IR 05000424/1985045

Insp Rept 50-424/85-45 on 850930-1004.No Violations or Deviations Noted.Major Areas Inspected:Licensed & Nonlicensed Personnel Training & Qualification

ML20198E044
Person / Time
Site:	Vogtle
Issue date:	11/05/1985
From:	Julian C, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198E035	List: IR 05000424/1985045 ML20198E030
References
50-424-85-45, NUDOCS 8511130135
Download: ML20198E044 (18)

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R If!og ' UNITED STATES

'o NUCLEAR REGULATORY COMMISSION

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REGION il 101 MARIETTA STREET, * * ATLANTA, GEORGIA 30323

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Report No.: 50-424/85-45 Licensee: Georgia P.ower Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1 Insp2ction Conducted: Septembe 30 - October 4, 1985 Inspector:

F. R. McCoy '

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' Dave Signed NRR Reviewer: J. Koontz Approved by: 6 C. A. Julian, Acting Bbinch Chief m /// S/ [ 6

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Date Signed Operations Branch Division of Reactor Safety SUMMARY

' Scope: This routine, announced inspection involved 20 inspector-hours on site in the areas of. licensed and non-licensed personnel training and qualificatio Results: No violations or deviations were identifie .

8511130135 851106

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REPORT DETAILS a Persons Contacted'

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Licens'ee Employees

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• H..P. Walker, Manager, Unit.0perations-

• C.-E. Belflower, Quality Assurance Site _ Manager - Operations

. *G.' F. _Trudeau, Assistant Readiness Review Manage *J. ' D' Amico, Superintendent of- Regulatory Compliance

• W.?T..Nicklin, Regulatory: Compliance Supervisor .

. ~ * E. 'Swartzwelder, Acting Superintendent of Training

.*S. A. Bradley, Readiness Review Team Leader~

• H. Varnadoe, Readiness Review Team Leader Otherclicensee employees Lcontacted included engineers, technicians,. and -

office personne NRC eR'sident' Inspector

• J.= Rogge

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-*Attended exitiinterview 2; Exit Interview The inspection scope ;and findings were summarized on October 4,- 1985, with

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those persons ~ indicated in paragraph 1 above. The_ inspector described the-J areas inspected and discussed ~ in detail 'the inspection finding No dissenting comments were received from the licensee. The licensee.did not

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identify 1as proprietary any of the materials provided to or. reviewed by the-inspector

during this inspectio : Licensee Action _on Previo'us Enforcement Matters Thisfsubject was not addressed in the inspectio . ; Resolution of NRC Questions and Concerns with FSAR Chapter 13.and Readiness

- Review Modul . Duri ng _ - September _ 16-27, 1985, an 1 office review of - the . readiness review module 2; and- the Final . Safety._ Analysis Report -(FSAR) Chapter 13 was conducted by NRC staff members from Region II.and Nuclear Reactor Regulation f(NRR). This review generated questions 'and concerns which were discussed

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Lwith the applicant and resolved as indicated belo ~(NRC Question) ? ANSI N18.1-1971 sticulates that academic education and related technical training may not.be credited towards nuclear power pl ant..' experience. FSAR table 13.1.3-1 does not provide for this

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stipulation. Module 2, paragraph 4.1.2.1, appears to allow crediting of academic education and technical training towards nuclear experience for senior reactor operator (SRO) licensed management, supervisory, and staff personnel by means of the NUMARC weighting factor methodology of Table 4.1-4. The inspectors question whether or not it is the applicant's intent to use the methodology of Table 4.1-4 in order to determine if SRO candidates meet nuclear experience requirements. The inspectors do not consider that use of this methodology is appropriate for determining experience for fulfillment of ANSI N18.1-1971 require-ments. The inspectors note that use of the specified weighting factors

'could allow for an individual with no prior nuclear experience to be put up for SRO license solely on the basis of an academic degree, participation in the normal cold license training program, and a minimal amount of non-nuclear power plant experienc (Resolution) The applicant stated that the NUMARC weighting factor methodology is used only to determine collective shift experience and is not used to establish ANSI N18.1 experience. A review of paragraph 4.1.2.1 of the readiness review module reflected that this is in fact the stated case. This question is considered resolved with no further action required. (NRC Question) ANSI N18.1-1971 anc Regulatory Guide 1.18 require that the radiation protection manager (RPM), previously designated as Supervisor,. Radiation Protection, should be an experienced professional in applied radiation protection at nuclear facilities dealing with radiation protection problems and programs similar to those at nuclear power stations. The RPM should be familiar with the design features and operation of nuclear power stations that affect the potential for exposure of persons to radiation. The RPM should have the technical competence to establish radiation protection programs and the super-visory capability to direct the work of professionals, technicians, and journeymen required to implement the radiation protection program The RPM should have a bachelor's degree or the equivalent in a science or engineering subject, including some formal training in radiation protection. The RPM should have at least five years of professional experience in applied radiation protection. (A master's degree may be considered equivalent to one year of professional experience and a doctor's degree may be considered equivalent to two years of

. professional experience where course work related to radiation protection is involved.) At least three years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations, preferably in an actual nuclear power statio Additionally, ANSI N18.1-1971 requires the radio-chemistry supervisor to have a maximum of five years experierce in chemistry of which a minimum of one year shall be in radiochemistry. A minimum of two years of this five years experience should be related technical trainin A maximum of four years of this five years experience may be fulfilled by related technical or academic trainin fi

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.It:is the inspectors'{ understanding that the responsibilities for these

. positions; are combined .under the ; cognizance of the health physics-superintendent.- - Based .upon review of . Module 2, table. 4.1-1, and FSAR

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l table- 13.1.3-1, it does not appear that requirements for. the -position

of1 health - physics - superintendent conform to ANSI 'N18.1-1971 and Regulatory Guide 1.8. =The inspectors question the applicant's intent to _ satisfy. all ANSI N18.1-1971 and Regulatory Guide 1.8 requirements

'for this position. Additionally, the inspectors consider that FSAR

. section 13.1 ~ should be ' clear in delineating requirements for . thi s -

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_(Resolution) The applicant stated that the; health physics superinten-

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dent position referenced in the FSAR has been changed to be comprised -

of- twoJ positions as reflected in' readiness review module 5; health

. physics . superintendent and n'uclear chemistry superintendent. Addi-tionally,,the: applicant stated that the requirements of ANSI N18.'l-1971

- and. Regulatory Guide 1.8 were intended to be satisfied and, in actuality,_are satisfied for these: positions. The applicant committed

,to. revise the FSAR in order to recognize the two superintendent posi-

~ tions Land to . more specifically address the requirements of -ANSI N18.1-19711and Regulatory Guide 1.8. This item is considered resolved

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pending:' satisfactory revision of the FSAR as committed. Followup of

this item .will 'be

.through : Inspector Followup Item-(IFI) 424/85-45-0 iThe inspectors also recommended that resumes for personnel filling

' these positions be included in the FSA : (NRC Concerns)

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(1) FSAR. section 13.2.3 states that personnel will either meet the minimum education and experience recommendations of ANSI 18.1-1971 or will complete a. qualification program commensurate with their level of responsibility which will; demonstrate :their; ability to perform - tneir ~ job function With regard to the alternate qualification program, the inspectors are unaware o f- any regulatory -basis for' allowing provisions for such a qualification program and con' sider that the applicant should provide justifica-tion for-such a provision. 1This item was also deemed unacceptable p by the NRC and left as an open item in NUREG 1137, Safety Evalua-tion Report, dated June 198 (2) With regard to FSAR - Table .13.1.3-1, what is j the basis for indicating. that' the specified experience criteria are

" recommended" rather than required?"

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(3) NUREG 1137, Safety Evaluation Report noted that the applicant had stated in FSAR Section. 13.2.2.1.1 that' technicians and foremen who meet qualifications standards of ANSI N18.1-1971 will complete general ' employee training and on-the-job training before being assigned. independent task ~

Similarly, the applicant had stated

'that initial training for instrumentation and control and

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electrical and me::hanical . maintenance technicians and foremen

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'(FSAR Sections 13.2.2.1'.2 through 13.2.2.1.4) will meet education j and experience qualifications. of ANSI N18.1-1971 or will receive initial training. .That is, the applicant- did not plan. to provide

~ plant-specific training to these . personnel before . independent tasks ~were assigned to them. . The Safety Evaluation Report recommended that the applicant reevaluate its _ position for providing plant-specific training for nonlicensed personnel before assignment to independent' job. duties and recommended that plant-specific training ~be provided .to . supplement the personnel-qualifications and experience required . by ANSI N18.1-197 '

Additionally, the . inspectors note that personne1 ' who do not meet'

ANSI . N18.1-1971 ' experience requirements -should undergo formal training and on-the-job training which give them the equivalent of the / requisite . experience. In other words, designated I and C technicians with no prior experience should not be assigned independent tasks until they have had _ one year of related -

technical; training and two years of on-the-job I and C training ,

(supplemented with formal training). It is' requested that the; applicant inform the-inspectors of the conclusions. generated from the1 reevaluation of training requested in the Safety Evaluation '

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Report. . Additionally, it is requested that the applicant provide

justification - for apparently allowing technicians ; to perform independent tasks without requisite - experience as specified i ANSI N18.1-197 (Res'olution) :The - applicant stated that it ' was intended to use performance based training for mechanics, technicians, and equipment operators- for spectfic tasks where a particular individual could not meet ANSI N18.1-1971 -experience requirements and. that it was' the applicant's intent to allow this trained individual to perform this

- specific task' independently. .The . applicant stated _ that resolution of the.open item in the: Safety Evaluation Report was being pursued through-Amendment 19 to'the FSAR. The inspectors consider-that clearing.of the-

. open item in the. Safety Evaluation Report is_ ti:e appropriate vehicle

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for_ resolution of the issue concerning performance based training as an alternative to experience - and consider that no further action is required .through the readiness review program on this ite With regard - to initial training required for personnel who meet . ANSI 4

.N18.1-1971 requirements, .the _ inspectors reserve judgement pending further review and inspectio (NRC Question) In table 1.2-2 of Module 2, the initial qualification for Operations Superintendent, Operations Supervisor, Shift Supervisor,

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and Shift Technical Advisor does not cite ANSI N18.1-1971 or Regulatory Guide 1.8. In table 1.2-3, Plant Operator initial qualification 'does not cite. ANSI N18.1-1971. In table 1.2-5' Plant Engineering Supervisor's

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initial qualification does not cite ANSI N18.1-1971. In table ~1.2-6, mechanics, electricians, ~ instrument technicians, chemical-radiation :

technicians,'and health physics personnel initial qualification does !

not-cite ANSI N18.1-197 The inspectors request that the applicant

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~ identify the reasons for not citing appropriate standards and regulatory guidance in these table .

(Resolution) The applicant stated that where the readiness review module specifically broke down the ANSI N18.1-1971 requirement in

.either the tables or in the program descriptions, no specific reference to ANSI ' N18.1-1971 was considered necessary in the tables. The inspectors understand the applicant's basis for this editorial inconsistency. The applicant stated that it is not considered to be a program element of readiness review to make editorial changes to tne readiness review module. The inspectors have no further comment at this tim (NRC Comment) In table 4.1-10 of Module 2, education and experience requirements for chemical and health physics supervisors do not appear to comply with ANSI N18.1-1971; i.e., minimum five years experience, a minimum of two of the . years may be fulfilled by related technical training and a r.aximum of four years may be related technical or

. academic training. This comment was made in light of the' fact that the qualification criteria for the health physics superintendent in paragraph 4.b. was not fully know (Resolution) The applicant stated that it was considered that the experience criteria required for supervisors not requiring an NRC license was appropriate for these individual In consideration that it .is now understood that the - health physics and nuclear chemistry ~

superintendents are required to meet the requirements questioned above,

'the-inspectors have no further questions in this are (NRC Comment) A typographical error was noted in FSAR Table 13.1-3-1 where suggested education for maintenance foreman should be moved up one line in order to be applicable to the I and C superviso .(Resolution) This comment was noted for informatio (NRC Question) The criteria delineated in FSAR paragraph 13.2.1.3.2.2.B, concerning individuals assuming shift duties after being inactive for greater than four months, is not in compliance with the requirements of 10 CFR 55.31(e) in that there are no provisions for demonstrating satisfactory knowledge of the individual to the NRC. The inspectors question whether it is the applicant's intent to place people who are in this circumstance back on shift prior to requesting and. receiving specific NRC approval in each individual case, and if so, what is the basis for this action?

(Resolution) The applicant indicated that the FSAR did not fully address 10 CFR 55.31(e) and committed to change the FSAR and applicable draft procedures to properly implement that requirement. This item is considered resolved pending satisfactory revision of the FSAR and draft procedure Followup of this item will be through IFI 424/85-45-01.

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' .(NRC Question) --In FSAR- paragraph 13.2.1.3.2.3, what is the basis for exempting-personnel who achieve a minimum section grade of 80 from both lectures and lecture examinations pertinent to that sect' ion? This

' appears _ to be in contradiction to 10 CFR 55, Appendix A, introduction section~and paragraph ;(Resolution) The -applicant indicated that the FSAR did not fully-implement 10 CFR 55, Appendix A, requirements with respect to lecture

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' examinations. and ~ committed to revise the FSAR and applicable draft procedures ~ to properly implement the requirement. This. item is considered resolved pending satisfactory revision of the FSAR and draft procedure. Followup of this item will -be through IFI .424/85-45-0 . With regard to lecture exemption, the applicant indicated that this

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practice is in effect at .other utilities and that satisfactory g ades on annual requalification examinations and lecture examinations should be sufficient to allow for such an exemptio The inspectors have again' reviewed the provision for. allowing lecture exemptions -and, in light of the fact that lecture examinations are now to be administered to all personnel,'have no further commen '

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i -(NRC' Question) In FSAR paragraph 13.2.1.3.2.3, what is the basis .for-excluding the Operations Superintendent, Manager-Unit Operations, Deputy. General Manager, General Manager, and certified simulator

' instructors - from the requirement to have observation reports docu-menting the _ evaluation of their simulator- performance? If an individual is. licensed or certified, observation reports for this facet of. training should be part of the records pursuant to 10 CFR 55

. Appendix A, paragraph 5 ~ .

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(Resolution) The applicant indicated that all licensed personnel should have simulator . perfo'rmance observation reports included in - training records : pursuant to 10 CFR 55 Appendix A,- paragraph Additionally, the-applicant stated all personnel referenced above, with the exception of certified: simulator instructors, will have simulator performance observation ; reports included as part of their training records' and

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committed- to revise the FSAR and draft procedures to implement thi IFI 424/85-45-01 is assigned to followup on this item. With regard.to certified simulator instructor's observation reports, the applicant stated-that since a simulator instructor can fulfill his simulator requalification training-by evaluation of licensed personnel undergoing-

this phase of requalification ;and since the evaluator completes the observation report, it' is not considered appropriate that an observa-tion report be completed on the instructor. The inspectors consider ,

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'that' since NUREG 0737, item I. A.2.3, does not specifically address

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requalification simulator training for certified instructors, that the applicant's response is. satisfactor '(NRC Concern) Paragraph 4.e. of 10 CFR b5, Appendix A, requires provisions for participation in accelerated requalification should evaluations indicate a need. This includes the evaluations of ' para- '

graph- 4.b of -10 CFR 55, Appendix A, which constitutes the lecture

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.. examinations. The-provisions.of-paragraph. 13.2.1.3.2.3 for a lecture examination grade of less than 80 appear adequate for an individual who

'does'not completely fail the examination (e g., a grade of 70 to 80) o .

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- for subjects that.may involve future modification that' are not yet in place. In1 other instances, however,- it may ~ be necessary to. remove isomeone.from licensed duties and: place them in accelerated requalifica--

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. tion if Ta -. lecture examination ' is failed (e.g. , if an individual received a;substantially low lecture-. examination . grade on a subject _

<such- as. emergency procedures). General provisions should be

established for circumstances such as thes .(Resolution) The applicant concurred with this assessment and committed

- to revise the FSAR and draft procedures to address this concern ~. This item is' considered resolved pending _ satisfactory revision of the' FSAR and draft procedures _as committed. IFI 424/85-45-01 will provide fo . . followup of-this ite ' (NRC Concern)-In paragraph 13.2.1.3.2.2, what is the basis for. defining

- active and extensive-engagement of a reactor operator _or senio'r reactor operator as eight. hours t per quarter active participation in operation

of: ther plant or .VEGP simulator?- In NUREG 1137,- Safety Evaluation Report,,the NRC considered eight hours per quarter insufficien Additicnally, : the inspectors consider that all participation directed

towards _ maintaining active status should be at the : plan Credit

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- should not be taken for time spent at the simulato (Resolution) The applicant' committed to revise' the FSAR and draft

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procedures to-direct that participation in operation for maintaining Lactive - status shall be 'at the plant only. This item is considered resolved pending completion of FSAR and draft procedure _ revisions. . IFI-424/85-45-01_ will.-_ provide followup o'n .this ite The applicant -

iindicated that eight hours per quarter was still considered sufficient time for proficiency. maintenance .and noted that' the Safety Evaluation

' Report did not designate the eight hours per month recommendation as an- ~

open citem. -The inspectors have again reviewed the eight hours per

- quarter, provisions for. maintaining active status .and have. no further -

- commen . FSAR sections 13.2.2.1.5.c -and 13.1.3, in describing shift technical advisor (STA) qualifications, delineate experience requirements which

?;t are less conservative - than INP0 guidance for this position as

? delineated in - attachment 'C of 'NUREG 073 Module 2, table 4.1-3, states in part- that STAS will have '18 months nuclear power plant:

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- experience (6 months of which is atcVEGP). This experience criteria E .  : exceeds that delineated in the FSAR. The staff does-not understand how i- the. program description for STA qualifications presented in . Module 2

. can reflect requirements different from those reflected in the FSA This is of particular concern since the qualification requirements presented in - the . FSAR are less conservative than the program description in the readiness review module. The staff requests that U .the a~pplicant identify the intended STA qualification requirements and i

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identify'the reasons why the readiness review module is not compatible with the FSA (Resolution) The applicant stated that the program delineated in the readiness- review module is the actual program and that it is accept-able to implement programs in excess of FSAR requirements. The inspectors have no further commen (NRC Concern) Module 2, table 4.1-2, and FSAR table 13.2.1-1, require three weeks of walkthrough training for applicants who have been previously licensed 'or certifie It is considered that these previously licensed- or certified candidates should have the same hot participation and shift experience, including walkthrough training, that other candidates addressed in Tables 13.2.1-2 through 3.2.1-4 have. Previously licensed personnel could take credit for prior hot participation. The applicant should address this concer (Resolution) The applicant indicated that this was an FSAR error only and that the inplace _ program required full hot participation experience,:on shift experience and walkthrough training for previously licensed . and certified SR0 candidates. The applicant committed to revise the FSAR to correct this error. This item is considered resolved pending satisfactory correction of the FSAR. IFI 424/85-45-01 will provide for followup of~this ite (NRC Concern) Table 13.2.1-1 of the FSAR indicates that hot license applicants who have previously held an SRO license will not be required to complete the three months of observation trainin They will complete three weeks of VEGP walkthrough training instead. This is not in compliance with NUREG 0737 which -requires three months shift training as extra man on shift for hot license trainin ES-111 of NUREG 1021 states:

Up to a maximum of one month of the three months on shift in training can be waived for determining eligibility to sit for an examination. The wiriver should be granted only if there is good cause (i.e., good firith effort by utility to complete training, no other exam administvation planned for some time, license needed to meet NRC requirement), the candidate has completed all other eligibility requironients, and the utility agrees to complete training in a tim 11y manner and certify in writing as to successful completion prior to final licensing action. The region

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should ensure - that the utility's schedule for completion is compatible with the schedule for finalizing licensing action This is the only regulatory guidance that the staff is aware of for waiving on shift training and this can only be done on a case basis and

. must be clearly delineated with basis on NRC Form 39 I

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(Resolution) The applicant indicated that this was an FSAR error only and that it was intended that all hot license candidates participate in three months - of observation training in accordance with NUREG 073 The applicant committed to revise the FSAR to correct this error. This item is considered resolved pending satisfactory correction of the FSA IFI 424/85-45-01 will provide for followup of this ite (NRC Question) NUREG 0737 Item I.A.2.1 requires hot license SR0 candidates who are non-degreed to have held a reactor operator's license for one year. It is not clear how this requirement is imple-mented through either the Module 2 Commitment Matrix or the FSAR. The staff does note that the requirement is addressed in table 4.1-3 of Module 2 as part of the program description. The concern here.is assurance that program requirements are in the commitment, tracking syste '(Resolution) The commitment matrix contains a commitment that -the licensed operator qualification program be in accordance with NUREG 0737, item I.A.?.1; which, as a result of the reference to I.A.2.1, includes the requirement for non-degreed hot license SRO candidate to have held an operator's license for one year. Aithough.this does not specifically identify each element of I.A.2.1 as a separate commitment, the applicant stated that it considered this item to be adequately addressed. A review of the SR0 qualification checklist reflected that the particular requirement addressed above was in the checklist. The

inspectors have no further commen ' (NRC Question) How is feedback of operating experience per HUREG 0737, Item I.C.5., factored into the operations staff requalification training program? This does not appear to be identified as a necessary part of training in FSAR section 13.2.1.3. (Resolution) The applicant stated that procedures 60005-C, 00709-C, and 10016-C govern required. reading for operations staff and factoring of operat'ng experience . into the requalification program. The inspectors reserve judgement in this area pending further review and inspectio This item will be reviewed further as IFI 424/85-45-0 (NRC Question)

(1) In Table 1.2-1 of Module 2, there is a difference between dates given for mitigating core damage training program development; e.g., December 1985 is the date given for General Manager, Manager Unit Operators, Maintenance Supervisor and Health Physics Superintendent, while April 1985 is the date given for Superinten-dent of Regulatory Compliance, Superintendent-Nuclear Training,

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L Operations Superintendent, and Shift Superviso The FSAR stresses that training for mitigating core damage is "not a separate program but is integrated into licensed personnel training..." and that personnel ."will complete training in miti-gating core damage commensurate with their responsibilities"

-(FSAR S13.2.2.3). This same comment exists. in Table 1.2-6 for instrument technicians and chemical-radiation technicians. The staff does not understand the reason for the different program-development dates for this training nor how this relates to the FSAR 13.2.2.3 commitmen .(2) NUREG 0737 Item II.B.4. requires training for_ mitigating core damage for licensee personnel. This item requires that shift technical advisors and operating personnel from the Plant Manager through the operations chain to the licensed operators shall receive all the training irJicated in Enclosure 3 of

. H. R. Denton's March 28, 1980 letter. Additionally, this item requires that managers and technicians in the instrumentation and control, health physics, and chemistry departments shall receive training commensurate with their responsibilitie FSAR section 13.2.2.3 states that the plant manager will complete training in mitigating core damage commensurate with his responsibilities. Is-it the applicant's intent to reduce that training required _for the Plant Manager to less than that delineated in Enclosure 3 of H. R. Denton's March 28, 1980 letter? If so,~what is the basis for this action?

(Resolution).The applicant stated that there is one program development date for one initial program and that the differences in dates is an editorial error. The applicant stated that the Plant Manager would receive all of the training delineated in Enclosure 3 of H. R. Denton's March 28, 1980 since that is " commensurate with his responsibilities".

Although initial training is -to be conducted as a single program, the applicant. stated that provisions are underway to individualize training for specific replacement personnel where NUREG 0737, item II.B.4, recognizes this as appropriat The inspectors have no further comment.

< (NRC Question) In Section 4.1.1.2 of Module 2, training for managers and superintendents is described as being limited to GET and emergency plan trainin Beyond that, training is at the direction of the General Manager, Nuclear Operations. This description does not appear to be acceptable since applicable managers and superintendents must have training for mitigating core damage per NUREG-0737, Item I.A. (Resolution) The applicant stated that this was an editorial oversight in paragraph 4.1.1.2 of the readiress review module and that the training was actually required as reflected in Table 1-2 of the modul , , , . , . .. .. ,- .. . . - - .. . . .. - . . . -

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. A1 review of this table reflected appropriate managers' and superinten-

. ~ dents 1were 1 designated for mitigating. core - damage training. The h applicant stated that it is not. considered. to.-be a readiness review h' . ' program elementi: to ;make editorial changes . to - the readiness review -

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chemistry, and instrument and control appe}ar.to not be required to:have-

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s i - ftraining=for mitigating core damage listed.as a commitment as described- '

in1FSAR S13.2.2.3 if ~ they meet qualification requirements.- of . ANSI

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, l(Resolution) ' The applicant - stated that the .FSAR :was editorially

,a . incorrect and committed to correct the FSAR such that all the requisite supervision would be required in the . FSAR to have training for miti-(g gating coreidamage. 1The applicant stated that supervision qualifica--

- tion checklists would have ensured that the supervisors did,lin. fact, receive; this trainin This item 1s considered - resolved pending satisfactory revision. of the FSA IFI 424/85-45-011will provide for:

,  ; followup of this item.

• : . (NRC -Concern) Table 6.1-1 of Module 2. reflects that the applicant's -

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' readiness review team .did not . inspect FSAR 13.2.2 (Training . for ,

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Mitigating Core ~ Damage for Supervisors). - As noted he" rein, the staff nhas concerns that in some cases,=NUREG 0737, item-II.B.4,- requirements were not properly implemente '

'(Resolution) The applicant noted this concern and indicat'ed that the-

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' readiness review was not intended to 'do a 100% review. The' applicant-

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(' indicated that this tarea was . not ! specifically inspected sinca ~ the

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applicable procedure,- 00742-C, is -in ~ draft 1 status -and not issued. In M consideration of the resolutions - delineated. in paragraphs ' 4.q. , .4'.r. ,

, . ;and 4.s, above, the' inspectors have no further comment.' ' . (NRC J Question) In Table 1.2-7, ;the qualificatio ., ofimethods and training ' specialists 'must include SR0 certification .if these personnel

~are . instructors of systems,- integrated - plant response, transients, or ,

' simulator courses. 'In ' addition,1 such instructors must be enrolled -in

.requalification training. Is'it--intended that any of these' methods and

- training specialists be used ~ to instruct systems, integrated plant response,- transients, or simulator courses? ,

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.(Resolution) The applicant stated that methods and training specialists

do Jnot teach systems, integrated plant response, transients, or simulator 1 courses .and consequently are not required to be - SRO F certified. A review -of paragraph 2.2 of the readiness review module

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confirmed this. The. inspectors have no further commen (NRC Concern) In Module 2, sections 6.2.3 and 7.1.2, finding 2-7 does

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notnappear to give an appropriate resolution to the problem of

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" contract instructors" not being enrolled in a requalification progra ~

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(Resolution) The' applicant was able to demonstrate that the corrective action of finding 2-7 addressed the fact that "all" SR0 licensed or certified instructors would be enrolled in instructor requalificatio .The . applicant stated that "all" included contract instructor The inspectors have no further commen . w- (NRC Question) NUREG 0737 Item I.A.2.3 requires that facility instructors who = teach systems, integrated response, transient, and simulator courses be enrolled in appropriate requalification program The. March 28, 1980 letter from H. R. Denton ' states that this require-ment is to ensure instructors are cognizant of current operating history, problems and changes .to procedures, and administrative

' limitations. It is not understood how completion of the annual written SRO audit examination as delineated in paragraph 4.1.7.5 of Module 2

.will accomplish,- by itself, these requirement (Resolution) The applicant stated that this was, in fact, the basis for Vogtle readiness review finding 2-7 and that the resolution ' to that '"'

finding would eliminate this . concer The inspectors reevaluated finding 2-7 to confirm.the applicant's statements and have no further comment with . respect to the specific question; however, during the evaluation of this particular concern, the inspectors noted that the applicant had included provisions for- renewal of certification in the-event of extended absence from instructor requalification in FSAR section 13.2.1.3.3. Thesa provisions allow certification to be renewed by preparing for and taking or conducting a comprehensive written audit examinatio The inspectors consider that " preparing for and conducting" an audit examination is not sufficient for certification

- renewal since this provides a very limited basis for demonstration of knowledge to teach. The inspectors consider that renewal should be based on the instructor " preparing for and taking" an audit examination and additionally in the instructor becoming completely currant- with required reading and training administered in the areas of feedback of operating experience, plant modifications, procedure changes, admini-

.strative limitations, and problem Resolution of the scope of training necessary for instructor certification renewal is-identified as a_part.of inspector followup item 424/85-45-0 x, (NRC Question) In Table 4.1-2, of Module 2, the syllabus for SR0 systems training does not include reactivity control mechanisms and-indications per FSAR Table 13.2.1-1. Is it intended that this training be given?

(Resolution) The applicant stated that the training is to be given and that this is an editorial error in the module. .The applicant stated that it is not intended to make revision to the readiness review module. The inspectors have no further comment on this ite (NRC Comment) The hot license training requirements in FSAR tables 13.2.1-1 through 13.2.1-4 do not address the need to participate in reactor and plant operation at power levels greater than 20% or the

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need to manipulate controls of the reactor facility (as opposed to simulaCor) during five significant reactivity changes. Although these criteria are not. mandatory, failure to' complete them can result in hot license candidates being required to perform a reactor startup as part of the NRC administered operating tes (Resolution) This comr.ient was provided for information onl (NRC Comment) With regard to on-shift assignments at VEGP for cold

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license candidates as' delineated in paragraph 4.1.2.4 of Module 2, what defines the -on-shift duties and can it be demonstrated that these

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duties in conjunction with walkthrough training provide sufficient depth of knowledge for the walkthrough portion of the NRC examination?

3 Also, completed items on checklists associated with this portion of training should be signed by the supervisor tol whom these individuals

, are assigned, not the individuals themselve The applicant should

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address this concer (Resolution) The applicant provided copies of hot participation experience checklist and walkthrough training program checklists. The applicant stated that the onshift at VEGP checklist is still under

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development and not yet issued. The applicant stated that it_is intended that personnel participating in preoperational testing can take credit for this participation prior to issue of the checklist and that.such

participation would be fully documented. The inspectors will reserve judgement on the adequacy of hot participation, walkthrough training, and onshift checklists pending further review and inspectio The commitment matrix does not appear to contain the following FSAR commitments:

(1) A commitment to have operators and senior opirators relieved of licensed duties to participate in accelerated requalification training if they score less than 80% overall or 70% on any category of annual requalification examinations (from FSAR 13.2.1.3.2.3).

(2) A commitment to give written requalification lecture examinations with criterien scores of 80%. Scores of less than 80% require additional training within 3 month (3) A commitment for cold license applicants to have 6 weeks of hot participation experience at a same type plant and at least 6 weeks of VEGP shift experience. including walkthrough training (per FSAR Tables 13.2.1-1 through 13.2.1-5). ,

(4) A commitment for specific training' topics not yet included in training which are to be taught just prior to precritical license examinations as specified in FSAR section 13.2.1. .-

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(5) A commitment for evaluation of training program effectiveness per FSAR 13.2. (Resolution) With regard to item: (1) through (4), the cpplicant was

.able to demonstrate where the commitment matrix contained the particular commitment. In the case of item (5), the applicant stated that the Vogtle readiness review team consciously did not include this

.. item-in the matrix due to its generality. The inspectors will reserve judgement on the implementation of item (5) pending further review and inspectio In NUREG 1137, Safety Evaluation Report, the NRC noted that the applicant has not committed ' to provide for retesting of simulator response as specified in section 5.4. of ANSI /ANS 3.5-1981, " Nuclear Power Plant Simulators for Use in Operator Training," which is used tu verify software capability and modeling of plant dynamics based on analyses of plant transients and accidents. Therefore, this aspect of the applicant's simulator was not found to be fully in compliance with provisions of Regulatory Guide 1.149. Upon review of the applicant's description of Lproposed simulator performance testing provided by letters dated May 10, May 28, and July 29, 1985, it was concluded that the ' applicant's simulator testing program, as described, did not meet-the objective of testing design analysis data and showing correlation between the complete plant data base and the simulator data base. This item was identified as an open item in NUREG 1137, Safety Evaluation

. Report. With respect to readiness review Module 2 on this item, the inspectors al o note the following:

'(1) . In table 3.0-2, the applicant states that " simulator testing will be continuous while in use. Operators and instructors will identify problems which shall be documented, investigated and corrected." The applicant's simulator testing program is not acceptable since it does not meet the intent of ANSI /ANS (2) Section 4.2 contains no commitment for the Vogtle simulator to conform with Regulatory Guide 1.14 (3) The verification plan for ANSI /ANS 3.5-1981 as described in table 6.1-1 (page 6 of the table) does not delineate "line by line" compliance since the applicant's program is known not to be in compliance. Similarly, on page 15 of table 6.1-1 conformance with Regulatory Guide 1.149 cannot be verifiable "line by line" since the NRC has found that the applicant's program for simulator performance testing is not acceptable. " Simulator testing... con-tinuous while in use" does not comply with Regulatory Guide 1.149 and ANSI /ANS (4) In sections 6.2.3 and 7.1.2, finding 2-5 makes no mention of compliance with Regulatory Guide 1.149 or ANSI /ANS 3.5 which address the problem described. The applicant's response does not appear to be acceptable since only simulator change notices

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generate operability testin Independent simulator performance testing per. ANSI /ANS 3.5 is not don (5) Section 1.3 of Module 2 makes no reference to compliance with DL Regulatory Guide 1.149 or ANSI /ANS 3.5 for simulator performanc (Resolution) .The1 applicant indicated that readiness review was conducted to be current with the FSAR -as submitted and consequently

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would not reflect :the concern generated in the FSAR as an open ite The inspectors noted the applicant's comment and consider that clearing of the open item in the Safety Evaluation _ Report is the appropriate r vehicle for resolution of this concer (NRC. Question) In table 1.2-2 of Module 2, the additional training for the operations supervisor gives a program development date of August 1986 for general' employee training (GET) while all other GET dates are listed as August 1985. Is there a reason for this difference in dates?

(Resolution) The applicant stated that this was a typographical error and that the correct date was August 1985. The applicant stated that it was not intended to revise the readiness review module. The inspectors have no further commen (NRC- Question) In table 1.2-2, of Module 2, the number of employees completing STA training is listed as 1 If only 8 STAS are planned for VEGP Unit 1 fuel load, why is the number so great? Does this number in'clude STAS for both units?

(Resolution) The applicant stated that it was intended to develop depth in the ranks of STAS in order to be able to fill Shift Supervisor positions from these rank The inspectors have no further commen (NRC Comment)

(1) In table 1.2-6 of Module 2, the commitment that continuing training is "to be determined" does .not correspond to the FSAR commitment for continuing training to include courses as listed in curriculum outlines for mechanics, electricians, technicians, and quality control specialists (FSAR 13.2.2.1.1 through 13.2.2.1.4).

(2) In table 1.2-8 of Module 2, continuing training for supervisors and foremen in-health physics, chemistry, controls and instrumen-tation, mechanical and electrical maintenance are listed as at the discretion of their superintendents. This does not correspond to the FSAR commitment for continuing foreman training "unless they have already completed the offered course" according to the curriculum outlin .

(3) In section 4.1.8.3 of Module 2, continuing training for various

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nonlicensed supervisors and foremen should not be "at discretion -

of the superintendent" but conform to the curriculum outlines as described in FSAR sections 13.2.2.1.1 through 13.2.2.1.1 (Resolution) The applicant stated that the specific continuing-training programs have yet to be developed as the module taoles so indicate and will not be developed until the indicated program development date indicated in the table. Consequently, the readiness review did not attempt to provide specific program descriptions. The inspectors have no further comment on this ite (NRC Question) In table 4.1-8 of Module 2, the engineer training syllabus, two topics are. listed that are not included in FSAR 13.2.2.1.11; i.e., electrical systems and accident analysi Is it intended that this training be given?

(Response) The applicant stated that this training would be given and that the noted condition is acceptable since the actual program is in excess of FSAR commitment The inspectors have no further commen . Synopsis .ot Inspector Followup Item 424/85-45-01, Resolution of Training Program and Qualification Discrepancies Complete commitment to revise FSAR Section 13.1 and draft procedures to more accurately delineate ANSI N18.1-1971 and Regulatory Guide experience and education' requirements for the positions of health physics superintendent and nuclear chemistry superintendent (paragraph 4.b.). Complete commitment to revise FSAR Section 13.2.1.3.2.2.B and draft procedures to fully address 10 CFR 55.31(e) (paragraph 4.g.). Complete commitment to revise FSAR Section 13.2.1.3.2.3 and draft procedures to properly implement 10 CFR 55 Appendix A, paragraph requirements with respect to administration of lecture examinations (paragraph 4.h.). Complete commitment to revise FSAR 13.2.1.3.2.3 and draft procedures to maintain observation reports documenting evaluation of all licensed personnel pursuant to 10 CFR 55 Appendix A paragraph 5 (paragraph 4.1.). Complete commitment to revise FSAR Chapter 13.2.1.3.2.3 and draft procedure provisions for failure of requalification lecture examina-tions (paragraph 4.J.). Complete commitment to revise FSAR paragraph 13.2.1.3.2.2 and draft procedures to require the : eight hours per quarter participation in operation for proficiency maintenance be performed at the plant and not the simulator (paragraph 4.k.).

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Complete commitment to correct FSAR table 13.2.1-1 error.with regard to hot participation, walkthrough, training and onshift experience for

.previously licensed or certified SR0 candidates (paragraph 4.m.). Complete: commitment to revise FSAR table 13.2.1-1 error with regard to hot license SRO candidate observation training (paragraph 4.n.). Complete commitment to correct editorial error in FSAR section 13.2. which did not require training in mitigating core damage for health

~p hysics, chemistry and instrument and control supervisors if they met ANSI N18.1-1971 requirements (paragraph 4.s.). Resolve concerns associated with the scope of- training required for-instructor certification renewal in the event of extended absence

'(paragraph 4.w.). Results of Readiness Review Module 2 On Site Scoping Assessment Conducted September 9-11, 1985 During the period of-September 9-11, 1985, the inspector conducted a scoping assessment of readiness review module 2 in order to become familiarized with the readiness- review program and to determine the most appropriate method for inspecting the module's bounded area This assessment involved 16 inspector hours onsit The inspector noted that one of the Vogtle readiness review team findings concerned undocumented grade changes on license candidate examinations. The corrective . actions -associated with this finding involved the-initialing of future grade changes by the instructor adjusting the grade. The inspector reviewed one exainination with the acting Superintendent of Training where grades had been changed and expressed concern that the applicant was not

' taking action to document -the basis for deleting a particular question or

- revising the answer to the question. The review of an examination lended support 'to the necessity for doing - thi In an exit interview of September 13, 1985, resolution of this concern was identified as an inspector followup item (IFI 424/85-45-02).

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