IR 05000369/1986022

Insp Repts 50-369/86-22,50-370/86-22,50-413/86-31 & 50-414/86-34 on 860804-08.No Violations or Deviations Noted. Major Areas Inspected:Licensed & Nonlicensed Operator Training

ML20213D108
Person / Time
Site:	Mcguire, Catawba, McGuire, 05000000
Issue date:	10/30/1986
From:	Mccoy F, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20213D080	List: IR 05000369/1986022 ML20213D078
References
50-369-86-22, 50-370-86-22, 50-413-86-31, 50-414-86-34, NUDOCS 8611100424
Download: ML20213D108 (18)

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't . * _ UNITED STATES p g>m RE!tfg*o NUCLEAR REGULATORY COMMISSION '

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REGION 11 ,.

y j 101 MARIETTA STREET, * '*- ATLANTA. GEORGI A 30323

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.s-Report Nos.: 50-369/86-22,J50-370/86-22,-50-413/86-31, and 50-414/86-34

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Licensee: Duke Power > Company 422 South Church Street Charlotte, NC 28242 Docket' Nos.: ~50-369, 50-370,- License Nos.- NPF-9, NPF-17, 50-413 and 50-414 NPF-35 and NPF-48 Facility Name: McGuire and Catawba Inspection Conducted: August 4-8, 36 Inspectors: _

r _gf 7'fa F . R .7McCoy ate Signed

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L. J. Watson D. Falconer P. B. Moore Approved by g , i m i obo[94 B. $/. Wilson, Section Chief Date Signed Division of Reactor Safety SUMMARY Scope: This routine unannounced inspection was conducted in the areas of licensed and non_ licensed operator trainin Results: No, violations or deviations were identifie e61105 9 PDR ADOCK 0500 1 G

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REPORT DETAILS Persons Contacted Licensee Employees

• R. Kimray, Instructor, Catawba Nuclear Station

• D. Tower, Operations Engineer

• B. Kohler, General Manager, Production Training Services-

• J. Painter, Instructor,'McGuire Nuclear Station, Operations

• B. Newman, Instructor, McGuire Nuclear Station, Operations

• H. Deal, Instructor, McGuir.e Nuclear Station, Operations

• W. Griffin, Senior Instructor, McGuire Nuclear Station, Operations

• R. Wilson, Senior Instructor, Instrumentation and Electrial

• S. McInnis, Nuclear Production Engineer

• B. Travis, Superintendent of Operations

• L. Wright, NPD. Specialist II

• G. Gilbert, Operating Engineer

• T. Parker, Supervisor, Nuclear Training and Development Other licensee employees contacted included engineers, technicians, operators, and office personne Resident Inspectors W. Orders, SRO, McGuire S. Guenther, R0, McGuire K. VanDoorn, SRC, Catawba P. Skinner, SRO, Catawba M. Lesser, R0, Catawba

• Attended Exit Interview Exit Interview The- inspection scope and findings were summarized on August 8, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings l i'sted below. No dissenting comments were received from the license The-licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during the inspectio . - ,

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2 .McGuire Operator Training Licensed.0perator Training (41701)

The inspectors reviewed licensed operator training with emphasis on the requalification program, as it related to individuals involved with preselected events and operating eva-luations in the- recent past at McGuire Nuclear Statio The following LERs were reviewed:

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LER 369/85-14: On May 7,1985, core alterations were started' on the unit without completing 'the required surveillance on source range neutron flux -monitor This was attributed to an administrative / procedural deficienc LER 369/85-27: On September 11,1985, the 18 pressurizer heater group was declared inoperable while the 1A diesel generator was inoperabl The_ Nuclear Service Water flow balance / heat balance test performed in March 1986, in addition to the above LER's, were the evaluations from which selected individuals were chosen for review. The ' following observations were made with regard to this review:

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The ability to readily retrieve training records for licensed operators was. considered marginal due to the logistics associated with record storage. Although the licensee was able to: provide specific material requested . in every case, the varied record locations and format required a significantly greater amount.of time to audit records than i s . normally encountered at other

_ Region II. plants. Consequently the scope of record inspection was significantly reduced from that originally planned in a one week inspection time frame. Records are retained in a variety of formats in three separate location As an example, annual requalification training s'ummary reports (TSR-10s), license applications, licenses, and completed biennial simulator manipulation forms _are retained in hard copy format at the plant records storage area. Student examination answers are retained on microfiche at the plant records storage area. The actual examination questions and answer keys, however, are retained at the plant training facility. Documentation of class attendance for hot license training is retained on microfilm at the plant record storage are Substantiating data for requalification lecture attendance is retained in hard copy format at the plant training facility. Documentation of simulator manipulations which are- within a two year cycle are retained at the simulator. The inspectors do not consider that this situation is conducive to

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either self-evaluation and analysis .cn quality assurance-audit and

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re.v i ew. Consideration 'should be given to consolidation of all licensed operator training records to a singl.e location and to maintaining' records of current (within a two year period) training in a more readily usable format. The licensee acknowledged this concern and committed to evaluate implementation of consolidated and more usably formatted system of record storage. Resolution of this concern is identified as an inspec. tor followup . item (369, 370/86-22-01)

A review of annual requalification examinations, results, and answers for 1984 and 1985 reflected two individuals who exhibited only marginally satisfactory performance for two successive year In each case pass'ing grades were achieved by re-evaluation and regrading of specific answers. Although in each case it appeared that a basis existed. for the specific regrade of each question, there appeared to be no licensee management review of this proces ~

The inspectors expressed concern that marginal performance in requalification should be viewed by licensee management with a more hardline philosophy to assure, without question, operator proficienc In discussion of this concern with operations and training management, the licensee acknowledged the inspector's concerns. They committed to establish with the Employee Tr.aining and Qualification System (ETQS) Standard, provisions for requiring operations and training department management review and approval for examination regrades which result in an individual changing from a fail to a pass-status. The inspectors noted several examples where examinations had been regraded, and where the prior grades and point values had been ~ obliterated, the person regrading the question was not identified, and the reason for the regrade was not identified. In discussion of this concern with training department management, the licensee committed to establish, within 'the ETQS -Standard, provisions for the proper technique of regrading examinations including documentation of the reasons for specific question /

answer credit changes. Completion of these actions and subsequent review of implementation is identified as an inspector followup item (369, 370/86-22-02).

Interviews with licensed reactor operators (R0s). and the occurrence of events such as that reported in LER 369/85-27, provided indication of possible weaknesses in training associated with ' Technical Specification interrelationship's. A review of selected training materials indicated that training is coaducted in this area as part of simulator trainin The simulator guide for multiple malfunctions addresses Technical Specification interrelationship as an established objectiv The inspectors noted, however, that Technical Specification Limiting Conditions for Operation (LCOs) and their interrelationship are not specifically evaluated during simulator performance evaluatio Training staff members indicated that

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'they considered' this ev'aluation to be inherent in the evaluation elements of utilization of materials and -supervisory ability for SRO. The inspectors consider that including a specific evaluatio element for . Technical Specification LCO interrelationships could provide a meaningful feedback mechanism to assess adequacy of knowledge in this area, and would better assure fulfillment of learning objectives.for~that simulator guide. Resolution of this concern is identified as an inspector followup item (369, 370/86-22-03).

The inspectors observed two classes being taught to the operations personnel in requalification trainin It was noted that SR0s, R0s, and, in some cases, non-licensed operators are taught in the

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same requalification classes. Although the inspectors acknowledge that there are some benefits with this type of teaching arrange-ment for the less experienced personnel, the inspectors also consider that caution should be exercised to ensure that all personnel are receiving requisite instruction at the level of their position. Training objectives indicated that the Technical Specification LCOs were to be covered in the classroom forma Instead, the licensed operators were instructed to review much of this material through self-stud Classroom Technical-Specification

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training appeared directed at the non-licensed . operator Instructors opinioned that this material was presented to assist nuclear equipment operators .(NEOs) in learning the basics of Technical Specifications, and that Technical Specifications were easier to learn through self-study by licensed operators. Since this class was designated as a requalification class for licensed operators, the inspector expressed a concern that the licensee should assure that the material presented ~ would primarily benefit an individual with a licensed operator's level of knowledg Instruction primarily directed toward non-licensed levels should be presented during segregated instruction period _

Although the inspectors determined that some amount of Technical Specification training was conducted during simulator training', a concern was expressed that classroom coverage of the Technical Specifications should be more comprehensive including such areas

, as entry into multiple LCOs and. action statements, definitions, and administrative Technical Specification The licensee acknowledged these concern The inspectors also observed that the requalification self-study time allotted was not adequately controlled. It was not clear

[- that students were utilizing the time appropriately and that instruction assistance and guidance were provide This is of particular concern because the licensee had previously taken credit for self-study time to meet the minimum required licensed operator requalification classroom instruction requirements. The

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licensee stated that self-study time would n.at be counted toward

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i . . the . minimum requalification contact hours in the future, and acknowledged that the control of self-study time should be

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reviewed to assure appropriate utilization of this tim The _ inspectors also noted that the licensee credits this self study time toward fulfilling the required contact hours for the pre planned lecture phase of requalification. Within the sample of personnel reviewed, however, there were no specific examples noted of actually utilizing self study in lieu of ' lecture attendance to satisfy minimum program requirement The inspectors consider that the potential for this occurrence exists under the present licensee policy, and that the substitution of

'self-study for lecture attendance is unacceptable. Observation of several requalification self-study sessions revealed little formality or structur The inspectors consider instructor control, direction, and assistance necessary to ensure effective use of self-study time, particularly if training credit is based on i Resolution ~ of this concern is identified as an inspector followap item (369,370/86-22-04).

The inspectors reviewed pass rate data for 1984 and 1985 annual requalification written examinations and simulator examinations, licensee' audit examinations for hot license Class VIII and NRC examinations administered in March.and May of 1985. This data is provided in Table Although pass rates ' appear to be somewhat better for licensee examinations than for NRC examinations, the differences are small enough to be considered inconclusiv The inspectors reviewed the status of INPO accreditation for licensed operator training programs and noted that accreditation was awarded for licensed operator and licensed operator requalification training progra ns by letter from INPO dated May 30, 198 In discussion with training department management it was noted that the licens'ee was devoting significant resources to the reorganization and consolidation of training management under a single organization, to improving simulator capability' by purchasing a new simulator, and to' developing new classroom facilities for licensed operator training. These changes are expected to be phased in through 1987 and 1988, and should enhance training quality at McGuir . .

TABLE 1

. Tabulation of Pass ~ Rate Data for SRO and R0 Exams

. Type of- Number Number Year ' Exam Administered Failed Remarks 1985 NRC (SR0) 12 2 2- Simulator Exam Failures 1985 ~NRC.(RO) 13' 3 1- Simulator Exam Failure 1- All written sections failed with overall grade of 66.5%

1- Section 3 failure with overall grade of 75.7%

1985 Licensee Audit 11 1 1- Individual failed (SRO) HLP VIII . oral, simulator, and written with a Section 5, Section 6-failure and overall grade of 76%

1985 Licensee Audit 6 1 1- Overall written (RO) HLP VIII grade of 76%

1985 Requal (combined 66 0 R0/SRO)

1984- Requal (combined 71 4 1- Section failure; RO/SRO) subsequently passed 1- Section failure of 53%; subsequently passed 1- Simulator failure of 78%; subsequently passed 1- Simulator failure of 78%; subsequently passed

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b. Review of Nuclear Production Department Employee Training and Qualifications System Manual ~

The licensee issued the Nuclear Production Department (NPD) Employee Training and Qualification (ETQS) Manual on February 14, 1985. The ETQS manual established the new comprehensive training and qualifications system for all NPD employees. .The document scope states that the ETQS is a systematic approach towards analysis, design, development, implementation and' evaluation of NPD training programs. The ETQS is based on INP0 guidelines and incorporates. current industry techniques for maximum human resource development and utilization. The manual also applies to portions of the Production Support Department, the Human -Resources Department and to some vendor Administrative topics addressed include management and administration of the' programs, goals, organizational roles and responsibilities, specific procedures for training and qualification through task checkout of employees, and training records. The ETQS manual also contains the higher tier procedures for implementation of the training and qualification requirements for specific areas including operations, general employee training, nechanical maintenance, instrument and control maintenance, planning and materials, chemistry, health physics and other-area The inspector reviewed the general topics discussed in the ETQS, .and the following corporate level procedures were selected for detailed revie (1) NPD ETQS Standard No.102.2, Rev.1, Training and Qualifications System Development Model, dated 3/1/86 This procedure provides a description of the basic concepts used to develop the ETQS program. The ETQS is modeled after an INPO developed performance based training and qualification plan. This plan provides for analysis 'of the specific job and goals for the job, design of an appropriate instructional plan including entry level requirements and lesson objectives, development of training materials and methods, implementation of training, and evaluation of the training effectiveness including subsequent employee performanc The new program allows for a training and/or qualification analysis of an employee, resulting in certification of the employee's ability to perform the key tasks of a specific jo This approach allows the licensee to take credit for previous experience or training to qualify an employee for a job based on demonstration of the capability to perform the key task .- ._.

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(2) NPD ETQS Standard No.102.3,. Rev.1, Design and Implementation of Training, dated 11/15/85 The procedure contains instructions on the development' of new programs or revisions to existing modules, lesson plans, etc. The procedure 'provides guidance for evaluating training materials, such as certain forms of test questions, -lesson plan objectives, and overall test quality, for effectivenes (3) NPD ETQS Standard No.106.0, Rev. O, Performance Feedback to the ETQS, dated 11/15/85 The procedure provides instructions on the development of position

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analyses and tracking mechanisms for evaluation of employee's performance and training needs. This procedure also establishes feedback mechanisms to correct ETQS program weaknesse (4) NPD ETQS Standard No. 107.5, Rev. O, Employee Qualification System (EQS), dated 11/1/85 The procedure establishes a computer program for managing ETQS documentatio Review of these documents and program implementation indicates that the licensee has essentially completed. the training and qualification program design and governing document In addition, goals for implementation of specific elements of the program, such as ~the development of task analyses and the field qualification of employees have been established. Progress towards these goals is evident. The program is comprehensive and detailed, and with proper implementation should provide well managed performance based trairiing of licensee employee c. Non-Licensed Staff Training (41400)

The licensee has developed a comprehensive program under the ETQS program for training and qualification of nuclear equipment operators, instrument and. control technicians, and mechanical maintenance personne This program includes classroom training, on-the-job training and task qualification, and periodic requalification trainin (1) Review of Operating History and Abnormal Events The following LER's were reviewed:

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LER 369/85-13: On May 2, 1985, gear case lubricating grease was found in the electrical compartments of some Limitorque motor operated valve actuators. This was due to a personnel error during preventive maintenanc .

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LER 370/85-27: On October 26, 1985, a turbine trip was

. initiated when an improperly aligned fuse caused the loss of field relay-to sense a voltage step as a loss of excitation-conditio The fuse was improperly' installed due to a lack of trainin The inspectors also reviewed the training conducted in March, 1986, for implementation of a new procedure for flow balance of the Nuclear Service Water System (RN). Training records of selected personnel involved in the above . events, or conducting these tests, were reviewed and interviews conducted with the same personne In general, the licensee's actions regarding training 'in response to the incidents and the test appeared to be adequate Training on plant events and on major tests was being conducted in crew meetings, by the cognizant engineer, or by meetings with the

.section leader. Training programs for non-licensed operators were revised to reflect training needs identified during the events reviewed. In addition, the licensee had added a valve maintenance training program to the Instrument and Control Section training due to training related problems experienced in the plan .

The inspector noted during the review of records that several individuals were given credit for a class when no actual class hours were documented. In all cases identified, the licensee was able to demonstrated that the course had been taught as part of a more comprehensive course, and that .the total hours for the two courses were recorded under one listing for the comprehensive course. This practice could lead to problems in auditing records in that records of numerous courses had to be reviewed to determine the ccmprehensive course which had included the course of interest. Each course should be documented separately, or a suitable cross reference develope (2) Review of Training Program for Non-Licensed Operators The inspector reviewed the requalification training schedule for non-licensed operators, attended requalification lectures, and observed training walkdowns for systems in the plant. The non-licensed operators are included in the requalification training classes provided to the licensed operators. For selected classes, the licensed and non-licensed groups are split to allow training at basic levels for the non-licensed operator The instructor was well prepared and able to answer question Teaching techniques kept the class involved. Material presented concerned significant industry events and appeared to benefit the students. No concerns were identifie .

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The ETQS program for non-licensed operators has been implemente Task requirements have been issued. New non-licensed operators are qualified prior to performance of the t a s k .' Incumbent non-licensed operators were grandfathered into the program, but will be reassessed and qualified to each task by January 198 Completion of those tasks specified by the ETQS program prior to performance of' the tasks is accomplished by on-the-job training (0JT) and/or walkdowns by a trainer who is an SRO. The operator is then qualified .by a seco_nd SRO through walkdowns or interview

' to . assure that the operator has adequate knowledge of the task / syste Non-licensed operators who received training prior to the start of the ETQS program are certified as capable of performing required tasks either by evaluation, or plant walkdown of procedures /

system (3) Review of Craft Training The inspector interviewed several technicians to determine if training was being conducted on events and test No concerns were identified in this are Essentially all task descriptions for the instrument and control section and. the mechanical maintenance section have been completed, and an initial assessment has been made of each employee's task qualification Training of OJT trainers and qualification of employees in the field is in progres The licensee's goal for completion of the qualification is late 198 The licensee stated that an INPO accreditation team would be assessing the programs in Novembe inspector followup items (50-369/85-13-06,50-370/85-12-06) are close . Catawba Training Programs The inspection team conducted an evaluation of the effectiveness of the licensed operator, non-licensed operator and non-licensed staff training programs. The inspection methodology involved the review of plant operating history to select abnormal events or operating evolutions in which training deficiencies appeared to have been a contributing factor. -Once identified, plant personnel involved were selected for interviews and/or training record reviews to determine training program effectivenes Within the areas inspected, no violations or deviations were identifie Licensed Operator and Senior Operator Training The inspectors evaluated the licensed operator and senior operator training program Interviews and/or training record reviews of operators involved in the following plant events were conducted:

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(1) LER 413/85-57: From September 24, 1985, at 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br />, to September 25, 1985, at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, with the rod position deviation monitor inoperable, the demand position indication and the digital rod position indication were not compared at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by Technical Specification (2) LER 414/86-09: On April 24, 1986, a steam generator _ level channel which was determined to be out of calibration was not placed in the tripped condition pursuant to Technical Specification (3) LER 413/86-18: On March 24, 1986, both trains of auxiliary-feedwater were rendered inoperable for over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when operators failed to recognize that tagging the train A discharge valve in the open position resulted in the inoperability of train A due to

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pump runout consideration (4) LER 413/86-23: On April 20, 1986, a reactor trip occurred during unit startup when an operator at the controls failed to block the HI FLUX SOURCE RANGE REACTOR TRIP signal after receipt of the permissive which allows this trip to be blocke The inspectors ' verified that selected licensed operators and senior operators involved in the above events successfully completed an initial training program and were examined and licensed by the NR Lecture and simulator attendance records, module quizzes and l examinations were_ reviewed to ensure that selected operators adequately participated in required training and requalification training.

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The inspectors reviewed curriculum guides and instructional material ,

including student tests, instructor lesson plans, and training and qualification records (0JT) to determine if training deficiencies contributed to the above event Several aspects of the above events were determined to have involved training related contributors by both the inspectors and the license In each case, the licensee provided adequate feedback of the identified training need, and appropriately updated and revised operator training programs to correct the deficienc Review of the programmatic aspects of the licensed operator training and requalification training programs indicated that these programs l were adequately administere The ETQS provided appropriate control l over program analysis, design, development implementation and

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procedure changes, etc. was an established process which resulted in up-to-date instructio Immediate training needs were accomplished by the Operations Organization through tne Operator Update Program.

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A review of the 1985 hot license preparation class audit examination results indicated that the licensees initial training programs were providing adequate instruction and evaluation of license candidates.

l Of 24 license candidates taking the audit examination (14 R0, 10 SRO),

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-21 (12 R0, 9 SRO) were evaluated as being prepared for the NRC license examination. -Of the 21 license candidates taking the NRC license examination, 21- candidates (12 R0, 9 SRO) passed the NRC license examination and received their license The licensee's licensed operator requalification program was initially approved by the NRC in NUREG 0954, Supplement No. 4 Safety Evaluation Report. The inspector noted that the as approved program did not require that licensed training staf f attend requalification segment'

training (systems and . integrated plant response lectures). The justification for this element of the NRC apocoved licensed operator requalification program will be discussed generically with the NRC Office of Nuclear Reactor Regulatio A review of the 1985 annual requalification examination indicated that the examination was of sufficient difficulty to challenge licensed operator knowledg Proficiency determination was accomplished by- a simulator class accident assessment examination. Examination grade summaries supported the inspectors conclusions regarding the difficulty-of the annual requalification examination. the average score on the 1985 annual requalification examination was 87?;, with the average grade on the accident assessment examination being 91?s. Of the 41 operators examined at the end of the 1985 requalification cycle, 4 required remedial training due to failing either the annual requalification examination (80?; overall or 70?; category) or the accident assessment examination (80?s). The inspectors verified that the failing operators were placed in an appropriate accelerated requalification program and removed from licensed duties until they had successfully completed accelerated training and were reexamine A review of these reexaminations indicated that they were composed of different questions of comparable difficulty.

r During the review of accelerated requalification, the inspectors noted that the removal of licensed personnel from shif t who have failed the annual requalification examination was an informal process consisting only of verbal notification to operation Due to the regulatory and safety implications of allowing a licensed operator, who had failed the annual requalification examination, to perform licensed duties prior to completing accelerated requalification, the licensee should formalize this process and maintain appropriate documentation as part of an operators official training record. This concern will be identified as an inspector followup item (413/86-31-01, 414/86-34-01). Non-Licensed Operator Training l The inspectors evaluated the non-licensed operator training program by interviews and/or training record reviews of selected non-licensed operators involved in the following events:

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l (1) 'LER 413/85-69: On November.28, 1985, with the 1A diesel generator inoperable, the availability of offsite power sources was not verified pursuant to Technical Specifications due to a non-licensed operator utilizing the wrong procedure to conduct the l required surveillance tes (2) LER 414/86-11: On May 4, 1986, a feedwater isolation occurred during rod drop testing when one of the reactor trip breakers reopened after a non-licensed operator had closed both breakers to support the testing'.

i- The inspectors verified that selected non-licensed operators involved l~ in the above events participated in the licensee's non-licensed l operator training program, and that they were appropriately qualified l to perform the task. Lecture attendance records were reviewed against

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the non-licensed operator curriculum guide and OJT qualification records were verified to be complete with evaluation sign-offs by qualified OJT task evaluator Participation in appropriate non-licensed operator requalification was also verified by the inspec' tors.

! For the events above, the inspector determined that the licensee has identified required training needs, and has provided adequate feedback

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and retraining to fulfill the identified need c. Auxiliary Shutdown Panel Event l The inspectors reviewed selected training related areas concerning the auxiliary shutdown panel event that occurred on June 27, 1986, during a

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loss of control room test. The inspectors verified the following:

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The three designated operators (2 R0, 1 SRO) attended the remote shutdown system lecture during their-license preparation class.

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The licensee had an approved remote shutdown system lecture guide l

which included students materials, applicable procedures and l references, and a lesson plan denoting measurable objectives.

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Immediate training needs identified from the event were l

accomplished through the update training provided prior to unit l

restart.

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The update training cov.ered the post event human factor plant modifications, as well as the operator errors and transient respons All licensed operators received the update trainin The completion of this training for current hot license class candidates will be identified as an inspector followup item (413/86-31-02,414/86-34-02). _ _ _ ~ _ _ _ . . _ _ _ . ._ _ _ _ - _ . ... _ __ _

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The revision of all aspects of the licensed operator training and requalification training program was underway to correct identified training deficiencie .During the revie1. of this area, the inspectors noted that a significant training re. lated contributor to this event was a breakdown in the design and' training organization interfac The inability of the training organization to adequately interface with the corporate design organization to obtain design details of recent modifications to the auxiliary shutdown panel impacted the quality and completeness of operator trainin Presently, this interface is weak and lacks formal definition and responsibility designation The licensee should formalize this interface and improve its efficiency. This concern will be identified as an inspector followup item (413/86-31-03, 414/86-34-03).

During a walkdown of the Unit 2 auxiliary shutdown panel, the inspe'ctor noted several human factor concerns which were subsequently discussed-with regional management. These concerns were to be addressed during a management meeting scheduled to be held with Duke Power Company in the NRC Regional Office on August 11, 1986. The human factor concerns were as follows:

(1) The controllers for the following valves were setup such that 0%

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on the controller indicated that the valve was full open and 100%

l indicated that the valve was full closed. Open and closed labels were correctly designate .

(a) 2NV-294 NV Pumps A & B Discharge Flow Control (b) 2NV-148 Letdown Pressure Control (c) 2CA-60, 56 Au'x. Feed Pump 2A Flow to 2A & 28 S/G (d) 2CA-44, 40 Aux. Feed Pump 28 Flow to 2C & 2D S/G (e) 2CA-64, 52 Turbine Driven Aux. Feed Pump Flow to 2A, 48, 36 28, 2C & 20 S/G (2) The turbine driven auxilia ry feedwater pump turbine speed controller was setup such that zero on the dial indicated maximum speed and ten indicated minimum speed. Maximum and minimum labels were correctly designated. This control scheme is the reverse of the control scheme for the comparable controller located in the main control room, Maintenance Training The inspectors evaluated maintenance training through interviews and/or training record evaluations of maintenance personnel including those involved in the following events:

(1) LER 413/86-30: On June 11, 1986, test personnel were performing the excore nuclear instrumentation system calibration at power procedure. When the Power Range N-41 calibration was completed, calibration of N-44 was starte The test personnel failed to

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notify operations, which was using N-43/N-44 as the controlling channel for input -to Steam Generator (S/G) level control. As a result of this, the unit tripped on S/G low-low leve (2) LER 414/86-05: On . April 17, 1986, personnel discovered that a leak rate retest had not been performed on a containment isolation valve following-~ maintenance on the valv A test engineer reviewed the work' request and had incorrectly indicated that a retest was not require (3) LER 414/86-07: On April 22, 1986, a main feedwater isolation occurred during maintenance of the solid state protection system due to the input error inhibit switch being placed in normal with the reactor trip breakers open. The unit was in mode 4 at the time. The supervisor who reviewed the procedure, N/A'd the step requiring. the reactor trip breakers to be closed prior to placing the input error inhibit switch to norma (4) LER 414/86-23: On June 3, 1986, a main feedwater isolation occurred during testing of the solid state protection system. The reactor trip breaker was placed in the test position and closed, rather than in the correct position as required by procedur This event ' occurred due to the . technicians not following the procedur The inspectors verified that the personnel-involved in the above events had participated in the technician training program ~ and were appropriately qualified to perform the assigned tas Personnel records were examined for accuracy and completenes Training records were cross checked with the Employee Qualification System (EQS)

printout The inspectors found no evidence to indicate inadequate-trai~ning of the personnel whose records were reviewe The methods by which non-licensed personnel receive training and become qualified are delineated in the ETQS manua In each department, the EQS serves as a database for the employees qualifications. A supervisor may access the EQS to determine which technicians are qualified to perform a speci fic task or which specific tasks a particular technician has qualified fo A technician qualifies for a task via the Training and Qualification (T&Q) Guide. Each task has a guide that contains: a description of the task; prerequisites such as a training course or on-the-job training (0JT); procedures that contain the performance of the task; a i I

section by which the technician performs OJT supervised by an OJT trainer and is subsequently qualified by a qualifier; and documenta-tion of entry into the databas l l

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Technicians are given a self-study manual explaining how the T&Q guides wor The OJT trainer is responsible for planning, organizing, and conducting the training according to the information contained in this sel f-study manual . The OJT trainer is responsible for ensuring the trainee meets prerequisites and can complete each element on the T&Q-Guide before signing the T&Q Guide saying that the employee is traine If a deficiency is found, the trainer will list the proper deficiency code on . the T&Q Guid This provides feedback to the training department, and helps to identify potential training deficiencie The OJT trainer is responsible for reviewing the T&Q Guide elements for clarity, correctness, and proper sequencin If p.roblems are found, the ETQS Section Coordinator is notifie The qualifier is responsible for an " independent verification" to assure that the trainee, if unsupervised, can perform the task -with quality. If the trainee cannot complete each element due to a training deficiency, the proper deficiency code is listed on the T&Q Guide. The Qualifier reviews the T&Q Guide to ensure elements are clear, correct and in proper sequence. If problems are identified, the qualifier notifies the ETQS Coordina' to Since this'is a newly incorporated system, many of the technicians were qualified 'by " assessment" of the past' experience and qualification 'In the future, all qualifications will be performed in accordance with the manua Every six months, all technical personnel receive a printout detailing all of the tasks they are qualified to perfor Af ter review, the employee signs and returns the sheet indicating whether or not it is correct and noting what errors, if any, are contained in it. An employee may at any time remove themselves from a task if they do not feel competent in it due to infrequent performance or unfamillarit An extensive procedure change could nullify all qualifications associated with that procedure from the EQS, and require techn "ians to re qualify on the revised procedur Any information such as I&E Bulletins, Operating Experience Reports, or vendor information will be routed and incorporated into crew meetings ,

with attendance sheet The inspectors interviewed various personnel involved in the different levels of the ETQS including OJT trainers, qualifiers, supervisors, engineers, technicians and trainee Individual experience levels )

ranged anywhere from one to seven years. Queries were made as to how l well they understood the ETQS, where to report safety problems, approvals necessary to perform work, and what type of orientation

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training is given. Additionally, the inspectors asked whether there were any negative aspects to removing a previous qualification that

'they felt to be out-of practice i Each interviewee understood the ETQS, what approvals were needed to perform work and when QA

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notification was required. Any negative aspect of "de qualifying"~on a task would be counteracted by the investigation -that follows every Licensee Event Repor Overa' l l, the training program appears adequate.- The ETQS program is still in its early stages,. but it appears to have a comprehensive overview of training and qualification for the non-licensed staf e. . Licensee Actions on Previously Identified Inspection Findings IFI 50-413/84-93-03 and 50-414/84-42-03 concerned the development and establishment of a program to ensure that training personnel holding an operating license remain active and current in their licensed. dutie Operations Management Procedure 3-5, Rev. 4, dated ~ June 4, 1986, requires a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per quarter be spent on shift. It is indicated in .this procedure that it is their goal to obtain and document 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> _ per month. time on shif A review of the personnel records of several training' personnel with operators licenses reveale that they had been receiving 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of time on shift per month. The inspectors close out IFIs 50-413/84-93-03 and 50-414/84-42-0 IFI 50-413/84-93-06 and 50-414/84-42-06 noted the lack of a defined requalification program and qualification . task list This is addressed in section 6.d. of this report. This' item is closed.