ML17156B420
| ML17156B420 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/26/1989 |
| From: | Conte R, Gallo R, Howe A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B419 | List: |
| References | |
| 50-387-89-80, 50-388-89-80, NUDOCS 8911010049 | |
| Download: ML17156B420 (31) | |
See also: IR 05000387/1989080
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.:
50-387/89-80
and 50-388/89-80
Docket Nos.:
50-387
and 50-388
License Nos.:
Licensee:
Power 5 Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Facility Name:
Susquehanna
Steam 'Electric Station Units
1 and
2
Inspection At: Berwick, Pennsylvania
Inspection
Conducted:
August 21,
1989, to August 25,
1989
Inspectors:
T. Bettendorf,
PNL
T. Easlick; Operations
Engineer,
BWR Section
T. Mazour, Consultant
M. McCoy,
Human Factors Analyst,
W. Oliveira, Reactor
Engineer,
R. Pelton, Training and Assessment
Specialist,
T. Rebelowski,
Senior Reactor
Engineer,
S.
Shankman,
Chief, Training and Procedures
Section,
J. Wigginton, Chief, Facilities Radiation Protection, Section,
Team Leader:
<d'llen Howe, Senior Operations
Engineer
BWR Section,
Division of Reactor Safety
Jd~s
g
Date
Reviewed by:
Richard J.
Conte,
hief,
BWR Section
Opei ations Branch,
/o 2W~
Date
Appt oved by:
obert
M. Gallo, Chief, Operations
Branch
Division of Reactor Safety
ate
89
CK
Q
()
()g()()49 uiw'102+
9
Executive
Summar
A special
announced training program team inspection
was performed at the
Susquehanna
Steam Electric Station,
Units I and 2, from August 21 to
August 25,
1989 (50-387/89-80
and 50-388/89-80).
This in-depth team
inspection
focused
on Susquehanna's
training programs
and their implemen-
tation.
The specific training areas
inspected
were health physics,
mecha-
nical maintenance,
Instrument
and Controls (IEC), and licensed reactor
operator
and shift supervisor.
The inspection
included
a review of train-
ing program procedures,
training materials,
records, qualification stand-
ards,
and other applicable
documents;
observations
of classroom training,
on-the-job trai'ning,,simulator training,
and on-the-job performances;-
and
interviews with operators technicians,
trainees,
instructors,
supervisors
and managers.
Within the
scope of the areas
reviewed,
the training programs
at Susque-
hanna Units I and
2 are well designed,
implemented,
and strongly supported
by both training management
and line management
including the Senior Vice
President
Nuclear.
Areas of program strengths
and specific weaknesses
are
summarized
below:
The team concluded that the training programs satisfied all of the
compo-
nents of a Systems
Approach to Training (SAT) based
program
and the
programs
are functioning well.
The job/task analysis is comprehensive,
well defined,
and well implemented.
The training facility component of
the training program which includes the classrooms,
laboratories
and
equipment,
and support facilities is an overall strength.
Further,
the
team concluded that
an overall strength of the training
program is the comprehensive
program evaluation
process.
This process
systematically
evaluates
the effectiveness
of training which resulted
in
revisions to the training programs.
The technical
content of the Units of Instruction (UOIs) are generally
good but they are not structured
to assure
consistent delivery by instruc-
tors.
The licensee
is in the process
of improving these
UOIs and plans
to continue this process.
The Health Physics
(HP) training programs
were found to be effective and
of high quality.
Weaknesses
were noted with the
UOIs and with systems
training for HP technicians.
The Mechanical
Maintenance
(MM) training
programs
were found to be well implemented.
Weaknesses
were noted regarding
incomplete
implementation of the applicable
examination
development policy
and the apparent
low priority given to
MM certification.
The Instrument
and Controls (IKC) training programs
were effectively implemented with
weaknesses
regarding
incomplete
implementation of the applicable examination
development policy and the frequent
use of temporary approvals of UOIs.
The
team concluded that the training programs for reactor operators
and
shift supervisors
were performance
based
and well-implemented.
Weaknesses
la
were observed. regarding
UOI format, the indication that the licensee
has
committed to various requirements
for program implementation,
and
as indi-
'cated in the following paragraph.
As a'esult of this inspection,
one apparent violation of NRC requirements
was identified in that there
are
inadequate
requalification program provi-
sions to provide accelerated
training and retesting to licensed operators
who have failed
a comprehensive
written examination or annual
operating
test prior to their returning to licensed activities.
Details are given
in Section
6.3 of this report.
Jy
Table of Contents
Executive
Summary
1.
Background
and
Scope of Inspection
~Pa
e
la
2
2.
Overall
Program Assessment
3.
Health Physics
5
4.
Mechanical
Maintenance
10
5.
Instrument
and Controls
( IKC)
~
~
6.
Reactor Operator
and Shift Supervisor
14
17
7'.
Exit Meeting
Summary
~...
22
~ Appendix 1
Appendix- 2-
Appendix 3
Pre-Inspection
Requested
Information.
Persons
Contacted
~
Letter to the
NRC from W. Lowthert, Dated
September
12,
1989
.
~
~
~
~
~
~
~
23
.
24
26
p~
i,
DETAILS
Back round
and
Sco
e of Ins ection
The Nuclear Regulatory
Commission
consi'ders. effective training of
personnel
to be
an important part of safe nuclear
power plant operations.
This inspection
was in keeping with NRC policy as stated in, "Commission
Policy Statement
on Training and Qualifications of Nuclear Plant
Personnel,"
(as published
in Federal
Register
which states
that the
NRC will expand the method
by which is monitors the industry
training programs
by performing post-accreditation
reviews at selected
sites.
The inspection
was conducted
using inspection
procedure
41500, Training
and Qualification Effectiveness
and the guidance of NUREG-1220 "Training
Review Criteria and Procedures."
NUREG-1220 provides criteria to review
what is referred to as performance-based
training, or the Systems
Approach
to Training (SAT).
The criteria assess
what are considered
the five
elements
of these training programs.
The elements
are:
1.
Systematic
analysis of 'e jobs to be performed,
A
2.
Learning objectives that are derived from the analysis and.that
describe
desired
performance after training,
3.
Training design
and implementation
based
on the 1'earning objectives,
4.
Evaluation of trainee mastery of the objectives during training,
5.
Evaluation
and revision of training based
on the performance of
trained personnel
in the job setting.
The specific training areas
inspected
were health physics,
mechanical
maintenance,
Instrument
and Controls (ICC), and licensed reactor operator
and senior reactor operator.
The inspection
included
a review of training program procedures,
training
materials,
records, qualification standards,
and other applicable
documents;
observations
of classroom training, on-the-job training,
and simulator training and on-the-job performanc'e;
and interviews with
operators,
technicians,
trainees,
instructors,
supervisors,
and managers.
The inspection
was performed
by initially obtaining materials
from the
licensee.
The materials
provided are 'given in Attachment
1 of this
report.
Specific job tasks for the areas
r'eviewed were selected
and
several
training program procedures
were reviewed prior to arriving on
site.
The focus of the inspection
was
on (1) how the tasks
were analyzed;
(2) how training objectives
were derived from the tasks;
(3) how training
for the tasks
was designed,
developed,
and implemented;
(4)
how trainees
were observed
and evaluated
during training to determine their level of
task mastery,
and (5) how feedback
on training, trainee evaluations,
and
on-the-job performance
indicators
are incorporated into revision
and evalu'-
ation of the training programs.
Overall
Pro
ram Assessment
The team
made the following overall assessments
of performance
of the-
training programs.
Specific findings and conclusions will be described
in each training area
reviewed.
The team concluded that the training programs satisfied all of the
compo-
nents of a
SAT based
program
and the programs
are functioning well.
In
perspective,
the strengths
identified in .the following paragraphs
were
prevalent throughout the areas
reviewed
and the weaknesses
and problems
observed
were related to specific items within the programs.
The following are characterized
as program strengths:
Systematic
Job/Task Analysis
The team reviewed procedure
STCP-QA-112,
"Job/Task Analysis Program,
Revi-
sion 2."
This procedure
applies to all accredited
programs with the
exception of the technical staff and managers.
The team noted that this
procedure
incorporates participation of training personnel
and the associ-
ated work group including job incumbents
and determining
a systematic
approach
to developing
and selecting tasks.
Criteria for initial and
continuing training needs
are provided.
This procedure
assures
analysis
and development of the tasks
which support development of learning
objectives
and while the procedure
states
the task analyses
are historical
documents,
there are provisions to update
the task analysis if the
need
were to arise.
The tasks
are placed in Training Cross
Reference
Matrices
after selection for analysis
and training.
The Matrices reference initial
and continuing training criteria, units of instruction
and objectives,
criteria for deselection,
and provide
space for comments.
They are
required to be kept current via pen
and ink changes
by the responsible
training supervisor
and periodically revised
and approved
by appropriate
training and line management.
The team verified that the above elements
were incorporated into the
specific tasks
selected
from the Training Cross
Reference
Matrices via
interviews
and review of the documentation.
The team concluded that the job/task analysis is comprehensive
and well
defined
and that the job/task analysis is well implemented.
Development of Learning Objectives
Based
on reviews of the learning objectives for the specific tasks
selected,
the
team determined that learning objectives
developed for the
tasks
are easily tracked
from the Training Cross
Reference
Matrices,
they
w ~
clear'ly state
expected
behavior,
they supply the appropriate
conditions
and standards
for performance,
and they relate to the specific technical
knowledges, skills and abilities required to perform the task.
Provisions
are also in place to change
and update learning objectives,
The team concluded that the learning objectives
are specific, well struct-
ured,
and technically adequate.
As an additional
improvement,
the licen-
see plans to cluster related learning objectives.
Training Facilities
and Equipment
The team concluded 'via observation that the'hysical
component of the
training program which includes the classrooms,
laboratories
and equip-.
ment,
and support facilities is an overall strength.
Licensee
Management
has
found that the plant specific simulation faciliity, does not ful y
support its objectives.
Licensee
management
has therefore
determined that
th
simulation facility will be replaced
or upgraded
and
have addressed
thi
issue with the
NRC in a letter to the Regional Administrator date d
August 4,
1989.
Management
Support
The team found that training management,
line management,
and senior
management
strongly supported all training programs.
Regarding this
strong support,
the
team noted that training and line managers
met regu-
larly to discuss training issues,
line managers
knew they had primary
responsibility for training quality, and the training and line managements
fully supported policies to rotate
personnel
from the plant to training
and vice-versa.
The team also noted that the Senior Yice President-
Nuclear actively supports training by personally teaching
a course
as well
as frequently meeting with management
to discuss training issues'
Program Evaluation
The team reviewed procedures
that implement the program evaluation of the
SAT process.
These
procedures
adequately
define methods to systematically
evaluate
the effectiveness
of training programs;
to elicit feedback
from
trainee tests,
on-the-job experiences
and supervisors;
to incorporate
instructor and trainee critiques;
and to evaluate training instructors.
The team reviewed the
"Susquehanna
Training Center
1988 Training Evalua-
tion'Annual Report."
The team noted that this report is given wide
distribution
among plant and corporate
management..
This report details
both overall
and specific program performance
in preparing
the staff to
perform their jobs.
Senior plant management
indicated that evaluation of
training effectiveness
is expected
of plant supervisors
and managers.
In addition to the
summary report,
the team found evidence of consistent
and on-going evaluation of training programs.
Trainees,
supervisors,
job incumbents,
and instructors
indicated that they provide feedback
on
training program effectiveness.
Tracking and trending of these
data
were
found to provide input that resulted in training program
improvements.
Also, examination results were. used for both near term program adjustments
and long term modifications.
Several
components
of the evaluation of training are noteworthy.
These
include the analysis. of trainee
and supervisor
comments
about training and
the prompt feedback given to commentors with regard to the disposition of
their comments.
Another feature of program evaluation is the nuclear training group's
responsiveness
to both internal
and external
evaluations.
An extensive
Nuclear Quality Assurance
(NQA) audit was conducted
in May and June of
I988 to verify the effectiveness
of the training, retraining
and qualifi-
cation programs.
Areas were identified as needing
responses
by the
~ nuclear training group and were closed prior t'o the team's visit.
The
team also
found corrective actions in place to respond to items noted in
the
INPO accreditation
team visit of 1988.
In addition to outside evaluations
from corporate quality assurance,
INPO,
and
NRC, the nuclear training group contracts for an assessment
from
instructional technologists
and other training professionals
to recommend
improvements that might be
made to enhance
learning.
The team concluded that
on overall strength of the training program is
the comprehensive
program evaluation
process.,
A clear process
is in
place to systematically
evaluate
the effectiveness
of training programs
and to revise the programs
as required.
The following is
a specific weakness
applicable
to all programs:
The team noted that the technical
content of the Units of Instruction
(UOI) (which are utilized by the students
as study guides
and by the
instructors
as lesson
plans) is genera11y
good.
However, they are not
structured
to assure
consistent delivery by the instructors.
See Sections
3.2, 4.2, 5.2 and 6.2 for examples of UOI deficiencies.
The 1icensee
is
aware of this weakness
and plans to improve the UOI's as
an ongoing
ptoject.
Health
Ph sics
The inspectors
examined the licensee's
health physics technical selection,
training,
and qualification program
and found the overall program to be
-well-implemented with the necessary
program elements
in place
and func-
tioning to ensure
continued performance at the current high level.
In
addition to using NUREG-I220, "Training Review Criteria and Procedures"
as
a guide,
the program
was reviewed
and appraised
against the following
regulations,
guides (both
NRC and Industry),
and
good industry practice.
~
10
CFR I9.I2, "Instructions to Workers"
.
~
"Personnel
Selection
and Training"
Regulatory Guide 8.27, "Radiation Protection Training at Nuclear
Power Plants"
Regulatory
Guide 8.29, "Instru'ction Concerning
Risk From
Occupational
Radiation
Exposure"
ANSI/ANS-3. 1-1978, "Selection
and Training of Nuclear
Power Plant
Personnel"
3.1
Task Selection
The following tasks
were selected
from this licensee's
Health Physics
Technician J/TA Training Cross
Reference
Matrix by the team for
evaluation of health physics initial and continuing training:
~
Provide close health physics
coverage for workers in high dose
jobs (for example,
control
rod drive mechanism
replacement).
~
Direct the installation
and removal of temporary shielding.
~
Support the use of air line respirators.
~
Respond
to
a fuel handling accident.
~
Assist in developing contractor
HP technical training
program.'uring
the
1988 job analysis,
the task, "Assist in Developing Contrac-
tor HP Technician Training Program,"
was identified as
a management
task
and is not included in the initial or continuing
HP technician
training programs.
3.2
Desi
n and
Im lementation
The team reviewed the UOIs for the four tasks
selected
for train-
ing/retraining.
The instructional setting for all tasks
was evalu-
ated
by the Curriculum Committee during the initial development of
the,UOIs.
As new tasks
are selected for training, the Curriculum
Committee evaluates
the tasks to determine
the instructional setting
best suited for mastery of the task.
In general,
the organization
and presentation
of initial and continu-
ing training is based
upon the relationships
among learning object-
ives
and follows a logical sequence.
The team observed
the presentation
of a scheduled
general
worker
respiratory protection lecture.
The lecture
was evaluated
using the
licensee's
instructor evaluation
form (form STCP-331B)
and the guid-
ance of NUREG-1220.
The training was conducted
in accordance
with an
approved
UOI.
The instructor followed the UOI, was poised
and
professional
in his presentation,
and maintained class interest.
A
follow-up interview with the instructor verified the instructor
has
a complete
and thorough
knowledge of the subject matter
and was
confident in his ability to relate the subject matter in an under-
standable
manner.
Based
on the above
and feedback
from technicians
and
HP management,
the
team determined that the instructors
have
an
excellent rapport with the students.
The team concluded that high
quality instructors
are
a program strength.
7
The team reviewed training records
and found they are maintained
as
a real-time data
base for all instructors
and trainees.
Student
data is constantly being input into the data
base
and is generally
current through the previous week's instruction.
Class rosters
are
organized
by unit of instruction
and converted
to microfiche during
the calendar
year following instruction.
The training records
examined
were generally
complete
and auditable.
In interviews,
HP technicians
indicated that feedback
and communica-
tions between
the health physics working group
and the. training organ-
ization were good and had improved over the past
two years.
The tech-
nicians especially liked their ability to improve and,select initial
and continuing training through the Curriculum Committee.
Membership
on the health physics
committee included
Level I technicians,
Level
II technicians,
health "physics management,
and
members of the train-
ing organization.
This "grass-roots"
approach,
using
a broad
spec-
trum of personnel
including qualified technicians
as
a resource for
affecting change to the training program is viewed as
a program
strength.
Based
upon feedback given during technician interviews,
this practice
has
a positive impact
on worker morale
and their strong
attitude
toward training.
The license'e
has
a formalized and well-documented
on-the-job training
(OJT) program for the HPtechnicians.
All HP technicians
interviewed
agreed that the
10 week
OJT training following the initial training
more than adequately
prepared
new technicians for their assigned
duties.
HP line management fully supports
the dedicated
10 week OJT
period where the technician's training (guided
by an experienced
Level II technician) is focused with the technician free to maximize
the field learning aspects
of qualification.
When ready,
a techni-
cian demonstrates
a task
and is formally evaluated.
This evaluation
is documented
in the technicians qualification record.
The team concluded that the on-the-job training program following the
initial technician
classroom
phase of instruction is
a program
strength.
The structured training for professional
HP personnel
relies
on
self-improvement
methods (e.g.,
through self-study
and reading)
following written guidance
generally in the form of a subject
area
checklist.
Additionally, plant management
provides excellent
support
for professional
development
by allowing the professional
HPs to
attend technical
seminars
and meetings outside
the plant environment.
Ensuring that the professional
staff maintains contact with fellow
industry professionals
and routinely attend technical
seminars/train-
ing is viewed as
a program strength.
The
HP training facilities in the training center
are
good.
The
laboratory
equipment properly mimics the plant-side instrumentation,
and of special
note is the "spare" Post<ccident
Sampling
System
(PASS).
The
PASS mock-up is used
by both HP/Chemistry technicians
'nd
I&C as
a training aid.
The Control
Rod Drive Mechanism
(CROM)
removal
and rebuild mock-up
used
by mechanics
and
HP staff has
allowed for excellent, effective ALARA training.
The classroom,
technical library, laboratories,
administrative
support services,
and
the computer-based
training laboratory are all good facilities that
have
been properly designed
and effectively utilized.
The overall
quality, of the training facilities is viewed as
a program strength.
The current format of the UOIs provide the trainee with an excellent
tool for later review of lesson material.
However, while the units
of instruction contained
necessary
learning objectives,
the team
noted that appropriate instructor teaching activities, instructor and
trainee
references,
appropriate
evaluation methods/standards,
and
required materials in their current textual
format did not ensure
consistency
of instructor presentation.
Missing from the units of
instruction were several
of the more important portions of lesson
plans designed
to ensure consistent delivery such as:
I) embedded
instructor references
and aids (which indicates
when additional
information, transparency,
or job aid is used to enforce learning),
2) sample exercises
(radiation shielding problems,
dose rate problems,
etc.)
as
examples for use during lectures,
and 3) areas to allow for
customization of the lesson
plan by the instructor (pertinent,
perso-
nal anecdotal
material).
Additionally, while the technical
content
of the UOIs was good,
the team noted that the material for the task,
"Respond to fuel handling accident"
was inadequate
and not up to the
facility'
high standards.
The potential
problem with consistency of
presentation
and the one,
substandard
unit of instruction (out of
four tasks
reviewed)
are viewed as
a program weakness.
The
HP technicians
receive
one-week of plant systems training
(Nuclear Plant Operator course),
normally during the classroom
phase
of their qualification process.
The team determined this initial
orientation training does
not stress
or focus
on the radiological
aspects
and hazards'f
the systems.
Beginning in 1988,
as part of
the 80-hour per year continuing training program for qualified techni-
cians
and foremen,
systems training was initiated on
RMCU, offgas,
ECCS,
RHR,
and ventilation/exhaust
systems.
The
RMCU, offgas,and
system
UOIs were judged
by the
team
as
good.
The
ECCS and venti la-
tion/exhaust
UOIs were rated
by the team
as marginally acceptable
as
both units of instruction failed to provide the necessary
HP focus
and thorough coverage of the hazards associated'ith
these
systems.
Based
on interviews with the technicians
and
a review of the existing
systems training material,
the team concluded that the
HP technician
systems training provides
inadequate
focus
on radiological concerns
and hazards
and fails to uniformly cover all the pertinent
systems
that can
cause significant radiological
hazards
to the worker.
The
team's
concern is based
on technicians
providing back shift
coverage
(without additional supervision).
These technicians
need
adequate
systems training to help ensure
they take proper'recautions
and actions 'during normal, off normal,
an'd emergency
conditions.
Licensee
management
has
reviewed the team's
concern
and in a letter
to the
NRC, from W. Lowthert, Manager Nuclear Training, dated
Septe-
mber 12,
1989, the licensee
committed to revise the training program
to more effectively train
on systems
for the next initial training
session
conducted,
and in the
1990 continuing training program.
An- interview indicated that the formal evaluator-trainee
process for
task certification of the respiratory protection speciality
may not
have
been
conducted
as formally as described
in the training proce-
dures in all cases.-
Team- members
izterviewed
a recently qua'lified
technician
and
an experienced
s'enior technician qualified
for.thi.s'peciality.
They were found to be'nowledgeable
and
qualified.'ased
on verifying the qualifications
of- the above
personnel
there-.is
not an immediate safety concern,
however,
the question of informality
in the certification process
'remains
unresolved
(387/89-80-01,
388/89-80-01).
Using eleven
NRC and
INPO, generic
communications (i.e., Information
Notices, Significant Event Reports, etc.) pertinent to,the health
physics area,
the, team tried to determine
how these particulat
gene-
ric communications
impacted the training program.-
These ll generic
communications
were available in the tr aining center technical library.
The results of the licensee's
search
(using
an automated
tracking
system
computer print out and class rosters)
were
made available
for'eview.
Based
on the review of this information and identified UOIs
the team
was able to determine that three of the generic
communica-
tions
had
been integrated
into the formal training program.
It
appears
that the remaining eight generic
communications
were discus-
sed during the routine weekly
HP technician
meetings.
The team
reviewed the attendance
rosters for the
1987
and
1989 weekly techni-
cian meetings,
but the rosters for 1988 were not readily available.
Interviews with technicians
indicated that all technicians
do not
regularly attend the we'ekly technician meetings.
Because
of insuffi-
cient time, the team was unable to perform an in-depth evaluation of
the quality of generic
communication training provided at the weekly
technician
meetings,
and could not verify technician
attendance.
Based
on this review, the
team could not verify that pertinent
lessons
learned
from industry and onsite events
covered in the weekly techni-
cian meetings
are reaching all
HP technicians.
The team received
feedback
from a plant electrical technician (during
classroom training observation)
who was concerned
about
HP personnel
performing maintenance
on
HP survey instrumentation.
Specifically,
the concerned
technician believed that the
IKC shop
should
be
10
performing this maintenance
and that
HP personnel
did not have the
necessary
experience
or= training to properly perform maintenance.
The team discussed
this concern with the Radiological Operations
Supervisor
(ROS).
The
ROS was
aware of the matter
and stated
that'his
concern
has
been formalized as
an official union grievance;
The
ROS then described
the
HP department's
training and controls to
'nsure
that the
scope of maintenance
performed
by
HP was limited to
relatively simple tasks
and that all equipment
was thoroughly checked
and calibrated per approved
procedures
prior to returning it to
service.
The team independently
reviewed the maintenance
tasks
and
associated
training.
The team concluded that the tasks
were relati-
- vely simple and that training was adequate
for the performance of
this work.
Based
on the limited scope of the work, appropriate
licensee
management
oversight,
and adequate
training, the team deter-
mined this item is not
a safety concern
3.3 -Trainee Evaluation
Exemptions
from training are
based
on
a combination of performance-
based testing
and objective evaluation.
Typically, exemptions
are
only granted
to former Operations
Department for the systems
phase of
'the initial technician training program.
A review of the examination
bank revealed that the test items are
linked to the lesson objective
and job performance
requirements.
During initial training, trainees
are evaluated
using daily quizzes,
weekly exams,
and
a comprehensive
final exam.
Feedback is usually
given the day following the exam/quiz.
During continuing training,
exams/quizzes
are given following the lecture,
HP technicians
and trainees
who perform be'low standards
are provided
remediation
and retested.
As
a result of the job placement testing
program,
health physics trainees
have not required
removal
from the
training program.
Appropriate precautions
are taken to preclude
compromise of the exam/quiz contents.
3.4
Summar
of HP Trainin
The findings from the inspection of the
HP technician training
programs
indicate that Susquehanna
Steam Electric Station
has
an
'effective,
high quality performance-based
HP technician selection,
training,
and qualification program.
The team found that all
elements of the Commission's
Policy Statement,
with minor exception,
have
been
met and are being effectively implemented.
Two weaknesses
observed
were the need for re-formatting the UOIs to ensure
consis-
tent delivery of information and
a need to provide job-specific
systems training that stresses
the radiological
hazards
associated
with certain plant systems.
4.
Mechanical
Maintenance
MM
= 4.1
Task Selection
11
The following six tasks
were selected
from the licensee's
Mechanical
Maintenance
J/TA Training Cross
Reference Matrix:
inspect/repair
valves
align pumps
repair hydraulic control unit
rebuild control rod dri.ves
align equipment (belts,
motors, etc.)
verify equipment blocking
4.2
Desi
n-and
Im lementation
The team found that the Nuclear Technical Training Supervisor is
a
degreed
professional
with vocational experience.
The supervisor
was
involved with program development
and continues
to instruct in order
to maintain proficiency and support the high instructional workload.
The instructional staff consists of individuals with experience
in
the maintenance
disciplines which they instruct.
- One of the two
mechanical
maintenance
instructor positions is a rotational assign-
'ent,
where
an assistant
foreman is screened
and selected
for a two
year assignment.
Instructors indicated during interviews that the
instructional workload was high but tolerable.
The team noted that training responsibilities
are divided.
Formal
classroom training is the responsibility of the Training Department,
and on-the-job training is the responsibility of the Mechanical
Maintenance
organization.
Training Department
and Maintenance
managers/supervisors
meet quarterly as
a curriculum committee to
review training and revise it as required.
Interviews indicated
that managers/supervisors
are continually working together
on the
training program
and that there is excellent rapport between
the
Training Department
and the Maintenance organization.
Units of Instruction (UOIs)
M001 (valve maintenance),
M009 (bearings),
AD004 (protective permit and tag),
Y8015 (lockwiring) and
MM014
(rigging) for classroom/laboratory
training were reviewed.
training guide
MM623 (optical alignment)
was also reviewed. Mith one
exception,
these
UOIs provided the information necessary
for the
instructor to address
the stated
terminal
and enabling objectives.
This exception
was
MM015, where the enabling objective with respect
to use of safety
equipment
was not addressed
in the body of the
lesson
plan,
and consequently
was not addressed
by the instructor
when the team observed
conduct of this training.
12
Inspectors
observed
'the conduct of classroon/laboratory
training for
bearings
(M009), rigging (M014), lockwiring (M015) and permit and
tagging
(AD004).
They also observed on-the-job training (OJT) with
respect
to "main steam l'ine plugs
(MM087) and optical alignment
{MM623).
In general,
the team concluded that this training was
conducted in a professional
manner in accordance
with the established
UOIs/OJT guides.
Two exceptions
were noted.
One is described
in the
paragraph
above regarding
the
use of safety equipment,
and the other
was with respect
to the optical alignment
OJT.
While the
instructor was very knowledgeable
of the subject matter
and compe-
tently taught, those topics
he covered in the
OJT guide,
he
did not use the
OJT guide in conducting the training,
and as result
did not address
some learning objectives of the guide.
He completed
the lesson
in
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,
when the
OJT guide indicated that
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
was
needed.
The team noted that the
OJT instructor
had completed
the
required instructor training course for OJT and this was the first
time that
he
had provided
OJT instruction.
He was counseled
by
cognizant maintenance
and training supervisors
in the
need to address
all learning objectives
in OJT guides.
In observing
the conduct of training, the
team noted two instances
where training was
used to establ.ish plant policy without the asso-
ciated information also being reflected in related plant procedures.
The. first was in permit and tagging training (AD004), where
page
8 of
the
UOI indicates
"do not use solenoid valves (Target-Rock)
since
pos'itions
cannot
be verified."
A review of the referenced
plant
procedure
(OI-AD-050) did not provide any prohibitions with respect
to the
use of solenoid valves for isolation.
The other
instance
was
with respect
to UOI MM015 (lockwiring), where the practical
evalua-
tion requires
safety glasses
be worn, but the "Precautions"
section
of procedure
NT-GN-016 on lockwiring lists
no precautions,
and
nowhere else in the procedure is the
use of safety glasses
called
out.
In both instances
the team judged that while it was appropriate
for'hese
policy statements
to be included in the training sessions,
training should not be relied upon
as the only mechanism for communi-
cating these policies to plant personnel.
Both of these
courses
have
been taught several
times
and the team noted that tliese procedure
omissions
were not identified through feedback
from either students
or instructors.
During the main
steam line plug practical factor training observed,
the instructor found discrepancies
in the newly developed
procedures
being
used:
NT-062-024
(MSL Plug Installation
and Removal),
MT-062-
026
(MSL Plug Preoperational
Checks),
and NT-062-027
(MSL Plug Opera-
tional Checks).
The team verified that the instructor prepared
the
appropriate
feedback
form (Form MI-AD-02001) for each
procedure
and
submitted
them to the responsible
engineer.
The team reviewed the training records of job incumbents
interviewed
as well as the records for the training courses
observed.
These
records
were found to be auditable
and current.
13
4.3
Trainee Evaluation
The team found that exemptions
from training could be based
on prior
training or experience
and that the determination is objectively
based.
Provisions
are also
made for qualification deviation waivers
approved
by the Senior Vice President - Nuclear in cases
where the
individual may not fully meet the, requirements,
Discussions with
cognizant
personnel. indicated that. the Senior Vice President
had not
excused
any mechanical
maintenance
personnel
from qualification and
training requirements.
Some exemptions
from the accredited training
and qualification program were found in training records'hese
exemptions
were for similar training that
had been
completed
by
experienced
personnel
before the training was subject to accredita-
tion.
The team judged these
exemptions
to be
acceptable.'TCP-(}A-321,
"Administration of Training Course
Examinations,"
Revi-
sion
3 and STCP-gA-324,
"Technical
Exam Bank," Revision 0, deal with
the administration of training course
examinations,
with STCP-QA-324
specifically related to examinations
for maintenance,
I&C, and health
physics personnel.
These
procedures
were revised in December
1988
and January
1989, respectiv~ly.
The revisions to STCP-gA-324 include
provisions for developing
a new examination for each
exam admini-
stration
(a 'minimum of 30% of the
exam questions different than the
preceding
exam).
STCP-gA-324 contains
a provision'for not requiring
implementation of this procedure
step to develop
new examinations if
there are existing examinations.
Interviews indicated this provision
was intended to accommodate
a situation where there
was not sufficient
time available to develop
a
new examination in accordance
with this,
procedure.
Reviews of mechanical
maintenance,
(and
IKC) examinations
indicated
an inconsistent application of STCP-(}A-324 in that
some
'ecently
administered
examinations
have
been developed
in accordance
with STCP-gA-324,
and others
have not.
The team discussed
this
matter with licensee
'management
who stated that full implementation
was intended.
Licensee
management
in a 'letter to the
NRC from W.
Lowthert, Manager Nuclear Training, dated
September
12,
1989,
committed to fully implement this procedure
as of September
12,
1989,
During interviews with the mechanics,
they favorably described
the
Progression
Program examinations
and indicated that they ensure
MM
personnel
have adequate
plant specific skills and knowledge.
A review of the methods
used to control examinations
indicated that
there
are effective measures in,place to ensure that
exams
are kept
from unauthorized
personnel.
The team reviewed the records of four trainees that initially failed
end of course
examinations.
Three individuals repeated
the course
and passed
subsequent
exams.
One individual was tutored by the
instructor
and passed
a re-examination
the next day.
4.4
14'n
observation of the team regards
the low number (four out of about
55) mechanical
maintenance
personnel
that have completed full certi-
fication as
compared to other licensee
organizations.
Licensee
management
estimates
an .additional
22 people will certify by the
end
of 1990.
Management
also stated that it is intended that all
personnel
get certified.
While noting the above,
the team judged the
final certification of mechanical
maintenance
personnel
has not been
a high management priority.
The team ascertained
that there were
a
sufficient number of personnel
qualified to perform the needed
tasks.
Summar
of Mechanical
Maintenance Trainin
The team concluded that the training materials provide for effective
instruction.
Excellent working relationships
between
the Training
Department
and the Maintenance
organization
were evidenced
through
observation
of. training, interviews with training and plant
personnel,
and reviews of student evaluations
of training.
While
most training observed
was conducted
in a professional
manner,
consistent with established
lesson plans/units of instruction, there
were two training sessions
observed,
one in classroom training and
one in OJT,
who
e not all learning objectives
were addressed.
The
progression
program ensures
that mechanical
maintenance
personnel
have plant specific skills and knowledge,
and includes
comprehensive
written and practical evaluations.
Inconsistent
implementation of
the examination
development
procedure is
a concern that the licensee
has addressed.
The small
number of cert'ified mechanical
maintenance
personnel
does
not indicate
a high management priority toward comple-
tion of certification.
II
The above attributes
indicate
a strong training program, with
both'raining
and plant personnel
striving for continued
improvement.
5.
Instrument
and Controls
IEC
5.1
Task Selection
The following tasks
were selected
from the licensee's
Instrument
and
Controls J/TA Training Cross
Reference
Matrix:
5.2
perform response
time tests,
perform feedwater
system controller test,
perform SRM/IRM detector drive test,
- perform
PASS alignment test,
and
localize
a problem using plant parameters.
Desi
n and
Im lementation
The team found that the Nuclear Technical Training Supervisor is
a
degreed
professional
with vocational
education
experience.
The super-
visor was involved with program development
and continues
to instruct
15
in order to maintain proficiency and support the high instructional
workload.
There is one dedicated
I&C 'instructor in the Training
Department.
He is responsible
for the development
and conduct of
most
I&C technician classroom/laboratory
training.
He is experienced
.
in the
I&C area
and is
a certified instructor.
Training responsibilities
are divided.
Formal classroom training is
the responsibility of the Training Department,
and on-the-job train-
ing is the responsibility of the
I&C organization.
Training Depart-
ment
and
I&C managers/supervisors
officially meet quarterly as
a
curriculum committee to review training and revise it as required.
Interviews indicated that managers/supervisors
are continually work-
ing together
on the training program
and that there is excellent
rapport
between
the Training Department
and the
ILC organization.
Interviews with job incumbents
and supervisors
indicated that the
instructor frequently tours the plant to maintain his familiarity
with ILC equipment
and training needs.
Units of Instruction (UOIs) for AD004 (protective permit and tag),
IC017 (Bailey 7000 instruments),
and
IC018 (automatic
process
"control)
or classroom/laboratory
training were reviewed.
These
UOIs
were found to provide the information necessary
for the instructor to
address
the stated terminal
and enabling objectives.
The team observed
the conduct of classroom/laboratory
training for
'xcore
Neutron Flux Monitoring provided by the contractor
who
installed the equipment,
Protective
Permit and Tagging," and on-the-
job training (OJT) for the reactor
manual
con'trol
system
(RMCS).
The
training was conducted
in
a professional
manner
and in accordance
with the established
UOI's and
OJT guides.
The instructors
were
knowledgeable
of the subject matter.
Regarding
the neutron= flux
monitoring training, the instructor used
schematics
for the training
that were not plant specifics
Some of the circuitry included in
the schematics
and related discussion
did not apply to Susquehanna.
This was judged
by the
team to create
some unnecessary
confusion
and
complexity in the training.
Interviews of participants
in these training sessions
indicated that
the pace of the instruction
was geared to mid-level student ability.
Laboratory
and simulation equipment provided for training use were
determined to be
among the strengths of the program,
and are indica-
tors of an organization that is striving for continued
improvement.
The
I&C organization
has recently developed
a reactor
manual control
system simulator which allows for "hands-on" training
on this equip-
ment without jeopardizing
the safety or operation of the units.
The
Training Center also
has
a well-equipped
ILC laboratory with a combi-
nation of plant specific equipment
and conceptual
process
control
loops.
Interviews with I&C technicians
indicated that they have
confidence
in the instructors
and that good rapport exists.
16-
The team noted that the
ILC training program
had
a .relatively high
percentage
of UOIs for -I&C courses that have
been
approved for tempo-
rary use.
Susquehanna
procedures
allow for the training supervisor
to shorten
the review process for temporary'approvals
by eliminating
the concurrence
of the responsible
line department
when there is
insufficient time to obtain this review before the course is taught.
Statistics
provided to the team indicated that, overall in the Train-
ing Department,
about
5% of current
UOIs were approved for temporary
use.
However, for I&C UOIs, about 1/3 were approved for temporary
use.
Heavy use of temporary approvals for UOIs is considered
a weakness.
The team reviewed the training records of job incumbents
interviewed
as well as the records for the training courses
observed.
These
records
were found to be auditable
and current.
The team observed
actual
I&C Technician
performance of two survei ll-
ance
procedures
(Monthly Functional
Test of Drywell Pressure,
Sl-283-
221
and Meekly Functional
Test of Average
Power
Range Monitor Sl-178-
209).
The technicians
observed
were knowledgeable.
The procedures
were conducted professionally
and included pretest briefs and proper
communic-tions.
The team observed
one discrepancy
where
some sign-
offs for one test were
made prior to'actual"performance
of the steps.
The team followed up on this issue
and verified that the personnel
involved wou)d have voided the signoffs if the performance
had
been
incomplete.
Futher followup with licensee
management
found that this
was
an isolated
case
and that the personnel
involved have
been
briefed to document
procedure
steps after actual
performance.
Based
on the above
NRC review and licensee
followup, no further concern
was
indentified
~
5.3
Trainee Evaluation
The team found rigorous requirements
for entry to the
I&C program to
be
a strength.
These
requirements
include
an entrance
examination
and
an associate
degree
in engineering
or a related
science.
Exempt-
ions to training are processed
as described
in section 4.3 above.
A review of examinations
revealed that some'xaminations
were not
developed
in accordance
with STCP-gA-324
.
This finding is addressed
in section
4.3 of this report.
The certification program for several
I&C technicians
were reviewed.
Certifications were found to be thorough
and comprehensive.
There
are also special
equipment certifications for specific equipment
such
as acoustic monitoring and electro-hydraulic control.
The course
completion records for I&C courses
conducted during the
past
two years
were reviewed
by the team to determine
the actions
taken for individuals who failed examinations.
There were three
failures identified during this period.
In two cases
the individuals
II
17
involved were re-enrolled
in a 'sub'sequent
class
and passed
the next
examination.
In one case
the individual who failed
a course in July
has yet to be remediated
or re-tested.
5.4
Summar
of I&C Trainin
The team found that the training materials generally provide for
consistent
and effective instruction,
although
I&C Technician
UOIs
have
a much higher fraction of these
UOIs approved for temporary
use.
This practice
does
not provide the normal
user organization
review of
the materials.
Excellent working relationships
between
the Training
Department
and the
I&C organization
were evidenced
through observa-
tion of training, interviews with training and plant personnel,
and
.
reviews of student evaluations of training.
The one Training Depart-
ment instructor assigned
to I&C training is well respected
by I&C
personnel.
Training observed
was conducted
in
a professional
manner,
consistent
with established
units of instruction.
Not all examinations
are being
developed
in accordance
with a comprehensive
examination
procedure
that was initiated at the beginning of this year.
The selection
process for I&C technicians
includes stringent selection criteria and
comprehensive
evaluations
All but two of the
47
I&C technicians
are
certified to work independently,
with 35 fully certified.
This
indicates
a high management priority toward completion of
certification
The team concluded that the
I&C training program is generally well
implemented but with some weaknesses.
Reactor
0 erator
and Shift Su ervisor
6.1
Task Selection
The following tasks
were selected
from the licensee's
Reactor
Opera-
tor and Shift Supervisor J/TA Training Cross
Reference
Matrices:
Reactor Operator
Perform monthly MSIV closure
RPS instrumentation (test)
Start
a reactor
feed
pump
Respond
to
a loss of
Operate
HPCI for reactor pressure
control
Respond
to
Shift Supervisor
~
Approve radioactive waste discharge
release
permits
~
Supervise
refueling ops
as refueling floor SRO
18
Prepare
mainte'nance
work requests
Direct emergency
response
as site
emergency, director
Direct actions to ensure that core cooling and the S/D margin
are maintained
6.2
Desi
n and
Im lementation
In every
UOI the
team evaluated,
a systematic
approach
to presenting
the lesson
was undertaken,
and the content taught .the outlined learn-
ing objectives.
In addition,
the UOIs and Job Analysis provided
evidence that the instructional settings (i.e,, classroom,
simulator,
etc.) and materials
were evaluated
and the appropriate
instructional
settings identified.
These
documents
also outline the organization
and sequencing
of initial and continuing training.
The qualification and training requirements
for the training staff
are addressed
in STCP-gA-511,"Formal
Instructor Certification," Revi-
sion I, and there is evidence that these
requirements
are
met for the
Susquehanna
staff.
Observations
of classroom
and simulator instruc-
tion indicated that training is being conducted
in a superior
manner.
For example,
a lecture
on Industry Events
was observed
by the team.
The instructor had
good control of the class
and always kept to the
subject
and the le'ssons
to be learned
from the event.
The method
used in presenting
material to the class
was effective in that it
required active participation of the student
by inter facing with the
industry event via
a questionnaire
provided by the instructor.
Once
the students
completed
the questionnaire,
a group discussion
on the
questionnaire
was led by the instructor
and plant relevancy
was
propagated
by the instructor.
Overall, the instructors
in the classroom
were excellent
and demon-
strated
the instructional skills and abilities necessary
to ensure
optimal learning.
Furthermore,
the team found that the instructors
were knowledgeable
of their subject
area
and could effectively commu-
nicate the material to the students.
The quality of the classroom
instruction
and
use of visual aids
was found to be excellent
and
considered
a program strength.
Operators
interviewed indicated that the training department is do'ing
an excellent job and that the dedication of the instructors
was
considered
a program strength.
The operators
also indicated that
their problems
arid recommendations
were being handled
as expedi-
tiously as possible.
A review of the qualifications for personnel
involved with the train-
ing program and selected
operators
was conducted.
The review
included .the use of a computer tracking
system which provided
a
report titled, "Summary of Personnel
gualifications
by Cost Area."
These qualifications are consistent with the facility technical
speci-
fications.
Through interviews conducted with senior reactor operators,
reactor
operators,
and
members of the training department staff, the team
determined that initial and requalification training conducted at
Susquehanna
were both comprehensive
and effective'.
The communica-,
tions between training and operations is very good as indicated
by
the excellent working relationship
between
the two departments.
Communications
is fostered
by an
18 month rotational
program for
instructors
and operators,
weekly meetings
between
operations
and
training supervision,
and the effective
use of student critiques.
Interviews indicated that the on-going feedback
process
between
management
and operations
ensures
that training remains current
and
appropriate.
The incorporation of Licensed
Event Reports
(LERs) into training was
also reviewed.
Recent
Susquehanna
Unit I and
2
LERs were reviewed
to determine if any of these
events
can
be attributed to training..
There
was
no obvious correlation that training or the lack thereof
was
a casual
factor in current
LERs.
The Nuclear Training Group was asked to develop
a refresher
course
on electrical print reading
as part of the continuing operator
requalification training program.
This was the result of an event that
occurred in March
1989 in which an unplanned
ESF actuation
was initi-
ated
when
an improper fuse
was
removed for protective blocking
purposes.
As a corrective action the training department did receive
a request
and the topic will be included
on the agenda for the next
Requalification Curriculum Committee.
The incorporation of LERs into
training is judged
by the team
as
a program strength.
The team observed
a requalification class that
a subject matter
expert
(SME) (rather than
an certified instructor) taught
on core
reload.
The students
seemed
to drive the instructor's presentation
rather than the instructor following a prescribed
formatted presenta-
tion.
gueuing
from the assigned
requal instructor
assured
continuity
of material
being presented.
Learning objectives
were provided to
the student in the handout but the
SME did not cover the objectives
in class.
This may have left the student
unaware of what was
expected
and could lead to inconsistency
in the instructors presenta-
tion.
Overall,
however,
the class
was well received
by the students
and any disruptions
were caused
by over zealous
students
rather than
ones.
A concern
was noted in regard to the Units of Instruction.
The major-
ity of the training staff and operators
alike indicated that UOIs
should
be rewritten
and reformatted to ensure
the consistent delivery
of information.
This project is already
under consideration
by the
licensee.
.C
4
'20
A similar problem exists in the instruction of Administrative Proce-
dures,
Although the instructor has 'developed
exercises
that require
the student to research
the procedures
giving him a hands-on
famili-
arity that could not be. accomplished
in
a stand-up lecture presenta-
tion, this method is not used
by all instructors.
When the Training
Manager
was asked
when standardization
would occur, his reply
suggested
that this was
a low priority and
no firm date
had been set.
The team reviewed the licensee's
program for controlling active and
The licensee tracks active licenses via the
station shift schedule.
are upgraded to active
status
per "Return
To On-Shift Duty" procedure,
OI-AD-044.
This
procedure
establishes
requirements
for returning operators
to on
shift duty following an absence.
These
requirements
include
a review
of administrative
procedures,
plant modifications,
and the current
operations
agenda.
This is followed up by an oral examination
admi-
nistered
by the Supervisor of Operations,
This procedure
was revised
to include license
upgrade
from inactive to active status
in response
to an
LER dated
December
23,
1987, in which an individual possessing
was assigned
Refuel
Floor
SRO duties.
OI-AD-044
exceeds
the requirements
of 10 CFR 55.53(f) which delineates
what is
required of an operator before resumption of licensed duties.
One
problem in the documentation
of this procedure
was the inability to
determine
the exact time and date the required activation watches
were completed.
This problem was brought to the attention of the
licensee
and would be taken
under consideration
by the operations
staff.
6.3
Trainee Evaluation
The inspectors
reviewed
two tasks that required training and their
associated
learning objectives,
and checked
these
tasks against-the
exam bank.
A sampling of the objectives
were evaluated
in the
form of test questions.
Test items for the tasks
were consistent
with the objective.
Furthermore,
requalification
exams are evaluated
the next working day and the students
performance is available
on
request.
Trainees
who perform below minimal standards
are provided
an opportunity to retake
an
exam after they have performed
a self
study exercise.
STCP-gA-321
ensures
that
exams
are
used only once
which precludes
the compromise of test content.
The team reviewed NTP-gA-31.2, "Licensed Operator Requalification
Program Implementation," Revision
2 to determine
the licensee's
disposition of individuals who fail the annual requalification exami-
nation which consists of an operating test
and
a comprehensive
written examination.
Procedure
step
6. 10.3 states
that failure does
not requi re removal of the i ndi vidual from licensed duties, fai lure
requires
an evaluation of the individual's qualifications by the
Superintendent
of Plant and the Manager-Nuclear Training,
and retraining
and re-examination
of the individual in the categories
that were
failed as
soon
as practical.
c
t
21
Further review of the licensee's
application of this procedural
requirement, found that at least
one licensed
senior
reactor,. performed
licensed duties for 14 shifts 1n January
and February
1989 after
failing an annual
operating
examination prior to retraining
and
re-examination
in February
1989.
V
The team judged that the provision that permitted personnel
who had
not demonstrated
or maintained
a satisfactory
level of proficiency to
continue to perform or return to licensed duties after evaluation
by
management
and prior to retraining
and reexamination is an apparent
violation in =that
a licensed
senior reactor operator
who had not
'atisfied the conditions of his license pursuant to
was designated
by the licensee
to perform licensed activities in
accordance
with 10 CFR 50.54 (1) and the requalificati.on
program
required
by 10 CFR 50.54 (i-1) as described
in 10 CFR 55.59 did not
provide adequate
measures
to ensure qualified personnel
perform
licensed activities (387/89-80-02,
388/89-80-02).
The NRC's concern
in this matter was that license's
procedure
allowed
personnel
who had not demonstrated
or maintained
a satisfactory
level
of proficiency to perform licensed activities.
This concern
was brought to the attention of senior licensee
manage-
ment.
The licensee
immediately verified that
no one,
who has failed
annual requalification examination,
was currently performing licensed
duties.
Prior to the exit meeting,
the licensee
committed to ensure
that
no one
who had failed an annual requalification examination will
perform licensed duties prior to retraining
and re-examination.
After the exit meeting,
the team conducted
a review at the
NRC Region
I office to determine
the consi stency of licensee training and quali-
fications commitments.
The team rioted conflicting statements
existed
depending
on which revision of the ANSI/ANS Standards
for the "Sele-
ction, Qualification and Training of Personnel
for Nuclear
Power
Plants"
was referenced.
The following
were noted relative to licensee
committments to this standard:
a,
The Operational guality Assurance
Manual, Policy Statement
OPS-6
"gualification, Training,
and Certification of Personnel,"
Revision
2 references
ANSI/ANS-3. 1-1978
and step
5'.2 of the
procedure
which requires that
NRC licensed
personnel
be qualified,
trained,
and certified in accordance
with the requirements
of 10 CFR 55,
ANSI/ANS 3. 1-1978,
and Regulatory Guide 1.8 - Revision
1,
1975.
ANSI/ANS3.1-1978 paragraph
5.5. 1.3 '
contains
a
provision that personnel
shall not perform licensed duties until
successful
completion of mandatory accelerated
training after
an examination failures
b.
Unit
1 Technical Specifications section 6.4,
Amendment
No.
47
states
that
a retraining
and replacement training program for the
I
22
unit staff shall
meet
or
exceed
the requirements
and recommenda-
tions of section 5.5'f ANSI N18.1-1971
and Appendix "A" of 10
CFR part 55...
The Unit 2 Technical Specifications
are similar,
Appendix "A" of 10 CFR Part 55 was deleted
and incorporated
into the revision of the
10 CFR Part 55 rule implemented
May 26,
1987.
ANS1 N18. 1-1971 does
not address
disposition of
requalification examination failures.
C.
FSAR Chapter
17, "Quality Assurance,"
Revision 35, Table 17.2-1,
references
ANSI/ANS 3
~ 1-1978 with clarifications
and exceptions
in
FSAR Chapter
13.
FSAR Chapter
13,
step 13.2.2. 1.4, Acceler-
ated Retraining,
Revision 35, dated July 1984, states
that
fai lure of the annual requalification examination
does
not
require
removal
from licensed duties.
The lack of consistency
in the above requirements
is unresolved
pending further licensee
action
and
NRC review.
(387/89-80-
03, 388/89-80-03).
6.4
Summar
of Reactor
0 erator
and Shift Su ervisor Trainin
The team concluded that the training programs for reactor operators
and shift supervisors
were performance
based
and well implemented.
Notwithstanding the concerns
raised
regarding
the disposition of
licensed operators
who failed annual requalification examination,
the
findings indicate that the training program contains all of the
elements
that characterize
effective training.
7.
Exit Meetin
Summar
At the exit meeting held
on August 25,
1989,
the inspection
methods
were
described.
Major strengths
and weaknesses
were discussed.
The apparent
violation of
NRC requirements
was discussed;
the licensee
was thanked for
its cooperation
during the inspection.
The licensee
stated that they thought this was
an in-depth inspection
and
that the team conducted
the inspection
in
a professional
manner.
They
also stated that it was their intent to continue to improve training.
23
Appendix I
Pre-Inspection"
Requested
Information
The following is
a list of information provided by the licensee
to enable the
team to conduct the inspection:
~
Task lists for the positions being reviewed.
~
. Instructions/procedures
related to:
Systematic
methods
used to analyze jobs,
Training organization
goals, objectives,
and plans,
~ Responsibilities/authority
of training organization
personnel,
Methods for evaluating/selecting
instructional materials,
methods,
and media,
Methods for organizing/sequencing
of training,
Methods for keeping training programs current,
Maintenance of training records,
Selection of candidates
for training and the granting of
waivers/exemptions
from training,
Evaluation of training programs,
and
Training, qualification,
arid evaluation of instructors
Interface
between
the tr'aining department
and plant organization
Roster/organization
chart for the training organization
and the
training organization relative to the plant organizations.
Training schedule
for the past six months
and the next six months for
the positions
being reviewed.
gualification and experience
standards
for Radiation Protection
and
Chemistry technicians,
supervisors,
and managers
gualification and experience
standards
of instructors for the
positions being reviewed.
24
Appendix
2
Persons
Contacted
Penns
lvania Power and Li ht
PP5L
ab
ab
ab
ab
b
'a
ab
ab
a
ab
ab
ab
ab
ab
a
ab
c
ab
ab
a
J.
J.
W.
R.
M.
S.
W.
J.
G.
H.
E.
A.
J.
G.
M.
A.
H.
J.
W.
T.
ab
J
ab
a
a
ab
M.
J.
L.
J.
ab
ab
ab
ab
a
a
ab
a
H ~
R.
R.
H.
B.
D.
K ~
R
~
ab
b
a
b
J.
G.
R.
K.
ab,J.
Alwood, Research
and Evaluation Supervisor
Blakeslee,
Assistant Superintendent
of Plant
Bogle, Construction
Supervisor
Byram, Superintendent
of Plant
Deckman,
Nuclear Technical Training Supervisor
Denson,
Outage
Supervisor
DiDomenico, Simulator Instructor
Edwards,
Personnel
and Administrative Supervisor
Fetterman,
Administrative Supervisor
Fetterman,
Instructor
Figard,
Supervisor of Maintenance
Fitch, Operations Training Supervisor
Fritzen, Radiological Operations
Supervisor
Glaser,
IKC
Haring, Mechanical
Maintenance Instructor
Iorfida,
ICC Supervisor
Keiser,
Senior Vice President-Nuclear
Lex, Nuclear General
Training Supervisor
Lowthert, Manager Nuclear Training
Marlowski, Dayshift Supervisor
McClintock, Training Document Control Specialist
McGann, Technical
Information Services
Supervisor
Minneman,
Supervisor-Nuclear
Emergency
Planning
Oberiender,
Stenographer
O'ullivan, Installation Engineering Supervisor
Palmer, Jr., Supervisor of Operations
Peal,
Operations
Training Supervisor
Prego,
gA Supervisor
- Operations
Riley, HP/Chemistry Supervisor
Rizzo, Instructor
SSES/CBT
Roth, Senior Compliance
Engineer
Roush,= Supervisor
Nuclear Instruction
Schwarz,
NPE Resident
Senior Project Engineer
Snarponis,
Curriculum Development Supervisor
Stanley, Assistant Superintendent
Outages
Stotler,
Supervisor of Security
Tutorow,
Foreman
Mechanical
Repairs
White, Supervisor Training Support
Institute of Nuclear Power 0 erations
R. Burri s,
Program
Manager
25
United States
Nuclear
Re ulator
Commission
ab
S. Barber,
Senior Resident
Inspector
ab
T. Bettendorf,
PNL
b
M. Claussen,
Technical Assistant,
ab
T. Easlick, Operations
Engineer,
Region I
ab
A. Howe,
Team Leader,
Region I
ab
T. Mazour, Consultant,
NRC
ab
M. McCoy,
Human Factors Analyst,
ab
W. Oliveira, Reactor
Engineer,
Region I
ab
R. Pelton,
Training and Assessment
Specialist,
ab
T. Rebelowski,
Senior Reactor
Engineer,
Region I
ab
S.
Shankman,
Chief, Training and Procedures
Section,
a
J. Stair,
Resident
Inspector
ab
J. Wigginton, Chief, Facilities Radiation Protection Section
a
Denotes
attendance
at the entrance
meeting
on August 21,
1389
b
Denotes
attendance
at the exit meeting
on August 25,
1989
c
, Denotes
interviewed by the team but did not attend entrance
or exit
meetings
The inspectors
also contacted
other administrative,
technical
operational,
and
training personnel
during the inspection.-