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Insp Rept 50-400/86-48 on 860609-13 & 17-19.No Violation or Deviation Noted.Major Areas Inspected:Training & Maint, Including Special Processes Procedures,Vendor Manuals & Cold License Operator Training Program
	ML18019B111
Person / Time
Site:	Harris
Issue date:	07/22/1986
From:	Christensen H, Wilson B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML18019B110	List: IR 05000400/1986048; ML18019B109;
References
	50-400-86-48, NUDOCS 8608180006
	Download: ML18019B111 (26)
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Report No.:

50-400/86-48

,'REUNITED STATES 5--NUCLEAR REGULATORY, COMMISSION REGION,II 5,101 MARIETTASTREET, N.W. ',

ATLANTA,'GEORGIA30323, t tE

Licensee:

Carolina Power and Light Company P. 0.

Box 1551 Ra1eigh, NC 27602 Docket No.:

50-400 Faci1ity Name:

Harris

Inspection Conducted:

June 9-13. and June 17-19, 1986 Inspectors:

H.

C r)stensen B. Mi1son K. Poertner C. Vanderniet P. Moore

Approved by:

CYV B.

1son, Acting Section Chief Division of Reactor Safety License No.:

CPPR-158 Date gne

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Date Signed SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of training and maintenance.

Results:

No vio1ations or deviations were identified.

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REPORT DETAILS Persons Contacted Licensee Employees e

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Bradley, Operations Campbell, Maintenance Manager Collins, Operations Manager Geise, Harris Energy and Environmental Center Gibson, Assistant to the General Manager Harness, Assistant Plant General Manager Howe, Specialist, Regulatory Compliance Hudson, Harris Training Unit McKenzie, Acting Director, QA/gC Operations Olexik, Director, Nuclear and Simulator Training Unit Powell, Training Director Smith, Operations Support Supervisor Tibbitts, Director of Regulatory Compliance Thompson, Operations Wallace, Specialist, Regulatory Compliance Watson, Yice President, Harris Nuclear Project Whitehead, Operations gA Supervisor Willis, Plant General Manager VanMatre, Manager, Technical Support Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.

NRC Resident Inspectors

G. Maxwell, Senior Resident Inspector

- S. Burris, Resident Inspector

- W. E. Holland, Resident Inspector, Watts Bar

Attended exit interview on June 13, 1986

- Attended exit interview on June 19, 1986

- - Attended both exit interviews 2.

Exit Interview The inspection scope and findings were summarized on June 13 and, June 19, 1986, with those persons indicated in paragraph 1 above.

The inspector described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received from the licensee.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio Pf;,I f

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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

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Unresolved Items Unresolved items were not identified during this inspection.

5.

Maintenance (35743B)

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Corrective Maintenance The inspectors reviewed the following procedures:

Maintenance Management Manual (MMM)-001, Rev. 2, Maintenance Conduct of Operations MNN-12, Rev. 4, Maintenance Work Control Procedure NNM-13, Maintenance History Records MMM-002, Rev. 1, Corrective Maintenance MNN-003, Rev. 3, Preventive Maintenance MMM-008, Rev. 0, Control of Maintenance Welding MMM-010, Rev. 0, Threaded Fastener Tightening Procedure NMN-011, Rev.

1, Cleanliness and Housekeeping Administrative Procedure (AP)-20, Clearance Procedure AP-004, Rev. 0, Description of the POM AP-005, Rev. 2, Procedures Format and Preparation AP-006, Rev. 5, Procedure Review and Approval AP-007, Rev. 3, Temporary and Advance Changes to Plant Procedures AP-024, Rev. 0, Temporary Bypass, Jumper and Wire Removal Control AP-038, Rev. 0, Deficiency Tag Procedure AP-610, Rev. 0, Processing Vendor Recommendations, Vendor Manual Revisions and Equipment Technical Information AP-011, Rev.

1, Safety Reviews AP-014, Rev. 4, Criteria for gualified Safety Reviewers Plant General Order-015, Vendor Manual Review Plant Engineering Section Instruction-3.2. 1, Processing and Control of Vendor Manuals Corrective Maintenance Instruction-0006, Corrective Maintenance of Masonei lan Series 700 Controllers Preventive Maintenance (PN)-M0014, Limitorque Inspection and Lubrication (Annual)

Corrective Maintenance (CM)-M0063, Terry Steam Turbine Disassembly and Maintenance PM-M006, Rev. 2, Monthly Lubrication Schedule PM-N007, Rev. 2, Semi-Annual Lubrication Schedule PM-M0010, Rev. 0, quarterly Lubrication Schedule

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The inspectors reviewed the above procedures and conducted interviews with plant management, Operations and Maintenance personnel to verify that the licensee's maintenance program contained the following attributes:

Written procedures were established for initiating requests for routine and emergency maintenance.

Criteria and responsibilities for 'development, review, and approval of maintenance requests were established.

Criteria and responsibilities that form the basis for designating the activity as safety or non-safety related were established.

Criteria and responsibilities were designated for performing work inspection of maintenance activities.

Administrative controls for special processes were established.

Methods and responsibilities for equipment control were clearly defined and established.

Written procedures were established and responsibilities designated for cleanliness control of safety-related components and systems.

Administrative controls and responsibilities for general house-keeping were established.

The licensee has implemented an Automated Maintenance Management System (AMMS) for initiating and tracking work requests.

This system uses a

computer system to generate the work request form.

The computer system identifies the equipment as safety-related or non-safety related.

Eg status is identified in maintenance procedures relevant to the work on the piece of equipment and on part numbers for replacement parts.

The inspector revi'ewed the work request form and had the following observation:

The work form does not contain a

separate block to identify post-maintenance testing requirements.

MMM-012, Maintenance Work Control Procedure, tasks the Maintenance Planner with identifying post-maintenance testing requirements and'tates that these require-ments should be identified in the description of work block of the maintenance request form.

In discussions with the planning section of the inspector determined that the planners have no established guidelines for determining what post-maintenance testing is required after the completion of maintenance activities.

The Operations Department has Operations Work Procedures that identify the clearance boundaries for specific equipment, the LCO requirements for removing a

piece of equipment from service, the testing of redundant systems required per Technical Specifications and the surveillance testing required to prove

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operability prior to returning the equipment to service.

The inspector suggested to the licensee that they review the maintenance program in the area of post-maintenance testing; in particular, the licensee should consider providing a separate space on the work request form to identify and document post-maintenance testing requirements and establishing guidelines for the maintenance planners in the area of post-maintenance testing requirements.

Preventive Maintenance The inspectors reviewed the administrative and maintenance procedures that establish and direct preventive maintenance activities.

Procedure MMM-003, Preventive Maintenance Program, Section 3.0 delineates the responsibilities for the preventive maintenance program.

The preventive maintenance program is controlled via the AMMS which contains the master schedule for preventive maintenance.

The inspectors reviewed selected preventive maintenance procedures.

The procedures reviewed appeared adequate.

Special Processes The inspectors reviewed two special processes procedures, MMM-008, Control of Maintenance Welding, and MMM-010, Threaded Fastener Tightening Procedure.

The procedures appeared adequate.

Responsibilities were well defined and the use of approved procedures and qualified personnel were required procedurally.

Procedure MMM-008, Step 5.4.5 states:

"Any NDE performed as an information only exam...

will not require a

Repair Weld Data Report (RWDR) unless required by the MP (general welding) procedure."

No criteria has been established in the MP procedure for when an RWDR would be required.

The inspector was informed that the licensee would review this procedure.

This item will be identified as an Inspector Followup Item (400/86-48-01).

Vendor Manuals The inspectors reviewed control of vendor manuals.

Vendor manuals at Shearon Harris Nuclear Power Plant (SHNPP)

are not classified as controlled documents.

The distribution of vendor manuals, however, is controlled.

The inspector was informed by the licensee that controlled distribution helps prevent those personnel from using a vendor manual with possibly erroneous information in it.

The licensee has three (3)

plant documents:

Administrative Procedure-610,

"Processing Vendor Recommendations, Vendor Manual Revisions, and Equipment Technical Information"; Plant General Order-015,

"Vendor Manual Review";

and Harris Plant Engineering Section Instruction-3.21,

"Processing and Control of Vendor Manuals".

These documents detail the methods by which any vendor revisions of manuals or recommendations are incorporated into the applicable controlled procedure.

This system appears to control vendor informatio 'H v

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The inspectors reviewed four vendor manuals for their retrievability and comparative accuracy against the procedures that reference them.

Procedure CMI-0006, "Corrective Maintenance of Masoneilan Series 700 Controllers",

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manual of the same name.

In the procedure, Figures Pl and P3 were unreadable.

Procedure CM-M0063, "Terry Steam Turbine Disassembly and Maintenance",

references the vendor manual.

Step 7. 1.2(3) of the procedure does not reflect cautions contained in the vendor manual.

These items were identified to the licensee for resolution.

6.

Operating Staff Training (41301)

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Cold License Operator Training Pr ogr am The inspectors reviewed the training and qualification associated with on-shift cold licensed personnel.

This review encompassed the activities of approximately 30 operators in their progression toward achieving a cold license.

The inspection included a review of Training Instruction (TI) No. 202A, Cold License Operator Training Program and TI-205A, Plant Systems gualification Procedure:

The inspectors reviewed the records of approximately 20 licensed operators.

During the review, the inspectors noted a discrepancy in the way personnel were completing their system qualification checkout sheets.

Some individuals received large numbers of signatures in a

single day.

The inspectors felt it would be impossible to adequately test the knowledge level of an individual on such a large number of signatures in a single day.

The licensee training staff informed the inspectors that this discrepancy had been noted previously and that the individuals identified as having these large numbers of signatures had explained, by written memo, the reason for the signatures.

In virtually all cases, the checkouts actually covered several days; however, the person giving the checkouts signed and dated all the signatures on one day.

The licensee is sending a

memo to all system experts which will set a limit on the number of signatures to be given in one day.

A statement to this effect will also be included in the appropriate training instruction.

This item will be an Inspector Followup Item 400/86-48-02.

The review of operator records prompted the inspectors to review the process of selection of cold license program qualified system experts for TI-205A.

A list of these system experts is maintained by the Training Department and is separated by system.

The name and date of qualification is available from the list.

Because the plant has been under construction, four individuals with previous Senior Reactor Operator licenses at similar facilities were designated as the first system experts.

The workload of giving oral system checkouts and system walkthroughs became too taxing for the original four systems experts, so the licensee Training Department decided to increase the number of systems experts.

The Training Department assigned several

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systems to various individuals.

These individuals were then to study the system and receive an indepth oral examination by the Training Department on the system.

Successful completion of the oral examination qualified the individual as a

system expert and the individual was included on the gualified System Expert list.

Some of the individuals added to this systems expert list were still in the licensing process and in some cases were giving checkouts to individuals in their license class.

This practice could lead to inadequate checkouts, because the expert has not finished training on all plant systems and therefore, would not fully understand the interaction of interconnected systems.

The inspectors consider the practice of using system experts for checkouts as basically good but inclusion of a

person on the expert list should be limited to individuals who have completed their training.

The inspectors conducted interviews with 21 operators in order to assess their opinion of the systems training they received.

The interviews revealed weaknesses in the areas of Emergency Service Water, Normal Service Water, and the Incore Nuclear Instrumentation.

The Training Department stated, prior to the inspection team's final exit from the site, that training on these systems would be included in the next continuing training cycle.

The systems training program appears to be of the length required by the TIs and the knowledge level of the operators appears to be adequate except for the above noted exceptions.

During the interviews, the operators commented on the use of the several different valve numbering systems by the licensee.

Interviewees informed inspectors that the operators use the Westinghouse numbers when discussing systems tests and operations, however, the plant uses a facility numbering system on procedures and labels.

They also stated that at least two more sets of numbers can be encountered (EBASCO, and an earlier facility system)

when performing maintenance and testing.

This is to be expected during the construc-tion of a facility; however, the continued use of several sets of numbers could create confusion on the part of the operating staff after construction has been completed.

One numbering system should be

"designated as the final accepted system and it should be adopted for use by all plant personnel to avoid any future confusion.

This item will be referred to as an Inspector Followup Item (400/86-48-03).

The inspectors reviewed several of the licensee's system descriptions, student handouts, lesson plans, and simplified flow diagrams used by the licensee's Training Department.

The system descriptions are currently being revised to include plant changes and modifications.

The lesson plans and student handouts appeared to be adequate in providing the student the needed material.

Simulator Training The inspectors observed the conduct of simulator training on June

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and June 18, 1986.

The training was conducted in accordance with approved lesson plans which included learning objectives, preplanned simulator scenarios and evaluation criteria for each position (e.g SRO, RO, BOP).

At least two simulator instructors were present for the observed training sessions and conducted the training sessions in a professional atmosphere.

The inspectors critiqued the performance of the instructors and the trainees with facility management.

Suggested areas of improvement were noted; however, overall, the training appeared to be comprehensive and well received by the trainees

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The trainees at the observed sessions were licensed by the NRC in December 1985.

Their NRC examinations in November 1985 did not include simulator examinations, since CPSL was in the process of replacing their old simulator with a more modern and plant-specific machine.

In a meeting between the NRC and CPSL on July 23, 1985 (Meeting Summary transmitted by letter to CP8L dated August 7, 1985),

CP&L requested and was granted waivers of simulator examinations for the first group of

"cold" applicants due to unavailability of a simulator The trainees observed during this inspection were noted to exhibit deficiencies, particularly in their ability to use and follow procedures.

The inspectors reviewed facility administered evaluations for all other licensed personnel who had participated in the simulator requalification training.

Deficiencies in the use of procedures and ability to recognize some malfunctions were noted in many of their evaluations.

The licensee stated that the one week of scheduled training for these personnel was their first opportunity to be trained on the new simulator.

The licensee also stated that many of these people had completed their last simulator training as much as one to two years earlier'he inspectors reminded the licensee of. a letter written to CPSL from the NRC dated November 22, 1985.

That letter stated that the second group of Shearon Harris cold license candidates would be required to take simulator examinations (these examinations were administered in May 1986),

and although the first group of candidates were granted waivers,

"unforeseen circumstances" may require reconsider ation of these waivers.

The licensee acknowledged the findings of the inspectors with respect to the deficiencies noted on the observed simulator evaluations'hese deficiencies were attributed to the length of time since previous simulator training and the routine of shift operations at a plant in the last stages of completion with many procedures still under development.

In a meeting in the Region II office on June 20, 1986 the licensee committed to provide an additional three weeks of simulator training for cold license group I prior to power operation with two weeks of this training to take place prior to fuel load.

This training will be conducted with approved lesson plans and evaluations'ince this training and the evaluations will be audited by NRC inspectors and/or examiners, it will be carried as a followup item (400(86-48-04).

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Review of Non-Licensed Operators Training The inspector reviewed the training and qualification associated with on-shift non-licensed personnel.
This review encompassed the activities of four non-licensed operators and included a review of Training Instructions (TI) and training records.
The inspector reviewed the records of four non-licensed operators.
During the review, the inspector noted no discrepancies and the training records appeared to be adequately maintained.
The inspector conducted one interview of a non-licensed operator and found weaknesses in the area of Normal and Emergency Service Water systems component location, type, and flow paths.
In the inspectors opinion, more interviews are necessary to determine if the system knowledge deficiencies identified above are evident in other non-licensed operators.
This concern will be identified as an Inspector Followup Item (400/86-48-05)
that will be addressed on a
future inspection.
Additionally, the inspector monitored a
lecture provided to the Auxiliary Unit Operators.
The instructor was prepared and responsive to the questions asked by the students.
The students were attentive and motivated.
A professional atmosphere conducive to learning was maintained by all throughout the lecture.
Plant Management and Supervisory Training The inspector reviewed the licensee's FSAR section 13.2.1. l. 1, which states, Plant supervisory personnel not possessing technical training'ufficient for their area of responsibility will attend specialized training courses.
These courses include the following areas:
Transamerican Delaval Diesel Generator Training, Westinghouse Nuclear Services Division Instrumentation and Controls Training, Nuclear Engineering Training, and Maintenance Training.
All the above training took place, except for the Westinghouse Nuclear Services Maintenance training.
The licensee stated in a
memorandum dated June 18, 1984, serial SHNPPA-84-824, that the personnel currently filling these positions possess the technical skills and training sufficient for their areas of responsibility.
The Maintenance training consisted of the following areas:
Introduction to Nuclear Power Plants, Radiation Protection, Nuclear Power Plant Equipment Maintenance, and Maintenance Management.
The maintenance supervisory personnel appeared to have sufficient technical skills and training to satisfy the FSAR require-ment.
The inspector reviewed the training program for technical staff and managers, TI-116, Rev. I, dated March 25, 1986, lesson plans, and three training records associated with this program.
The program contains the following topics:
GET, Introduction to Nuclear Procedures, Technical Specifications, Regulations, Codes and Standards, Power Plant
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Applications and Plant Operations, Systems Course, Plant Modification Process, and Mitigating Core Damage.
The technical staff and managers identified in the program are required to complete the training during the first year of employment.
The documentation of training and the training program appeared adequate to meet the needs of the technical staff and managers.
Shift Technical Advisor (STA) Training The inspector reviewed Training Instruction, TI-601, Shift Technical Advisor Training and Retraining, Revision I, dated April 3, 1986, the FSAR section 13.2. 1.1.3, and selected STA training records.
The STA program consists of training in the following areas:
Theory (approx.
480 hr s.),
Management and Supervisory Training (approx.
hrs.),
Procedures Training (approx.
125 hrs.),
Systems Training (approx.
200 hrs.),
Simulator Training (approx.
120 hrs.),
and on-the-job training as an extra man on shift in the control room for approximately 480 hours0.00556 days 0.133 hours 7.936508e-4 weeks 1.8264e-4 months .
Additionally, a
person who successfully completes the SRO license training program is considered to have acceptable training in lieu of the STA training program.
The review of several training records indicated that the last set of STAs went through the plant's cold licenses training program.
This program covered the same topics as the STA training program.
The STA requalification training program is the license operator requalifica-tion program.
The STA training program appeared to be in conformance with Harris FSAR.
General Employee Training (GET)
The GET program, as stated in the Harris Training Instructions Manual TI-300, Revision I, dated March 15, 1985, is divided into three levels of training.
Level I training allows personnel to enter and work unescorted in the protected area but not in the radiation controlled areas.
Level I training consists of nine topics which include the following:
plant security, plant descriptions, personnel safety, quality assurance, quality control, emergency alarms, drug abuse, fundamentals of radiation and power plant operations, and fire protection.
Level II training consists of topics in the area of radiation protection which allows personnel to enter and work in radiation controlled areas.
The last level of training, Level III, is provided to selected personnel to aid them in monitoring others while working in radiation controlled areas.
The GET program also requires annual retraining and all personnel must receive an 805 on all exams to have successfully completed the training.
The GET program, as defined in TI-300, appeared to meet the requirements of Harris'SAR.
Additionally, the inspector monitored selected portions of the GET Level I training course.
The lectures consisted of personnel safety and quality assur ance and quality control.
The students were provided with a GET handout, with fill-in-the-blank questions.
The instructor
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appeared well prepared, he had a clear voice, and he stimulated good class discussion.
The classroom was located in a trailer, which had a
few disadvantages.
Visibility of the front of the class could be blocked by the trailer 's center pillars.
Additionally, outside construction noise would interfere with the instructor's presentation.
The room's lighting was good, cooling appeared adequate, and the desks and seating were adequate.
The training methods included oral presentation, overhead projectors, and video tapes.
Additionally, audio tapes of the various plant alarms were used.
The inspector reviewed the lesson plans, the student handouts, and interviewed selected personnel on the adequacy of GET.
The program, as defined by TI-300, meets the requirements for GET training and appeared to be adequate.
Maintenance Training Harris FSAR Section 13.2. l.1.4 states in part, any training required will be in accordance with the CP8L Craft and Technical Development Program and will apply to Instrumentation and Control Technicians (IKC), Mechanics and Electricians.
The inspector reviewed the Craft and Technical Development Program, training instructions associated with plant-specific training courses, lesson plans, 'ix training records, and six interviews with maintenance personnel.
The maintenance program consists of generic training, plant-specific training, and on-the-job training.
The generic training, administered by the Nuclear Training Section, Harris Energy and Environmental Center, consists of five levels of training which are accomplished by classroom, laboratory,
. and self-study.
The plant-specific training is conducted by the plant training unit and consists of GET, systems training for craft and technical personnel, mitigating core damage training, and several other courses.
The on-the-job (OJT) training program is performance based and is documented by completing Qualification Checkout Cards (QCC).
The generic and plant-specific training are used to support the QCC system.
Certain generic and plant-specific training is required for maintenance personnel to complete a
given level of qualification.
Harris'nstrument and Control, Electrical and Mechanical maintenance training programs were awarded INPO accreditation on December ll, 1985.
The generic training program is governed by the Craft and Technical Development Program manual, which includes the administrative procedures and list which courses are required for each level of qualification.
Additionally, TI-113, Related Technical Training and On-The-Job Training For Selected Maintenance Classification, Revision 2, dated December 6,
1985, provides the guidelines for training, continuing training, and on-the-job training to meet maintenance qualification requirements.
The instruction contains the qualification checkout cards, the QCC answer guides, and an index which
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requires certain qualification cards to be completed for each level of qualification.
The licensee has procedures to govern individual plant-specific training courses, examples are TI-108, which controls Systems Training for craft and technical personnel, and TI-108-A, which controls the Mitigating Core Damage Training for technical personnel; but, the licensee lacks a general procedure stating the plant-specific training requirements of each maintenance department.
The licensee does have a
computer system that tracks an individual's training and lists the training course that he is required to complete; but these training course requirements are informally controlled.
The inspector informed the licensee of the concern of not having a formalized plant-specific training program.
The licensee informed the inspector that they would proceduralize their plant-specific training requirements and take credit for what they are actually doing.
This item will be an Inspector Followup Item (400/86-48-06).
The inspector reviewed TI-108-A, Mitigating Core Damage (MCD) Training for technical personnel, dated March 9, 1985, MCD lesson plans, the computer records of craft personnel who have not completed the required training, and attended one classroom lecture.
The instructor of the lecture was well prepared and used the lesson plan effectively as a
guide.
The students were provided with a text during the course, but must return it upon completion of training.
The classroom was well lighted, cooling was adequate and all desks had good visibility of the front of the room.
TI-108-A, MCD Training for technical personnel, is designed for technicians, foremen, supervisors, and managers of the Instrumentation and Control ( I8C), Environmental and Chemistry Controls (EKC),
and Radiation Control (RC)
departments.
The course is approximately 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months for the ISC personnel, and approximately
hours for the EKC and RC personnel.
To successfully complete the course, a minimum grade of 80K is required.
The licensee submitted a
letter to NRR on April 21, 1986.
In this letter they stated that:
Only licensed operators will receive annual retraining per the licensed operator requalification program on mitigating core damage.
Managers and technicians in the Instrumentation and Control, Health Physics, and Chemistry sections will receive training commensurate with their responsibilities, but will not receive retraining.
The inspector informed the licensee that no retraining was inappropriate and that NRR would be contacted to determine resolution.
NRR informed the inspector that they have received the letter and it is under review.
The licensee was informed that this concern will be an Inspector Followup Item (400/86-48-07)
pending NRR resolution.
In the review of training records, the inspector noted one case where an individual failed a training course two times and passed the course on the third attempt.
A review of the examination indicated that the test the individual was given was basica'Ily identical.
The inspector expressed the.concern that the individual was learning the test and not the course material.
The licensee informed the inspector that a
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memorandum dated October 10, 1985, 'addressed this concern and they are taking actions to provide more varied examinations.
The maintenance training program for ISC, Mechanical and Electrical Craft appears adequate.
7.
Followup On Previously Identified Items IFI 400/85-16-10:
The training of managers and technicians in the instrumentation and control, health physics, and chemistry sections on mitigating core damage (MCD) (TNI-II.B.4) prior to fuel load.
The inspector reviewed the computer tracking systems for MCD training.
This system maintains track of all assigned personnel required to have the MCD training.
As of June 11, 1986, approximately six environmental and radiation control technicians, approximately five 18C technicians, and 14 technical support personnel have not received MCD training.
The licensee has established a
system to actively track all personnel required to received MCD training and to ensure that they receive this training.
Inspector Followup Item 85-16-01 is close t
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IR 05000400/1986048

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