ML20137K616
| ML20137K616 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/08/1986 |
| From: | Dudley N, Keller R, Kister H, Ruscitto D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20137K573 | List: |
| References | |
| 50-320-85-13, NUDOCS 8601240145 | |
| Download: ML20137K616 (6) | |
See also: IR 05000320/1985013
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U.S. NUCLEAR REGULATORY COMMISSION
Region I
Report No.
50-320/85-13
Docket No.
50-320
License No.
Priority
--
Category
C
Licensee:
GPU Nuclear Corporation
Post Office Box 480
Middletown, Pennsylvania 17057
Facility Name:
Three Mile Island Nuclear Station, Unit 2
Inspection At:
NRC Region I, King of Prussia, PA
Inspection Conducted:
July 31 - October 31, 1985
Inspectors:
1/ (f 40 SP
//- /5- 85
L h. Oudie ,it!1/W
utirfcf
N. F
p Reactor Engineer (Examiner)
date
i
@.Ruscitt ~ ,;
a' tor Engineer
date
Reviewed By:
flkh
R Keller, Chief, Projects Section 1C
date
/k
/M7I
Approved By:
.
H. Rister KChief, Projects Branch No. 1
I
date
Summary:
This inspection found the requalification program conducted by TMI-2 to be
adequate for a basis of certification of presently licensed Senior Reactor
Operators (SRO) to directly supervise defueling operations.
The evaluation
included monitoring training sessions at the facility and at the Pennsylvania
State University Reactor, observing on-the-job training sessions, auditing
training records, and inspecting the written and oral examinations given by the
licensee.
The evaluation extended over four months and involved 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> of
direct inspection effort. The training provided and the evaluation made by the
licensee are adequate for insuring that SR0s, who successfully complete the
program, .have the requisite knowledge and skills to safely direct defueling
operations.
Even though there is a rapid evolution of procedures and equipment, a formal
system for identi fying and incorporating changes into the requalification
program has not been developed.
8601240145 860114
ADOCK 05000320
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Details
A.
Scope
This inspection consisted of a comprehensive review of the requalification
program.
Some requalification classes, which presented defueling system
designs and operations, were attended.
Specialized training conducted at
the Pennsylvania State University Reactor Facility was evaluated. On-the-
job training sessions on the Defueling Training Assembly (DTA) were at-
tended.
A review of the comprehensive examination, the training attend-
ance records, the on-the-job training cards and the final grades on the
comprehensive examination was conducted.
Observations were conducted of
some licensee administered oral examinations.
Discussions were held with
training staff and licensed SR0s at each phase of the evaluation.
B.
Findings
Requalification lectures were attended on June 19 and 24, 1985 and the
following lesson plans were observed being taught.
Canister Positioning System
Lesson Plan:
12.2.01.156
Control System, Cable Management System and Jib Cranes
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Lesson Plan:
12.2.01.159, .163, .161
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Canister Handling Trolleys
Lesson Plan:
12.2.01.160
Canister Handling Tools
Lesson Plan:
12.2.01.166
All lectures were presented by the contractor engineers who were directly
responsible for the systems.
The technical quality of the lectures was
acceptable.
The interest generated by each lecture was directly related
to the personality of the instructor.
The instructors were knowledgeable
and able to answer all questions. Good use was made of the audio-visual
equipment.
The students were attentive and asked many questions concern-
ing the possible improper operation of the systems.
The lectures pre-
sented an adequate coverage of the defueling systems and the operators
took an active role in understanding and learning the material being
presented.
Training was observed on June 25, 1985, at the Pennsylvania State
University's Reactor Facility. Dr. S. Levine of Penn State University had
designed six experiments, using the test reactor, to simulate different
conditions in the TMI-2 core, ranging from deboration to collapse of the
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fuel in the core. The operators were given an introductory lecture before
each experiment, conducted the experiment, recorded and plotted data, and
were provided with a summary of what information could be derived from the
readings.
Some operators expressed difficulty in relating the detector readings,
which they recorded, to the expected responses they would see at TMI-2.
An effort was made at each lecture to tie the observed reading directly
back to the TMI-2 core. This unique training provided the operators with
direct exposure to a critical reactor in off-normal configurations and,
as such, was found to be an acceptable means of heightening operator's
awareness of criticality concerns.
On-the-job training was observed on September 27, October 1 and 2,1985.
The procedures conducted during the observation included vacuuming rubble,
removal and replacement of a canister top, dewatering of a canister,
grappling of a canister, operation of the hydraulic system, and operation
of the audio visual systems.
The candidates for fuel handling SRO licen-
ses conducted training, for the operators, on the procedures and on the
applicable limitations and precautions for each evolution.
The system
engineers conducted training, for the operators, on the hardware associ-
ated with each evolution. This training provided hands on practice with
the equipment which would be used in the reactor building.
The opera-
tional problems and difficulties not addressed in the classroom became
obvious one morning when the visibility of the water in the DTA was
limited.
The operators were forced to cooperate and depend solely on
underwater cameras to conduct the planned defueling operations.
The
operators were able to conduct the planned evolutions but at a reduced
speed.
The practical training conducted on the DTA allowed operators to gain
proficiency with the defueling equipment they expect to use in the reactor
building. The evolutions conducted on the DTA were found to be adequate
to meet the intent of the on-the-job training portion of the requalifica-
tion program.
Review was made of the on-the-job qualification cards of all licensed
SR0s.
Only Phase 1 of the qualification cards was inspected.
Phase 2,
Canister Handling Bridge and Transfer System had been delayed due to
equipment unavailability, and is being conducted as the systems become
available.
Some items from the FHSR0 on-the-job training cards were deleted from the
SRO requalification on-the-job training cards.
The deletions were made
due to line items being assigned to the Recovery Systems and Support group
for completion, or due to line items being repetitive such as attachment
of end effectors to long handle poles.
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The safety of personnel and equipment would have been enhanced if the
rigging qualification card had been completed prior to beginning the
defueling on-the-job card, since a significant amount of rigging is
performed durir.g defueling training.
Three oral examinations, administered by three different instructors, were
observed. The oral examinations lasted an average of li hours and met the
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requirements of the facility training procedure. Some instructors did not
make use of the DTA or canister handling bridge for hands on demonstration
of areas being examined. One instructor did not visit the fuel handling
building to conduct discussions of canister handling bridge and canister
transfer system.
Some instructors did not examine the SR0s in the direct
usage of procedure and allowed the SR0s to discuss procedures from memory.
The oral examinations were found to be adequate. However, this portion of
the requalification program was also determined to be the weakest.
The NRC reviewed the two comprehensive examilations which had been pre-
pared by the licensee. The examinations cond ained well written questions
which provided adequate coverage of defueling systems and procedures.
The
two examinations contained a limited number of duplicate questions so that
security on the second examination was ensured.
However, the NRC found
that the examination did not adequately cover core criticality concerns.
Prior to administration of the examinations, additional questions were
added which examined the area of criticality theory.
A review of the grading of the comprehensive examinations was made. Four
of the sixteen SR0s taking the exarrination failed with grades less than
80%.
The grading and subsequent facility regrading was found to be
acceptable.
A review was made of the training records. It was found that liberal use
had been made of the provisions in the training procedure to allow indi-
viduals to miss requalification lectures if the weekly quizzes were com-
pleted. Of the sixteen SR0s, only six had attended all 1985 requalifica-
tion lectures. Two SR0s had failed the weekly quizzes for Cycle 85-3 and
had not taken a reexamination. All SR0s were responsible for completing
requalification requirements by October 31, 1985, even though the compre-
hensive written examinations were administered October 21 and 28,1985.
These findings indicate that attendance at requalification lectures and
completion of requalification program requirements are not given high
priority. However, no direct correlation can be found between attendance
at lectures and comprehensive examination scores.
An audit of the on-the-job training qualification cards was completed.
All operators were signed off for completing all items on the initial
phase of the qualification cards.
However, the records were located at
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two separate locations and controlled by two separate work groups.
The
responsibility for the completion and control of the records was unclear.
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On one SR0's qualification card, all performance items were signed off the
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day before the inspection.
The licensee stated that the individual had
not signed for attendance at the training sessions on the DTA and that his
completion of the qualification items had to be reconstructed from
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instructors' memory. These findings indicate that the licensee does not
have an administrative system for tracking and documenting training
received by individuals. Also, there is no established system for audit-
ing the training records.
This issue is addressed in the Resident
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Inspector's monthly Inspection Report Number 85-21 and was resolved by the
assignment of a Site Operations Engineer to establish a system for ongoing
review of training records of operators performing defueling tasks.
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A check of the training program was made to see how information contained
in the October 10, 1985 SER for Early Defueling, Revision 4, was to be
incorporated into the training program. The training department had not
received a copy of the SER as of October 30, 1985.
The training depart-
a
ment has an informal tracking system for identi fying information which
needs to be incorporated into the requalification program. Information is
received and evaluated as to its applicability to a system and as to the
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type of report which contains the information.
The information is then
reviewed for content and an instructor is assigned to make any required
changes or additions to lesson plans. The latest update to this system
was October 5, 1985.
These findings indicate that there is no mechanism
for timely
identification of equipment,
procedure and programmatic
changes. Also, there is no mechanism for providing timely training and
distribution of this information. The licensee is to explain how changes
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to equipment and procedures will be identified and how operators will be
informed of the changes.
(0 pen Item 50-320/85-13-01)
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Exit Meeting Held October 31, 1985
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NRC personnel
N. Cudley, Lead Reactor Examiner
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W. Travers Acting Director, IMI-2
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C. Cowgill, Chief, TMI-2 Project Section
R. Cook, Senior Resident Inspector
Licensee Personnel
T. Demmitt, Deputy Director, TMI-2
R. Rogan, Director, Licensing and Nuclear Safety
A. Miller, Manager, Plant Operations TMI-2
F. Perry, Operator Training Manager
R. Maag, Supervisor, Licensed Operator Training
J. Auger, Licensing Engineer
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Summary of Comments
The NRC stated that, as a result of the inspection of the requalification
program, the program could be used as a basis for the NRC to accept tne
licensee's certification that presently licensed SR0s were qualified to
directly supervise defueling operations.
Minor deficiencies which were
identified during each aspect of the program inspection were discussed
with the appropriate licensee staff personnel and corrective actions were
taken.
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The NRC stated two concerns resulting from the inspection. First, was the
ability of the training department to identify changes in procedures and
equipment, and to disseminate that information in a timely manner. Second,
was the ability of the licensee to maintain and audit individual's train-
ing records.
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The NRC requested that the licensee supply the comprehensive retake exam-
ination and retraining program for the SR0s who failed the comprehensive
examination. This information would be used to support the NRC's accept-
ance of the licensee certification of those SR0s.
The licensee acknowledged that the NRCs concerns were valid and that their
importance had been brought home by events that had occurred earlier in
the week.
The licensee expressed an appreciation for the NRC support
provided during the certification of operators to direct defueling opera-3
tions.
Summary
The licensee's requalification program is adequate to train and certify
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presently licensed SR0s to directly supervise defueling operations.
The
25% failure rate on the comprehensive examinations is indicative of an
evaluative process which provides good differentiation between knowledge-
able and unknowledgeable operators, however, it calls into question the
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motivation of individuals to assimilate the material which is presented in
the training program.
Also, the attendance and timely completion of
requalification requirements indicates SR0s place a low priority on
training responsibilities.
Even though the requalification program adequately covered the present
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body of knowledge, it is questionable whether the program can respond to
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the rapid evolutionary changes in equipment and procedures.
An informal
management system is in place which would eventually identify and provide
training for plant changes. This process would take three to four months,
which is an unacceptable delay considering the rate at which changes are
made and implemented.
There is no established program to track individual's qualifications on
individual tasks or pieces of equipment.
This has lead to problems in
assignment of indiv
sals to tasks for which they had not been trained.
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