed procedures and documentation, and interviewed'  !

training department and' operations personnel to determine the means and effectiveness 3cf training-feedback mechanisms. Inspectors found that.the training proce'yres provide a computer-based training-feedback system that

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responds to inputs from: operations, engineering, and licensing personnel, and causes modifications to the trainin In addition, nonlicensed personnel are surveyed weekly during classroom training and three months after conmietion of initial nonlicensed operator training for feedback on training effectim nes The inspector noted that one E0 submitted a detailed critiqud of his initial training to the Office of Trainin The Director Office of Training, responded promptly, and members of his staff met with the E0 to ensure that the operator's feedback was understood and incorporated to the maximum extent possibl The inspectors interviwed and observed performance of nonlicensed operations personnel oh the 4:00 pm to midnight shift to assess training and training-feedback' mechanism effectiveness. A watch engineer and two qualified EOs were interviewed; all considered the NLOT program to be effective. The watch engineer expects the recent program improvements to help implement the on-the-job training (0JT) program more effectively, as i

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'l well as to. provide better qualified EO One E0 had attended an intro-'

^ductory course for OJT evaluators and expected to improve as an OJT evaluator with additional training. The other E0 pointed out that quali-fied EOs had reviewed all. student handouts prior to use in the initir.1 E0 training program and cited several instances of effective utilization of the training-feedback mechanis i The inspectors asked one E0 to simulate a system lineup of the standby liquid: control system, and another E0 to discuss lineup' verificatio Both EOs demonstrated acceptable knowledge levels with regard to plant procedures and equipment location, and were judged to be competent and capable'of performing required tasks. In addition, the inspectors questioned one E0 with regard to Technical Specifications and systems interrelating with standby liquid control and several other system The E0 demonstrated an acceptable level of knowledge in all area '6.1.2 Conclusion Overall, the NLOT program was evaluated to be effective. It produces

' qualified, competent equipment o.perators. In addition, the administration of the program was'found to be effective, well-organized, and supported ~by managemen .2 Instrument and Control-(I&C) and Maintenance Technician Training

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6.2.1 Program" Review'-

Both the I&C and maintenance technician training programs were reviewed and determined to meet the commitments contained in the USAR and appli-cable' industry standards. Both training programs are undergroing con-

'A siderable upgrading in anticipation of INPO accreditation. The Office of Training is now providing much of the specialized training that was previously conducted by vendors. On-the-job training is conducted by the applicable station department, but improved documentation of this training to the Office of Training is now being provide .

The maintenance training program will be submitted to INPO for accredi- )

tation in July 1987, The inspector verified that the station maintenance l department has expended considerable effort in reviewing the Office of  ;

Training maintenance training procedures in support of the INP0 accredi- i tation process and assuring that the training program addresses the '

station needs. The inspectors also interviewed the Office of Training l division managers about the development and revision process for the maintenance training programs. Through these discussions, it was

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determined that there is an effective feedback mechanism to assure that the maintenance training program results in an acceptable level of job performance. Also, station maintenance management stated that inadequate i performance will result in retraining the individual and appropriate changes to the training program. The maintenace training program consists of two parts, the mechanic B program and the mechanic A-1 progra I i'

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l The mainte9ance ' mechanic /B trsining progr.am co nists of approximately-2 '

years of *spedalized training and DJT at 'the station, working as an '

assistanh w fer,a fully quaYified mechanic 4 (A-1). Progress to the A-1 '!

level -is depwr, dent on seniorith and position availability. . Specialized A-1 level training is provided in,24 additional functional areas to fully  !

qualify thipersonnel. Qualificationhn these specialized areas requires

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completion of"the classroom training'tnd OJT with a fully qualified mech-anic in the particular functional area, arwel satisfactory per~

formance evaluations by the individual, the mechanic who provided the OJT, 4 and the individual's superviso The I&C training progr-am will be submitted to INPO for accreditation in September, 1987. Previously, training was mostly OJT and vendor-supplied-courses. The upbraded program will be a combination of OJT, vendor-supplied courses, and classroom and laboratory instruction at the training cente I&C department job function task analyses are now being developed. These analyses will list the skills and knowledge required for each task. The analyses are being jointly developed by the plant and training personnel. (Similar 561nt plant and training department effort is being. pursued in other training programs.) For exangle, vendor-required training is identified by the plant and administered by l the training department. Les"bn plans are developed by the training department and reviewed and co2 curred in by p1 4 nt Mrsc4rel, i.esson plans  %

are reviewed for both technical 4cd instructional adequacy by the user department and the Office of Training. The inspector reviewed the I&C i training program files and verified that lesson plant had been developed l for the ro6 drive control system, rod position indication, system, the Alterrex excitation systems' course, the I&C administstE n course and the evmputer administration course Thenewtrainfedprogrf,mwil]riquire60 st>eks of training tur new technicians coming out of h,igh schoo Thd DJT program eineest implementation for I&C and maintenance technicians requires that a new technician is to accompany and assist a qualified ,

technician, in a particular area, until the new technician and his or her supervisor determine'the technician is ready for qualification. In making '

that determination the immediate supervisor will review the variety of tasks tid individual has performed, assess the technician's ability and know' edge of the tasks, and determine whether the individual feels.

l qua Hiied.' The supervisor will then recommend the individual to the c'epartment manage- who has responsibility for qualifying the individual.

L If thj technician does noi feel ready, he or the will remain in the OJT L training program until 9 or she feels confiden Under the new DJT program for I&C technicians, qualifica$.lons of the individual will be more objective, in that they will be based on the task analysi,s skil r; and knowledge needed for each job fqction. This task oriented qualification program will consist of approximately 22 qualifi-cat %n areas for I& Both departments use three metho-Is for providing refresher training: \

weekly tai? board meetings, routing of reading material with signoff, s ,

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n sheets, and pre-job ~ briefings. The primary purpose. of a ta11 board meeting is.to discuss safety' issues and get feedback from technicians on proble areas. . In January 1987, both departments began logging all their

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' refresher. training in~the. individual qualification files. The inspectors reviewed a sample of the records-documenting the refresbar training, and verified that all three. types of refresher training medhods had been offered ~since.the first of the yea The-inspectors observed ongoing maintenance and I&C activities, including shop fabrication of parts for the service water traveling screens 'and maintenance on 4160 volt vital switchgear, the I&C surveillance activities

.for tailpipe pressure calibration and functional testing per SP 44.201.05, and the Rosemount Model 510 differential pressure unit trip system bench test per SP 46,001.10. The results of these activities were acceptable,

'The-technicians'and mechanics involved in the activities were knowledge-able and' proficient.in the observed dutie The' inspectors interviewed sixfI&C technicians and six maintenance

_ mechanics regarding their training, as well as their supervisors regarding training program implementation. In addition, individual T&Q folders for-a sample.of 12 technicians and mechanics were reviewed. From these y f' discussions and reviews the following observations were mad J' Te'hnicians c and. mechanics are receiving the training necessary to perform their tasks in a safe manne j 2; OJT is well-controlled and documented, with the individual not cualified for a particular task until both he or she and management feel that he or she is read '^

1 The licensee has established a financial incentive program to u encourage technicians to take college courses

• The-licensee has established and documented a refresher training L program that provides recent information to the technicians and mechanics in a timely manne . .The training and qualification program files were current and in-cluded all the training received, both OJT and classroom, along with the training certificate . The I&C technicians receive, on the average, a minimum of four weeks of special or refresher training a year.

l ' Individuals felt that they had received adequate trainin . Plant management is involved in the development and review of the training being offered by the Office of Trainin .g

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6.2.2 Conclusion The I&C and maintenance personnel training programs were found to be effective and to provide competent staf The administration of the program was also found to be effective, well-organized, and supported by managemen .3 Plant Support Staff Training Programs The HP, fire protection, STA, and Nuclear Engineering Division (NED) T&Q implementing procedures were reviewed and found to be consistent with the qualification needs and , training programs. They adequately implement the corporate T&Q policy. The training programs for HP and STAS were submitted for INPO accreditation in March 1987. The licensee plans to submit the NED training programs by September 198 The inspector interviewed station department managers and the Office of Training division managers and verified that they have participated in the development and improvement of training programs, as well as the implementation of on-the-job trainin The inspector also verified, with each division, that an appropriate interface with the QA organization and the Office of Training had been established, especially in the areas of qualification development, training program development, recordkeeping and retrieval , operational feedback, and improvements to the training program Throughout these discussions, the inspector observed a high degree of management commitment to a high quality training program and recognition of the importance of well-trained perso.ue A sample of 15 T&Q folders, four qualification matrices and five examination grade sheets were reviewed, and all records were found to be consistent with records management policy. For each of the folders, the individual position specifications were reviewed and the individual qualification records were checked against the qualification description (scope, effective and expiration dates, status, etc.). Also, the certificates of qualifications were checked against the attributes of the individual (experience, education, etc.) plus the necessary training for qualificatio Interviews were conducted with select individual Through these discus-sions, the inspectors verified the accuracy and completeness of the training and qualification files.

l l The inspector observed HP involvement in the disassembly of a reactor water cleanup pump. The inspector noned that HP job performance was adequite. The inspector also discussed radiation work permit preparation, qualification of HP personnel, qualification of maintenance personnel assigned in areas of !!P requirements, ALARA (as low as reasonably achievable, with respect to radiation exposures) reviews, instrument calibration, and dosimetry with an HP technician and his superviso For all the areas reviewed, no programmatic problems were foun _ _ _ _ _ - _ _ _ _ _ _ - _

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1 6;3.1 Conclusion-Overall, the support staff training programs were found to be effectiv .

Qualification supporting documentation was adequate to ensure that licensee commitments had been followed. Administration of the program meets established; criteria, and management commitment to a high quality training program was eviden .

. Exit Interview The team met with Messrs. S. Skorupski and VL Steiger, Jr. as well as

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other licensee personnel (listed in Attachment 1), periodically during the

. conduct of this inspection and at the end of the inspection report period to summarize the scope and preliminary finding Based on Region I review, it was determined that this report does not contain information subject to 10 CFR 2 restriction _ _ - _ - _ _ _ _ _ _

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l ATTACHMENT 1  :

Shoreham T&Q Team Inspection Personnel Contacts The following personnel were present at the entrance and exit meeting 'for the NRC Region I team inspection of training and qualification programs at the l

Shoreham Nuclear Power Station conducted June 22 - 26,198 In addition, during the course of the inspection, the team met with other licensee management and staff and various contractor personnel as necessary to support the inspection activitie N. RC C. J. Cowgill (Team Leader) Chief, Reactor Projects Section No. 10, DRP F. J. Crescenzo Resident Inspector - Shoreham Nuclear Power Station..DRP K. Halvey Gibson Resident Inspector - Sale;n Nuclear Generating Station, DRP R. H. Lo Project Manager, Project Directorate I-2, NRR C. S. Marschall Resident Inspector - Nine Mile Point Units 1 and 2, DRP W. Oliveira Reactor Engineer, Quality Assurance Section, DRS J. A. Prell Reactor Engineer, Operational Programs Section, DRS R. J. Summers Project Engineer, Reactor Project Section No. 2B, DRP State of New York S. Sholly New York State - Consultant, MHB Technical Associates LILCO S. S. Skorupski * Assistant Vice President for Nuclear Operations L. Britt Manager, Nuclear Licensing

. L. Calone * Manager, Operator Training Division H. Chau ** Manager, Engineering Assurance R. Crowe Manager, Operations Staff E. Eisenberg * Sur rsisor, Training Administration G. Gisonda * Supervisor, Nuclear Licensing G. Krieger * Supervisor, Nuclear Emergency Preparedness J. Notaro Manager, Quality Assurance, Safety and Compliance (QASC)

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'LILCO(continued).

J. Powers * Audit Section Head (QASC)

J. Scalice Assistant Plant Manager C. Seaman Manager, Quality Control

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JJ., Smith;** Director, Office of~ Training W.~Steiger,.J Plant Manager i LD., Terry Manager, Production Training Department L

D. Toner ** Supervisor, Administrative Section E. Youngling *

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Manager, Nuclear Engineering Department

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ATTACHMENT 2 DOCUMENTS REVIEWED The following documents'were reviewed on site and form a partial basis for the conclusion of the inspectio : Shoreham Training and Qualification Audit, May 21, 1986 NB-86-01 Personnel Qualification and Training of Plant Staff Personnel QS-86-03 Corporate Nuclear Training - Support Department . Quality Assurance Department Audit Response Forms: (1 through 35) for Audit NB-86-01 and QS-86-0 , CAR No. 2 .

Corrective Action Request Nuclear Training Division failed to implement timely CA to resolve audit findings No. 1 , VPN 086-195, J. D. Leonard, Jr. memo to W. Steiger, et.al . ; Implementation of Training Qualification Program (Draft) August 8,198 . DDT-86-0109 (Draft) Training Qualification Program August 6, 198 . QAM-86-196-Extension of Completion Date NB-86-01/QS-86-11 " Implementation of new T&Q Program extended to March 31, 1987" dated November 17, 198 . NRB-C-87-070 Shoreham Training and Qualification Audit June 8,198 . QSD-86-88 Audit (Quarterly) Personnel Qualification and Training August 18, 198 . VPN087-112, J. D. Leonard, Jr. memo to W. Steiger, et. al . ; Implementation of Executive Directive 87-03 (Rev.1), Training and Qualification Progra . INPO 82-022, September 1982, Technical Development Program for Technical i

Staff and Manager . Minutes to Meeting July 9,1986, regarding resolution of audit findings rebated to NB-86-01/QS-86-0 . Memorandum July 14, 1986 from J. D. Leonard, Jr. to W. E. Steiger et. al .

Subject: Engineer in Training Program, 1 Training and Qualification Program, Rev. . Chronological List of Welding Instructor Activitie . Welder and Brazer Performance Qualification Status Repor . Wi-R, Rev. 1, Procedure for Welding Instructor Requirement _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ o

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17, SP 12.014.04, Rev. 2, Training Responsibilitie '

18. -SP 41.011.01, Rev. 10, I&C. Technician Qualification Progra . First Level Basic Supervisory Workshop Agenda and Attendance sheets for

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February 1980, March / April,1982, March 1983, September / October 1986,

. October 1986, March 1987,. April 1987 and May 198 . First Level Supervisory Orientation agendas and attendance sheets for April 1985, July'1985, September 1985, February 1986, March 1986 and March 198 . First Level Supervisory Workshop agendas and attendance sheets for June 1985, September 1985,. December 1985, March'1986, May 1986, June 1986, September 1986, March 1987 and April 198 . Advanced Supervisory Workshop agendas and attendance sheets for April 1981, November 1981,' November 1982, June 1986, November 1986, January 1987 and February 198 . Management Workshop agenda and attendance sheets for December 1980, June 1981, September / October 1982, January / February 1987 and May/ June 198 . .LILCO Deficiency Report No, 86-19 . LILCO Deficiency Report No. 86-12 .' Equipment Operator Qualification Guide . Modified Cold Licensee Training Progra . Grade Summaries (SNPS Systems and Procedures)

29. Attendance Sheets'(SNPS Systems and Procedures)

30. Operations Section Training and Qualification Program, Revision . Trip Unit Data Sheet . I&C Refresher Training Lo . I&C Qualification Specifications Appendix . SP 41.011.01-4, Revision 9 Documentation of I&C Refresher Trainin . Instructor Training Program Fil . Storeroom Personnel Training Program Fil . Onsite/0ffsite Emergency Preparedness Administration Training Program I Fil _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ -

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38. -NOSD Procedure 11, Revision 1 Lesson Plan.

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39. Memo OT-87-0822 dated May 26, 1987, D. Terry to Instructor . Monthly Audits of N0.SD Training and Qualification File . NRC Bulletin 79-19 Refresher Training File . Radwaste Training Program File . Health Physics Training Program File '4 I&C Training Program File .4 I&C Technician Task List . SP.41.011.01 I&C Technician Qualification' Program.-

47. OCS 19.01, Revision 1 Course Sequence and Time Schedul . OCS 20.01, Revision 1 Trai;.ing History 4 Shoreham EPIP Training Program Fil . Shoreham OPIP Training for Offsite Emergency Preparedness Section Progra .

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i ATTACHMENT 3 L

LILCO ORGANIZATION CHART Chief Executive Officer I .

I-I President & Chief Operating Officer l

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Executive Vice President l

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l l l l I Director l Director Office of Training l QA, Safety & Compliance I

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Vice President for

, Nuclear Operations I

I Assistant Vice' President l l

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l l l Plant Manager Manager Manager l . Nuclear Operations Nuclear l ~ Support Department Engineering l Department l

l l 1 l l Manager Manager Manager Manager Operations Maintenance Radiological Outage &

Division Controls Modification Division Division

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