Text

Accreditation Renewal Self-Evaluation Report Maintenance and Technical Training Programs, Jan 1995
	ML20137M358
Person / Time
Site:	Saint Lucie
Issue date:	01/31/1995
From:	Fincher P, Sager D, Jason West; FLORIDA POWER & LIGHT CO.
To:	;
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ACCREDITATION RENEWAL SELF-EVALUATION REPORT Maintenance and Technical Training Programs i-January 1995 l

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ST. LUCIE NdCLEAR PLANT FLORIDA POW $R NblGHT COMPANY p

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s; Florida Power and Light Company St. Lucie Nuclear Plant i

ACCREDITATION RENEWAL l

r SELF-EVALUATION REPORT t

. Florida Power & Ught Company, St. Lucie Nuclear Plent respectfully submits this self-evaluation report for accreditation renewal of the following maintenance 'and technical training programs:

Instrument and control personnel Electrical maintenance personnel Mechanical maintenance personnel and supervisor i-Chemistry technician i

Radiological protection technician Engineering support personnel The self-evaluation and report fo ow the guidelines in ACAD 91-015 The Objectives and Criteria for Accreditation of Training in the Nuclear PowerIndustry, and ACAD 91-016, Rev.1, The Process for Accreditation of Training in the Nuclear Power Industry.

Questions concerning this report should be directed to:

Mr. Pat L. Fincher Site Training Manager St. Lucie Nuclear Plant Training Department P. O. Box 128 Ft. Pierce, Florida 34954-0128 Telephone.: (407) 468-4161 Fax: (407) 468-4266 JANUARY 1995

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Florida Power and Light Company St. Lucie Nuclear Plant ACCREDITATION RENEWAL SELF-EVALUATION REPORT Submitted By:

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Pat L Fin'cher Site Training Manager St. Lucie Nuclear Plant

\\feff A.WesN S(iteServices Manager St. Lucie Nuclear Plant Dav

. Sager Site V c President St. Lu e uclear Plant 6

JANUARY 1995

ACCREDITATION RENEY iles south of Ft.

SELF-EVALUATION RF

of 1983. Both Table of Conte' the on-site 9tograms for INTRODUCTION Initial Accreditation and Previous Renewals..........

Training Quality and Effectiveness....................

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SeN-Evaluation Methodology........................

Summary of Training and Qualification Programs (Table).....

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OBJECTIVE

SUMMARY

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.: i Objective 1:

TRAINING PROGRAM CONTENT......

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9 Instrument and Control (l&C) Joumeyman Training Program..

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Electrical Maintenance (EM) Joumeyman Training Program 39 i

Mechanical Maintenance (MM) Joumeyman Training Program...

23 Maintenance Supervisory Training (MST) Program.....

.......... 28 34 l

Chemistry Technician (CT) Training Program L

Radiological Protection Man (RPM) and Health Physics

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Dosimetry Technician (HPDT) Training Program...

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Engineering Support Personnel (ESP) Training Program..

48 Objective 2:

ORGANIZATION AND MANAGEMENT OF TRAINING 54 Objective 3:

DEVELOPMENT AND QUALIFICATION OF STAFF...

62 Objective 4:

ANALYSIS, DESIGN AND DEVELOPMENT...

...................68 Objective 5:

CONDUCT OF CLASSROOM TRAINING AND INDIVIDUAllZED INSTRUCTION AND TRAINEE EVALUATION...

72 Objective 6:

CONDUCT OF LABORATORY AND IN-PLANT TRAINING AND TRAINEE EVALUATION..

78 Objective 7:

CONDUCT OF SIMULATOR TRAINING AND TRAINEE EVALUATION 88 Objective 8:

SYSTEMATIC EVALUATION OF TRAINING EFFECTIVENESS 89 ATTACHMENTS :

ORGANIZATION CHARTS :

POLICIES AND PROCEDURES i

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1 The St. Lucie Nuclear Plant is located on Hutchinson Island on the east coast of Florida six miles south of Ft.

f Pierce. St. Lucie Unit 1 began commercial operation in December of 1976 and Unit 2 in August of 1983. Both unts are 810 MWe Combustion Engineering pressurized water reactors. Training is conducted at the on-site Nuclear Training Center and in the plant. This report reflects a critical self evaluation of the training prograrns for the fotowing personnel:

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- instrument & controlpersonnel i

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- Electrical maintenance personnel

- Mechanical maintenance personnel and supervisors

- Chemistrytechnicians i

RacSologicalprotodion technicans

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- Engrwering support personnel initial Accreditation and Previous Renewals r

The National Nuclear Accrediting Board initially accredited the three maintenance, chemistry technician, and cngineering support personnel training programs on September 23,1987 and renewed their accreditation on June 13,1991. The health physics training program was initiaNy accredited on June 6,1986 and was renewed on l

January 25,1990 and on June 13,1991.

The mantenance supervisor training program was initially developed in 1989. With the' issuance of ACAD 90-010 Guidelines for Maintenance Supervisor Selection and Development, the program was compared to the guidelines i

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.13 cnsure congruence. This program has been reviewed using Revision 1 of ACAD 90-010 and is being l

submitted as part of the mechanical maintenance program to the Accrediting Board for the first tirre during this round of accreditation renewal.

Training Quality and Effectiveness St. Lucie provides high quality training programs that are effective in preparing personnel to operate and maintain the two nuclear units safely and reliably and in maintaining personners job knowledge and performance. This is evident by the plant's performance record and feedback from both intemal and extemal evaluations of the plant

- and the training programs. For example, St. Lucie has a historically excellent performance record, in 1992, the plant received the first SALP report in Region 11 history with all performance categories rated as "1", and the NRC I

l recogruzed the plant as one of the superior operating nuclear power plants for the second time in a row, The U.

S. Council for Energy Awareness (USCEA) also commented, "St. Lucie's record reflects the nuclear industry's j

commitment to achieving ever higher levels of excellence in safety and performance."

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In the 1992 SALP report, maintenance training was commended for its quality and cftectiveness as the f llowing excerpt shows: "The maintenance training program continued to be strong. Training iacilities and programs in the area of motor-operated valves were good. Maintenance training materials in the area of service water were thorough and of high quality. Also, the training program was well presented and comprehensive." Additionally in 1992. St. Lucie achieved a " category 1" rating by the INPO plant evaluation team.

In March 1994, an NRC inspection report stated "the [rsdiation protection) technician staff appeared knowledgeable and well trained." The inspector reviewed lesson plans, handouts and examinations administered to radiation protection technicians during their continuing training on the revised 10 CFR Part 20 changes and based on this review, observations of technicians performing work and discussions with plant personnel, they concluded that " training in these areas appeared adequate to support ongoing work." In May 1994, a World Association of Nuclear Operators (WANO) team conducted a two-week evaluation and two of the five commendations reported in their Executive Summary were: "an experienced, knowledgeable and stable station staff," and " effective line management identification of training content needs, resulting in timely enhancements to training programs." The team also recognized two strengths in training and qualification practices: (1)

enhanced leaming activities during orientation training for engineering support personnel have improved training effectiveness" and (2) "an enhanced self-evaluation process, supported by a computerized information management tool, provided comprehensive and timely feedback on training effectiveness." The WANO team also identified some weaknesses regarding the effectiveness of training in addressing all root causes of performance deficiencies (see Objective 8) and coaching during the conduct intemal quality assurance audits of training have also recognized strengths. For example, among the strengths cited in the October 1994 report are: the professionalism and qualifications of training department management and staff (see Strength at Objective 3 in this report); ESP training, particularly the four-week orientation segment; l&C training, particularly the integrated plant training received with every system maintenance training module, j

and the training department's self-assessment methodology and practices including " aggressive intemal corrective action mechanisms"(see Strength at Objective 8). The report also noted that the " training department's program for delivering training based upon plant specific, industry related and Owner's Group events is very good." No weaknesses were identified during this audit.

Since the last accreditation renewal, several organizational changes have taken place at FPL that have had a positive impact on the effectiveness and efficiency of St. Lucie's accredited training programs. These changes are resulting in increased management involvement in training, improved responsiveness to plant changes and training needs, and resource savings (see Objective 2).

Dunng a self-evaluation interview, the HP department head said that training had contributed to their receiving no NRC violations for the past five years, and to the reduction in radiation exposure and personnel contaminations.

He also noted that training has contributed to a smooth transition in implementing the new 10 CFR 20 requirements, due to a joint effort by HP and training staffs. The continuing training for radiation protection 2-

technicians coupled wah aggressive engewering controis and decontamination efforts, yulded a significant j]

reduction in the use of respirators w!!hout incurring additenal intamal dose. Approximately 2,600 respirators were -

v used for the 1992 Unit 2 refueling outage, compared to less than 300 respirators issued during the 1994 Unit 2

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' outage with no intomal dose received.

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During post-training interviews and surveys, job supervisors and job incumbents have commented that they have j

benefited from training. Some of this feedback notes how training has enhanced plant safety'and reliability (see j

Objective 8 for examples). Other indicators of safe performance hclude a minimal number of lost time accidents, j

restricted duty cases and OSHA recordable injuries during the past four years, particularly since the plant has had j

a refueling outage for one or the other units each year and for both units in 1994 with the most recent outage l

completed in 35 days and ahead of schedule.

f Training staff have supported refueling outages directly by working in the plant on a variety of assignments (see Strength at Objective 3). These outage and other temporary assignments in the plant have contrbuted to '

j maintaining instructors' tecnnical skills, the technical quality of training materials and instructors' credibility during I

training delivery._ in April 1994, an ongoing accreditation review team, consisting of staff members from the '

l corporate office and a National Academy training coordinator, reviewed the programs using ACAD Objectne 2 criteria and interviewed 32 line managers, supervisors and job incurnbents. This team reported that line l

personnel rate the credibihty of instructors and the quality of training very high and that training is very responsive is requests from line organizations.

I The following are some examples of timely response to plant requests for training classes and changes to training

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programs. In response to maintenance management requests, the programs were redesigned to provide core training for initial qualification and advanced training for designated joumeymen selected by management for i

more complex or specialized maintenance jobs. The program was also modified to provide for duty area level k

qualification and the training department developed a computerized training information management system that includes qualification information. This system is on-line through the plant's wide area network (WAN) No maintenance supervisors and foremen can access qualification records during work order planning and scheduling.

Continuing training is responsive to personnel performance problems. For example, on September 14,1994, a i

norr miss involving starting work on a wrong valve during VOTES testing occurred that was caused by a failure to self-check and within five days the maintenance manager requested training. The maintenance training group

- 3eveloped, piloted and revised a lesson, and beginning on September 22, presented ;t to maintenance personnel j

over five class sessions. Management observed this training and noted that it met their expectations.. As a result, J

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~ cn-the-job performance has met management expectations regarding self-verification and technical specification adherencei This was evident by the completion of the subsequent refueling outage without incident and within f )

35-days which was ahead of scheduie Another example of timely response as well as efficient use of resource

~ irwolved a seminar on rework and plant equipment clearances, also provided prior to the 35-day outage. All three 3,

mairgenance tranng groups worked cn the lesson that incorporated job r levant ex:mples provided by the maintenance manager. Within a week of the manager's request, the seminar was presented to personnel from all three maintenance departments..

Some other examples of training provided in response to changing plant needs include the following. A chemistry lab course on the operation and maintenance of Dionex lon chromatography equipment was provided in 1991 during continuing training. Student feedback noted this training had helped them make better on-the-jou decisions and the lab course was subsequently incorporated into the initial program replacing self-study materials.

In 1993, training was provided on the atomic absorption spectrophotometer to support changing plant rnethods ard the purchase of new plant equipment. In 1994, lab training was provided on the multi-channel analyzer for gamma spectroscopy as continuing training and again incorporated into the initial program. Feedback from students indicates they feel more knowledgeable and are better able to troubleshoot the multi-channel ana.lyzer equipment on the job as a result of the training.

Since the previous accreditation renewal, many training instructors have begun using innovative training techniques and advanced technoicgies to improve training effectiveness. Such instructional strategies are increasing student motivation, encouraging student invoivement in the teaming process and promoting mastery of leaming objectives. For example, to develop ESP students' understanding of system operation and integrated plant response, pairs of students are assigned major plant systems to draw one-line diagrams including connections with other systems. Students maintain a system status board and describe the changes to their assigned systems, while tne instructor leads the class through simulated plant evolutions. At anytime during the discussion, the students can look at the whiteboards around the rcom and see the status of all major plant systems. (See Strength at Objective 5 for other examples.)

The academic community also recognizes the quality of St. Lucie's training programs. In 1993, Indian River Community College reviewed the maintenance, chemistry and health pilysics training programs and decided that training on selected content is equivalent to a total of 100 academic credits. The content and credits equate to 32 college courses that students can apply toward specific associate degree program options in electronics engineering technology and industrial management technology (see Strength at Objective 1). Students who complete initial training programs at St. Lucie may receive the designated credits on their college transcript toward a specific degree option. Depending on the program, the credits range from 23% to 38% of the 64 credits required for an associate degree at the college.

Training and plant personnel are pursuing higher education degrees in programs coordinated through the Nuclear Training Center. As a result, many training staff members have eamed or are pursuing degrees from the University of Central Florida, Florida institute of Technology, Thomas Edison Sthte College and University of Marylard (see Strength at Objective 3).

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j The indicators and examples described above attest to the quality cnd effectiveness of St. LucTs accredited j

training programs. Details are further described in appropriate sections of this self-evaluation report. For j

example, each program description includes several examples of positive aspects of training. Information is provided on significant changes made to training programs and training processes and the results of these chan0es. Throughout the report are additional examples of noteworthy training quality charactenstics. The report

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describes how the training programs meet the accreditation objectives and criteria including strengths and j

improvements resulting from ongoing evaluation and feedback and the accreditation self-evaluation process.

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. How the changes, improvements and standard good practices are contributing to improved plant, personnel and j

training performance are noted.

4 Self-Evaluation Methodology At St. Lucie, three key ingredients combine to ensure a critical self evaluation of accredited training programs: (1) a systematic self-evaluation methodology, (2) line management involvement and oversight, and (3) a computerized accreditation inf0rmation management system. This approach ensures self-evaluation activities i

lead to meaningful improvements to training programs and processes, and result in ongoing training effectiveness 1

recognized in improved personnel and plant performance. A description of management involvement and the computerized system is provided at Objective 8 (see Strength). The following describes the systematic self-evaluation methodology that involves four phases: (1) ongoing program evaluation and feedback activities, (2) ongoing accreditation reviews, (3) self-evaluation report preparation, and (4) an independent team evaluation.

This methodology is consistent with the guidance provided in ACAD 91-016, Revision 1 The Process for Accreditation of Training in the Nuclear PowerIndustry.

Phase 1 involves ongoing program evaluation and feedback" activities that include: student evaluation / testing, cxam evaluation, student / instructor critique, evaluation of l'nstructors/ evaluators in all settings, evaluation of change actions and operating experience, advisory board and review committees, management observation of training / task performance, post-training evaluation of }ob incumbent / supervisor feedback, and monitoring training performance and improvement actions. These evaluation activities provide the necessary feedback to ensure training programs continuously produce competts4 personnel and meet plant training needs.

Phase 2 involves ongoing " accreditation reviews" that are conducted to determine the training programs' status in meeting accreditation objectives specified in ACAD 91-015 The Objectives and Cnteria for Accreditation of Tr-ining in the Nuclear Power Industry. A review team leader and training program supervisor prepare an evaluation plan that guides the conduct of an accreditation review. Review teams use specially prepared evaluator guides to collect data related to specific accreditation criteria. They conduct interviews, observations and document reviews. During Phase 2, teams review much of the evaluation / feedback data collected during Phase 1. Team members set priorities to check areas that have been identified as industry recurring weaknesses 1

and problems at other.utilit,ies. They also collect evidence of training effectiveness with respect to personnel and plant performance irrprovement, customer satisfaction and training process management practices. Review I

1:ams consist of mernbers from St. Luci] trcining program st:ffs other than the program being reviewed, training l

staff from Turkey Point Nuclear Plant, training and other staff members (e.g., health physics and chemistry) from the corporate office, supervisors from the line organization and occasionally members from other industry groups.

During me review period (typically three to five days), team members interact closely with training program staff membe,a.and line personnel to ensure a thorough self-evaluation. To prepare for this third round of accreditation, 13 reviews were conducted involving over 20 different review team members (some individuals served on more than one team); involving over 80 line managers, supervisors and job incumbents; and., involving the 22 training staff members who manage and implement the training programs being submitted for accreditation renewal.

Team members report the results of their reviews in the on-line accreditation information management system.

Team members' reports include a " review summary" that includes brief descriptions of the status of training processes, the rnethodology used during the review, arJ any concems, accomplishments (including impact on personnel ard plant performance) and follow-up items. The information reported is then reviewed by the applicable program supervisor, instructors and instructional technologist who identify areas requiring further analysis or irnprovement action. When appropriate, selected items are discussed during training review committee rneetings and improvement action plans are prepared %d carried out. Improvement action schedules and status are maintained in the accreditation information management system. This system is easily accessible, so instructional technologists can update data, program staff can check the sta'tus of evaluations and improvement actions, and management can monitor activities and results. This review process provides the necessary feedback to ensure training programs continuously meet accreditation objectives and provides information that is the basis for the accreditation renewal self-evaluation report.

Phase 3 of the self evaluation process uses data resulting from Phase 2 accreditation reviews and improvernent actions to prepare a draft of the "self-evaluation report". While instructional technologists prepare sections of the report, they involve program staff in yet another phase of critical assessment of their programs. The self-evaluation report information is ordline in the same computer files used during Phase 2 and is accessible to all program staff. During Phase 3, review data is clanfied, results of improvement actions are checked, remaining weaknesses are further analyzed, noteworthy strengths are identified, follow-up items are pursued and program data is updated in order to prepare a complete and comprehensive draft of the self-evaluation report. Training and line management review this draft to ensure it reflects a balanced and accurate desenption of training programs, training processes and training results.

Phase 4 of the self-evaluation process is a week long " independent team evaluation" of all the programs being submitted for accreditation renewal. The structure and methodology for this evaluation parallels an Accreditation Team Visit (ATV). This independent team of peer evaluators consists of members from Turkey Point, the corporate office and other utilities. The team uses the dra.,ft self-evaluation report to review the programs, paying particular attention to the status and results of improvement actions and applicable areas identified as weaknesses at other utilities. The team conducts interviews with line and training personnel, conducts observations of training and wurk performance, and conducts document reviews of training procedures, materials 1

'and records. The 1:am vertfies self-identified str;ngths and improv: ment actions described in the self-evaluation report and provides feedback on the quality and accuracy of the information reported. This indepe-dent evaluation provides the feedback necessary to ensure St. Lucie has conducted a thorough self-evaluation without bias or bhnders. Team findings are used to improve the self-evaluation report and adjust improvement actions and training programs as necessary. The programs described herein were evaluated by ten team members, each assigned specific areas based on their background and experience. Over 40 line managers, supervisors and irambents were involved in interviews. Feedback and results of the independent team evaluation are incorporated into this final self-evaluation report.

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SUMMARY

OF TRAINING AND QUAllFICATION PROGRAMS i

Updated aS of 2/23/95 Poputetten Frequency W Inhiel Neder of tiessee G1. date el 16mds:t of Bhndeeof stadesde Answeieenenuisg Bhnder of Treinano ce trewns and typiest and studente since inet iset Wilmitrewns hoewte.e assedhe sentmins e,eemg hew einse henwetem Progran progrom resn+er el mudemo seeredtenenrenewie etese end suneer as m,paeneinaw lishms aserednesse es,, en,

emoned emedeneeneesed treWng snowel techming tseWng ia c 1991: 2 studens itet: 44 1991: 137' Mareenance -

45 As requested by plant 1992: 28 894 4

1982-48 190t 219 Same but'xtrs as Jourreyman (1-3 students) 1993: 7 (2 stedents) 1998: 51 1903 181 irhaltraining 1994: 2 1994: 48 1994: 307 Eleceical 1991: 15 students 1901: 32 1101: 163 '

Marnerance 30 As requested by plant 1992: 14 1!94 4

190t 27 In t 167 Sseinstructors as Journeyman p 5 students) 1993: 0 (3 students) 1903: 30 19ht 79 inihel Raining 1994: 3 1994: 31 1900 61 Metamcal 1991: 30 s1udent 1991: 83 1991: 144 '

Mardenance 82 As requested by plant 1992: 24 6/27/94 3

1992: 84 190t R9 Same rstructors as Journeyman (Vanes to most needs) 1993: 0 (3 stsdents) 1983: OS 1993: 82 initalraining 1994: 3 1994: 84 1904: 173 Mechancal 1991: 3 classes;I students 1991: 5 1991: 8 Mamtenance 25 As requested by plant 1992-1 chss;6 students 10694 1'

100t 16 1992: 16 Sameinstncer as Supeneser (10-14 students) 1993: 0 (8 students) 1993: 13 1993: 12 innial rainirg 1994: 1 class;8 students 1994: 17 1904: 12 1991: 5 students 1901: 18 1901: 138 Chomstry 15 As personnel are hred 1992. 2 1%93 1.5 1992: 17 1992: 48 Sameinstuctrs as Te&noan (1-2 students) 1993. 1 (1 stsdent) 1903: 17 1993: 100 kAltaining 1994: 1 curren9y armiled 1994: 16 1994: 42 1991: 2 studen's 1991: 20 1991: 44 Aadsbgcal 32 As personnel are hred 1992: 1 10/29513 15 feet 20 1992: 38 Sameinstnscurs as Prot cson Man (1-2 students) t993: 2 (1 sesdent) 1903: 32 1993: 19 innial rainmg 1994: 1 currenty enrolled 1994: 32 1994: 44 Heahh ftysa 1991: O Sameinstructra 1991: 4 1991: 28 Sameinstructra Dosenetry 4

As personnel are hred 1992: 0 11/17 0 who support RPM 190t 4 1992: 12 whosupport HPM Te&ncan (1 stedent) 1993: 1 student (1 student) taming 1903: 4 1993: 6 taming 1994: 0 1994: 4 1994: 8 Eng neenng 1991:(MTS) 2 classes:42 students 1901: (MTS) 84 1991; 20 Sepport 91 Twceannuah 1992: 0' 7/94 1'

1992: (MTS) 84 1992: 8 Same instructcr as Personnel' (16 students) 1993: 2 classes; 32 students (16 students)

-1993: (ESP) 73 1993: 4 kwtet taininD 1994: 2 classes; 30 students 1994: (ESP) 92 1994: 8 Not all journeymen attend every advanced or roqual tra ning dass; al joumeyman do artend corenumg tainmg en operatmg exponence feedback. See progwn desestpeens ter breakdown of annual connnuing taining hours.

1 2 Also supgried by otor tainmg deperiment instructors and guest rstrucers from fie plant and corporate stats when ava4able 3

The Eng noenrg Suppor1 Personnel (ESP) training pmgen replaced me Manager / Technical Stafl(UTS) training pmgram and the Inst ESP innial tuining does began en 2/16.93.

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TRAININ2 PROGRAM CONTENT f

OBJECTWE 1: Training program content provides the trainee with knowledge ' nd skills needed to a

perform functions associated with the position for which training is being conducted. The content of Infilal training prepares trainess to perform independently the duties and tasks for which they are being 4

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trained. The omdent of continuing training is selected to maintain and improve incumbent job performenos.

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SUMMARY

Initial and continuing training programs for plant maintenance and technical personnel are 3

developed and maintained using a systematic.gns&ch to training (SAT) methodology. ; initial training provides

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i students with the competencies and confidence to independently perform their assigned duties and tasks.'

Continuing training enhances students' knowledge and skills, keeps them current with changes and improves job

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1 performance. Training program content is based on job and task analysis, industry guidance, and ongoing evalualion and feettack. Job ar alysis identifies the duties and tasks required to functon in each job postion and

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which tasks are selected for trr2ning. Task analysis identifies the essentmi knowledge, skills and specEle task j

j performance requirements. Industry training guidelines are also used when determining content and program requirements. Ongoing evaluation and feedback ensures training programs continuously meet the needs of i

individuals and the plant.

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j The training staff in conjunction with plant department heads, or representatives by specific system, equipment

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and/or task, establish certification and qualification requirements. Plant administrative procedures provide

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g guidance for the selection of initial and continuing training content and specify requirements for each accrediteo

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y training program. An index to training-related polices and procedures is included as Attachment 2 to this report.

Program sequencing ensures that prerequisite training is appropriately and logically ordered. Program content is updated to incorporate change actions, operating experience and new guidance, initial and continuing training

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i-programs are effective in preparing and maintaining a highly qualified plant staff. Additionally, the local community college has evaluated the program content for credit recommendations toward specific degree l

programs.

b Significant Chenges Since Previous Renewal Dutv Area N=lificatinn - Since the previous renewal of the three maintenance training programs, the qualification method has been modified. In 1992, qualification of journeymen to independently perform work was refocused by I

maintenance management and training supervision. Quatrfications are now granted at the duty area level after a 1

_joumeyman completes the training and evaluation requirements for all tasks in a duty area. For example, instead of joumeymen electricians being granted qualification after completing the training and evaluation requirements for maintenance of 480-volt air circuit breakers that is in the power distribution duty area, electricians must 1

complete the training and evaluation requirements for all tasks in that duty area before working independently on l

power distribution equipment. Not all joumeymen are qualified to perform all duty areas, instead designated

. g joumeymen are selected for advanced training and qualification in specified duty areas designed to meet plant l

T needs. This provides for efficiency and effectiveness of job performance. Qualif' cation data is now on-line and updated on a continuous basis by the training staff and is accessible to plant maintenance supervision who assign

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work. This enables more effident work order planning and scheduing by idedfying thos] joumeymen who are qualsfied to independently perform specific work.

6 See the chemistry, health physics and ESP program descriptions for significant changes made to these programs since the previous renewal.

Program improvements in Progress As a result of the on going self-evaluation process, an improvement effort was initiated in 1994 to upgrade the quality of maintenance training materials. Instructors are reviewing leaming objectives to ensure higher-order skills are specified, enhancing instructional activities to ensure each objective is addressed, and modifying test items when necessary to ensure appropriate measures of student learning are developed. They are incorporating more detailed instructions about operating experience in tesson plans, where appropriate, to ensure consistent delivery of training from session to session I.ab guules are now developed to ensure lab training is consistently presented. By the end of 1994, training materials that have been upgraded include 19*/. of the instrument and control (l&C) curriculum,14% of the electrical maintenance (EM) cuniculum,31% of the mechanical maintenance (MM) cuniculum, and 100% of the maintenance supervisor training (MST) cuniculum. This is a long-term project spanning several years and expected completion is 1996. Some of the l&C lessons that have been improved include Soldering (#1802682), Overhaul of Bettis Piston Actuators (#1702050), and Operation of the Fisher Flowscanner (#1802079). Some of the EM lessons that have been improved include Polar Crane Maintenance

(#1502940) and Shrinkable Tubing (#1502060). Some of the MM lessons that have been improved include Mobile Crane (#1301290), Polar Cranes (#1302282), and Unit 1 Upper Guide Structure (#1301830). These improvements have resulted in more consistent delivery of instruction, more active leaming by students, and positive feedback f rom students as well as management who observe training.

Weakness

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During the independent Team Evaluation, the team identified some tasks that were added to the joumeyman j

electrician's job scope but were not added to their task list. Some.MOV tasks were previously performed by the joumeyman mechanic and were transferred to the electrician's job scope. When these MOV tasks we,e deselected from the mechanic's task list, they were not added to the electrician's task list. However, since the transfer of these tasks, the task performance requirements have not changed and thus the training and qualification requirements for these tasks have not changed. All designated electricians have completed training

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and qualfication requirements prior to performing these tasks in the plant independently. As a result of the evaluation team finding, the transferred tasks have been identified, added to the electrician's task list, and the existing training has been revalidated to ensure it addresses all task performance requirements.

The maintenance of site air conditioning systems was previously performed by contracted personnel and has been assumed by the electrical maintenance department. The electrical maintenance department established and implemented air conditioning training, which is provided by the local community college, independent of the training department. As a result, air conditioning tasks were not added to the electrician's task list. However, the

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4 elecidcal maintenance depenment had evaluated the cogege course, and detirmined that it addressed the task 1 l

pedormance requirements, pdor to initially implementing the training. As a result of the evaluation team finding, corrective adion was ta.en to add air condtioning tasks to the task Est, reevaluate the college course to complete contractor training evaluation,' and incorporate student records into the quaEfication records system.

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The MOV and air consterung tasks are futy incorporated into the EM treining' program. All electncians.

j designated to pedorm these tasks have been trained and quaghed prior to working independently and there have been no personnel pertormance problems associated with these tasks. Furthermore, no similar task Est problems i.

were idonanare tor the other pmgrams being submitted for accrestahon renewal. However, to prevent recurrence l

- and ensure that tasks transferred fem one job position to another are added to the appropriate task Est, a..

standng agenda item has been added to the training review committee agenda. This will ensure any task Nst j

4 addhons, deselections or modificabons, and the reasons for these changes, will be identified on an ongoing basis d these meetngs. When tasks are transferred to another job, the responsible lead instructor wiu be noGEed of l

. the transfer to ensure the transferred tasks are addressed by the appropriate training review committee and l

added to the appropriate task Est. Training procedures have been modified to provide better guidance on the 7

handingof taskNotmaintenance.

i Strength In 1993, Indian River Community College reviewed the maintenance, RPM and chemistry training programs and T

determined equivalent academic credits appEcable toward specific associate degree programs established by the

[

college. The following lists for each degree option, the number of college credits and the percentage of total required credts that St. Lucie personnel may obtain following completion of in-house initial training programs I

15 college credts toward a degree in Electronics Engineering Technobgy, instrument and Control Option, constituting 23% of the required 64 credits l

21 college credits toward a degree in industrialManagement Technobgy, Electrical Option, constituting 33% of required 64 credits

]

18 college credts toward a degree in industrialManagement Technobgy, Mechanical Option, constituting 28% of required 64 credits l

22 college credts toward a degree in IndustrialManagement Technobpy, Chemical Option, constituting 34% of required 64 credits I'

24 college credits toward a degree in IndustrialManagement j

Technobgy, Health Physics Option, constituting 38% of required 64 credits l

L Use of industry Guidance during Systematic Training Development The systematic process used to establish and maintain training program content is specified in AP 0005756 1

4 Systematic Training Devebpment. The process involves the use of industry guidance during content selection l

irdudng documents, guidelines and regulations issued by the National Academy for. Nuclear Training, INPO, NRC and other industry sources. The specific industry guidance documents used to develop and maintain the c

j e

4 >

i l

l'

' meirtenance and techrscal tr-tning programs are rfscussed in appropriate secti:ns throughout this r: port. The i

corporate and plart potcies and procedures that provide guidance for establishing and maintaining training programs, including the administrative procedures that govem each program, are listed in Attachment 2 to this report. The individual program descriptions, that follow the responses to the Objective 1 criteria, describe the job i

positions and functions, training prerequisites, program basis and details for each program.

I initialTrainin0 Program Content 4

The content for initial training programs is derived from an analysis of the knowledge and skills necessary for I

competent job performance. Job and task analysis have been conducted for chemistry, health physics and maintenance joumeymen programs to identify duties and responsibilties and determine actual kid:$- and skiE requimments. Reviews of appropriate industry guidance documerts are conducted during the idertification f

of duty areas, tasks and supporting knowledge, skills and abitties for each program initial training content for j

maintenance supervisors and engineering support personnelis derived from the suggested areas in the l

mppue=Ma academy guidelnes and the training needs of the target populaton Guidance documert reviolons and -

j other change actions are considered for appEcabilty in accordance with AP 0005766 Training Resources, j

indorrnation ancf Material Control. When changes in job scope are identified, new requiremerts are analyzed for l

t any new knowledge or sidlis and initial training content is developed or modified as appropriate. The individual program descriptions that follow this section describe initial training content and requirements including any j

i segrvficant changes made since the last accreditation renewal 4

N ;

Continuing Training Program Content t

1

+

Cortinuing training programs mairtain and improve job incumbents' knowledge and skills. Training staff and plant department supervision identify and select continuing training content. Training Review Committees (TRC's) approve continuing training tasks and topics (see Program Descriptions for sample topics provided each year i

since the prev 6ous accreditation renewal). The content is based on the following sources:

+

I plant design changes and modifications l

plant and industry operating experience new or revised plant procedures i

training program evaluation data infrequently-pertormed, difficult or critical tasks company-required requalfication requirements (e.g., CPR) 1 training required by regulatory agencies job performance deficiencies and other training needs identified by plant departments

}

AP 0005766 Training Resources, Information and Material Controlspecifies guidance for evaluating operating exp:

6

hange actions to determine training relevancy and if appropriate to include in continuing training j

progh

'.dny change actions have been covered during cortinuing training since the last scradtatica j

renewal in-house and industry operating experience reports are automatically reviewed for applicability and I

f incorporated in training as appropriate. (See Objective 8 for more details about the process and examples.)

I INSTRUMENT G CONTROL JOURNEYMAN TRAINING PROGRAM Program Description 1

PROGRAM FEATURES Job Position / Function The Instrument & Control (l&C) training program provides joumeymen specialists with the knowledge and skills required to repair and maintain instrumentation and control systems and components. I&C specialists are responsbie for the maintenance and calibration of pneumatic and electronic systems and subsystems that provide primary and secondary process control, reactor and turbine protection and regulation, and alarm annunciation. These include auxiliary feedwater, radiation monitoring, seismic instrumentation, reactor regulation and protection, nuclear instrumentation, and emergency safeguards systems.

Training Prerequisites l&C specialists are selected through a competitive bidding process in accordance with the Memorandum Of Agreement (MOA) between FPL and the International Brotherhood of Electrical Workers. The l&C speclafist job classifications require three years working experience in the instrumentation and control field and should include one year related technical training in addition to their experience. This requirement is stated in the plant's Quality Instruction, Ol1-PR/PSL-3, Maintenance Organ!zation, which is consistent with ANSI /ANS 3.1-1978.

]

O Students who enter the l&C training program meet one of the following requirements:

- Bid in as joumeyman with l&C classification from within FPL system

- Assoc! ate of Science degree in electronics and three years related experience

- U. S. Navy Electronic Technician at E 5 level or above There are two classifications of I&C specialists who participate in the training program-l&C specialist nuclear and l&C digital specialist nuclear. The program is the same for both job classifications except in addition to the entry requirements listed above, an applicant for digital specialist must either be a designated digital specialist from another FPL plant or complete three college classes in digital applications (two classes in microprocessors and j

one class in computer programming),

Meeting these requirements ensures students have attained the prerequisite knowledge and skills necessary to begin the I&C training program, including basic hand tools, soldering, basic electronics, introduction to pneumatics, power plant f amiliarizalion, safe work practices and mathematics. The practice since initial accreditation has been to transfer qualified joumeymen from other FPL plants to fill open positions at St. Lucie.

13

' Program Basis

{

The 1&C training program is developed and maintained using a systematic approach to training (SAT) that is consistent with INPO 85 006, Pnncpies of Training System Development (TSD). The program is based on a job

' and task analysis of the l&C specialist's job performance requirements. The task list is revalidated periodically involving both plant and training personnel. The program design is congruent with ACAD 92-008 Guidelines Apr

[

Trainiry and QuaWiostion of Maintenance Personnel. A task-to-training cross reference matrix is maintained

~

UMoAnate. Administrative Procedure 0005748 Nuclear Maintenance JourneymarVSpecialist Training Program l

3rAcifies program guidance and requirements for the initial and continuing training and qualification of

)Nmeymen. The l&C program consists of the foliowing segments:

4 initialTraining f

Maintenance Fundamentais in.t.umor on a. C,.,oi Funda,nentais Spoonal Fundamentals

]

Corninuing Trainina Advanced Training that incorporates on-the-job training Requallfication Training Operating Experience Feedback Training Ref ar to the Training and Qualification Sequence chart at the end of this program description for each program segment s training settings, durations and content.

I Program Details Duration Initial training is 178 hours0.00206 days 0.0494 hours 2.943122e-4 weeks 6.7729e-5 months ; continuing training varies based on plant needs and has averaged 211 hours0.00244 days 0.0586 hours 3.488757e-4 weeks 8.02855e-5 months per year over the last four years.

Training Methods: Classroom presentations using accelerated leaming techniques and interactive videodisc instruction when applicable, laboratory exercises, on-the-job training (see Strength at Objective 5).

Iggino Methods Written exams and job performance measures.

Program Evaluation: Feedback is solicited from students, instructors, job incumbents and plant supervisors. The maintenance training group's instructional technologist conducts program data analysis and evaluations.

Management observation of training, monitoring of personnel and plant performance, and intemal and extemal evaluations also provide feedback to the program. On-going accreditation reviews involve evaluating the program against accreditation criteria and determining program results (see Strength at Objective 8). The Plant Training Advisory Board End I&C Tr:.t.Lg Review Committee provide oversight and monitor training effectiveness.

instructors Four full-time instructors support initial and continuing training, one who has additional administrative

. duties as the designated lead instructor. These instructors have responsibility for all training-related activities required for development, delivery, administration and maintenance of the program and materials. The instructional staff is highly qualified including a strong technical background maintained by supporting in-plant l

outage duties (see Strength at Objective 3).

.14

INITIAL TRAINING

)

I Program Objective

'The objective of the l&C initial training is to prepare individuals with the basic knowledge and skills required to function as an l&C specialist in plant-specific work situations. An l&C speciaEst.must complete this training before worldng independentlyin the plant.

I Program Segmenta l

18C initial training includes three segments of fundamentals.

The maintenance fundamentals segment provides classroom and lab training that includes site-specific administrative requirements, industrial safety and work control practices.

The instmmentation and gontrol fundamentals segment provides classroom ard lab training that includes an overview of pressurized water reactor theory and instruction on diagrams, clearances, oscilloscope operation and caibration of pnecmatic and electronic loops. This segment includes task performance evaluations.

The spedal fundamentals segment for l&C specialists consists of one course on working in confined spaces that includes classroom and lab training covering plant procedures, environmental hazards and testing the atrnosphere with an oxygen meter.

l 1

CONTINUING TRAINING Program Objective j

The objective of l&C continuing training is to develop advanced competencies and maintain and enhance job proficiency, Continuing training provides advanced knowledge and skills leading to specific duty area qualification, supports required requalification training, addresses plant and industry operating experience, and reviews changing requirements.

Program Segments The advanced trainina program consists of classroom, laboratory and on-the-job training (OJT). This program segment provides 180 specialists with more complex skills and knowledge required to perform non-routine, infrequent and specialty tasks selected for advanced training. The intent of advanced training is to ensure that 1

desianated specialists achieve the qualifications required to independently perform specific job assignments.

l Advanced training is D21 intended to qualify M 1&C specialists on M advanced training topics and is provided at the request of l&C department management. Advanced training is provided for first-time qualification as well as to retrain or refresh specialist's knowledge and skills to enhance job performance during outages or special I

assignments. This segment includes task performance evaluations (TPE). The 1&C department is responsible 1or OJT including the associated TPE's. Currently (as of 12/1/94) there are 131&C department personnelwho are certified to conduct OJT/TPE.

15-

The recualificahon trainino segment consists of courses that designated l&C specialiL must complete Gither annually or biennially as required to maintain certain qualifications. This curriculum includes courses on self-contained breathing apparatus (SCBA), CPR, first aid, Target Rock solenoid actuators and a soldering refresher. Requal training sessions are scheduled as determined by l&C department requirements.

Operating exnerience feechack (OEF) trainino is scheduled annually for all l&C specialists, typically in quarterty sessions. OEF sessions cover lessons leamed from in-house and industry events as well as changes in plant equipment, procedures and industry requirements. OEF training may incluoe content or activities from the initial or advanced training curriculum.

Sample Topics Since Previous Renewal The following are examples of continuing training topics delivered each year since the previous accreditation renewal. Alll&C spar

Ente participate in operating experience training. Designated specialists participale in advanced and requal training. The number of training curriculum hours conducted each year is indicated in parentheses.

1991 (137 hrs. - 108 Advanced; 15 Requal; 14 OEF) Nicolet storage oscilloscope operation; process control introduction and characteristics; controller tuning basics; and advanced control methods.

1992 (219 hrs. - 180 Advanced; 23 Requal; 16 OEF) Seismic training; fundamentals of measurement and temperature, pressure, flow, level and analytical measurement.

1993 (181 hrs. - 136 Advanced; 37 Requal; 8 OEF) Fisher Ibwscanner; process measurement; Nicolet storage oscilloscope; and in-house and industry operating experience.

1994 (307 hrs. - 248 Advanced: 47 Requal; 12 OEF) Rod control; reactor protection; radiation monitoring; and in-house and industry operating experience.

POSITIVE ASPECTS OF TRAINING l

i The l&C instructors have incorporated accelerated leaming techniques into several training courses including lessons on proccss measurement, subassembly and assembly structure, circuit paths and circuitry logic, the reactor protection system, loose parts monitor and Bettis actuator overhaul (see Strength at Objective 5.)

instructors make efficient use of resources to provide training that challenges I&C specialists. Equipment salvaged from the plant is refurbished and used during lab training including the lessons on rod control, the Bettis f

and ITT Barton actuators, and the Unit 1 radiation monitoring system (see Objective 6). The lesson on the j

reactor protection system uses the plant-reference control room simulator (see Objective 7). Continuing training j

covers change actions and in-house and industry operating experience to provide l&C specialists the opportunity to discuss changes and lessons leamed that are relevant to their job (see previous section on Sample Topics 2

Since Previous Accreditation Renewa!)

g g

g

t INSTRUMENT & CONTROL MAINTENANCE JOURNEYMEN Training and Qualification Sequence MAINTENANCE FUNDAMENTALS l&C FUNDAMENTALS SPECIAL FUNDAMENTALS ADVANCED TRANNG SMe introduction Nudear Power Production Overview Workingin Confined spaces Riggmg Mamienance Faclities Piping and instrumenta5on Diagrams Primary Systems Job Descriptions Electrical Bluepnnts/ Control Wiring FeedwaterSystem AFAS Record Mars erieri System Diagrams Turbine System v -

Documents, Records, Forms and Verify an h-Plant Oearance Unit 1 and Unit 2 Radiation Standards Start a Task Monsonng Procedures Finish a Task Hydrogen Samphng Eiyweas Drawogs Calitrate aPneumaticLoop Seismic hstrument Site and Plant Layout Calibrate an Electronicloop Reactor Regulation Lists TablesandVendor-Supplied Oscilloscope Operation Reactor Protection System Documents Nudear hstrumentation incere/Excore Procurement of Replacement Parts Unit 1 and Unit 2 Rod Control and Equipment ESFAS Engineered Safeguards Work Request loose Parts Montor Transportation Equipment Process Measurement Fundamentals Chemicats and Pressurized Gases Plant Annunciator Systems Working from Heights M&TE Lab Duties Protective Equipment Raychem introduction to industrial Safety Soldering Safety Tagging Bettis Actuators Electrical Safety ITT-Barton Actuator Fisher Fbwweer Gassroom -

43 hours4.976852e-4 days 0.0119 hours 7.109788e-5 weeks 1.63615e-5 months Qassroom -

54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months Classroom -

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months '

Oassroom -

681 hours0.00788 days 0.189 hours 0.00113 weeks 2.591205e-4 months Laboratory -

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Laboratory -

64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months Laboratory -

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Laboratory -

83 hours9.606481e-4 days 0.0231 hours 1.372354e-4 weeks 3.15815e-5 months in-Plant 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months in-Plant 292 hours0.00338 days 0.0811 hours 4.828042e-4 weeks 1.11106e-4 months

El.ECTRICAL MAINTENANCE JOURNEYMAN TRAINING PROGRAM Prograrrl Description PROGRAM FEATURES Job Positions / Functions The electrical maintenance (EM) training program provides joumeymen electricians the knowledge and sidils required to repair and maintain plant electrical equipment. Electricians are responsible for the maintenance of systems and subsystems that generate, provide or utilize electrical power including electric cranes, motors, diesel generators, attemating current and direct current power supplies, inverters, motor operated valves, batteries, and cables and wires.

Training Prerequisites Joumeymen electricians are selected through a competitive bidding process in accordance with the Memorandum Of Agreement (MOA) between FPL and the intemational Brotherhood of Electrical Workers. The electrician job 1

classification requires three years experience in electrical maintenance that may be fulfilled by an approved apprentice program which includes three years of field work or by three years of applicable industry experience.

This requirement is stated in the plant's QuaEty instruction, O!1 PR/PSL 3, Maintenance Organization, which is consistent with ANSI /ANS 3.1 1978.

Students who enter the EM training program have:

' a high school or General Education Development (GED) equivalency diploma

- completed an electrician apprentice program or equivalent training and experience or three years applicable industry experience i

Meeting these requirements ensures students have attained the prerequisite knowledge and skills necessary to begin the EM training program, including basic hand tools, safe work practices, rneters and test equipment, National Electric Code, principles of electricity, protective devices, prints and troubleshooting, switchgear, power plant farniliarization, batteries, motors, generators and motor operated vanes.

Program Basis The EM training program is developed and maintained using a systematic approach to training (SAT) process that is consistent with INPO 85-006, Principles of Training System Development (TSD). The program is based ort a

}ob and task analysis of the joumeyman electrician's job perforrnance requirements. The task list is revalidated periodically invoMng both plant and training personnel (see Utility-identified Weakness at the Objective 1 Summary). The program design is congruent with ACAD 92-008, Guidelines for Training and Qualification of Maintenance Personnel. A task-to-training cross-;eference matrix is maintained up-to-date. Administrative Procedure 0005748 Nucie:r Maintenance JoumeymantSpecsalist Trbning Program specifies program guidance

' and requirements for the initial and continuing training and qualification of joumeymen. The EM program consists of the following segments:

{

h, !

}-

Initial Trairunp Maintenance Fundamentals Electrical Fundamentals Continuing Traininn Advanced Traming that incorporates on-the-job training Requalification Training 4

Operstmg Exponence Feedback Training Refer to the Training and Qualification Sequence chart at the end of this program descnption for each program segment's training settings, dura:bns and content.

. Program Detalle Duration: initial training is 131 hours0.00152 days 0.0364 hours 2.166005e-4 weeks 4.98455e-5 months ; continuing training varies to meet plant needs and has averaged 114 hours0.00132 days 0.0317 hours 1.884921e-4 weeks 4.3377e-5 months 2

per year overthe past four years.

l Trainino Methods: Classroom presentations / discussions, hands-on laboratory and field exercises, on-the-job training (see Strength at Objective 5).

Testmg Methods: Written exams and job performance measures.

1.

Program Evaluahon Feedback is solicited from students, instructors, job incumbents and plant supervisors. The maintenance training group's instructional technologist conducts program data analysis and evaluations.

Management observation of training, rnonitoring of personnel and plant performance, and intemal and extemal evaluations also provide feedback to the program. On-going accreditation reviews involve evaluating the program i

against accreditation criteria and determining program results (see Strength at Objective 8). The Plant Training Advisory Board and EM Training Review Committee provide oversight and monitor training effectiveness.

instructors Four full-time instructors support initial and continuing training, one who has additional administrative duties as trie designated lead instructor. These instructors have responsibliity for all training-related activities j

required for development, delivery, administration and maintenance of the program and materials. The instructional staff is highly qualified including a strong technical background maintained by supporting in-plant outages (see Strength at Objective 3).

INITIAL TRAINING 4

4 PqmMMW i

The objective of the EM initial training is to prepare individuals with the basic knowledge and skills required to

.' function as a journeyman electrician in plant-specific work situations. An electrician must complete this training before working independently in the plant.

e 1g.

J

l Program Segments i

4 EM initial training includes two segments of fundamentals.

The mantenance fundamentals segment consists of classroom instruction that covers site-specific administrative requiremems, industrial safety and work control practices that are commore to all plant maintenance departments.

This segment includes a task performance evaluation in the electrical safety module.

The electrical fundamentals segment consists of classroom instruction that is oriented to the electrician's job functions Topics relate to electrical maintenance administrative requirements, tools and equipment, diagrams and drawings, basic troubleshooting and an overview of pressurized water reactor theory. This segment includes 1

task performance evaluations of which one, Ground and Test High Voltage Power Distribution, is performed in the i

plant.

CONTINUING TRAINING Prograrn Objective The objective of EM continuing training is to develop advanced competencies and maintain and enhance job proficiency. Continuing training provides advanced knowledge and skills leading to specific duty area qualification, supports required requalification training, addresses plant and industry operating experience, and reviews changing requirements.

Program Segments The advanced trairuna consists of classroom, laboratory and on-the-job training (OJT). This program segment provides joumeymen electricians with more complex skills and knowledge required to perform non-routine, infrequently performed and specialty tasks selected for advanced training. The intent of advanced training is to cnsure that designated electricians achieve the qualifications required to independently perform soeafic job assignments. Advanced training is Dol intended to qualify all joumeymen electricians on all advanced training topics and is provided as requested by EM department management. Advanced training is provided for first-time duty area qualification as well as to retrain or refresh electrician's knowledge and skills to enhance job performance during outages or special assignments. This segment includes task pertormance evaluations (TPE).

The electrical maintenance department is responsible for providing OJT including the associated TPE's. Currently (as of 12/1/94) there are five EM department personnel who are certified to conduct OJT/TPE.

The recualification trainina segment consists of courses that designated joumeymen and chiefs rnust complete i

either annually or biennially to maintain their qualification on grounding and high voltage testing, self-contained breathing apparatus (SCBA), CPR and first aid. Requal training sessions are scheduled as determined by EM department requirements.

Operatina ernerience feedback (OEF) trainino is scheduled annually for all electricians typically in quarterly sessions. This program segment focuses on lessons teamed from in-house and industry events as well as j

e.

[,

I changes in plant equipment, procedures and indu2ry requirements. OEF tr::'ning may include content cr andvilles from alther the initial or advanced training curriculum.

Sample Topice Since Previous Renewal

(

The following are examples of continuing training topics delivered each year since the previous accreditation

~

renewal All electricians participate in operating experience training. Designated electricians participate in advanced and requal tralning. The number of training curdculum hours conducted each year is indicated in pareneheses 1

1991 (163 hrs. - 132 Advanced; 19 Roqual: 12 OEF) Advanced troubleshooting, raychem instaBahon, OSPDS power line conditioning, cleanliness control procedures, test equipment caEbration, jutnpers and Biled leads, engineering information regarding the identification of stress corrosion cracking, and quauty instructions on non conforming conditions and reports.

1992 (167 hrs - 136 Advanced; 15 Requal; 16 OEF) Advanced troubleshooting, ernergency diesel preventeve maintenance, polar crane maintenance, procedures regarding control of heavy loads, equipment protecdon, sensitive systems, post maintenance testing, discussion of outage plant change /modificadons i

2 -

affecting the EM department, and the qua8fied seismic positions for Westinghouse air circuit breakers.

1993 (79 hrs - 52 Advanced; 15 Requal: 12 OEF) Valve operator maintenance, low voltage and nigh voltage taping, forkBft operation, procedures regarding hazardous material' control, asbestos, and chemical control.

1994 (61 hrs. - 28 Advanced; 25 Requal; 8 OEF) Plant change / modification for replacement of the capacitors on Unit 2 instrument inverters, i.nclusion of asbestos information in plant work orders, human

(, l,

[

factors report on a personnelinjury that occurred while moving a storage battery, and a USNRC generic I

letter regarding record keeping.

NOTE: The number of advanced training hours decreased during the past two years because a sufficient number of designated joumeymen required to support plant needs are qualified in the specific duty areas.

POSITIVE ASPECTS OF TRAINING

}

Continuing training is responsive to job performance needs and is implemented to support plant schedules and j

individual job assignments. For example, prior to the 1994 Unit 2 outage, hands-on polar crane maintenance training was provided for selected electricians who indicated the training was effective in preparing them to efficiently and accurately inspect, operate and maintain the polar crane during the outage. In September 1994, training was provided in response to a near miss to reinforce self-checking, resulting in no performance problems 1

during the subsequent outage. A seminar on rework and plant equipment clearances was presented in 1994 i

within a week of being requested by th6 maintenance manager, The mariager provided job relevant examples to incorporate in the lesson plan that was developed involving all three maintenance training groups. Lessons j

leamed from other in-house and industry events have been reviewed during continuing training (see Objective 8 for examples).

j 21 -

O O

h ELECTRICAL MAINTENANCE JOURNEYMEN Training and Qualification Sequence MAINTENANCE FUNDAMENTALS ELECTRICAL FUNDAMENTALS ADVANCED TRAINING Site Irtroduction Enh TedaiHazards Power M&TE Manitenarce FacMies Workingin Conlined Spams Power Dstribution Jcb Dew 4& dis Nuclear Power Produchon Overview Heactor Protechon Record Marmgement System Forklift Operation 125v00 System Documents, Records, Forms ard Test Atmosphere With Oxygen Meter kistrumertinverter Standards Electrical Administration Training Generator Procedures Ppig and Instrumentation Diagrams Mobile Crane Ergneenng Drawings Read Electncal Drawings Motors Site and Plantlayout Measurement and Test Equipment Scattolds Lists. Tables and Vendor-Supplied Basic Troubleshooting.

LTe@4 Diesel Generator Documents Ground and High Voltage Test Power Dstribution Gantry Cranes Procurement of Replacera.ent Parts Generator Grounding and Testing Motor Operated Valve and Equipment Verify a Clearance Polar Crane Maintenance Work Request Battery Load Testing Transportation Equipment Insulating Training Chemicais and Pressurized Gases Working fra Heights Protective Eq.?pient introduction k: hidustrial Safety Safety Taggir.g Electrical Tably Controlof Heavyinads and lifts l

Classroom -

45 hours5.208333e-4 days 0.0125 hours 7.440476e-5 weeks 1.71225e-5 months Classroom -

68 hours7.87037e-4 days 0.0189 hours 1.124339e-4 weeks 2.5874e-5 months Cassroom -

157 hours0.00182 days 0.0436 hours 2.595899e-4 weeks 5.97385e-5 months Laborafory -

Ihour Laboratory -

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Laboratory -

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months In-Plant Ihour in-Plant 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months

"":f.CT. ~

l I

MECHANICAL MAINTENANCE JOURNEYMAN TRAINING PROGRAM e

Procram Description PROGRAM FEATURES Job Positions / Functions Mectanical maintenance (MM) training provides journeymen rnechanics with the knowledge and skills required to repair and maintain rnochanical eqti.pment at the plant. Mechanics are primarily responsible for the maintenance of the reactor, vake, piping, pump and compressor systems and subsystems that generate steam, provide feedwater or route cooing water. Mechanics also operate cranes and forklifts and conduct general maintenance actMties.

Training Prerequisites Journeymen mechanics are selected through a competitive bidding process in accordance with the Memorandum Of Agreement (MOA) between FPL and the intemational Brothe,?.ood of Electrical Workers. The joumeyman mechanic job classification requires three years working experience in their speciality that may be achieved through a rnecnanical apprenticeship program or by appEcable industry experience. This requirement is stated in the plant's Quality instruction, Olt PR/PSL-3, Maintenance Organization, which is consistent with ANSI /ANS 3.1 1978.

Students who enter the MM training program have:

a high school or General Education Development (GED) equivalency diploma completed a maintenance mechanic apprentice program or equivalent training and experience

\\

i Meeting these requirements ensures students have attained the prerequisite knowledge and skills necessary to l

begin the MM training program, includng basic hand tools, safe work practices, welding fundamentals, lubrication, pumps, heat exchangers, shop math and power plant familiarization.

Program Basis The MM training program is developed and maintained using a syster:ntic approach to training (SAT) process that is consistent with INPO 85-006, Principles of Training System Development (TSD). The program is based on j

a job and task analysis of the mechanical maintenance joumeyman's job performance requirements. The task list is revalidated periodically involving both plant and training personnel. The program design is congruent with.

ACAD 92 008, Guidelines for Training and Qualification of Maintenance Personnel. A task to-training cross reference matrix is maintained up to-date. Adrrinistrative Procedure 0005748 Nuclear Maintenance JoumeymarvSpecialist Training Program specifies program guidance and requirements for the initial and continuing training and qualification of joumeymen.

23 -

y.

i

. The MM pogram consists of the following seg/T fis:

i 1

initialTrairuna 3

Maintenance Fundamentals -

Mechanical Fundamentais Special Fundamertals cantinuing Training l

Advanced Trairung W% Training Operaung Expedence Feedback Training Refer to the Training and Quatlication Sequence chart at the end of this program description for each program segment's training settags, duratens and content.

Pfogram Details

,rhEalGO initial training is 235 hours0.00272 days 0.0653 hours 3.885582e-4 weeks 8.94175e-5 months ; continuing training varies to meet plant needs and has averaged 146 hours0.00169 days 0.0406 hours 2.414021e-4 weeks 5.5553e-5 months per yearover the past four years.

Trainino Methods: Classroom presentations / discussions, hands-on and laboratory exercises, and on-the-job traming.

Testing Methods: Written ev.aminations and job performance measures.

Pronram Evalumnon: Feedback is solicited from students, instructors, job incumbents and plant supervisors. The maintenance training group's instructional technologist conduds program data analysis and evaluation.

Management observation of training, monitoring of personnel and plant performance, and intemal and extemal evaluatons also provide feedback to the program. On-going accreditation reviews involve evaluating the program j

against accreditation criteria and determining program results (see Strength at Objective 8). The Plant Training Advisory Board and MM Training Review Commhtee provide oversight and monitor training effectiveness.

i instmctors' Three full-time instructors support initial and continuing training, one who has additional i

administrative duties as the designated lead instructor. These iristructors have responsiblity for all training-related activities required for development, delivery, administration and maintenance of the program and

. materials. The instructonal staff is highly quabfied including a strong technical background maintained by supportmg in-plant outage duties (see Strength at Objective 3).

4 INITIAL TRAINING Prograrn Objective The objective of the MM initial training is to prepare individ6,als with tne basic knowledge and skills required for joumeymen mecharucs to function in plant-specific work situations. A mechanic must cornplete this training before wondng independently in the plant.

~

. 24

+

\\.

Program Segments MM iritial training includes three segments of fundamentals.

The maintenance fundamentals segment consists of classroom instruction that covers site-specific adtrinistrative requirements, industrial safety and work control practices that are common to all plant maintenance departments.

This segment includes a task performance evaluation (TPE) in the electrical safety module.

The mechanical fundamentals segment consists of training that is oriented to the mechanic's job and includes task performance evaluations. Topics relate to mechanical maintenance tools and equipment, basic methods, blueprint reading, an overview oi pressurized water reactor theory, control systems and components, and administrative requirements.

The soedal fundamentals segment consists of four courses on rigging, scaffolds, working in confined spaces and equipment clearances, and includes task performance evaluations.

CONTINUING TRAINING Program Objective The objective of MM continuing training is to develop advanced competencies and maintain and enhance job proficiency. Continuing training provides advanced knowledge and skills leading to specific duty area qualification, supports required requalification training, addresses plant and industry operating experience, and reviews changing requirements.

Program Segments

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The advanced trainina program consists of classroom, laboratory and on-the job training (OJT). This program segment provides mechanics with more complex skills and knowledge required to perform non-routine, infrequently performed and specialty tasks selected for advanced training. The intent of advanced training is to ensure that designated mechanics achieve the qualifications required to independently perform soecific job assignments. Advanced training is Dgilntended to qualify M mechanics on d advanced training topics and is provided at the request of MM department management. Advanced training is provided for first-time qualification as well as to retrain or refresh joumeymen's knowledge and skills to enhance job performance during outages or special assignments. This segment includes task performance evaluations (TPE). The MM department is responsible for providing OJT including the associated TPE's. Currently (as of 12/1/94) there are 16 MM department personnel who are certified to conduct OJT/TPE.

j The reaualification trainino segment consists of courses that designated mecnanics and foremen must complete either annually or bienniall; as required to maintain their qualification on self-contained breathing apparatus (SCBA), CPR and first aid. Requal training sessions are scheduled as determined by MM department requiremerts.

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Onaratino experiones faecenack (OEF) trainre la scheduled annually for all mechanics typically in quartirty l

l sessions. OEF sessions cover lessons learned from in-house and industry events as well as changes in plant l

equipment, procedures and industry requirements. OEF training may include content or activities from other the initial or advanced training curriculum.

l Sample Topics Since Previous Ronced l

The fotowing are examples of continuing training topics delivered each year since the previous accreditation i

renewal. Alljoumeymen mechanics participate in operating experience training. Designated mechanics particDete in advanced and requal traming The number of training hours conducted each year is indcated in parentheses.

[

1991 (144 hrs. - 132 Advanced; 4 Requal; 8 OEF) Pump alignment, turbine gantry crane, asbestos abatement, removal and instaustio' of the reactor coolant pump seal, reactor maintenance ovatview,'SCBA n

j and operating experience feseack.

1992 (179 hrs.- 163 Advanced; 16 OEF)) Mobile crane operation, forklift operation, polar crane memtenance, turbine gantry crane, Unit 2 reactor maintenance, asbestos abatement, basic valve maintenance and operating exponence festack.

1993 (82 hre. - 62 Advanced; 8 Requal; 12 OEF) Unit i reactor maintenance, asbestos abatement, SCBA and operating experience feedback. NOTE: The lower number of hours as compared to other years is due 3

to using MM training resources to provde 126 hours0.00146 days 0.035 hours 2.083333e-4 weeks 4.7943e-5 months of fundamentals training to utilityworkers during 1993.

1994 (178 hrs. - 158 Advanced; 6 Requal; 14 OEF)) Unit 2 reactor maintenance overview, emergency closure of containment penetrations, constant level oiler, hytorque, polar crane, turbine gantry crane, laser g'I I algnment, mobde crane operation, asbestos abatement, SCBA and operating experience feedback.

POSITIVE ASPECTS OF TRAINING 4

j Continuing training provdes lessons loamed from operating experience, contributes to plant and job performance improvements and makes efficient use of resources. For example, lessons leamed from a May 1993 in-house incident involving incorrect ;nstallation of the bearing housing reservoir oiler on the Unit 1B low pressure safety injection pump, were covered during continuing training and incorporated into the Mechanical Fundamentals module on Lubrication (#1301150). In 1994, lab training was provided to reinforce application of an infrequently

. used gasket compresson method for installing flanges,(#1408943) and feedback from 86 participants was strongly positive about the opportunity to practice this method. Post-training feedback from job incumbents and supervisors regardmg the effectiveness of laser algnment training (#1308645) has consistently indicated its value to improved personnel performance. Continuing training, provided prior to a Unit 2 outage, field tested and identified some deficiencies in a revised procedure on threading and unthreading reactor head studs, which were addressed before the procedure was implemented during the outage.

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MECHANICAL MAINTENANCE JOURNEYMEN Training and Qualification Sequence MAINTENANCE FUNDAMENTALS MECHANICAL FUNDAMENTALS SPECIAL FUNDAMENTALS ADVANCED TRAINING SRe introdxtion Blueprint Readng Rgyng Safety Valves Mamienance Facilities Start / Finish a Task Scaffolds Specialty Pumps Job Descriptions Lubrication Workingin Confined Spaces Forklift Record Management System Bearings Equipment Clearance Compressors Documents Records,Formsand Lapping and Bluing Reactor Maintenance Unit 1 Standards Fasteners Reactor Maintenance Unit 2 Procedures Couplings Polar Cranes Erpreiirg Drawings Pump Theory Mobile Crane Site and Plant layout Mechanical Seals Emergency dosure of Containtnent Lists, Tables and Vendor-Supplied Valve Fundamentals Penetration Documents Checking Out and Checking in M&TE Radwaste Faters Procurement of Replacement Parts Maintain Constant Level Oiler Turbine Gantry Cranes and Equipment Nuclear Power Production Overvew Lubrication and Repair of Personnel Work Request Airlock Transportation Equipment Valve Specialties Chemicals and Pressurized Gases RCP Seal Working Inm Heights Alignmen!

Protective Equipment Laser Argnment introduction to Industrial Safety Reactor Maintenance (General)

Safety Tagging Plant Systems Electrical Safety Controlof Heavy Loads and lifts Cassroom - 45 hours5.208333e-4 days 0.0125 hours 7.440476e-5 weeks 1.71225e-5 months Cassroom - 116 hours0.00134 days 0.0322 hours 1.917989e-4 weeks 4.4138e-5 months Cassroom - 41 hours4.74537e-4 days 0.0114 hours 6.779101e-5 weeks 1.56005e-5 months Cassroom - 309 hours0.00358 days 0.0858 hours 5.109127e-4 weeks 1.175745e-4 months Laboratory - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Laboratory - 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months Laboratory - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Laboratory - 52 hours6.018519e-4 days 0.0144 hours 8.597884e-5 weeks 1.9786e-5 months In-Plant

- 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in-Plant

- 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months MAINTENANCE SUPERVISOR TRAINING PROGRAM Proaram Descrintion l

PROGRAM FEATURES Job Positione/ Functions Maintenance supervisor training (MST) provides foremen and supervisors with the necessary managerial and administrative knowledge and skills required to supervise maintenance crews. Maintenance foremen and supervisors are responsible for the direct supervision of maintenance utilityworkers and joumeymen in the mechanical, electrical, and instrument and co1 trol maintenance departments.

Training Prorsquisites Maintenance management selects the supervisory personnel who are in the MST target population. ' This determination is based on each job position's accountabilities and qualification requirements, which are stated in 011-PR/PSL-3 Mairrenance Organization. For exarnple, production supervisors must have a minimum of four years of responsible power plant experience and special crew supervisors must have a high school diploma or equivalent and a minimum of four years of experieace in the crafts or disciplines they supervise. Other positions in the tiarget population must have similar qualifications at the time of appointment to the active positions. These requirements ensure the prerequisite technical expertise for maintenance supervisory job positions. There are no other prerequisite requirements for the MST program.

Program Basis The MST program is based on a job analysis of the foreman / supervisor's job performance requiremments. This job analysis was conducted prior to the issuance of ACAD 90-010 Guidelines for Maintenance Supervisor Selection and Development. When the guideline was issued, it was used to review the program design to ensure the training content correlated with academy recommendations. Plant personnel in key managerial and supervisory positions served as subject matter experts during the identification of specific content and development of the program. These subject matter experts assisted in the delivery of the first implementation of MST initial training in January 1990 to a class of inecumbent supervisors. Feedback from the incumbents was used to improve the depth of content and instructional design. Since then, five additional sessions of initial training have been implemented and the training has been maintained up-to-date with changing plant requirements and industry guidance. Administrative Procedure 0005821 Maintenance Supervisor Training specifies program guidance and requirernents for the initial and continuing training. The MST program consists of the following segments:

Initial Trainina Maintenance Supervisory Orientation interpersonal Managing Skills Observation Skills 1

s }

i Plant Communication Sidils Managing the Job

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Supervising the Job Safely Administrative Skills

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Job Familiarization Continuing Trainino Technical Refresher Training with joumeymen Administrative Training i

Management / Leadership Courses 1

Refer to the Training and Development Sequence chart at the end of this program description for each program segment's training settings, durations and content.

Program Details Duration

Initial training is 92 hours0.00106 days 0.0256 hours 1.521164e-4 weeks 3.5006e-5 months ; continuing training varies to meet plant and individual needs, and has averaged 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per year over the past four years.

l Trainino Methods Classroom presentations, dscussions, interactive and field exercises.

Testing Methods Written examinations.

f Emgram Evaluation: Feedback is soEcited from students, instructors, job incumbents and line management. The j

maintenance training group's instructional technologist conducts program data analysis and evaluations.

Management observation of training, monitoring of personnel and plant performance, and intemal and extemal l

evaluations also provide feedback to the program. Ongoing accreditation reviews involve evaluating the program against accreditation criteria and determining program results (see Strength at Objective 8). The Plant Training '

Advisory Board and maintenance training review committees provide oversight and monitor training effectiveness.

Instructors: The MST program is supported by one full-time instructor who coordinates the program and has instructional duties. Other maintenance instructors and guest instructors from the plant and corporate staff assist in delivery when available.

INITtAL TRAINI'NG Prograrn Objective The objective of the MST program is to help line supervisors develop the competencies necessary to effectively supervise bargaining unit personnel and to work effectively with personnel from other departments to meet nuclear objectives and requirements. The program includes positional roles and responsibilities, plant work processes, administrative requirements, basic supervisory skills, and job f arniliarization activities.

f Program Segments MST initial training consists of seven major segments of classroom training. Each segment includes one or more f

instructor-led lessons that are modular units providing flexibility in scheduling the training. Instead of the instructional units being scheduled for twelve consecutive days, for example, the units are scheduled based on plant schedules. Supervisors can retum to work in the plant between scheduled instructional units. This concept maximizes the supervisors' availability to the plant while they participate in the training program. Job familiarization activities are performed in the plant. The following is a brief desenption of each program segment.

Maintenance Suoerviserv Orientation provides 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of classroom instruction on the roles and responsibilities of the supervisor and management's expectations of supervisor performance.

Internersonal Mananino Skills provides 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of classroom instruction on clarifying and confinning, constructive criticism, managing differences, giving credit and discussion skills. Students participate in class discussions, individual exercises, video exercises, role plays and a case study. The session ends with a simulated department meeting providing the instructor the opportunity to evaluate students' use of the skills.

Observation Skills provides 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of classroom instruction and a field exercise. The four steps to observation are reviewed from the perspective of a plant supervisor. Students spend four hours in the plant practicing skills while observing a crew and then retum to the classroom to present and discuss their observatioons.

Plant Communication Skills provides 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of classroom instruction on communication principles and practices, and the essentials for conducting crew meetings, tailboards and shift tumovers. Students practice skills using plant work order packages.

Manacino the Job provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of classroom instruction on coordinating and scheduling work, getting the job ready, directing work activities in progress, and reviewing jobs upon completion. Students review administrative procedures and participate in exercises using work packages.

Suoervisino the Job Safelv provides 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of classroom instruction on the supervisor's responsibilities in implementing the industrial safety program. Students participate in exercises and discuss safety-related procedures, accident prevention methods, and accident investigation and reporting requirements.

Administrative Skills includes 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of classroom instruction that provides an overview ef regulatory documents and the plant configuration control process. Students become f amiliar with the regulatory bases for plant procedures and technical specifications, ano design control and engineering of plant changes / modifications.

Job Familiarization provides new supervisors opportunities to interact with other work groups to develop a better understanding of their functions and duties at the plant. Based on incividualleaming needs, new supervisors complete worksheets that state specific objectives, references and activities related to functional areas.. - - -

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l CONTINUING TRAINING Program Objective

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. The objective of conunuing trasrung for foremervsupervisors is to keep them abreast of technical change actions -

and operating exponence, and to further develop their adrmnistrative and management / leadership skills.

dl' Program Segments i

Maintenance foremen and supervisors receive three types of continuing training: technical refresher, administrative related, and management / leadership courses.

Technical training includes operating experience feedbadt (OEF) training, required requal training such as CPR, and advanced training topics. Foremervaupervisors attend this training with joumeymen in their department.

l OEF training varies in content and cluration for each maintenance group and foremervsupervisors typically attend classes with their crews. Technical refresher training for foremervsupervisors is based on departmental and

.l indwidual needs and is identified by their respective training review committee.

Administrahve trairung includes such topics as administrative procedure use, emergency preparedness, personnel requirements, and any Nuclear Division training for all plant supervision. Maintenance management, plant management, and division management identify specific administrative training for foremen / supervisors based on f

organizational and individual needs.

II j

Management / leadership training includes courses offered by the Corporate Education and Training (CET) department such as Dynamic Leadership skills, Effective Listening, Coaching in the Workplace, and Stress Management. Maintenance management designates specific courses for individual foremervsupervisors based on organizational and individual needs.

4 Sample Topics During Past Four Years The following are examples of continuing training topics attended by foremen / supervisors each year since 1991.

The hours indicated in parentheses represent the required OEF training. The MST instructor maintains a record i

of the technical, administrative and management / leadership oourses completed by each member of the target j.

population.

J 1991 OEF training with joumeymen (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ); Self-Contained Breathing Apparatus (SCBA) and CPR requal 1

l training: Documenting Discipline Training; Management Action Program (MAP) courses including MAP Leadership Skills and MAP-Leadership Principles i

1992 OEF training with joumeymen (16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ); SCBA and CPR requal training; Supervising the Job Safely:

Handling Employee Concems; Effective Listening and Effective Negotiating 1993 - OEF training with joumeymen (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ); SCBA; Partners in Performance and Managing Projects 1994 (53 hours6.134259e-4 days 0.0147 hours 8.763227e-5 weeks 2.01665e-5 months ) OEF trainig with joumeymen (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ); SCBA; Coaching in a Changing Workplace.

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PROGRAM IMPROVEMENTS SINCE INITIAL DEVELOPMENT j

Since the issuance of Revision 1 to ACAD 90-010 and using feedback obtained from students and during accreditation reviews, improvements have been made to update the training materials and modify the program design. Some of the improvements include: (a) administering pretests to determine the specific prograrn segments incumbent supervisors should attend, (b) delivering the lessons according to a flexible schedule over a several-week period instead of during two consecutive weeks, (c) adding the Supervising the Job Safety module l

to initial training which was originally delivered during continuing training, and (d) establishing a job fam:14anzation segment for tfw program, in addition, as instructors prepared materials for use during classes offered in 1994, they reviewed and modified leaming objectives when appropriate, enhanced lesson plans with any additional technical content required by the objectives, incorporated additional innovative instructional techniques to maintain student involvement, and reviewed and modifsd test llems too ensure ailleaming objectives are adequately measured. These l

improvements resulted in more up-to-date content and positive feedback from students as wel8 as management who observed training in-progress.

1 POSITIVE ASPECTS OF TRAINING j

The initial training for maintenance supervisors is effective in conveying and reinf orcing raanagement philosophy and expectations. Beginning with the orientation and throughout the instruction, foremerGupervisors are exposed to plant and industry goals, policies and requirements, and the supervisor's specific responsibilities associated with numerous plant procedures. Members of the management team visit each class expressing their expectations, encouraging teamwork and listening to the issues and concems of participants. An emphasis is placed on the interactive role of the supervisor that is delineated from the hands-on, technical nature of the joumeyman's job function. The training is implemented using a variety of instructional techniques to encourage student involvement in the leaming process. A mix of foremen and supervisors from all three maintenance

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departments have attended each class. This strategy provides students the opportunity to hear the concems of coworkers from other maintenance departments and to share techniques and build teamwork. Sturtents bring their experiences to the instructional environment, discussing the difficulty associated with working with people l

and taking back with them to the job environment a toolbox of techniques to improve their supervisory performance. Comments from students after retuming to the work environment indicate that they are applying the skills during interactions with peers within and among the various maintenance departments to manage conflict and solve problems. Continuing training is effective in keeping supervisors current with plant equipment and procedure changes as well as lessons leamed from operating experience. Having the opportunity to attend 4

' continuing training with joumeymen provides supervisors with current information for crews.

A MAINTENANCE SUPERVISOR Training and Development Sequence e

INITIAL TRANNG JOB FAIAUANZATION Mantenance Supervisory Onentation Industnal Safety interpersonalManagng Skm Ergneering Support Gmup Observason Skas Mainienance Managemet Plant Communcaten Skils Outage Management Managog the Job Plannog and Scheduling Supemsog the Job Safety Operatons Manager and Supervisors Adnnrestrative Sims i

5 Cassroom - 88 hours0.00102 days 0.0244 hours 1.455026e-4 weeks 3.3484e-5 months in-Plant

- variable hours in-Plant

- 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Skas Practce) e W

T

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CHEMISTRY TECHNICIAN TRAINING PROGRAM Proaram Deserlotion PROGRAM FEATURES Job Positions / Functions The chemistry technician (CT) training program develops the necessary skills and knowledge required to i

. tion as a technician in the plant chemistry department. The primary responsibilities of the chemistry technician are the quality control of water for the nuclear steam supply iystems, monitoring all water discharge from the plant for chemical content and detennining radioisotope concentrations in all liquids and gases released from the plant to prevent pollution of the envittnment. Additionally, technicians must be able to anticipate and prevent unusual incidents and respond approp stely if an event shouh occur.

Training Prerequisites The chemistry technician job qualEicatio,1 requirements are that an individual has three years of work experience in chemistry of which one may be iri a technical training program. These requirements are stated in 011-PR/PSL-2, Operations Organizationwhich are consistent with ANSI /ANS 3.1 1978. Students who enterthe CT training program have a high school or General Education Ocrelopment (GED) equivalency diploma, although j

most entry-level students have completed some post-secondny courses or have eamed an associate degree, and have related work experience. The CT program is des'.gned assuming no other prerequisite knowledge or skills than general secondary education. The point at which students enter the training program may be determined by past experience or education and individuals may be exempted from certain instructional units based on that experience / education.

Program Basis The CT training program is developed and maintained using a systematic approach to training (SAT) process that is cxmsistent with INPO 85-006, Princip* ; of Training System Development (TSD). The training program is based on a job and task analysis of the chemistry technician's job performance requirements. As job requirements change, the chemistry technician task list is updated. This ensures that the basis for the training program is consistent with the technician's job requirements and used to guide the design of training. The training program design meets the guidelines outlined in INPO 87-010 Guidelines for Training and Qualification of Chemistry Technicians. A task to-training cross-reference matrix is maintained up-to-date. St. Lucie Administrative Procedure 0005743 Chemistry Personnel Training Programis the site document specifying requirements for initial and continuing training and qualification of technicians.

j The CT program consists of the following segments:

InitialTrainina Orientation / Fundamentals 4

34

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Shift Position (Classroom 4 ab: OJT) _

I'*

Specific Areas of Responsibility,(Classroom; OJT)-

Cortmumo Trainem

( ' f Change actions and Operating Experience Refresher Training (infrequent, difficult or critical tasks) '

d 3.

Posten Hotation Requirements

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Outage-related Traming i

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Refer to the Traming and Qualification Sequence chart at the end of this program description for each prog segment's training seeings, durations and content.

i A

Program Detalla Duration

The intial traming is approximately 82 weeks. Continuing training varies each year to meet p and has averaged 82 hours9.490741e-4 days 0.0228 hours 1.35582e-4 weeks 3.1201e-5 months per year over the past tour years.

Classroom presentations, laboratory exercises, self study modules and texts, field l

Traininp Methods:

observations and on4he-job training.

Testmg Methods: Written exarmnatens and task performance evaluations.

Program Evaluahon Feedback is solicited from students, instructors, job incumbents and pla 16Giscal training group's instructional technologist conducts program data analysis and evaluatio accreditation reviews involve evaluating the program against accreditation criteria and determining program h,,

resuts (see Strength at Objective 8). The Plant Training Advisory Board and CT Training Review C l

provide oversight and monitor training effectiveness.

Instructors' The initial and continuing training programs are supported by one full-time instructor and one instructor who supports both chemistry and health physics training. The instructors are previousty qua chemistry technicians, maintain their technical expertise by supporting plant outages and other in i'

and have completed initial instructor training requirements and enhanced their educational backgro i

last accreditation renewal (see Strength at Objective 3).

I INITIAL TRAINING Program Objective The ob;ective of the CT initial training is to prepare individuals with the knowledge and skills to fulf lectucian's duties and responsibilities.

Program Segments Initial training consists of classroom, laboratory, self study and on the-job training (OJT) and qualification specific tasks. Classroom instruction provides the fundamentals that are prerequisite to more c y

. task pertonnance. Laboratory instruction is conducted in the chemistry training lab and plant labs an 09 D-

.?

y e

i provides hands on appiscation of fundamental principles and d6velopment of higher order skills. Self Gudy instruction is direded self-study with individual instructor assistance when necessary.

Students use two types of self-study materials including modules and texts. Self-study texts presern lessons on theoretical subjects. After completing texts, students are evaluated using a written examination. The modules present task-specific information that uses plant procedures to guide an individual through the task. Field observations, on-the-job practice and task performance evaluations (TPE) are completed as directed in the self-study modules. To complete a module, the student must successfully perform the specified task while being evaluated by a qualified OJT/TPE evaluator. Each self-study text takes about eight hours to complete and each self-study module takes about four hours, although the activities and time involved are subject to individual variations in self-paced leaming and evaluated task performance.

As the student completes initJ twining requirements, the student is certified competent to properfy pedorm -

specific responsbilities of a chemistry technician. A new student first completes shift position qualifications and then qualifies in each of the seven areas of responsibility (see description of each program segment below). The training department recornmends to the chemistry department that the student is qualified. The chemistry department head makes the final determination regarding qualification.

The initial training program provides for efficiency in completing training requirements and maximum contnbutson to productivity for the chemistry department. Other than the classroom instruction and training in the Nudear Training Center lab, the student completes initial training requirements almost entirely while working in the plant.

The candidate achieves techmcian qualification through the macar/ of specified skills and knowledge and demonstrated task performance while functioning in the chemistry department. This approach to chemistry training and qualification was recognized as a positive aspect during previous accreditation team visits.

The QdgDiation/ Fundamentals segment consists of classroom instruction and associated study time on the organization, duties and functions of the plant chemistry department, and important theoretical areas and specific equipment topics related to the nuclear industry (Science and Fundamentals of Engineering).

The Shift Position - Classroom / Lab segment consists of classroom instruction and hands on lab exercises that cover topics including first aid and personnel decontamination team, ion chromatography, and multi-channel analyzer / gamma spectroscopy.

The Shift Position - OJT segment consists of observed field activities, modular training, and quallfication on selected tasks in the seven areas of responsibility within the chemistry department. The seven duty areas include counting room, environmental, secondary chemistry, primary chemistry, radiation monitors, effluent release accounting, and effluert release compliance. During this segment, the student rotates for approximately two weeks among each duty area, developing performance-related skills while working in the chemistry department.

During this period, a qualified technician orients the student to the routines of each area. The student observes a 36-

t i

chemistry todmician portorming specific tasks and practices tasks under the direct supervisisn of a qualified technician. Designated OJT instructors / evaluators conduct formal on-the-job training and task performance evaluations to qualify students on the selected tasks in each duty area. When the student completes training and evaluation requirements, the chemistry department head decides if the student is qualified te work independently.

l 4

The Snacile Areas of Resnonsbikv - Classroom segmert consists of classroom instruction designed to support a theoretical understanding of au taska in the program. This classroom instructen develops an understandmg of the relationship of the systems affected by the tasks in each area.

The Snecife Arpas of Roanonshinty - OJT segmert consists of self-study instruction and on-the-job trainng, evaluation and quatlication on the remaining tasks in each area of responsibility within the chemistry department.

After qualification in the first duty area, and while workmg as a qualified tedinid.n in that area, the student teams

^

and quatlies on tasks in other areas. When all the required tasks are loamed and evaluated in a duty area, the technician then becomes quaNiiod to work independently in that area. The student is expected, over a 12 to i

.15-month period, to qualify in an areas of responsibility.

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CONTINUING TRAINING i-l Program Objecthre f

The objective of CT continu'ing training is to assure personnel maintain the level of knowledge and skills required y, i

j to accomplish routine and emergency duties. All chemistry technicians attend continuing training. Chemistry department supervision may attend continuing training on selected topics.

Content Selection / Approval Continuing training topics are determined jointly by the chemistry and training departments and are selected from 2

l the standard sources (see " Continuing Training Contert* at Objective 1). Selected initial training materials are included periodically in continuing training. These materials include refresher training on tasks that are either infrequently performed, difficut or criticalin nature. Additional training is provided in response to special situations or outage-related needs at the request of piart supervision or technician feedback. As technicians i

rotate to a differert area of responsibility, they complete position rotation requirements to ensure their knowledge and skins are up-to-date. The CT Training Review Commitee (TRC) approves continuing training topics.

Sample Topics Since Previous Renewal The following are examples of the topics covered during continuing training each year since the previous accreditation renewal. The number of training curriculum hours conducted each year is indicated in parentheses.

1991 (138 hrs.) Dionex operation and maintenance; biennial modules including effluent samping, liquid l

and gaseous releases, technical specifications, water treatment plant, analysis of isotopic activity, PASS, I

accdont chemistry, atomic absorption, dose calculations, gas analysis, and ion chromotography, h,

1992 (48 hrs.) - lon chroinir.cy.puy integrator operation, bloodbome pathogens, environmental issues,

.17.

chemistry refueling activities, industry events, cnd SCBA.

l 1993 (100 hrs.) - Industry events, first aid and personnel decontamination team, hazardous communication, lab hygiene, SCBA, multimedia first aid, human performance evaluation system /self checking, environmental comprehensive quality assurance, Chemistry Data Management System, gas chromatography, atomic absorption spectrophotometer, and position rotation checksheets.

1994 (42 hrs.) - Multi-channel analyzer / gamma spectroscopy, plant systems, fundamentals re new, industry events, emergency preparedness, environmental issues,' instrument theory and troubleshoo%1g.

NOTE: The variance in hours every other year is due to the additional refresher training modules on infrequently performed, difficult or critical tasks that incumbents complete on a biennial basis.

j SIGNIFICANT CHANGES SINCE PREVIOUS RENEWAL l

Since the last renewal, the program has been maintained current with the changes that affect the cherrustry

)

techtweian's performance requirements including new/ revised plant procedures and equipment, and in-house and industry operating experience. The two major changes involve additional lab training and modified position rotation requirements.

Additional I nh instruction By 1991, a fully functional chemistry laboratory was added to the training center. It is i

fumished with much of the same equipment and resources that are in the plant laboratory. The chemistry training lab provides for hands-on training on instrument operation, tear down, and maintenance procedures. Since the previous accreditation renewal, several self-study modules included in the initial training were converted into laboratory instruction. In 1991, a lab course on the operation and maintenance of ion chromatography equipment was developed and implemented as part of continuing training. Its success led to its implementation in the initial program replacing self study rnodules. This course is designed to provide advanced instruction on the setup, operation and maintenance of the Dionex lon chrornatography systems currently used by the chemistry department. In 1992, a course on the multi-channel analyzer for gamma spectroscopy was developed replacing the self-study approach with theory and hands-on lab training. Student feedback has been positive.

Position Rotation Reauirements To better meet the continuing training needs of the chemistry department, a change was made to the position rotation requirements in the second quarter of 1992. Rather than requiring technicians to requalify on selected tasks in their new area of responsibility, position rotation checksheets were designed for each duty area and are used to assess individual training needs. Upon rotation, chemistry group supervisors complete a checksheet for each technician. Prior to rotation into a duty area, the responsible group

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supervisor conducts a walk-through arxi'or discussion with the technician that covers, at a minimum, the topics listed on the checksheet. The supervisor sign-off on each item is designed to verify knowledge and skills required to rotate in the area. Major emphasis is placed on changes since the last rotation. In addition to the topics listed on the checksheet, the supervisor may include other requirements such as reading specified plant documents or completing self study modules. If the supervisor determines that an individual can not be signed-off on a 38

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particular item, refresher training es provided prior to the individual rotating in the position. This change has provided for more flexbility in the program and has enhanced the effectiveness of continuing training.

i ONGOtNG leMBOVEMENTS When the self study modules were initially developed for initial training, each contained detailed procedural instructions that duplicated the plant chemistry procedures. As plant procedures are revised, the trasrung modules are updated. To make the maintenance of training materials more efficient, an improvement effort was initiated in 1992. As each module is updated, binywnd information is improved to provide more in-depth information about the task including why it is performed and why it is important. Instructions for task practice are also being improved ' Task practee utilizes plant procedures as instructed in the modules. Chemistry department personnel

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find these improved modules more user-friendly and more effective in training new technicians. During the first

- quarter of 1992, an additional instructor, with shared responsbilities for chemsstry and health physcs training, was j

4 added to the technical training staff to assist with the timely incorporation of new and revised procedures, equipment and methods and with making improvements to self-study modules or converting them to lab instruction, This effort is not a project but is a standard ongoing practice to continuously improve chemistry training materials.

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i POSITIVE ASPECTS OF TRAINING s

Continuing training reinforces management philosophy and expectations and promotes nucletr professionalism and safety. For example, in 1993 when the plant initiated a self-checking program, all technicians were criented i

to the principles and practices of Stop-Think-Operate Prove (STOP) during their continuing training. Operating experience and changing industry requirements are reviewed during continuing training to maintain and enhance chemistry technician job performance. For example, in 1993, instruction on environmental comprehensive quality assurance was provided based on new regulatory requirements. Providing timely continuing training that is responsive to changing plant and industry requirements ensures that all chemistry technicians at St. Lucie are up-to-date and able to perform chemistry functions that ensure safe and reliable plant operation. Continuing training is effective in challenging techncians to anticipate and prevent unusual incidents and ensures they i

maintain a high level of knowledge and skills to respond appropriately if an event should occur.

T instructors use innovative techniques to enhance the quality of chemistry training. For example, a link over the wide-area network (WAN) computer system was established with the chemistry department's Lab Information Management System (LIMS). Instructors access the system to retrieve real-time chemistry analysis results and trends and use the data to support material development and classroom instruction. Using actual data enhances the instructor's ability to develop relevant and timely training material that strengthens the teaming process. The WAN has also provided the opportunity for chernistry instructors to share training materials with their counterparts 4

at FPL's Turkey Point Nuclear Training Center. This sharing has provided for more efficient use

. timely developmert and updating of training materials.

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a

1 CHEMISTRY TECHNICIAN Training ano Qualification Sequence ORIENTAT10MUIDAtefTALS Orgarnaton Gemetry Technaan Dunes Ocamuncanons Pressunzed Water Reeca Ovennow Matemenes Cassical Physics Heat Transler. Fbid Fbw. and b. 4._ a Edoar Physa Chemstry Matenal Science cassroom - 600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months

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SHIFT POSITION CLASSRO0t% LAB SHFT POSITION.OJT Fest kd and Personnel Decontarmnation Team Coun!m0 oom R

Mult Channel AnalyreriGamma Spectoscopy Ermonmental bn Chromatography Secondary Chenustry Primary Chomsty Radanon Monsors E%entRelease Accountng Efluent Release Comphance Cassroom - 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Set Study 4n-Plant - 560 hours0.00648 days 0.156 hours 9.259259e-4 weeks 2.1308e-4 months laborawy - 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months

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SPECIFIC AREAS OF RESPONS191UTY CLASSROOM SPECIFIC AREAS OF RESPONS181UTY-OJT Secondary Chemstry and Chemsty Cormal Reagent Preparation Pnmary Chemsty and Chermstry Contol Standants Preparation hierpretog AnaW Resuhs Chemstry and Radochemstry Analyses the t and 2 Radiaton Monstonng Samping Procedures hierprehng Techmcal Smb.IODCM Water Treatnent Systsat OilSite Dose Calculations Gemistry Cakulatons Efeuent Release Contal Report N..

. c.ts Acadent Gemisty Consideranons Cassroom

- 56 hours6.481481e-4 days 0.0156 hours 9.259259e-5 weeks 2.1308e-5 months Soll StudyhPlant - 1215 montis u.

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HEALTH PHYSICS (Radiological Protection) TECHNICIAN TRAINING PROGRAM Procram Description 9

PROGRAM FEATURES Job Positions / Functions The health physics (HP) training program is provided for radiological protection technicians who function in two distinct job positions in the health physics department. HP training is provided for the radiation protection man (RPM) and the health physics dosimetry technician (HPDT).

The primary respcasLilities of the RPM include evaluation and documentation of radiological conditions in the nuclear plant and the irnplementation of the necessary radiological control measures as they apply to nuclear plant workers and members of the general public.

The primary responsibilities of the HPDT include maintaining the thermoluminescent dosimeter (TLD) system, issuing and handling of TLD's, maintaining all radiation exposure rer.nrds as required by regulations and procedures, respirator fits, and operating the whole body counter. Currently all four HPDT's are qualified, thus no initial training is currently in progress.

Training Prerequisites RPM job qualifications in Oli PR/PSL-2, Operations Organization state that RPM's meet ANSI /ANS 3.1 1978 requirements which are three years of working experience in health physics of which one year should be related technical training. Students who enter the RPM training program meet the position qualification requirements upon hiring or qua'ify upon completion of the training program. Entry-level students also must pass FPL's RPM j

screening exam that includes components on adaptability, mechanical comprehension, numeric ability, and a personality inventory. This requirement ensures students have the prerequisite knowledge and abilities necessary to begin initial training.

Students who enter the HPDT training program have completed the routine screening requirements assoc' lated with the hiring of general employees. While dosimetry technicians possess a high school diploma or recognized J

equivalent, there are no other prerequisites for the training program nor are there any ANSI /ANS requirements for this position.

Program Basis The HP training program is developed and maintained using a systematic approach to training (SAT) process that is consistent with INPO B5-006, Principles of Training System Development (TSD). HP training is based on a job and task analysis of the RPM and HPDT jobs conducted to identify performance requirements that are used to design the training program. Task lists are up-dated as job requirements change and are revalidated periodically,

.r-G ensure the program basis O maintained current with plant ch r,v.s. Task analysis defines the knowledge and

- skEs and specific task performance requirements that are used to design and develop training. A task-to training cross-reference matrix is maintained up-to-date. The recommendations outlined in ACAD 93-008 Guidelines for i

. Tran p and QuailAlcation of Radoiopical Protection Technicians are also considered when designing training.

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h' St. Lucio Admirustrative Procedure 0006737 Health Physics Department Training Program is the site document

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i specifying requirements for initial and continuing training and quaillication of technicians. The program'is.

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structured to provide training in the following areas:

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RPM initialTraining Systems and Theory Training On-the-job Trainmg and Performance Testing d

i Continuing Traininn i

W events, plant / industry changes, plant department requests 1

HPDT InitialTraming Specific Duty AreaTraining Cluster 1: Dosimetry

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Cluster 2: Records Cluster 3: Bioassay l

l Contmuing Tramina in-house / industry events, plant / industry changes, plant department requests I

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Refer to the Trainng and Qualification Sequence charts at the end of this program description for each program l

segment's training settings, durations and content.

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Program Detalle..

Duration initial training for RPM's is 1186 hours0.0137 days 0.329 hours 0.00196 weeks 4.51273e-4 months and for HPDTs is 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months .

4 f

Continuing training for both positions varies to meet plant needs and over the past four years has averaged 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months per yeaf for RPM's and 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months per year for HPDT's.

l Class Size: RPM initial-1 to 2 students: HPDT inilla! usually 1 student.

RPM continuing 2 to 8 students: HPDT continuing - 2 to 4 students.

l Training Methods: Classroom presentations, discussions and interactive exercises, lab exercises, directed

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i self-study and on-the-job training (see Strength at Objective 5).

Testino Methods: Wrtten examinations, task performance evaluations.

I Proaram Evaluahon Feedback is solicited from students, instructors Job incumbents and plant supervisors The technscal training group's instructional technologist conducts periodic observations and program evaluations.

j Ongoing accreditation reviews involve evaluating the program against accreditation criteria and determinmg

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program results (see Strength at Objective 8). The Plant Training Advisory Board and HP Training Review f

Commillee provide oversight and monitor training effectiveness.

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Instructorr The training programs cre supported by one full-time instructor and one instructor who supports both HP and chemistry training. Instructors are responsible for developing and maintaining the program and materials, coordsnating and delivering training and performing administrative responsibilities. The instructional staff is highly

~

qualified and have enhanced their technical experience and educational background since the previous accreditation renewal (see Strength at Objective 3).

Intial and continuing orethe-job training (OJT) and task performance evaluation (TPE) are shared responsibilities between the health physics and training departments. Training personnel develop and maintain OJT/TPE

)

materials and observe and evaluate OJT/TPE activities and personnel. Health physics personnel conduct OJT/TPE, evaluate and qualify student performance, and monitor the effectiveness of OJr/TPE activities and results. Currently (as of 12/1/94) there are 16 HP department personnel who are certified to conduct OJT/TPE.

INITIAL TRAINING Program Objective The objective of HP initial training is to prepare technicians with the knowledge and skills required to perform independently their assigned duties in a safe, reliable and efficient manner. HP training is structured to meet students' needs and is designed to meet industry and regulatory requirements.

j Program Segments RPM initial Trainina includes two program segments that provide approximately 16 weeks of science and

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fundamentals instruction and evaluation followed by on-the-job training and performance testing that takes place over a period of approximately two years while working in the plant HP department.

The Systems and Theorv segment consists of classroom instruc* ion and associated study time that covers important theoretical areas and specific equipment topics related to the nuciear industry. The curriculum is adapted from the Science And Fundamental Engineering (SAFE) orogram and contains eleven general courses comprising fifty-nine lessons. Classroom instruction also mludes a sixteen hour course on the radiation monitoring system.

The On-the-Job Trainina and Performance Testino segment consists of individualized and modular instruction and evaluation. OJT is conducted.in conjunction with regu arly scheduled plant activities. The program is a joint responsibility of the health physics and training depa tments. Qualified OJT instructor / evaluators within the health physics department conduct most of the OJT/TPE. The training department provides support for the OJT/TPE process and is responsibl( for record keeping and program trad(ing.

HPDT /nifiat Trainina consists of self. study and on-the-job training and task qualif. tation. Specific duty area

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training is organized into three segmerrts or clusters, namely dosimetry, records, ai d bioassay. The student continues through the program completing qualification for all the requisite tasks whiO functioning in the health 43

..j physics department. As cach task performance evalution b successfully completed, the t;chncian b qualified t3 perform that task independently, All evaluations are conducted by qualified OJT evaluators. The student is expected to become a fully qualified HPDT within a 52 week period.

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i The Snacific Duty Area Cluster 1 - Dosimetry segment develops the knowledge and skills required to perform tasks related to the implementation and maintenance of the thermoluminescent dosimeter (TLD) program

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and the maintenance of plant exposure records.

4 The Snacife Duty Area Qiuster 2 - Records segment develops the knowledge and skills required to perform i

I exposure history tasks.

t The Snacife Duty Area Cluster 3 - Brassav segment develops the knowledge and skills required to perform i

whole body counting, resperator fit testing, and evaluation of intemal contamination.

1 3

4 CONTINUING TRAINING Program Ot$ective The ot$ective of continusng training is to assure HP technicians maintain the high level of knowledge and sid8s required to pe 1orm routine and emergency duties. The amount of continuing training varies each year to meet l

plant needs. All RPM's and HPDT's attend continuing training. Their job supervisors are invited to attend continuing training sessions.

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Sample Topics Since Previous Renewal The following reflects examples of the topics covered during continuing training since the previous accreditation renewal. The number of training curriculum hours conducted each year is indicated in parentheses.

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RPM Contmuing Traming i

1991 (44 hrs.) - Emergency planning, SCBA, pre-outage topics, and multi-channel analyzer.

1992 (38 hrs.) Intemal dosimetry, Panasonic TLD (theory and dose algorithms), Merlin Gerin dosimeter l

(teledose and air samplers), neutron dosimetry and multi-badging, hazardous materials, emergency planning, and REMACS computer system.

i 1993 (19 hrs.) Emergency planning, HP medical emergencies,10 CFR Part 20 procedure changes and related industry events, SCBA, TeleMerlin, and airbome radioactivity (10 CFR Part 20).

1994 (44 hrs.) - Emergency plan, process monitors, procedure changes and related industry events.

i HPDTContinuina Trainire 1991 (28 hrs.) - REMACS computer system, fastscan, in-house and industry operating experience.

j 1992 (12 hrs.) -TLD and body count.

1993 (6 hrs.) - TEDE-ALARA and procedur'e changes.

l 1994 (8 hrs.) - Portacount and body counter result conversion.

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SIGNIFICANT CHANGES SINCE PREVIOUS RENEWAL Since the last renewal, the program has been maintained current with the changes that affect HP performance requirements including regulatory changes, new and revised procedures, and new equipment and techniques.

For example, in 1993 when 10 CFR Part 20 had changed, the new requirements were analyzed, continuing trainirg was developed and implemented for RPM's and the changes are being incorporated into the initial training materials prior to them beirq used. Some of the new equipment installed iri the hN!th physics department include the Telemerlin obtained in 1993 and used by the RPM's, and the new body counter and portacount respirator fRsting equipment obtained in 1994 and used by the HPDT's. Associated tasks were identified and analyzed, and training was developed and implemented for the technicians.

POSITIVE ASPECTS OF TRAINING Health Physics management is actively involved in the training program to ensure it meets department needs and maintains effectiveness. The HP operations supervisor conducts an oral board with each RPM candidate after all initial training requirements are completed and before qualifying the technician. Job supervisors typically attend continuing training with technicians who have indicated that the supervisors often discuss the content covered in the training classes with the technicians when back at the job site. Supervisors obtain feedback from students about training classes and take this feedback to the TRC meeting to assist in decision-making regarding the training design and schedule. Selected RPM's are invited to attend TRC meetings.

During 1991 through 1993, HP training staff facilitated preparation and testing activities for the National Registry of Radiation Protection Technologists (NRRPT) certification exam. The staff purchased study material, organized study curriculum, f acilitated study sessions, tutored, arranged and paid for exam administration, and performed all

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associated administrative services including bulletins, updates, reminders and motivation strategies. Ten RPM's, seven supervisors and one instructor passed the exam and received certification. These efforts benefited participants by building individual confidence, team skills and professionalism while enhancing their fundamental knowledge of the science and technology of radiation protection. Participants also benefited their personal education by receivmg up to 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months of equivalent academic credits through the American Council on Education's (ACE) Program On Non-collegiate Sponsored instruction (PONSI).

l I -

RADIATION PROTECTION MAN Training and Qualification Sequence SYSTEMS AND THEORY ON-THE JOB TRA# wig Ape EVALUATION Communcation Surveys Pressunzed Water Reactor Ovennew Count Room Mathematics Respiratory Protection CassicalPhysics Decontanwnation hs.udr air,s, Heat Transfer, Fluid Flow Radiological Protecton r

Nuclear Physics Emergency G5puiE:%s Radallon Protection Handling Radoactive Material Chemistry kistrument Calibragon MaterialSoence Respirator Repair Elecincal Soence Print Reading Radation Monitoring System Qassroom - 656 hours0.00759 days 0.182 hours 0.00108 weeks 2.49608e-4 months Sell-Study /in-plant - 530 hours0.00613 days 0.147 hours 8.763227e-4 weeks 2.01665e-4 months t

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s Ti L--------- --- ---------

I HEALTH PHYSICS DOSIMETRY TECHNICIAN Training and Qualification Sequence SPECIFIC DUTY AREA CLUSTER 1 Thermoluminescent Dosimetry Issuance Maintenance Reporting Multi-badging Self-Study /hPlant - 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months s /

SPECIFIC DUTY AREA CLUSTER 2 Records Individual Records Daily Exposure Summaries NRC Forms Terminations Self-Study /hPlant - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months v

SPECIFIC DUTY AREA CLUSTER 3 Bioassay Whole Body Counting Respiraw Fitting Self-Study /In-Plant.12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

l ENGINEERING SUPPORT PERSONNEt. TRAINING PROGRAM l

j Proaram Description i

PROGRAM FEATURES Job Positions / Functions l

The engineering support personnel (ESP) training program consists of instruction designed to provide l

fundamental knowledge and skills in plant operations and nuclear power plant technology for personnel who function as supervisors, engineers or technicians in departments that provide technical support to the plant. The objective of the program is to improve the trainees' job performance by developing a. broader understanding of their important role in the safe and reliable operation of the plant.

i The ESP program provides training for numerous departments that are directly and indirectly involved in plant operations and maintenance. The target population is composed of job positions from the following dapartments.

Techrucal Staff (System Engineer, Test and Code Engineer, HPES Coordinator)

Reactor Engineering (Reactor Engineer)

Site Engineering (Station Modification Engineer, Procurement Engineer)

Failure Analysis (Technician)

Nuclear Assurance /OA (OA Engineer, OA Analyst)

Health Physics (Supervisors)

Predictive Maintenance (Engineer, Supervisor)

Electrical Maintenance (Supervisor, Technical Support Engineer, Planner)

Mechanical Maintenance (Engineer, Analyst)

Instrument and Control M intenance (Supervisors Engineers)

Training Prerequisites The manager of each department determines who will be in the ESP target population based on the guidance provided in ACAD 91-017 Guideline for Training and Qualification of Engineering Support Personnel. This determination is based on each job position and associated acccuntabilities that affect unit reliability and safe operation of the plant. In addition, each job position has a list of qualifications necessary to fulfill that position.

Some job incumbents have an associate or bachelor's degree in engineering, science or a related technical field, or equivalent work experience. Using this target population selection process ensures students have the prerequisite knowledge and skills necessary to begin the ESP training program.

Program Basis The ESP initial training program was first offered in February 1993, replacing the original manager / technical staff (MTS) training program. Curriculum for the ESP program consists of segments from the MTS program as well as additional segments developed to meet the guidelines outlined in ACAD 91017. St. Lucie Plant Administrative 48 -

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4,.

P Procedure 0005749 Engineer /np Support Personnel Training provides specific guidance and requirements for the training and queulication of targeted personnel. The ESP program consists of the following segments:

.3 f. 3, l

InitialTraining 4

'( !

'Orleidation Training Pooltion-SpecNic QualNication -

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l Continuing Training trFhouse and industry events, plant and industry changes, plant department requests b

Refer to the Training and Quaufication Sequence chart at the end of this program description for details regarding each program segments traming settings, durations and content.

Program Details Aggklo Initial orientation training is four weeks and position-specific requirernents are completed within two

> years Of job assignment. Continuing training varies to meet plant needs and has averaged 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per year over the past four years.

Class Sira: Typicauy 16 students.

Trainmp Methods

Classroom lebres, discussions and exercises using accelerated leaming techniques when I

applicable and the plant-referenced simulator.

l Testina Methods: Written examinations (a score of 280% on each exam is required), qualification guides.

f)l Proaratn Evaluation Feedback is solicited from students, instructors, job incumbents and plant supervisors. The technical training group's instructional technologist periodically conducts observations and program evaluations.

On going accreditation reviews involve evaluating the program against accreditation criteria and determining i -

training program results (see Strength at Objective 8). The Plant Training Advisory Board and ESP Training j

Review Ccmmittee provide oversight and monitor training effectiveness.

Instructors

One full-time training departrnent instructor is responsbie for developing and maintaining the program and materials, coordinating implementation, delivering instruction and performing associated adrmnistrative duties. Instructors from the operatior's and maintenance training groups and guest instructors from plant engineering, technical staff and other plant departments and division staff groups are used when the subject

. matter expertise is available. Instructional staff is highly qualified (see Strength at Objective 3).

. INITIAL TRAINING Program Objective The objective of ESP !nitial training is to provide a foundation of knowledge' and skills necessary to prepare an individual for assignment to a broad range of duties and responsibilities. The program is structured to meet student needs and is designed to meet industry requirements.

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Pfo9 tam Segments I

driantanon Traininp is intended for newly hired individuals and is applicable to all engheering support personnel.

It is designed to develop a broad understardeng of nuclear technology and to instill a c'ommitment to safety and professionalism in new personnel. The training department has responsibility for managing this program component. Usually, the orientation training is conducted two or three times each year. The following is an I

overview of each rnejor segment of orientation training.

h The indocinnation segment is designed to provide the student with a basic understanding of the plant -

organization,VC"--+W,eGal functions and responsbihties, plant layout and an iraroducten to plant p

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The administrative segment is designed to provde the student with a basic understanding of piart policies and procedures, regulatory guidelines, configuration management and engmeering drawings.

The fundamentals segment is designed to provide the student with an understanding of basic atomic and

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nucisar physics, electrical science, heat transfer and fluid flow, chemistry, process control theory, material science and core protection. Most of the fundamentais training is incorporated into the plant systems and components training and is addressed under the applicable topical areas.

b The niant systems and components segment is designed to provide the student with a basic understandog of plant systems includin0 their design basis, functions and operation.

The ittegrated plant opershons segment is designed to provide the studert with a basic understandmg of systems relationships, plant operational transients, accident sequences, startup procedures, shutdown procedures, refueling procedures, emergency plans and plant characteristics and controls. The plant-referenced simulator is used during this segment when available.

Pos# tion-Socc#c Qual #icaten includes review and evaluation of those engineering support activities that could have a significant effect on safe and reliable plant operation. Each department with job positions identified in the ESP target population has estabhshed and maintains a qualification guide for their personnel that identifies commonly performed activities for evaluation and qualification. Departments have addressed the development and administration of required position-specific qualification guides in their plant administrative procedures. Most i '

of the qualification guides include a combination of required reading and tasks performed on the job. Upon 1 -

completion, the qualification guide is forwarded to the training department for placement in the individual's training

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file. Each department is also responsible for providing a periodic update of the student's progress to the technical training supervisor.

j CONTINUING TRAINING -

Program Objective The objective of continuing training is to ensure engineering support personnel maintain and improve their

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techmcal and admmistrative knowledge and skills. Continuing training is provided annually, typically two or three times throughout the year.

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i Sample Topics Since Previous Renewal

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l Continuing training topics are determined by a training review cornmittee (TRC) composed of representatives 9

from each department in the ESP target population and the training department. Topics are selected from the i

j standard sources (see " Continuing Training Content" at Objective 1) as well as from corporate training programs and specific trarung and development activities (technical or managerial) within the individual target population j

departments. The following reflects examples of the topics covered during continuing training provided by the St.

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Lucie training department since the previous accreditation renewal. The number of training curriculum hours conducted each year is indicated in parentheses (Nete: MTS stands for manager / technical staff.)

1991 (MTS - 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months ) - St. Lucie Plant operating plan, problem investigation and correction (PIC), changes l

to administrative procedures and quality instructions, and in-house and industry events (LER's, SER's, l

SOER's).

I s

1992 (MTS 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) Outage management, health physics, reactor engineering, hur tn relations, and industry events.

j 1993 (ESP - 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) - Self-verification,10 CFR 20 changes, industry events and operating experience, plant j

changes / modifications, and revised procedures and policies.

1994 (ESP - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) - SER 93-28 and 93-30 on-line leak sealing operations, SER 93-26 main turbine damage, SOER 94-1 nonconservative decisions and equipment performance problems, IN 93 72 i

j observations from recent shutdown risk and outage management pilot team inspections, and SOER 93-1 j

steam generator tube rupture events.

Student knowledge and skills are evaluated during each continuing training session using several different j

methodt including case studies. During case studies, participants are organized into small groups and expected to make 'a formal presentation to the class on assigned topics. For example, one case study analyzed the steam generator tube rupture event related to SOER 931, Student participation in these exercises has been very good and the effectiveness of the training has been evident.

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SIGNIFICANT CHANGES SINCE PREVIOUS RENEWAL.

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The manager / technical staff training program was initially accredited in 1987 and was renewed in 1991. In response to the issuance of ACAD 91-017 in January of 1992, design and development activities for the ESP l

training program began in February. Departments with job positions within the target population were identified through surveys ccreeming their activities and those specified in the ACAD guideline. Management from these i

departments participated in identifying their targeted personnel, reviewing the training department's efforts in developing the initial orientation program, and developing their initial position-specific qualification requirements.

The first initial orientation training class was delivered to sixteen participants on February 16,1993. Feedback j

l from this first trainirs effort was very favorable overall with a few suggestions regarding minor curriculum changes to the program. Since.then, orientation training has been offered to maximum size classes four more times as of f

the first quarter of 1995.

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POSITIVE ASPECTS OF TRAINING Accelerated leaming techniques have been incorporated into the program delivery making the training more effective and interesting, innovative activities that encourage student participation and enhance the leaming process are used in several lessons including Plant Organization Plant Electrical, CVCS, Main Steam, Condensate and Feedwater, Heater Vents and Drains and integrated Plant Operations (see Strength at Objective 5 for examples). During the simulator demonstration, some scenarios and hands-on activities include reactor startup to criticality, criticality to point of adding heat, placing the turt)ine generator on line, power ascension, and reactor coolant system leakage, downpower, trip and loss of coolant accident (see Objective 7).

I Post-training feedback from students has been very positive reflecting comments about the value of the training.

In particular, students discussed the value of leaming from the difficulties of others and how others in the industry deal with the same issues being addressed at St. Lucie. One student who works very closey with instruments in the reactor vesselintemais, said he feels strongly that the training has helped him considerably with that aspect of the plant. Another student said he could take off his " blinders" since attending ESP training. He noted it.at in the l

past he had usually ignored anything upstream and downstream of his job, but concentrated on his one specific area of responsibly, but the training has enabled him to focus on the big pictu're. Another student noted that as a result of the training he understands more how the plant operates, how the systems, both safety and non-safety j

systems, work together, and the non-safety systems that are still critical to keeping the plant on-line. Another positive indication of the quality of the training is that supervision and personnel who are outside the target population are requesting to attend the ESP training.

ENGINEERING SUPPORT PERSONNEL

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Training and Qualification Sequence ORIENTATION TRANNG POSm0N SPECIFIC QUAURCATION Indoc!maton Qualificaton Guides are completed as specilled in Admnsirative departmental admhistrafrve procedures:

Fundamenla!s Plant Systems and Components *

- Reactor Enyneering Integrated Plant Operations"

- TechnicalStaff

- Ole Engineenng y

- Failure Analysis t

- Nudear Assurance

- HeaMh Physes

- Predictrve Maintenance

- ElectncalMamienance

- MechancalMantenance

- hstrument & Control Montenance Classroom - 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months h-Plant

- vanable hours includes in-plant wakdowns

" indudes simulator exercises L

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o ORGANIZATION AND MANAGEMENT OF TRAINING OBJECTIVE 2: Utility management effectively directs and adequately supports plant training activities.

SUMMARY

FPL nuclear management is committed to supporting and ensuring all plant training and qualification programs result in highly competent personnel to operate and maintain its power plants safely, reliably and in a professional and cost-effective manner (see Attachment 1 for organization charts). The plant training department implements and maintains training programs on an ongoing basis in direct support of the plant and corporate business plans. Plant management and line supervision provide active direction and support of training activibes Plant staff, procedures and processes are in place to ensure adequate communication and feedback.

Plant and training personnelinterf ace regularly to provide direction and make decisions regarding the accredited training prograrns. The Plant Training Advisory Board (PTAB) consists of plant and training management and conducts regular meetings, usually quarterfy, to discuss site training issues. Training reviewpmmittees (TRC) provide line and training supervision with periodic opportunities to identify, discuss and reso ve issues that affed the conduct of training programs.

Training activities are developed, conducted, evaluated and maintained using a five-phase systematic process.

Administrative Procedures (APls) and Quality Instructions (Ol's) are employed as plant-wide and departmental procedures and policies which delineate various aspects of the plant's systematic approach to training (SAT) (see for list of policies and procedures). The current training organization and budget are adequate to meet plant training needs. The Nuclear Training Center (NTC) has adequate classroom and laboratory facilities to support accredited training programs. Training records are processed and maintained according to plant procedures.

Changes Since, Previous Accreditation Renewal Manacement Orcanization Chances - Since the last accreditation renewal in 1991, changes in management have been made at the corporate, plant and department levels to improve organizational efficiency. The site training manager now reports to the site services manager rather than the plant general manager. Personnel in the positions of plant general rnanager, site services manager, maintenance manager, and the l&C, EM and MM department heads, as well as the nuclear training manager at the corporate office are new to the positions but not new to FPL. Changes to the training organization include consolidating supervisory functions resulting in seven versus twetve supervisors and eliminating the coordinator level of supervision, splitting the maintenance and supporting technical training functions into two separate sections, and establishing two rotational instructor positions in the maintenance training section while maintaining a total of 65 training department positions as it was in 1991. These changes are resulting in increased management involvement in training and training's responsiveness to p! ant changes and training needs. For example, in 1993 the maintenance training review j

committee structure was modified to provide more focused oversight for each program. Instead of one committee that govemed all three programs, three separate TRC's were established. This revised approach is more 54 -

effective because the entire meeting agenda is dedicated to a single program, thus more time is spent rddressing individual department training issues, performance needs and program improvements.

3' Management Observations - Since the previous accreditation renewal, management commitment to line j

involvement in training has been strengthened in January 1994, the division president issued nuclear policy, NP-914 Management Observation of Training and Qualifcation Programs establishing management expectations for observation activities. During a PTAB meeting, plant management reviewed industry recurring problems related to management involvement in training and enhanced their methodology that is resulting in increased l

management observations of training in-progress and written feedback provided to the training department on training quality and effectiveness. For example, during a six month period through November 1994, management conducted 42 observations of maintenance and supporting technical training sessions and noted that overall, instructor characteristes, student performance and training effectiveness met management expectations.

Management observations provide direct feedbad( on the qualty and effectiveness of training and on-the-job task performance, The following are some comments that management noted. The electrical department head, who observed a class on diesel preventive maintenance, noted the instructor was " involved to the right level, joumeymen were helping each other adding lessons leamed through experience with diesels, task practice was realistic enough to simulate on-the-job requirements." The I&C department head, who observed a class on the flowscanner, noted the instructor did " excellent interacting with students, Specialists very interested in subject, program is directly related to increasing plant equipment performance." The mechanical department head, who observed a class on Unit 1 lower cavity ductwork rigging, noted "very good class participation."

The plant manager, who observed a class on the cherry picker, noted the instructor's " experience, knowledge and confidence were apparent, [and the instructor) clearty has the respect of the class." An I&C supervisor, who observed a class on Raychem, noted "very lively discussions, [ instructor) enforced procedure adherence,

[ students) provided good ' field condition' feedback, recent changes in Raychem installation procedures made this refresher course very valuable to the workers." The maintenance manager, who observed task performance of compressor preventive maintenance, noted the incumbent " verified clearance tags, wore hard hat and safety glasses," and the foreman

directed belts be replaced," an appropriate response to the worker's questions. The technical training supervisor who observed task performance noted the (,hemistry technician "was very knowledgeable about the task... performed analysis appropriately and effbiently throughout the task...

explained what he was doing and why."

Management observations are summarized and reviewed during PTAB and TRC meetings to ensure training continuously meets individual and plant needs, and to determine any necessary improvements to training programs. Management observations can result in immediate improvements. For example, when the mechanical maintenance department head observed nobile crane training, he had a different crane brought on site to use for training because he felt the one being used was inadequate (see Objective 8 for other examples).

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i Line Management Responsibilities St. Lucie's line management is responsible for the effective conduct of site training and qualification programs.

Line management responsibilities, authority and working relationships are govemed by quality instruction, OI 1 PR/PSL 3 Site Organ /zation. Senior plant management holds line managers and supervisors accountable for the qualification of their personnel and the quality of their training programs. Line managers ensure training programs meet individual and departmental training needs by observing, evaluating and supporting training activities and interfacing with training staff on a regular basis. Training department responsibilities and authorities required of personnel involved in the management, supervision and implementation of training are addressed in quality instruction, Of 1-PR/PSL-10 Training Organization. The administrative procedure for each accredited training program further specifies responsibilities for designated line and training department personnel (see for list of procedures).

The Plant Training Advisory Board (PTAB) provides oversight and direction for all training programs. This group consists of the site vice-president, plant general manager, department managers representing the accredited training programs and the site and corporate training rnanagers. During PTAB meetings, usually held quarterfy, j

management reviews the status of training programs, observation and evaluation results, student and plant performance, industry initiatives and training issues, concems, priorities and action items. Training program supervisors present the status of ongoing activities and identify items requiring management input and direction.

The board pays particular attention to accreditation self evaluation activities and improvement actions ensuring support is provided and improvements are successful. Feedback and support from these board meetings has resulted in improvements made to maintenance and supporting technical training programs (see Objective 8 for examples).

Line Management Ensures Effective Content and Conduct of Programs Line management provides direct input into the content and conduct of their training programs through a variety of methods to ensure they develop and maintain highly competent personnel. Each accredited program has a training review committee (TRC) that meets regularly to review training objectives, content, materials, schedules, student performance, observations, feedback and new action items. TRC participants include plant department heads, line supervisors, plant department support staff, training supervision, instructors and instructional technologists. Some TRC meetings involve student representatives, subject matter-experts and plant management. The TRC's review and approve changes to programs and determine content for continuing training. For example, the three maintenance TRC's reviewed and discussed feedback that was solicited from job incumbents and job supervisors regarding the effectiveness of pre-outage training conducted during the second quarter of 1994 and their perceived training needs related to an upcoming outage. TRC members used this information to determine content for the continuing training provided before the fourth quarter refueling outage.

During self-evaluation interviews with some incumbents and supervisors, they commented that ref resher training is not provided on some topics and new equipment. To make incumbents and supervisors aware of the content review and selection process and let them know their feedback and input is considered, future TRC meeting minutes will be available for supervisor and incumbent review. TRC members review the status of self-evaluation 56-

activities and many other items related 13 their training programs. Line personnel review cnd approve program modfications, training schedules and other actions taken to improve their programs as a result of self evaluation enorts to ensure the program meets their department's training needs and the accreditation objectives (see oejecove a for examples of program improvements).

While TRC's provide a forum for formal dialogue between plant and training personnel, ongoing informal interface is the key to ensuring traming programs continuously meet the needs of each plant department. Some examples of informal communication that provides foetack to training may occur before or af'er regularly held plant management meebngs, through oc: mail over the plant's PC-based wide area network (WAN), written memorandums or notes, regular photte calls, periodic visits to the training center, follow-up discussions after management observahons, meetings with students or scheduled PTAB and TRC meetings. Unsolicited feedbad is processed through the traitung relevancy review process specified in AP 0005766 Training Resources, frWbrmsten ancf Maferlist Control. For example, when the mantenance manager requested training after a near miss and before the HPES report was issued, this request was processed using the standard system outlined in AP 0005766 (see Objective 8 for process description). While the process provides for automatic, fomal review of aN incident reports, it is informal communication such as in this example that is often the key to timely training (see sodion on " Training Quality and Effectiveness" in the introduction for details regarding this near miss).

Training and Quellfying Replacement Personnel All replacement personnel are required to complete initial training programs as specified in plant procedures to ensure they meet qualification requirements before working independently on assigned jobs (see Program Descriptions for the requirements for each job position).

Corporate and Plant Training Goals Plant and corporate goals are established in the form of business p!sne on an annual basis. Business plan goals at each organizational level are linked to show commitment to public and regulatory requirements. The Nuclear Division's annual business plan specifies objectives and indicators against which the division's performance is measured. The St. Lucie plant's " operating plan" establishes the plant priorities, objectives and supporting indicators. This operating plan includes major training-related activities and the training manager is an active member of the Plant Lead Team that administers the operating plan. The training department establishes and monitors performance indicators that directly relate training priorities to plant objectives. The corporate training staff's annual business plan specifies objectives and projects in direct support of plant training and nuclear division objectives.

Management's commitment to training begins with the nuclear division president and continues through the management ranks to the first line supervisors. The president holds monthly meetings with the corporate training manager that are often attended by either the St. Lucie or Turkey Point site training manager. They discuss training policies, processes and improvement actions to ensure training activities, resources and support are focused on business plans and industry expectations. Some improvements that have been made as a result of E

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4 this regular inteiface with the president include issuing policies on examination standctds (NP-911) and managereant observations (NP-914). Tne cx>rporate manager of nuclear training is responsible for providing guidance. support and oversight of training within the nuclear division that includes the two nuclear sites.

Responsioliities include coordinating the development and implementation of standardized practices and programs that are common to the nuclear sites.

A Joint Training Assurance Board (JTAB) consisting of the training managers and key supervisors from both sites and the corporate office review common issues and concems, industry and regulatory initiatives, pofey development, joint projects and corporate staff support. Some of the improvements that have been made as a result of the JTAB interface include centralizing maintenance of fitness-for-duty and general employee training and development of cornputer-based training (CBT) programs, and coordinating support for accreditation set-evaluation activkies between the two plant sites including peers evaluators from the corporate office and other utilities. Decisions and actions taken as a result of the interface meetings with the president and among the training staffs are reviewed during PTAB and TRC meetings as sppwpiiate in support of plant training goals.

Training System Polleles and Procedures A training system methodology is implemented as the primary management tool for analyzing, designing, developing, implementing, evaluating and maintaining performance-based training programs. Nuclear Policy NP-900 Systems Approach to Training establishes management expectations for the training system used to manage and conduct accredited training programs. AP 0005756 Systematic Training Developmentis the St.

1.ucie plant implementing procedure that provides guidance for each phase of SAT. AP 0005757 Systematic Evaluation of Training E//ectiveness provides specific guidance for evaluating training programs. AP 0005766 Training Resources, information, and Material Controlprovides specific guidance for maintaining training programs. Other policies and procedures address specife aspects of the SAT process and provide guidance for individual accreotted training programs (see Attachment 2).

Training Funding and Staffing The training department organization currently consists of the site training manager and six direct reports including the initial operations, continuing operations, maintenance training, technical training, simulator engineering and administrative supervisors. There are 65 permanent staff positions in the training department.

Two positions in the maintenance training group are rotational instructors from the maintenance departments.

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There is no full time contracted training staff. Attachment 1 includes the training department's organizational chart.

Annual budget activities ensure that training programs are adequately funded and staffed. The annual budgeting process, including staffing, establishes priorities and funding levels for the ensuing training year. Each training group prepares formal budget requests that are analyzed by training management and finalized to support identified needs and priorities. The training department budget, which is consistent in priority with other plant departments, is submitted to plant management for review and approval. The training budget then becomes part 58 -

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.. i of the plant budget that b subject to corporate management review and approval. Fsedback from plant management, supervision and students has cor4Mned that plant training needs are being met.

pl j Training Facilities, Equipment and Meterials V

-The Nudoar Training Center (NTC) is a complete tranng facdsty designed to comprehensively support a wide variety of training activities. The condition of the facilities and equipment is monitored constantly to ensure that they most identified training needs. The NTC includes twenty-one classrooms, six laboratories and workshop

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- areas, a control room simulator, an auditorium-size room, libraries and document rooms, office space and storage j

areas, and a visitors center.' The NTC is included in the routing of techrucal references. in-house training support services are avadable to ensure that instructional materials are sufficient and current. The NTC is well equipped with the necessary space and integral training aids to support accredited training program activities.

Instrudional aids and equipment are obtained and rnaintamed to ensure they are sufficient to support traming activities instructional equipment available includes overhead projectors, television monitors, videocassette

-1 recorders / players, slide projectors, whiteboards and flipcharts. Consumable training supplies and equipment are mamtained in the trawung material storage area. Development and maintenance of instructional aids can be l.

performed by the NTC instructors or a media specialist as appropriate. Full audio-visual media development (still photographs, videotapes, audio r6 cording) is conducted by the rnedia specialist.

A laboratory facility on the second floor of the NTC provides training and performarce opportunities to students in both the CT and RPM programs. Located on the first floor of the NTC are laboratories, one for each maintenance.

program, and a general shop area where equpment and rnockups are staged and ready for use. For example, the l&C laboratory provides opportunities for equipment calibration and troubleshooting, system design and j

testing and experimentation regardless if the system is pneumatic, analog electronics, digital electronics or some combination. There are numerous equipment mock-ups available and many are actual retired plant components and equipment that has been modified for instructional purposes. Among the available equipment are various types of pumps, compressors, valves, valve operators, electrical motors and breakers. (See Objective 6 for more information on lab / shop facilities.)

Computer based training and interactive video leaming systems have recently been added to supplement the training curriculum. These systems effectively combine the power of the computer and the impact of motion video j

and graphics to deliver self-paced comprehensive instruction. The training library on the second floor of the NTC

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is maintained to providefurrent technical reference materials for instructors and students. Examples of the j

technical references available are plant change / modifications, plant and training procedures, plant piping and wiring drawmps, Final Updated Safety Analysis Reports, technical specifications, Unit 1 and Unit 2 plant curves, erwironmental qualifications lists, instrument technical manuals, and industry and regulatory documents. Also sharing the NTC are the St. Lucie Plant's Human Resource Department (second floor) and FPL's Energy i

Encounter visitors center (first floor). Throughout the visitor's center are interactive displays, exhibits, computer

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games and demonstrations about electricity and nuclear power. Approximat;ly 42,000 people trur the visitor's center each year with the majority being students f rom the local schools.

Contracted Training Training provided by contractors or vendors is used infrequently. When such training is obtained, the instructional staff reviews material and moniters instruction provided by contractors to ensure its acceptability. AP 0005757 Systematic Evabation of Training E//ectiveness provides guidance for evaluating contractor training for acceptability.

Attendance and Makeup Training The plant policy is that training be attended when scuduled or promptly made-up when missed. Scheduling personnel for idenillied training activities is the responsibility of the plant departments. The independentTeam Evaluation identified a few individuals who had not made-up required operating experience feedback continuing training during 1994. Data shows that attendance rates for 1994 averaged 94% for maintenance personnel and 95.4% for technical support personnel. As a result, management took immediate action to issue policies requiring mandatory attendance at required continuing training, and requiring monitoring attendance as a standing a0enda item at TRC meetings and at PTAB meetings. Make-up training was scheduled for individuals who missed classes. Completion of make-up requirements is currently 27% and is expected to be completed during the first quarter of 1995.

Entry-level, Training and Qualification Requirements, and Exemptions The entry level skills, knowledge and experience requirements are identified.for each of the training programs (see the Program Descriptions that follow Objective 1) Personnel enter a joumeyman position in one of three ma'intenance disciplines by using a union bidding process. As new personnel are hired, they complete designated training and qualification requirements prior to working independently in the plant. Training and qualification requirements are specified in the administrative procedure for each program (see Attachment 2). AP 0005742 Exerrption from Training provides guidance for exempting personnel from training segments based on their past experience, education and training. Exernptions are used primarily for joumeymen or technicians who have held a'similar position at Turkey Point or another FPL generating facility and who have documented proof of competency in the area being exempted. Exemptions are discussed at TRC meetings and each exemption is approved by the responsible plarn department head.

Qualifying Contractors and Other NorFplant Personnel St. Lucie Plant does not usually employ contractors as joumeymen or technicians during normal operations.

During scheduled refueling outages, contractors have been retained to perform assigned health physics duties as senior technicians, junior technicians and decontamination support personnel. RP:HP-0001 Guidelines for Training and Qualification of ANSI Contract Health Physics Technicians provides the corporate guidance used at FPL nuclear sites to ensure HP contractors are trained and qualified to do plant-specific work. Contractors also have been retalned to perform assigned joumeyman duties. Appopriate qualification documentation is required 60 -

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p and reviewed before a contractor b hired in accordance with 017-PR/PSL 1 Controlol PurchIsed Mat: rial, Equpment and Services. The 01 specifies training requirements for long-term contractors, who are those employed on site for six consecutive months or longer. Plant department management assigns Site Contract' Coordinators who are responsible for ensuring their department's contractors receive required training before

,i worldng independently. The training department provides a Contractor Orientation class for site contract coordinators.

Training Records Training records are maintained on programs a'nd individuals. The NTC maintains, controls and secures training records in fire rated cabinets. AP 0005741 Nuclear Training Center File Management provides a standard guideline for the records management process. The procedure identifies personnel responsibilities, identifies documere to be processed, specifies record retention periods and establishes processes for filing and retrieving records. Long-tenn record retention is mairdained on microfilm under controlled conditions.

During accreditation reviews, several instances were identified where exemption records could not be located. As a result of this feedback, an audit of the records system was performed to identify and correct exemption records deficiencies.

Since the last accreditation renewal, a PC-based maintenance training and qualification records system we developed using the NTC's LAN that is tied into the piant's WAN. Maintenance supervisors / foremen now have online access to joumeymen qualification status that enables more efficient work order planning and scheduling. f,l Some plant personnel interviewed during the Independent Team Evaluation indicated that joumeymen j

qualifications are not always specifically verified using available qualification information. As a result of this i

feedback, the online system has been made more easily accessible to line supervisors, and management expectations conceming assignment of qualified personnel have been thoroughly reviewed with personnel responsible for making work assignments.

I Self-evaluation teams also identified that the process used to document approval of training materials is net consistent for all types of materials resulting in some materials having no supervisor approval signature.

Procedural guidance for approval signatures was not specific in this area. Some document approval was indicated by the approval signature on the Resource Action Request (RAR). To correct this situation, training records have been thoroughly audited to ensure each unquely numbered instructional material has a supervisor approval signature.

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I DEVELOPMENT AND QUALIFICATION OF STAFF l

OBJECTIVE 3: Training staff members (utility and contracted,if used) possess the knowledge, experience, and skills required to fulfill their assigned dulles, f

SUMMARY

Training department personnel have and maintain the knowledge, skills and experience required to i

fulfill their duties and responsibilities. 011 PR/PSL-10 St. Lucie Plant Training Organization specifies the educational, technical and experience qualifications for training department personnel. Procedures and instructions delineate positional requirements. Guidelines pertaining to job qualification, initial and continuing training requirements, and evaluation of instructional and technical skills in the various training settings. AP 0005735 St. Lucie Plant Training Instructor Qualification and Requalification detines 1he instructor training and qualification program that is based on the guidance provided in INPO 88-012 Guidelines forinstructor Training and Qualification. Instructors maintain qualifications by fulfilling the instructor continuing training requirements Continuing training is designed to enhance instructor skill needs, cover instructional methodology and address training procedure revisions / adherence. Continuing training is provided using college level courses conducted by a local university, vendor courses and in-house training. Technical skills are maintained through in-plant activities including outage assignments. Subject-matter-experts who provide topical instruction for accredited training i

programs are monitored during their instructional presentation by qualified training department personnel to ensure quality.

Changes Since Previous Accreditation Renewal Instructor Evalua'tions - Training program feedback and annual evaluations have indicated that training department instructors have maintained an effective level of instructional skill proficiency. As a result of this feedback and discussions during the accreditation team visit for the operations training programs in 1993, a change was made in the process used to conduct instructor evaluations in the various training settings.

Previously, each training department instructor was evaluated anaually in all settings in which each instructs, however only a small sample of the plant personnel designated to conduct on-the-job training 4ask perfortnance evaluation were evaluated annually. The change that was made was to evaluate annually a representative sample of training and plant personnel qualified to conduct training and evaluation in any setting. The annual sample was designed so that within a four year period all qualified personnel would be evaluated at least once in each applicable setting. However, if observation and feedback indicated a trend toward deficient performance, additional evaluations would be conducted. During the Independent Team Evaluation, the team, which represented seven different plants within Region Two, noted that this change was not consistent with standard industry practice. This was confirmed by a survey of other Region Two plants and through consultation with a National Academy representative. As a result, in 1995, St. Lucie has returned to their original practice of conducting annual instructor evaluations for all training department instructors in each setting they are assigned to instruct. A representative sample of the designated plant personnelwho are qualified to conduct OJT/TPE are t

evaluated annually. This change is now reflected in AP 0005735..

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Traininp Staffina chanpas Since the previous renewal, staffing changes hava occurred in the mamtenance and j

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technical training groups. Three rnaintenance instructors retired and have been replaced with personnel from plant memtenance and from Turkey Point training staffs. A full-time instructor (previously serving as an 4

instructional tednologist) has been hired to support the maintenance supervisor and planner training programs.

Two rotahonal assignments have been established to permit plant maintenance supervisory personnel to rotate 1

Into the maintenarce training group One instructor was hired to support the health physics and chemistry -

trainmg programs. The ESP instructor rnoved to the Emergency Response staff and has been replaced by an 1

instructor who was a licensed operator. The instructional technology (IT) staff has been decentralized resulting in.

one IT assigned to each tramink section (viz., maintenance, technical, operations initial and operations requal training). The IT vacancy in the maintenance section was filled by a individual fmm a position on the plant's Speak Out/HPES staff who had provously worked as an IT in the training department.

I Shength Both the tomrucal and educational qualifications of the trainin0 staff have been enhanced since the previous accreditation renewal Plant management has recognized the strong technicat qualifications of training personnel I

and has relied upon that expertise during recent plant modifications and refueling outages. Instructors and support staff have performed plant modification, emergency plan and outage responsibilities in the following areas since the previous accreditation renewal:

- Extensive rnodification of the common water treatment plant hI

- Emergency Plan off-site monitoring team leader Refueling outage functions including Merlin-Gerin radodosimetry installation i

turbine maintenance l

pressurizer nozzle repair freeze sealappication i

wo:k order planning and parts identification measurement and test equipment distribution

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i actuator overhauls l

control rod drive troubleshooting loose parts monitor calibration breaker refurbishing supplemental safety department staffing These activities have benefited training by giving instructors and support staff the opportunity to perform in-plant activities to maintain and enhance their technical understanding of plant systems and operations. The training staff finds this enhanced knowledge usefulwhen developing and delivering instruction, communicating with plant I

personnel and providing training support services. In addition, instructor support of outage activities maintains i

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their credbility with students during training sessions. The plant also has benefited by making Gfficient use of in-house resources ard having significant roles filled by personnel with plant-specific technical expertise.

Training staff have samed or are pursuing higher education degrees in programs coordinated through the Nuclear Training Center. Through the instructor continuing training program that uses courses taught by a local university, one instructor eamed a masters degree and three instructors eamed bachelors degrees in vocatio_nal education from the University of Central Florida (UCF). The training manager eamed a bachelors degree in applied science from Thomas Edison State College,1.= technical training supervisor is working on a bachelors in nuclear science through the University of Marylancs on-site degree program, and the l&C lead instructor is working on a master of science degree in management through Florida institute of Technology's (FIT) on-site program. Other instructors and plant personnel have taken courses offered on-site by UCF, FIT and Indian River Commun+ty College (IRCC) in pursuit of higher education degrees (NOTE: This was a good practice identified in the March 1992 INPO Plant Evaluation Report.)

Training Staff Qualffications Training personnel responsbie for management, supervision, instruction and development / revision of the accredited programs have and maintain the qualifications required for their positions. 011 PR/PSL-10 St Lucie Plant Training Organization specities the educational, technical and experience qualifications for training department positions. Training management and supervision participate in a variety of developmental activities including instructor continuing training, Corporate Education and Training (CET) courses, off-site industry meetings and workshops, peer evaluator on accreditation team visits and in-plant outage responsibilities. The instructional staff participates in structured initial and continuing training activities designed to develop and maintain their instructional and technical qualifications (see " Continuing instructor Development" section below).

Instructional Skills Training Program AP 0005735 St. Lucie Plant Training Instructor Qualification and Requalification detines the initial instructional skills training program that develops the necessary competencies required to develop and deliver nuclear training programs. New instructors are scheduled and begin their initialtraining within about two weeks of assignment.

Each instructor receives an indoctrination and orientation to training, department procedures. The new instructor then completes the initial training requirements unless otherwise exempted because of documented experience or education. The initial training addresses the major content areas associated with the systematic approach to training including analysis, design, development, implementation and evaluation. The curriculum is based on the guidance provided in INPO 88-012 Guidelines for Instructor Training and Qualification. Instructional requirements are met through a guided self-study approach using eleven modules from the Electric industry instructor Training series and four modules from the Ohio State University sponsored project for vocational education teachers. An instructional technologist works one-on-one with each new instructor. Initial training includes the following topics:

Training needs, job and task analysis Designing instruction, objectives and lesson plans

- Introducing and summarizing a lesson 64 -

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- - Working wth adun tarners 4 Techniques for classroom, latyshop, tours and wakthroughs -

- Case methods, questioning sklus and audio-visual aids

- Evaluating student performance

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Guest instructors Individuals with apacialaed skills and/or knowledge in a particular subject matter may deliver instruction to plant.'

personnel as guest instructors in accordance with the guidance in AP 0005735 St. Lucie Plant Training instructor j

Guafhcation aruf BequaWicetion. Guest instructor qualifications are reviewed and established by trasning

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j personnel prior to training implementation. Guest instructor activities are monitored by training supervision and f

instructional personnel to ensure the relevancy, sufficiency and quality of instruction. For example, the ESP and MST programs use guest instructors from the plant and corporate staffs.

i Training for OJT/TPE Personnel

, Au site personnel responsible for conducting on-t e-o tra n ng (OJT) and task performance evaluations (TPE) hjb ii

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receive training in a consistent methodology that includes proper demonstration / practice and evaluation techniques. Each person is observed and evaluated in the performance of these essential OJT requirements prior to quaillication. AP 0005767 On-the-Job Training and Task Performance Evaluation provides the guidance that is covered in the course for personnel designated to conduct OJT/1PE. A master list of qualliied OJT/TPE j-personnel is maintained by the training department and is distributed to the appropnate plant department supervision.- A sample of qualified personnel is identified annually to be observed and evaluated while they

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conduct OJT/TPE. These observations / evaluations are performed by designated training staff personnel. Line management also observes OJT/TPE activities and provides feedbacP.to the training department. During accreditation reviews, it was determined that some qualified OJT/TPE personnel were not aware of the pl. ant procedure providing performance evaluation guidelines (see Objective 6 " Changes Since Previous Accreditation Renewal" for a dismssion of the improvement actions taken).

Instructional and Technical Evaluations 4

Training department instructor performance is evaluated in accordance with AP 0005735 St. Lucie Plant Training instructor Qualification and Requalification. The procedure delineates a consistent evaluation methodology and

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provides a standard format. Allinstructors receive an initial evaluation of their technical skills and instructional skills. Instructional technologists conduct the instructional skills evaluations and training supervisors conduct the technical skills evaluations. Depending on assigned instructional settings, instructors may receive additional evaluations, such as during laboratory and on-the-job training. Instructors' technical skills and instructional s' kills are evaluated annua #y (see " Changes Since Previous Accreditation Renewal" immediately following the Objective 3 Summary). Training settings and evaluation activities are tracked on a matrix maintained by the instructional 16G6elogist who has primary responsibility for instructor mntinuing training. In addition to these formal instructor 4

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~ evaluations, instructors are observed during the ongoing accreditation reviews of training corbucted in each I

setting (see example's of observations at Obtective 5 and Objectrve 6) and during management observation of 4

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i training in-progress (see Cxamples C2 Objective 2

Changes Since Previous Accreditation Renewa!" section).

These observations provide feedback on training qua!!!y characteristics and effectiveness. Training management j

and supervision use this feedback when reviewing instructor continuing training needs. Observations have also

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resulted in improvements to training programs (see Objective C).

Continuing instructor Development Continuing training needs are determined by using information from the instructors' evaluations, reviews by training management / supervision and instructor needs surveys. The annualinstructor training plan documents the process used io select continuing training topics. Continuing training and development activities enhances instructors' technical knowledge, improves instructional skills and keeps them abreast of changes in training procedures and management expectations. The continuing training program includes college-level courses conducted by.a local university, vendor courses and in-house training. Some instructors have eamed degrees as a result of the college murses offered as continuing training (see Strength at Objective 3). Among the classes delivered since the previous accreditation renewal are the following that have resulted in improved instructor performance.

in 1991, a Media Presentation Skills course provided instructors the opportunity to gets hands on practice with a variety of instructional equipment and training aids. Instructors have increased their use of a poster-maker to produce professional-looking flipcharts and walicharts, and their use of a video / opaque projector to project pictures, objects and small pieces of equipment during classes.

in 1991, an Advanced Test Writing course focused on writing multiple-choice test items and instructors 'used their own previously developed items during class exercises. Instructors have improved their construction of items, development of distractors, and matching of items to objectives levels.

in 1992, Teacher Effectiveness Training emphasized concepts and techniques for improving communication and developing rapport between instructors and students. The course provided instructors an opportunity to analyze their role as a professional trainer and how students perceive their role, instructors developed a personal philosophy about their ro'le that helped them improve their communication with students in and out of the classroom environment.

4 in 1992, the Accelerated Leaming Workshop provided instructors with a variety of creative ideas to involve students in the teaming process. Instructors are now using such techniques as ice breakers, games, simulations, team exercises / presentations and other interactive activities, and have increased the use of color and visual aids in their teaching. Test scores, and feedback from students and management, have been very good (see Strength at Objective 5).

In 1993, a Computer-Based Training (CBT) Design Theory course provided key concepts and processes for designing and developing C'BT and an overview to other advanced technology applications. Instructional staff

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who were working on a CBT project at the time also completed training on the authoring system and computer managed instruction (CMI). While the benefits for most instructors was an increased awareness of aRemathre technologies, direct application to the job was most obvious for the CBT project staff. The team improved their awiskJi to designing the instruction resuting in a more consistently formatted and professional CBT product that gained positive student feedback.

In 1994, a Procedures update class and an OEF/ LAB /OJT process update class were conducted for instructors in response to improvement areas being identified during intemal and extemal evaluations. Instructors reviewed signliicant changes to training procedures and management expectations regarding AP 0005756 Systematic Training Devsiopment, AP 0005757 Systematic Evaluation of Training Ettectiveness, AP 0005766 '

Training Resources Information andMaterial Cont,ml, and AP 0005735 Instructor Qualification and ReguaJtication. The process update class reviewed guidelines for incorporating operating experience feedback into training materials, developing lab guides, and conducting on-the-job training and task performance evalushors.

i Since the previous renewal, instructors' use of personal computers has increased significantly. As a result, many have requested computer training during the instructor needs surveys. In response, instructor continuing training has included courses on software applications taught by indian River Community College and in-house experts.

Currently, every instructor has a PC and uses it to update training materials, create training aids and graphics, access training records and reports, and communicate among training and plant personnel.

Instructor technical knowledge is maintained by structured in-plant activities that total a minimum of 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months per instructor each year. Many instructors exceed this requirement by performing outage-related duties (see Strength at Objective 3). Besides outage assignments, some of the other in-plant activities that instructors pertorm include system walkdowns, interviewing sub}ect matter experts about task perf ormance, and observing maintenance or surveillance activities. In-plant activities are documented and rnaintained in instructor records.

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ANALYSIS, DESIGN AND DEVELOPMENT OBJECTIVE 4: A systematic process is used to determine job performance requirements, g : city training program content, prepare supporting training materials, and maintain the training program.

SUMMARY

A systematic approach to training (SAT) methodology is used to develop pertormance-based training programs. AP 0005756 Systematic Training Development provides the guidance for analysis, design and j

l development. Programs are based on an annlysis of job performance requirements. The periodic review and maintenance of plant-specific task lists ensures program basis documents are up-to-date. Training program content is based on analysis data that identifies essential knowledge, skills and abilities necessary for successful Job performance. Subject matter experts provide information during task analysis. Evaluation of feedback from plant personnel, procedure revisions, plant change / modifications and other changes are used to identify new or modified tasks. These change actions, as well as operating experience, are analyzed for training relevancy on an ongoing basis in accordance with AP 0005766 Training Resources, Information and MaterialControl.

2 Specific leaming objectives that include conditions, actions and standards are developed or modified based on analysis and evaluation data. Leaming objectives are sequenced to progress from simple knowledge and skills to more complex and advanced competencies and task performance. Lesson plans and other instructional materials state the leaming objectives and include the necessary content and activities to ensure consistent and effective training. Test items are based on specific leaming objectives and used to construct multiple forms of critten exams. Performance tests are used to evaluate task performance in the laboratory and on-the-job training y

settings. Students must score 80% or greater to pass written exams and satisfactorily complete specified

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requirements in performance tests; otherwise, remediation and reexamination are administered.

Plant Specific Task Lists A valid plant-specific task list is developed and maintained by plant and training personnel. These task lists serve as the basis for the maintenance, chemistry and health physics training programs. Change actions that may impact task lists are submitted to the appropriate training program supervisor for review using the process outlined in AP 0005766 Training Resources, information and Material Control. These include but are not limited to job scope changes, plant change / modifications, procedure revisions, new equipment or too!s, industry or regulatory changes and feedback from intemal and extemal sources. Feedback from students, instructors, job incumbents and job supervisors is used to identify necessary changes and modifications to task lists and training program content. If a preliminary review of a change indicates that further action is necessary, a needs analysis j

may be conducted. If appropriate, a resource action request (RAR) (essentially, a training work order) is generated to begin revision or development work, as outlined in AP 0005766 (see Objective 8 for more details regarding the process used to make changes to training materials). The revision / development process may be used for adding new tasks, modif ying existing tasks, conducting task analysis or deleting tasks from a program's scope. In addition to ongoing maintenance, task lists are periodically revalidated. AP 0005756 Systematic i

Trarining Developmentprovides guidance for revalidation efforts. Task list revisions are reviewed during training review committee (TRC) meetings and are approved by plant and training supervision. -

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Some examples of changes made to task lists as a result of ongoing maintenance or revalidation efforts include the following. Added to the l&C list were tasks associated with overhauling Bettis piston actuators and rebuilding the ITT Barton actuator because the plait assumed responsibility for the maintenance of this equipment that was formerly performed during outages by contractors. The tasks " install and remove movable incore system" and

" test the system's fission charnber" (N007, N013, N015) were deselected f rom the I&C task list because equipment was removed from the plant The tasks " remove and install pressurizer manway cover" (N064, N065) were deselected from the mechanic's task list because these tasks are now performed by contractors. Tasks added to the mechanic's task list include "take oil samples", " install expansion anchors" and " operate hydrolaser",

Some new tasks associated with new HP equipment include RPM tasks using the Telemerlin and HPDT tasks associated with a new body counter and portacount respirator fit testing equipment. The independent Team Evaluation identified some tasks that were added to the joumeyman electrician's job scope, but had not been added to the revalidated task list. Immediate action was taken to incorporate these tasks into the EM training program (see Utility-identified Weakness at Objective 1 for details).

Task to-Training Matrices Program staff use training information management systems to maintain current task lists including a cross-reference to training materials. Task-to training matrices may include other information such as deselection codes, job analysis data, training settings and evaluation methods. The program supervisors and lead instructo maintain the task-to-training matrices as task list changes or revalidation efforts are completed.

b New and Modified Tasks New tasks or significantly modified tasks that are selected for training are analyzed to identify knowledge and skills necessary for competent task performance. Subject matter experts are involved to provide information during the task analysis process. This analysis data is used to make improvements to training materials. Newl developed or modified training materials are reviewed and approved by plant and training department supervis prior to iriitial implementation and in accordance with administrative procedures. The following are some examples of new or modified tasks that have been analyzed or task analysis that has been revalidated since the last acx:reditation renewal. " Calibrate liquid scintillation counter" (820) is a new chemistry task that was analyzed and the information incorporated in training materials (#2101810). " Analyze gross beta-gamma activity" (CO2) is a j

modified task that was analyzed and incorporated in materials (#2101808). New I&C tasks that have been analyzed include those associated with Fisher flowscanner operation and CEDMCS system maintenance.

Electrical maintenance task analyses that have been revalidated include tasks associated with polar crane maintenance and raychem applications.

Entry level Requirements The entry-level knowledge, skills and experience requirements for each of the programs provide a baseline that considered when developing or modifying leaming objectives. These requirements are identified in the program h,

descriptions (see Program Descriptions at Objective 1).

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Leamin0 Objectives Leaming objectives are derived from the analysis of knowledge and skills required ior cornpetent job performarrA. Leaming objectives specify training program content for specific lessons. Leaming objectives are sequenced to progress from simple knowledge and skills to more complex and advanced competencies reflected in the performance of spfAsiiAe work tasks or evolutions. Mastery of knowledge and skills in an earlier instruebonal sequence enables achievement of subsequent higher order objectives. Implementing procedures and course control doasments establish the sequence of training activities from initial entry through certificatiorVqualification. Leaming ob ectives are modified or developed to reflect changes in job performance f

requirements that occur because of procedure changes, plant change / modifications or other change achons improvements or changes to training are initiated by a training system action request (TSAR) that contains the details of the potential changes. Each TSAR is routed to appropriate program supervisors who review and evaluate the impact and relevancy to training. If the rowewer deterrrines changes are required, the TSAR is closed and a resource action request (RAR) is initiated to implement the required changes or improvements.

i Conditions, Actions And Staridards AP 0005756 Systemate Training Dembpment outlines a methodology for developing leaming objectives. The procedure provides guidarce on terminal, enabling and lesson objectives. Objectives contain actions that must be demonstrated by students to show mastery of the leaming objectives. Conditions under which the student wGI perform and the standards to which the student must perform are stated or implied. Instructors in all training j

programs strive to irnprove teaming objectives by writing them in more observable and measurable terms and including higher-order objectives when appropriate.

Test items Written test items are developed based on leaming objectives and are designed to measure mastery of knowledge and skills. Performanco test items are based on enabling'and terminal objectives and are designed to measure trainee performance against established task standards. Mastery of higher-order objectives are evaluated typically using case studies when students are required to analyze plant situations or event data or on performance tests when students are required to perform analyses or troubleshoot problems.

f Examinations Written, oral and perfonnance tests are used to evaluate student mastery of teaming objectives. The development, administration and security of examinations are conducted in accordance AP 0005754 Written Examinalbn Administration and Control, AP0005767 On-the-job Training and Performance Evaluation, and AP 0005756 Systematic Training Development. Exam validity is further established by test llem analysis that is i

performed on written examinations using a procedurally driven form or the Scantron's built in analysis program.

Item analysis identifies high error rate items that require further analysis. Analysis results are used to correct poor Items or improve instruction. Examination frequency, pertormance standards and guidelines for remediation and

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rolesting are spectied in each training program's administrative procedure (see Attachment 2). All examinahons

' are reviewed and approved by training supervision Students must scors 80% or greater to pass a written exam. Students rnust satisfactorily perform au requirements specNied in a performance test. Nuclear Policy NP 911 Trahng Examination Standards provid direction for handling students who fall to meet exam performance standards. Three attempts are allowed to emrammy complete an exam. If the student talis the third attempt, the student's case is reviewed by the applirehla training review committee to deterrmne if the student will be allowed to continue training with a remediation, be restricted from performing the task (s) for which the student did not demonstrate competency, or be removed from the current job assignment due to failure to meet qualification requirements. In au cases, the final deceion is made by plant management.

i Leeson Plane and Other Training Materials

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Lesson plans, sew-study modules, student texts, handouts, lab guides and on-the-job training guides are developed and modfied using systematic processes and are based on the learmng objectnes. The processe training development and training material modification are specified in AP 0005756 Systematic Training Deveeopment and AP 0005766 Training Resource, Informatson and MaterialControlrespectively. Instructio materials and supporting content are constructed in a manner that promotes consistent, effective delivery of training. Lesson plans and other training guides are developed using a consistent and unitorm format for 1

content and instructional activities.

For example, the lesson plan format provides information that guides the instructor during training delivery.

Leaming objectives are stated at the beginning of each lesson plan and instructors are guided to review and explain the objectives to students. Instructor / student activities are included in the lesson plans to support le objectives. Besides the text in the outline of instruction, other materials such as handouts, texts, modules i

transparencies may be available to support both presentation and instructional activities. Instructors are tra i

I and pro 6cient in using the key components of lesson plans. They ensure content is adequately covered and instructional resources are used as indicated to achieve the intended instructional outcomes.

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Sequence of Training l

The scope of instruction for each of the training programs identifies classroom, laboratory, self-study ardor i

I on-the-job training. The training settings are identified on task-to-training matrices and in program desenptions (see Training and Qualification Sequence charts at the end of each program description at Objective 1). Progr sequence is dependent upon a sequenced hierarchy of tasks selected for training. The objectives of the selec tasks are defined and students must successfully attain the qualification requirements prior to working

't independently on the job. The program administrative procedures or course control documents specify a train sequence that ensures completion of prerequisites prior to qualification. Qualification requirements are h,

estabished in conjuncbon with the plant department heads / representatives. The procedures and course cortrol documents estabissh the sequence of training activities from initial entry through certification / qualification.

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CONDUCTCF CLASSROOM TRAININ3 AND INDIVIDUALIZED INSTRUCTION AND TRAINEE EVALUATION OBJECTIVE 5: Trainee mastery of job-related knowledge is achieved through effective classroom training and Individualized instruction. Trainee performance is evaluated in a reliable and valid manner.

SUMMARY

Classroom training is conducted in an effective and efficient manner. Individualized instruction is used in ch-ws&y and health physics training and remedial training in the other programs to focus on individual needs of students as identified and required. Maintenance and ESP training use self-study for specific applications. Annual training plans are prepared to guide the implementation of training activities and accomplish the requirements specified in the program administrative procedures and other training guidance procedures (see for list). Training is conducted using approved materials that are technically accurate and up to-date and instructionally sound (well-organized to support leaming objectives). Instructors are prepared to deliver planned instruction and use innovative techniques to challenge students and keep them actively involved in the leaming process.

The conduct of trastung is observed and evaluated regularty through formal instructor evaluations, management observations of training, ongoing accreditation reviews and student critiques to determine training effectiveness and identify areas for improvement (see Strength at Objective 8). Students' knowledge and skill performance are evaluated regularly using written, oral and performance examinations that measure specified leaming objectives.

Exams are developed, administered and secured to ensure validity, consistency and reliability. Students must score 80% or greater to pass written exams and successfully complete specified requirements in performance evaluations. Remedial training and reexamination is provided when a student does not meet examination standards.

Strength Since the previous accreditation renewal, instructors are using a variety of creative training techniques and advanced technology applications. Such instructional strategics are keeping class attention, encouraging student participation and promoting mastery of leaming objectives. Creative techniques that make use of inexpensive materials and accelerate leaming include games, flash cards, music, color in materials / media and lava lamp.

Some specific examples include the following. To facilltate understanding of the design and layout of the site electrical distribution system, ESP students build the system using labeled cardboard boxes, platters and color tape on the classroom floor. Students use packages containing laminated magnetic pictures of all the major plant components to construct an operating configuration on a white board that shows all appropriate connections and interrelations. Students use cards with the names of job positions and photographs of current incumbents to build on organization chart on the whiteboard.

Some examples of instructional techniques that actively involve students in the teaming process and ensure the training is relevant to the job include the following. Case studies involve students in analyzing errors and determirung preventive measures. For example, students use assigned diagrams, procedure changes, methods i

or task atsivilles descreed in handouts /procedurcs and groups make presentations arxi lead class discuss 3ns.

Instructors pose plant scenanos and ask students to identify related equipment, tools and materials they would l

h take to the job site or how they would work safely. Instructors use questioning to determine how students would I'

I handle specific job stustions and ask experienced incumbents to share their experiences for the benefit of the newer personnel in the class. Plant analysis results and trend data are used to emphasize job relevancy of chemistry training content.

4 Some of the advanced technologies used include interactive videodisc instruction on process measurement fundamentals, computer-asseled instruction using a process control loop simulator prior to lab exercises'with a mock 4sp system, an LCD computer projection panel used, for example, dunng flowscanner training to display i

actual equipment data / records, and a video stand used to project opaque materials and small objects such as a -

dosimeter during HP training.-

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Student feetted has been very positive. Students feel classes are more interesting since instructors have enhanced the tradtional lecture method with more interactive actMties and hands on training. Instructor credhility is enhanced when customers are satisfied with training Management observations reflect positive ratings of instructor and student performance during training. Test scores are consistent and students are more confident in their ability to perform in the job environment. Post training feedback from students and supervisors 4

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is indicating the training is contributing to improved performance.

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}I Classroom Training Training is implemented with approved training materials and is well organized and current in accordance with the individual program administrative procedures (see Attachment 2). These procedures address initial and continuing training with regard to program structure, content, conduct of training and process requirements.

l Leaming objectives reflect the knowledge, skills and task performance requirements of specific job positions.

Leaming objectives are developed or modified when job performance requirements change because of procedure changes, plant change / modifications or other change actions and most are personable.

i Training materials reflect sufficient content to support achievement of leaming objectives. Before using training l

materials to conduct scheduled training, instructors ensure they are technically accurate and up-to-date. Training materials and course control documents include the instructions for conducting training activities. Lesson plans are sufficient in depth, content and detail to support learning and performance including higher order objectives.

l Student materials are complete, clear and technically accurate and supplemented with the most current revisions of plant procedures.

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l Training activities are designed to provide presentation of content, a series of structured exercises, self-study and examinations. Instructional materials are designed to support the leaming activities that are appropriate for selected traming settings and methods. Objectives and activities are structured and sequenced to provide for officsont and successlut achievement of training and qualification requirements.- As training materials are l

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developed and/or revised, they are reviewed and approved by the appropriate superviLor in accordance with AP 0005756 Systematic Training Development. Evaluation and feedback are used to improve instructional materials and examinations prior to their next use.

Instructor Properation Training is normally scheduled and approved far enough in advance for instructors to have adequate time before a class to review the lesson materials, make any personal enhancements and set up the classroom to ensure they deliver effective training. Lesson plans provide a framework, along with the instructors

preparation, to ensure consistent instructional delivery. The instructor training program provides opportunities for instructors to maintain their technical and instructional skills. Instructors work in the plant during outages, on special job assignments, or doing other in-plant activities to maintain their technical skills (see Strength at Objective 3).

Instructional skills continuing training addresses instructors' needs and has resulted in improvements to classroom instruction and student evaluation (See Objective 3 for examples). Instructor evaluations, student critiques and management observations provide inctructors with feedback on the quality of their instruction and preparation.

Accreditation review data reports some feedback and results of instructor preparation including the following.

Students generally perceive instructors to be technically knowledgeable and up-to-date with plant changes.

Student feedback indicates instructors take special effort to provide assistance and often provide classes that are challenging and fun. Students generally rate instructor performance very good to excellent. Instructors feel that they are well prepared and have an excellent training f acility in which to promote effective and consistent training.

High test scores and extremely low failure rate are the result of effective and consistent training.

This feedback and results are in part due to the dedication and competence of instructors and the effort they take to be well-prepared. During preparation, instructors f amiliarize themselves with the objectives, content and sequence of the material, and if necessary supplement their understanding of the subject with additional reading and/or research. They check to ensure the material is currently relevant to the plant. They prepare practical examples, questions and anecdotes that enhance retention and transfer of leaming to the job environment. They plan creative techniques to involve students in the class and encourage critical thinking and analysis. Instructors review any planned visual aids to ensure their quality and appropriateness. They ensure required reference materials are available and current and equipment is in operable condition for smooth delivery. Instructors make the necessary preparations for administration of exams and evaluations.

Instructional Techniques instructors use a variety of instructional techniques to encourage student participation in the leaming process and mastery of leaming objectives. Leaming objectives are listed in lesson plans and instructor guides and in student handouts and self study modules. During classroom training, instructors make an effort to focus students on the leaming objectives. Some of the techniques they use include the following: Objectives are reviewed during

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lesson introductions, referred to during the lesson when related content is first presented, emphasized as content 6 presented and docussed, and reviewed at the end of the lesson and prior 13 exams using questoning to assess understanding. When instructors recognize studems are having difficulty with an objective, they will adjust

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the tralrung to emphasize the topical area.

Observations of instructor performance dunng accreditation reviews revealed a number of indicators of training quailly. The following are some examples. Classes begm on time at the start and after breaks. Lessons are j

property introduced includmg overviews of objectives. Instructor-student interaction is good and students are j

actively irwolved in class discussens and activities. Instructors use questioning for a variety of purposes such as to gain atention, dieck understanding, pose problem stuations, solicit student experience and revow objectwos I

' at the end of class. Instructor use of media is good includog the proper use of the whiteboard and overhead with professional-loolung transparencies. Instructors use handouts, diagrams and procedures that are techrucally accurate and current.

I Transitions from one topic to the next are often explicitly noticeable during observations. Instructors use examples, anecdotes and relevant stories based on their past experience gained (a) while worldng in the plant,'

- (b) from attending a training class on the lesson topic, (c) during other classes they taught, and (d) from off-the-job and personal experience but related to the content. Lessons leamed from operating experience are often covered when relevant to the instructional content. Professional codes of conduct and rules are emphastred. Instructors properly supervise self-study, self administered exercises and quizzes, prachcal demonstrations, and field activities that require student self-direction and active involvement in leaming. Lessons.

'O are appropriately summarized.

I Students and job incumbents who weic interviewed during accreditation reviews provided comments about the quality of instructor performance. The following are some examples. Comments indicate instructors strongly emphasize safety in both the classroom and lab. Many times instructors and fellow students identify safety traps to avoid. Students find classes challenging and say instructors ask good questions upf ront to assess their current knowledge level and avoid covering indepth the areas they already know well. Students commented positively about instructors' technical knowledge being evident due to their past experience and they feel instructors have a high concem for students.

Students say it's obvious that most instructors put lots of time and effort in preparing for class and they appreciate Instructors' personal stories that relate to the course content. Some students noted continuing training is helpful and useful, particularly procedure updates and industry events when they review inspection reports of other plants. Students particularly find it interesting when instructors use mock-ups and actual equipment, and when the class size is small so they can discuss the content in more depth and share experiences. Students have expressed that classes are more interesting when instructors use games and other innovative techniques (see Strength at the Objective 5 Summary).

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Individua!!rd instruction l

Chemistry and health physics training uses self-instruction as a training setting. Maintenance training uses j

sew instruction as a method during some lessons delivered in the classroom and lab settings. ESP students use sew study to complete position-specific qualification requirements. Self-study is also used for remedial training.

The seN-instructional approach is consistent with adult leaming principles that suggest adult leamers are by nature seN directed an ; take responsibility for seeking resourr:es, relating their leaming to practical problems and j

solutions, and prefer immeduste application of leaming to their job or some other relevant situation. Whether a setting or a method, se#-instruction rnaterials provide specific guidarre to ensure students achieve leaming objectives and trainers monitor progress and provide assistance as students require.

l The chemistry and health physics programs use self-instruction in conjunction with on-the-job training. Students use sew-study modules that provide detailed content and instructions to guide leaming. Training instructors i

provide orientation, guidance and support to students and monitor student progress through the program.

Students use a variety of plant resources as they work through a module to ensure their understanding of concepts and procedures, observe practical demonstrations and prepare for evaluations. Designated OJT/TPE personnel provide formal instruction and conduct performance evaluations to_ ensure teaming objectives are mastered and task qualification is achieved.

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1 The maintenance programs use self-instruction as a method during some classroom and laboratory training. For example, during the process measurement course, l&C students work through interactive videodisc modules that include objectives, application exercises and pre and post tests, and the instructor is available to provide assistance. Likewise, during the Power M&TE course conducted in the EM lab, the instructor monitors progress while students work through self-study modules using different pieces of equipment. Students in the ESP program use qualification guides that include activities, content, resources and instructions to guide the student through completion of qualification requirements. Remedial training typically involves self-study whereby the student reviews required topics and completes assigned activities and the instructor provides assistance as required by the student.

Trainee Evaluation Student mastery of leaming objectives is evaluated using written, oral and performance evaluations. Depending on the program, classroom and self-instruction uses pre-tests, self-tests, case studies and post-tests. Only the latter is a formally documented written examination. The development, administration and security of formal examinations art; conducted in accordance with requirements specified in AP 0005754 Written Examination Administration ano Controland AP 0005756 Systematic Training Development. Examination 1requency, performance standards and guidelines for remediation and retesting are specified in each program's administrative procedure.

Generally, written exams include at least one test item for each leaming objective but some objectives are measured using multiple items. Item weighting is based on the item type, depth of content associated with the -

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g ot$ dive and/or 4:e importance of the objective to the job. For lessons that contain a large amount of content, 1,_

such as the ESP program, a represe.ntative sarnple of items are used to measure mastery of the objectives.

. g<g To minimize test anxiety, instructors use certain strategies when constructing exems. For example, items progress from sen1ple to rnore cornpiex objectives, items associated with similar or related oo ecSves are grouped s

together, or llems are grouped by test item types. Point values are often indcated for each item on an exam and some exams reference the objective for each item. Multiple forms of exams are used for lessons delivered in consecutwo sessions to ensure no test is compromised. Instructors proctor written exams which are generally administered within a specified completion time. Students rnet score 80 percent or greater to pass a written j

exam. If a student does not pass an exam, remedial training is provided that typically consists of individualized instruchon with oneen-one instrudor coaching and assistance followed by reexarnination using a different exam.

.1 Some lessons use the case study method for training and evaluation, for exarmie, to observe achievement of higher 4rder objectives and assess student understanding of selected operating experience. Case study

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. exercises last approximately one hour and include the use of worksheets and interaction among students.

Self administered tests and exercises are used in the chemistry and health physics programs and to some extent j

in the maintenance programs so students can assess their readiness for formal evaluations. For example, during i

maintenance supervisor training, students use self-checks to prepare for writte'n exams. Chemistry and HP students use self-tests in self-study modules to prepare for ;ask performance evaluations (TPE). TPE's are conducted in the laboratory and on-the-job training settings (see Objective 6). Qualification guides are used to evaluate ESP students during the position-specific program segment and also are completed ori-the-job (see Objective 6),

j For final qualification purposes, the health physics operations supervisor conducts a one-on-one oral board with each RPM after the student completes all training and task performance evaluations. The oral exam is structured based on the program objectives and lasts for about three to four hours. The supervisor uses the exam results to give feedback to students and to the training program (see Objective 8 for an example).

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i CONDUCTCF LABORATORY AND IN-PLANTTRAINING AND TRAINEE EVALUATION OBJECTIVE 6: Trainee mastery of job-related knowledge and skills is achieved through offectiver laboratory and in-plant training. Trainee performance is evaluated effectively prior to qualification and y

independent job assignment.

SUMMARY

Laboratory training and on-the-job training (OJT) provide hards-on activities for students while they leam job knowledge and skills. Handsen training uses approved materials that are performance-based and, depending on the program, include lesson plans, lab guides, self-ctudy modules, OJT guides, job performance measures (JPM's), qualification guides and plant procedures. Materials reflect objectives that are based on job and task analysis. Training administrative procedures provide guidance for the conduct of lab training and OJT.

Task performance evaluation (TPE) is conducted to ensure students have obtained the essential knowledge ard skills required to perform tasks. Evaluators conduct TPE in the laboratory and OJT (in-plant) training settings using job performance measures (JPM's). To pass a TPE, students must successfully complete the performance requirements specified in the JPM which are consistent with plant procedures. Tasks that are designated as

" perform orWy" require students to perform all critical steps or elements listed in the JPM; non-critical steps / elements may be simulated or discussed depending on the environmental circumstan0es at the time of the evaluation. A Verification of Satisfactory Completion form is used to document the results of each task performance evaluation.

Designated, trained, certified and technically qualified personnel conduct task performance evaluations. The individual program 6dministrative procedures and AP 0005767 On-the job Training and Task Performance EvaAsation specify OJT and TPE standards / criteria, controls for consistent and ettective conduct of OJT6PE and guidance for remediation and retesting. The OJT instructor / evaluator training course administered by the training department provides the skills and knowledge necessary for trainirig and plant personnel to conduct OJT ard TPE Personnel are designated qualified to conduct TPE after completing a JPM administered by a qualified OJT instructor / evaluator. A master list of qualified OJT instructor / evaluators is maintained by the training department and is distributed to the appropriate plant department supervision. A representative sample of qualified personnel is identified annually to be observed and evaluated conducting OJT/TPE by designated training staff personnel.

Line management also observes laboratory and on-the job training and task performance evaluation activities and provides feedback to the training department.

Changes Since Previous Accreditation Renewal Task Performance Evaluation Guidance Since the last accreditation renewal. areas to improve the conduct of task performance evaluations were identified during intemal and extemal evaluations. During accreditation reviews, it was determined that some qualified OJTRPE personnel were not aware of the plant procedure providing performance evaluation guidelines and although some personnel were aware of performance policies

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and standards, they were not adhenng to them consistently. This was confirmed during a World Association of Nuclear Operators (WANO) visit during which the evaluator observed coaching during the conduct of task -

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performance evalustsons. To correct this sitution, an OJT Tcsk Tecm wts formed directed by the Maint: nance

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J Trairing Supervssor. The team thoroughly reviewed and revised the OJT/TPE guidance to clearly emphasize management expectations regarding correct performance of there responsibilities. Team actions resulted in 3

i revising AP 0005767 to emphasize on-tha-job training as an instructional process separate from task performance i

evaluation.

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Actua5y, two areas of distinction have been made that have improved communication and practices regarding 1

hands-on trainmg and performance evaluation. ' The first distinction is between the laboratory and OJT as training settings, whereby lab training is conducted in the the Nuclear Training Center labs / shops and OJT is conducted in j

the plant. Trainers in both the laboratory and OJT settings use the same instructional methods (e.g.,

demonstratiorWprachce) and evaluation methods (i.e., TPE). The second is between OJT as the l

Instructional / training phase and 7ask performance evaluation" as the testing phase, whereby each requires cletinctly dlierent methods, process steps and instructor / evaluator responsibilities and skills. For example,CJT instruchon uses demonstrahorvprachce with coachang, but during TPE no coaching is permitted while the evaluator observes the student performing a task. Additionally, to ensure effective lab training, the maintenance I

training group has adopted a consistent, formal lab guide format that includes instructions for prepanno for and conducting the specinc lab that is the subject of the lab exercise instead of generic instructions. Instructors are convering materials to this new format as they prepare for scheduled lab training.

Plant management has placed renewed emphasis en proper performance of TPE used for personnel qualification before independent task performance. The revised procedure on OJT and TPE, along with several other 0f u

products developed by the task team, including job aids, were distributed to all plant personnel on the OJT l

instructor / evaluator qualification list. The package of materials distributed to plant personnel included:

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Cover memo from the training manager stating managerrant j

expectations and directions for maintaining OJT instructor /

i evaluator qualifications List of OJT/TPE problems identified at St. Lucie and the nuclear industry including solutions for each List of major changes to AP 0005767 On-the-job Training and Task f

Performance Evaksation, with the procedural step referenced next to each change j

. Complete revised copy of AP 0005767 approved by the plant manager Po$et size Handbook for On-the-job Training and Task Performance l

Evaksation with expectations stated by the site vice president on j

the insade cover Badge-size laminated card outlining the steps to conducting an OJT dpmonstratiorvpractice and task performance evaluation Blank sign-off sheet to sign after reading all the above and to

retum to training department (included in the package was the j

phone number of a training supervisor for use by personnel who had questions or required clarification)

The master list of qualified OJT instructcrs/ evaluators was updated to include only individuals who retumed a sigrHWf sheet resulting in 57 plant personnel on the list for the maintenance and supporting technical training i

programs. The plant departments have reviewed and reaffirmed their list of OJT/TPE qualified personnel. To reactivate qualifications, plant personnel are required to attend a continuing training class.

All training department instructors attended a mntinuing training class to maintain their OJT/TPE qualifications.

This training covered recent in-house and industry evaluation findings, procedure charges and management expectations regarding the conduct of OJT/TPE. Instructors received the same materials distributed to plant personnel.

The OJT instructor / evaluator initial training materials were revised to reflect the changes to AP 0005767.

Acceptable and unacceptable instructor behaviors durir;g the training phase and evaluator behaviors during the evaluation phase are stressed. This will ensure that all future designated OJT/TPE personnel receive instruction on current policisa and procedures and the skills required to effectively conduct OJT/TPE.

Since the implementation of this improvement effort, a sample of qualified OJT instructors / evaluators has been observed and evaluated and feedback was provided to each individual. Individuals not correctly and consistently irnplementing plant practices were counseled one-on-one to ensure they understood management expectations before ending the feedback session. During the independent team evaluation, a few of the OJT instructors / evaluators were observed and found to be very knowledgeable of the process and they conducted

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OJT/TPE effectively.

j In addition, during the first quarter of 1995, the maintenarce, chemistry and health physics personnel qualified to conduct OJT/TPE will receive classroom refresher training, and those individuals not observed since the improvement action was implemented, will be observed and evaluated conducting a task performance evaluation.

These improvement actions ensure that all appropriate personnel are cognizant of management expectations and

. designated personnel are conducting OJT/TPE effectively.

1 L.aboratory and On the Job Training Conditions Task periormance conditions, references, tools and equipment used during OJT and in-plant TPE are the actual job conditions since OJT is conducted in the plant. The conditions during laboratory instruction and TPE's conducted in the labs / shops, reflect actual job conditions to the extent required to ensure ettective training and evaluation (i.e., mastery of job performance requirements). Relevant conditions are specified in the training materials (e.g., JPM's list required materials, initial conditions, initiating cues).

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y Since the last accreditation, renewal, the maintenance trasning programs have shifted their Gmphasis to providing more handsen training in the labs and shop areas. The maintenance training labs are equipped with numerous models, mock-ups and refurtushed plant equipment. The fotowing'are examples of training aids used during memtenance lab exercises that are: (a) providang hands-on application of principles covered in the classroom (b) g actively irwolving studerts in the loaming process,- and (c) accomplishing TPE in the NTC whch minimizes unnecessary wear on actual plant equipment as well as avoiding situations that could affect plant safety.

Some of the laboratory training aids for l&C maintenance are:

Incore instrumentation (ICl) flange mock-tp -

Lab Volt controller and pneumatic simulators Annunciator training station Paos soldering station General Physbs computer-based troubleshooting module Some of the laboratory training aids for electncal maintenance are:

Eiger queglied safety parameter display Systems (OSPDS) inverter Eiger powerline conditioner 5

Instrument inverter

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Battery charger y

Reactor trip switchgear

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Motor operated valves (MOV's)

BBC load center Motor controlcenter Polar crane controller mock-up i

Some of the laboratory training aids for mechanical maintenance are:

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Reactor coolant pump (RCP) seal mock-up Goulds pump and charging pump Valve test bench Pressurizer safety valve Main Steam Safety va've Reactor model The CT and RPM programs use laboratory training to provide students the opportunity to practice skills and apply knowledge required to perform job tasks. The standard lesson plan format is used to develop lab instructions.

Some of the training aids and equipment for CT and RPM lab exercises are:

hI Dionex lon chromatographs.

Sph.iniac 1001 spectrophotometer Radiation protection equipment I

Totalorgaruc carbon analyzer Gamaspectroscopy/ multi-channel analyzer Computer link to chemistry department's Lab information Management System (LIMS)

A large portion of the CT and RPM programs are completed on the job (see Program Descriptions). Students use self study modules that provide detailed content and instructions to guide leaming (see Objective 5). Designated OJT/TPE personnel provide required OJT instruction and conduct performance evaluations to ensure teaming objectives are mastered and task qualification is achieved. The ESP program uses the plant-reference control room simulator as its laboratory environment during the four-week initial training program (see Objective 7). ESP position-specific qualification requirements are completed on the job.

Instructor /Evalustor Preparation Instructor / evaluator training, job aids and administrative procedures provide guidelines for preparing instructors to deliver lab training, OJT and TPE (see Objective 3). Initial training for training department instructors includes three instructional modules that cover the various aspects of conducting hands-on training: (1) conduct lab / shop exercises, (2) conduct tours and walkthroughs, and (3) conduct on-the-job training sessions. OJT instructor / evaluators complete an eight-hour course that covers management expectations, specific responshilities, required skills, valid methods, approved materials and the steps to conducting OJT and TPE.

Personnel are designated qualified to conduct OJT/TPE after completing a JPM typically administered by the OJT/TPE course instructor. A master list of qualified OJT instructors / evaluators is maintained in the Nuclear Training Conter and is distributed to the appropriate plant department supervision. A representative sample of the runt pe sonnel are observed and evaluated each year to ensure effective ard consistent OJT/TPE. Training tepartment instructors are evaluated annually (see Objective 3 for discussion of changes to this process).

odic management observations of training and task performance also provide feedback.

Besides plant and training management ensuring all designated personnel are prepared to conduct OJT/TPE by providing the above training and evaluation activities, OJT/TPE instructor / evaluators prepare themselves so they effectively implement training and evaluation sessions. To prepare for a demonstration practice, OJT trainers review the task performance requirements in the JPM or OJT guide and plant procedure, review available training materials and plan the demonstration, make notifications to obtain permissions as necessary, and set-up conditions, equipment, tools and/or materials to promote etfective demonstration / practice. Preparing for a task performance evaluation requires essentially the same activities. OJT evaluators review task performance requirements in the JPM or performance test identifying necessary cues, review applicable plant procedures and other required documentation, make any necessary notifications or obtain permissions, and set-up the corditions to ensure an effective task performance evaluation. Student feedback on instructor / evaluator preparedness is 4

typically obtained during or immediately foHowing a training module or block of instruction. Management i

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P-observations also provide feseack on OJT/TPE cffectiveness. Post-training fzedback on instructor /evaluat:r l

sedus and training effectiveness is also obtained as specified in AP 0005757 Systematic EvaAustion.

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The trainmg programs use laboratory activities to develop and maintain personnel's task performance skius and knowiedge. Lab exercises typically follow classroom instrudion such as the Dionex training for chemistry technicians. Some traeung courses are soiety conducted in the lab setting such as the lesson on the plant's structural bolting procedure for mechanics. Lab training is particularly important for developing analytical and tM::9 "-iv sidus. Feeeack from job incumbents who were interviewed during accreditation reviews noted -

that isb training includes troubleshooting and evaluating equipment conditions for repair and often introduces j

"laults" into the equipment. They also commented that working in the training Los is identical to the plant including equipment, tools and procedures except for conditions such as noise, radiation, pressure and energtred equipment. They asid instructors strongly emphasize safety in the lab.

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During instructional activities in the lab,1,1structors establish expectations up front, observe students pisi2,;6v i

sedus or tasks and provide coaching when necessary. Coaching entails asking questions to assess understanding and chauenge thmidng, providmg explanations or other information as students require, and providing

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encouragement to build confidence instructors provide feedback to students on how well they are doing and -

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what they could do better. Incorrect performance is addressed in a constructive way so students continue to do what they're doing correctly and concentrate on fixing misunderstandings. Instructors involve students in g

analyzing their own problems to determine solutions. The following are some examples of lab training that j,

j provide hands-on application of principles, reinforce self-checking and procedure use, improve joumeymen's and technicians

abiply to analyze and troubleshoot equipment problems and make repairs, and/or contribute to improved job or plant performance.

l l&C crews use an incore instrumentation (ICl) flange mock-up to practice disassembling and reassembling

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the flange prior to refueling outages. This training along with on-the-job improvements has resulted in a

' significant reduction in personnel radiation exposure and time spent dcing the job. Specific results as of 1992 were a 50% reduction in exposure and a 46% reduction in time spent and management has observed improvement each year since with the best yet during the Unit 1,35-day refueling outage in 1994.

Bettis actuator training emphasizes safety and self-checking because the consequences of inadequate performance are potentially f atal. During an overhaul of the actuator, l&C specialists practice inspecting this mechanical / pneumatic device to determine il there were any faulty components. During the recent outage, the l&C instructor who taught this lab observed one of his graduates performing the inspection successfuNy.

' During flowscanner training, students practice gathering data on valve assemblies (including positioner, actuator and current-to-pressure converter) to determine their proper function. When connecting the actuator and accessones on the valve, they rnust function together property. This is entical to the proper operation of the 83 -

f assernbly when placed.in service, l&C specialists arG transferring what they Cam during lab training 13 the job.

Since they began using the flowscanner, valves that have een chronic problems in the past are now functioning property when put back into service (e.g., pressurizer spray valves and safety injection tank control valves).

Training on scaffolding is now provided to journeymen mechanics and utilityworkers prior to outages and during the 1994 outages, management observed scaffolding was assembled and disassembled in a most expeditious manner.

During polar crane training, electricians set-up and calibrate a control system per the plant procedure, and test the equipment to ensure it works. Students who cornpleted this training have commented that it had improved their confidence and ability to perform this critical path job during the two refueling outages in 1994.

During EM traming on troubleshooting battery chargers and troubleshooting SCI inverters, the instructor often introduces faults into the lab equipment providing students the opportunity to practice evaluating equipment conditions for repair.

Continuing training for mechanics provides hands-on practice with threaded f asteners using maintenance department procedures. The training reinforces application of an infrequently-used gasket compression method for installing flanges. Feedback from the 86 mechanics was very positive with comments focusing on the opportunity to practice this method.

Chemistry technicians practice and are evaluated conducting analysis tests using a complex Dionex lon chromatograph in the training lab before performing those tests in the plant chemistry lab.

Multi-channel analyzer training for chemistry technicians provides the fundamentals of gamma n*ctroscopy and integrates those fundamentals with state-of-the-art counting equipment operation during lab exercises.

During lab training, RPM's analyze the association of dose and dose rate transmitted from the TeleMerlin onto computer screens and compare this data to what they have observed going on as a result of job coverage.

During airbome radioactivity training, RPM's perform calculations on air sample information converting the information into mrJhr. numbers. These exercises provide RPM's the opportunity to practice converting manrem numbers to committed effective dose equivalent (CEDE) data that they use to calculate the total effective dose equivalent (TEDE).

RPM's use new gas-flow couters and multi-channel analyzer equipment during lab training. They practice 4

preparing the counting equipmern for use. They verify the equipment is working and perform troubleshooting to identify any f aults, making readjustments or running tests as necessary and comparing results to sta,dards in calibration files.

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Laboratory Evaluation Evaluation of student performance is conducted using approved performance-based examinations. Essential j

knowledge and cognitive sidus covered during classroom instruction that precedes lab activities are measured g

using written exanunshons (see Objective 5). Harx!s-on performance of psychomotor skills, tasks and cornplex procedures that are covered during thb instruction are measured using task performance avaluations conducted in the lab setting (see " Task Performance Evaluation

below).

f Or>the Job Training

- The training department maintains an OJT Instructor / Evaluator Qualification Master List that includes the Individuals who are qualified to conduct OJT, The Hanchook lbr On-the-job Training and Task Performance i

Evabation provides desenptions and guidelines regarding OJT methods and materials and the OJT instructor's responsbluties and important sklus required to conduct effective OJT. One of the key responsbluties of OJT f

i trainers is to exhbit and erryhasize to the student the importance of safety, work quality, self-checking, teamwork

- and offident communication practices. Critical sklus of the OJT trainer include coaching, provuhng fecesck, j

reinforcing correct performance and assessing student readiness for task performance evaluation. OJT materials are developed and approved hs,.GQ to AP 0005756 Systematic Training Development, and depending on the l

program, include self-study modules, OJT guides, job performance measures (JPM's), job aids and plant procedures. Maintenance training uses plant procedures and JPM's during OJT. Chemistry and HP training uses self-study modules and OJT guides that include performance tests and require the use of plant procedures as appropriate. Methods used for training on the job consist of self-study, observation, discussion, walk-through,

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sitnulation and demonstration / practice (the preferred method).

The following are the steps to effectively conducting a demonstration / practice-Tell the student that s/he will eventually perform the task to be demonstrated without assistance Tell the student what to notice in the demonstration Perform the task to standard, desenbing each step before doing it Prior to practice, require the student to recall critical steps During practice, require the student to explain and then do each step Assess performance, provide feedback and a)ach as necessary Each program includes tasks selected for OJT. Prerequisite knowledge and cognitive skills required to perform j

these tasks are covered during classroom instruction or self-instruction prior to hands-on training. The training for a

many of these tasks comendes with scheduled outages, for exarnple, crane qualification training occurs a few months preceding scheduled refueling outages.

' Task Performance Evaluation Task performance evaluation (TPE) is conducted in the laboratory and in-plant settings. TPE determines if a

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student can independently perform a specified task to standard. TPE provides documentation that cnables department management to qualify its personnel to independently perform work assignrnents. Only designated individuals conduct TPE at St. Lucie. Qualifying plant personnel using this process ensures safe and reliable plant operation. AP 0005767 and the Handbook for On-the-job Training and Task Pertonnance Evaluation delineates the evaluator's responsibilities including the following:

Verifying students have met prerequisites and are ready to be evaluated Planning for and maintaining control during TPE to ensure plant and personnel safety 4

Conducting TPE using approved evaluation instruments and procedures Ensuring students perform critical steps and meet standards Exhibiting professionalism and integrity by not coaching and not.

providing directions and asking questions that are not in the test Documenting completion and serdng it to the training department-Recommending additional training when a student f ails Job performance measures are used to conduct TPE. JPM's include directions to the evaluator and student, the applicable testing modes (perform / simulate / discuss), task conditions and standards, required materials, cues and j

a performance checklist listing steps and standards and designating critical steps. The development, administration, and security of performance examinations are conducted in accordance with processes specified in AP 0005756 Systematic Training Development and the Handbook. The Independent Team Evaluation revealed the process for designating critical steps on maintenance JPM's was not consistently applied due to unclear understanding of the meaning of " critical step" as it applies to JPM's. Since maintenance JPM's were procedural driven, all steps were considered critical and all steps had to be performed, thus this situation did not result in any inappropnate qualifications. However, to ensure consistency throughout the training department, the meaning of " critical step" was clarified, procedural guidance was reviewed and improved, and all maintenance JPM's were reviewed and revised as necessary to ensure critical steps are appropriately designated.

The following are the steps to effectively conducting TPE:

Tell the student that s/he will perform (or simulate, or discuss) the task to be evaluated Inform the student of task conditions, initiating and terminating cues, ark 1 standards for the task s/he is expected to do Tell the student to explain each step before doing it Ask the student if s/he has any questions before the formal evaluation begins 4

Tell the student to begin the task and observe performance Assess performance against standards and document results 4

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i Students are provided sufficient opportunity to practice tasks under the supervision of a training instructor or l

quaillied incumbent prior to task performance evaluations. Once the student begins performing the task during TPE, s/he is not permitted to ask questions or receive any form of assistance from the evaluator other than using f

the specified plant procedure (s) required during actual task performance. After performing the task, the evaluator attends to any questions the student may have. Evaluation results are documented on a Verification of Satisfactory Completion form. Performance standards and the guidelines for remediation and retesting are i

specNied in the training program's administrative procedure and AP 0005767.

j If a modent does not successfully complete a task performance evaluation, the evalualo'r assets the student in determrung the cause of the failure and recommends remedial training activities to ensure success during a whaa9=nt attempt. The unsatisfactory attempt is documented on the Verification of Satisfactory Completion form, which is retained and used to document results of subsequent evaluations. Completed forms are used to update the student's qualification records and are stored in the individual student files in the training remrds room until they are transferred to the plant's documentation control department as required by plant procedures.

During the position-specific qualification segment of the ESP program, stuP.s are evaluated by supervisors to ensure they have the knowledge and abilities listed in departmental qualification guides. There is a qualification i

guide for each job position that makes up the ESP target population. Departmental procedures and guidelines J

provide specific guidance for mmpleting these requirements.

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CONDUCT OF SIMULATOR TRAINING AND TRAINEE EVALUATION OBJECTIVE 7: Trainee mastery of job-related knowledge and skills is achieved by effective simulator training. Trainee performance is evaluated effectively.

SUMMARY

The plant-referenced control room simulator is used like a lab for some ESP and I&C lessons. The ESP program uses the simulator for demonstrations that are sequenced to follow systems training and are provided in support of the Integrated Plant Operations segment during the initial orientation training. The simulator sessions are designed to improve ESP students' overall knowledge of systenveguipment operation and to develop a better understanding of off-normal and emergency operatbns. Qualified simulator instructors conduct the practical demonstrations in the simulator including reactor startup and shutdown, and transient and accident scenarios. ESP students have commented that these simulator sessions have been beneficial.

The 18C lesson on the reactor protection system (#1702630) uses the simulator at 100% power to illustrate Channel A system logic to l&C specialists being trained in logic matrix testing. Student feedback on this training in the simulator has been positive. The l&C program also uses several part-task simulators during lab training, e.g., process control simulators and control element drive mechanism system simulator.

Using the control room simulator for ESP and l&C training does not impact simulator training for licensed operators. The other programs submitted for accreditation renewal do not include training in the simulator.

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y SYSTEMATIC EVALUATION OF TRAINING EFFECTIVENESS OBJECTIVE 8f A systematic evaluation of training completeness and effectiveness is conducted. The results are used to modify the content and conduct of training programs, as appropriate.

SUMMARY

A process for the systematic evaluation of training effectiveness and its relationship to job performance is fully and effectively implemented. Guidance for evaluating accredited training programs is provided in AP 0005757 Systematic Evaluation of Training Et/ectiveness. The procedure provides guidance for a wide range of ongoing and comprehensive evaluation activities. Appropriate industry guidance documents supplement this guidance. Results of these evaluations, since the previous accreditation renewal, indicate the programs are being conducted effectively. When weaknesses are identified and verified, improvement action is taken in a timely manner. Improvement actions are monitored to ensure weaknesses are corrected and to prevent recurrence. Evaluation and feedback are provided by the following activities that are discussed in this section of the report:

Student course critiques instructor course critiques Job incumbent feedback Job supervisor feedback Training interface meetings Management observations instructor evaluations OJT/TPE evaluations Contractor training evaluation Training department indicators Exam evaluations Training relevancy reviews (change actions; operating experience)

Quakty assurance audits i

Extemal evaluations Training Plan needs assessments St. Lucie Action Report (STAR) rnonitonng Training System Action Request (TSAR); Resource Action Request (RAR)

Accreditation reviews Accreditation self-evaluation report preparaton Independent team evaluation i

Feedback is analyzed for indicators of the quality and effectiveness of training and summaries of feedback and recommendations for, review /improvemer't ac routed to training and plant department personnel. Modifications to the content or conduct of training bared on enange actions, operating experience and program feedback are Initiated, traded and implemented using the training relevrncy review cnd r;; vision / development proc;sses outilned in AP 0006766 Training Resources, Information and Material Control. A cornputerized system for relevancy reviews and revision / development work provides historical and in-progress data. Critical self evaluation,

of accredited programs is conducted using the objectives and criteria in ACAD 91015 The Objectives arzf Criteria k

' for Accred#stion of Training in the Nasar PowerIndustry and is consistent with the processes outlined in ACAD 91 016 The Process kr Accredkation of Training in the Nuclear PowerIndustry, Strength During 1993, training management initiated a review of the program evaluation processes. This effort resulted in 4

estathshing an ongoing and comprehensive accreditation self-evaluation methodology that has resulted in i

training program and process improvements and identNication of indicators of training quality and effectiveness i

that reflect customer satisfaction, performance resuNs and process efficiency. The new methodology was implemented beginning in January 1994 and consists of four phases: (1) ongoing evaluation and teostasck, (2)

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ongoing accre,mahan reviews. (3) self-evaluation report preparation, and an (4) independent team evaluation. A description of each phase is provided in the introduction to this repost (see introduction *SeN-Evaluation l

Methodology

section on page 6). As noted in the introduction, two addWional ingredients are key to St. Lucie's j;

crtical seN-evaluation process, namely,line management involvement and oversight and the use of a corgutorized accredNation information management system. The followir@ discusses each.

i Line Management involvement and Oversight c

j Line and training management are committed to a critical self evaluation of their accredited training programs and verNication that improvement actions are successful. Line management is involved in ongoing monitoring and 5

participation in seN-evaluation activities including: (a) business plan monitoring, (b) Plant Training Advisory Board l.

'and Training Review Cornmittee meetings, (c) management observation of training and performance, (d) accreditation reviews as interviewees, (e) self-evaluation report review (f) and independent team evaluation as interviewees. The following is a brief description of management involvement.

Accreditation renewalis a business plan objective and is closely monitored by the Plant Lead Team. The lead team meets weekly to review the status of business plan activities. Team members include the site vice-president, plant general manager, operations manager, maintenance manager, technical manager, services i

manager, licensing manager, site engineering manager, outage manager, construction services manager, nuclear material management manager, human resources manager and training manager. On a monthly basis, the lead team reviews the status of accreditation self-evaluation activities and action items to ensure they are on schedule, and that adequate support is provided and any necessary adjustmerits are made. Self-evaluation activities and action items are also reviewed at PTAB and TRC meetings (see Objective 2 for discussion of PTAB and TRC's).

Management observations of tr2Lmng and performance provides for direct observation of improvement actions as a result of seN evaluation activities (see Objective 2

Changes Since Previous Accreditation Renewal" section for

/l damenhn and examples of management observations).

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During the accreditation reviews conducted through June 1994, approximately 80 line managers, supervisors and job incumbents were interviewed for f eedback on their training programs. These interviews involved line personnel in a detailed self-assessment of how well their training programs meet the accreditation objectives and criteria. As a result, specific examples of training quality and effectiveness were identified and specific improvements were made to training programs and processes. These have been described throughout this report. Line management also reviewed the self-evaluation report and participated as interviewees in the week-long independent team evaluation that parallels an accreditation team visit. During the independent evaluation, over 40 line managers, supervisors and incumbents were interviewed, and the following week, line and training management reviewed the evaluation results during a PTAB meeting to determine any necessary improvement actions. Results of these final self-evaluation efforts have been incorporated in this report.

Comnuterized Accredltgrtlon Information Management System A computerized accreditation information management system is used to organize information related to accreditation renewal activities. The system provides on-line ' access for training management and staff responsible for monitoring and ensuring activities are successfully accomplished. A directory is established on the training department's local area network (LAN) for storing data files related to the maintenance and training accreditation renewal. Adequate write-access controls are used to ensure the validity and accuracy of information in the system. The system includes two major components: (a) self-evaluation data, and (b) accreditation renewal schedule. The following is a brief description of each.

The "self evaluation data" files are organized based on each section of the self-evaluatbn report. As accreditation reviews are conducted, data is reported in the appropriate sections of the files for each training program. This data provides on-line information about the status of how each program is meeting specific accreditation criteria and examples of program results. The data is used to prepare objective summaries and.

crit:ria responses for the accreditation self evaluation report (ASER). This system provides management the opportunity to print-out and review the ASER and supporting data at any time during the accreditation renewal period, in essence, a "living ASER".

The " accreditation renewal schedule" file provides online information regarding all scheduled accreditation activities from initial preparation for self-evaluation through to the final Accrediting Board presentation. The status of cach renewal activity is updated periodically providing training management and staff a tool for managing resources and monitoring progress. Specific improvement actions implemented in response to self evaluation results are incorporated in the renewal schedule and tracked to completion.

St. Lucie's systematic self evaluation methodology,line management involvement and oversight, and computerized accreditation information management system combined provide the key ingredients to ensuring a well-managed and critical self-evaluation that (a) leads to meaningful improvements to training programs and

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f' processes, and (b) resuts in engoing training effectiveness recognized in improved personn 1 and plant performance. Examples of improvements and results are provided throughout this report and some are summarized below.

Evatusting Feedback from Managers, Supervisors, Trainees and Former Trainees Fecesck from managers, supervisors, job incumbents and students is obtained periodically to evaluate tranng activities. The process specified in AP 0005757 Systematic Evaluation of Training E#ectiveness delinestes suggested frequency of data collection, analysis of data, disposition of summary analyses and subsequent responst2 ties to address suggestions or recommendations for improving training program content or methodology. Supervisors and managers provide feedback through training interface meetings and periodic j

departmental meetings Line personnel as well as training staff may use the processes outlined in AP 0005766 Training Heaources, information and Material Controlto initiate improvements to training programs and materials.

. The fotowing are some examples of feedback used to evaluate training effectiveness and improve training +

programs.

r Studert critiques Some examples of improvements to ESP orientation training as a result of student critiques include the following.

Students said the whole lesson on 10CFR50.59 was too much and wanted more on the PC/M process. In i'

response,50.59 information was reduced and incorporated along with the PC/M process in the Configuration Managemord lesson. Students requested some lessons be lengthened. The lesson on engineering drawings p,

was expanded from three to eight hours, and the CVCS lesson increased from four to six hours. Sequence Q

changes include placing the main turbine lesson before the feed and condensate lesson. Other improvements include a management introduction, a pretest, adding mid-week quizzes and plant walkthroughs, and making i

available a full set of P&lD drawings.

3 A review of the 1993 student critique data collected at the end of MM training classes indicates the instructors

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were rated very good to excellent by the students. The student course critiques for all classes averaged over 4.0 on a scale 1 5. l&C students interviewed during accreditation reviews commented that the instructors were very knowledgeable (" experts") on the technical content of the courses they conducted, keep up-to-date with the changes to plant equipment and systems, and were good communicators who added value to their training.

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instructor critiques i

improvements are often made as a result of instructor critiques. For example, the chemid.*y instructor initiated

' development of a lab course on the operation and maintenance of Dionex lon chromatography equipment to replace the sell study materials. With the chemistry department head's and training supervisor's approval, the lab instruction was developed, provided during continuing training in 1991, and incorporated into the initial program.

7 Often during outages, instructors check the effect of procedure changes, that were incorporated in training

. materials, on plant equipment and/or watch crews implement the changes after they have been trained. For example, the EM instructor observes crews performing grounding and high voltage testing for implementation of f

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. safety considerations reviewed during requalification training. While pert:rming in-plant cutags assignments, the j

i l&C instructor observed rod control maintenance that was covered during pre outage training.

Paat-traininn feedback

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' Post-training feedback from MM job incumbents and supervisors regarding the effectiveness of laser alignment -

training has consistently indicated its value to improved personnel performance. In response to feedback from

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i, chemist'ry technicians and their supervisors, the position rotation requirements were modified. Prior to sotating to

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a drierent area of responsibility, instead of the chermstry technician retaking all initial training associated with that j

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area, a chemistry grom supervisor evaluates the technician's astrent level of knowledge and skills completing f

specially designed rotations checksheets to identify individual training needs

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Line leadnad durina accreditation reviews in Adr81994,'one of the ongoing accreditation review teams consisting of staff members from the corporate office I

and an INPO peer evaluator interviewed 32 line managers, supervisors and job incumbents and found that overall l

1 line personnel rate the cromility of instructors and the quality of training very high and that trasning is very 4

responsive to the requests from the line organizahons s

Training Revww Committee (TRC) l in response to maintenance management's request, the programs were redesigned to provide core training that results in initial qualification and advanced training for designated joumeymen on complex and specialized tasks, j

and qualification at the duty area level versus after each task performance evaluation. Training curriculum is also modified as a result of TRC acthns in order to meet plant needs. For example, the EM department head requested training on forklifts and working in confined spaces be moved from the advanced to the initial training

program Specific lessons from the courses on pumps and on valves were moved from the advanced to initial i

training for mechanics. A soldering course was added to the advanced training curriculum for l&C specialists and l

a soldering refresher is now provided as requal training.

During a TRC meeting prior to the 1994 Unit 2 outage, the EM department head identified several electricians for

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polar crane maintenance qualification. A newly developed lab guide included lessons teamed from in-house operating experience and the use of a polar crane trainer for demonstration, individual hands-on practice and task performance evaluation. Feedback from electricians indicated this training was effective in preparing them to efficiently and accurately inspect, operate and maintain the polar crane during the outage. During a TRC 3

meeting, the MM department head requested that personnel in the mechanical maintenance engineering group become familiar with the use of the flowscanner because they have collateral responsibilities. Personnelin this q

group began to attend Level 11 flowscanner training with l&C specialists in October 1994.

-- Plant Traimng Advisory Board (PTAB)

Traimng on le'ak repair events was provided during ESP continuing training in response to plant management's suggestion at a PTAB meeting As a result of a PTAB meeting, the cperations and maintenance managers t

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expedited implementation of position specific qurlification guides that ce En ESP program requirement.

Joint Training Assurance Board fJTAB)

Coordmated through JTAB, training that was directed by Nuclear Division management, was provided on.

Handling Employee Concems for supervisors and Problem identification and Correction (PIC) for selected personnel Selected instructor training classes have also been a result of JTAB initiatives including the Accolorated Learning Workshop, CBT Producer Authoring System trsining and a course on Simulations and j

Games initially developed by staff for Turkey Point and attended by selected St.' Lucie instructors.1992 and 1993 JTAB adivities coordinated efforts during the development of the ESP program involving both plant sites and corporate engineering staff and facilitated staff engineer participation in site orientation training.

After a self-assessment of corporate training staff activities conducted by a team that included the trairung managets from both St. Lucie and Turkey Point, JTAB approved team recommendations that resulted in increasing staff support for coordination of accreditation renewal activities and expanding accreditation review activities. These improvements are resultity in more efficient use of resources and sharing of peer evaluators and lessons loamed between the two plant sites.

President's Training Undate meetmas As a result of site trammg managers participating in the corporate training manager's update meetings with the Nuclear Division president, more efficient development of nuclear policies has occurred including a policy on examination standards and on management observation of training and qualification programs.

Monitoring Training in All Settings The conduct of training is monitored and evaluated in all training settings using several evaluation methods.

Instructor performance is evaluated according to requirements in AP 0005735 St. Lucie Plant Training /nstructor QuaWication and ReguaWication. Instructors receive instructional skills and technical skills evaluations. Plant

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personnel qualified to conduct OJT/TPE are also observed and evaluated. Management observations of training are conducted in all training settings. Observation forms guide ratings of instructor characteristics, student

. performance during training and program content and delivery. Observations focus on whether or not i

management expectations have been met and the observer provides written comments when appropriate. During a

ongoing accreditation reviews, team members conduct observations of training in the different settings and provide feedbad that may be used to improve training programs. Feedback from other internal and extemal evaluations also may be based on observations of training. The following are some the results of monitoring and evaluating the conduct of training.

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Manaaement observatens When the mechanical maintenance department head observed mobile crane training ior maintenance mechanics, a different crane was brought on site to use for training because the manager believed that the one that was f'

.j being used was inadequate. An l&C supervisor identified an incorrect drawing being used during Bettis actuator i

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y overhaul training for l&C specialists and the correct drawing was obtained and incorporated in the training materials and used during subsequent classes. The M department head observed students helping each other and sharing lessons learned from their past experience during diesel preventative maintenance training. He reported that the task practice was a realistic simulation of on-the-job requirements.

instructor evaluations Instructor evaluations identified a need to improve instructional techniques that lead to scheduling accelerated leaming workshops for instructor continuing training. As a result, instructors are using a variety of creative techruques such as ice breakers, games, simulations, team exercises / presentations, cok)r in visual aids and others (see Strength at Objective 3).

OJT/TPE evaluations During aa,reditation reviews, interviews with cualified OJTTTPE personnel and observations of task performance evaluations (TPE) IM;cated some person 3el were not aware of the plant procedure on performance evaluation and others who were aware were not consi:,ter.ly implementing the procedure. This resulted in improving the j

procedure, developing job aids and revising OJT/TPE training to provide clearer instructions and emphasizing management expectations regarding the conduct of OJT/TPE (see Objective 6 " Changes Since Previous Renewa!").

Evaluating Trainee Performance Feedback from student performance on examinations during training is used to evaluate and modify training

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l programs. Exam scores are recorded in information management systems providing a historical record of student performance on exams in each training course. This information is monitored by program staff to identify any trends in student performance that may warrant program improvement. Student progress toward completion of

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training program requirements and remediation information is documented in annual training plans for training i

management's ongoing monitoring. Instructors also perform test item analysis on written examinations to identify I

high error rate items that may warrant further analysis. This item analysis process is outlined in AP 0005754 Written Examination Administration and Control. The following are some examples of improvements made as a result of evaluating examinations.

Exam evaluations The RPM instructor used students' written exam results as the basis for making changes to the lesson plan and exams for continuing training on airbome radioactivity. Follow-up interviews with students provided feedback that indicated the students liked the small group sessions, which consisted of about five students, because they could discuss the content in more depth than when the instructor uses the lectore method. When an RPM student did not perform well on systems questions during an oral board with the HP operations supervisor, the supervisor requested training provide more emphasis on systems during RPM initial training. Changes were made and the next three students performed stronger in this area during their oral exam.

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Evaluaung change Actions

' Change salons are monitored and evaluated for initial and continuing training applicability using the training

' relevancy revsew process specified in AP 0005766 Training Resour'ces, Information arid MaterialControl. Job scope changes, procedure changes, plant change / modifications (PC/M's) to systems or components, technical

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specification changes and regulatory changes are all systematically reviewed. In addition, results of intemal and extemal evaluations and inspections may trigger changes to training programs. 'If a change action is determined to be training relevant, they are incorporated into initial and continuing training using the revision / development process specified in AP 0005766 (see initiating, Trading and incorporating Changes to Training Programs" below for a descripton of these processes). The information management system used during these processes estabhshes a mechanssm for providing historical data and determining the current status of any change initiative.

The following are some examples of program improvements or training provided as a result of change actions I

including some feedback on training effectiveness.

l Job sconechanges Training provided on the Bettis and ITT-Barton actuators is now provided for 180 specialists because the plant has assumed responsbility for maintenance of this equipment that was formerly performed during outages by contractors. Training was provided to chemistry technicians on the atomic absorption spectrophotometer to support changing plant methods and the purchase of new plant equipment. Some of the new equipment installed In the health physics department include the Telemerlin obtained in 1993 and used by the RPM's, and the new body counter and portacount respirator fit testing equipment obtained in 1994 and used by the HPDT's.

Associated tasks were identified and training was developed and implemented for the technicians.

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Plant chanpen/ modifications (PC/M)

During 1993,150 specialists reviewed PC/M's involving the control element drive mechanism and the Fisher and Porter microprocessor controllers. Continuing training for chemistry technicians during 1993 covered a PC/M and reviewed how air ejectors affect condensate dissolved oxygen.1991 continuing training for mechanics included the PC/M on Goulds pump shaft sleeve roll pin modification.

Procedure chances During the 3rd quarter of 1994, MM continuing training included a hands-on laboratory exercise during which joumeymen implemented revised procedural guidance included in M-0039, Threaded Fasteners, and reinforced application of an infrequently used gasket compression method for installing flanges. Feedback from 86 participants was strongly positive about the opportunity to practice this method. Continuing training for chemistry technicians in 1993 included a new procedure on control of hazardous toxic chemicals draining to the erwironment.

Industry guidance changes

. With the issuance of ACAD 91017 Guidelines for Training and Qualification of Engineering Support Personnel, the manager / technical staff training program was replaced with the ESP program that is based on the new 96 -

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guidegnes.' As a result of accreditation reviews and using the revision to ACAD 90-010 Guidelines for

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Maingsnance S@ernsor Sedsction and DeveAppment, a job familiarization component was added to the MST i

program that includes the areas racommended in the revision as minirnum requirements for new supervisors as wet as others. The new self-evaluation iiwo,wk,;vgy used during this round of accreditation renewal was i

j developed using the guidance provided in the revision to 9,1-016 The Process for Accreditation of Tranung in the i

Nuedser Anwer Andusey.

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Raoulatory channes In 1993, chemetry technicians were provided continuing training on environmental comprehensive quauty -

assurance that was based on new regulatory requirements. During accreditation review interviews in 1994, the j

HP department head indicated that training has contributed to a smooth transition in implementing the new 10 CFR 20 requirements due to a joint effort by the HP and trasung staffs that included conducting three pilots before

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irgismenling the RCAT requal program resulting in a low failure rate and high understandmg by plant and s

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tergorary personnel who worked during outages. These results coupled with continuing training for RPM's,.

i aggressive engineering controls and decontamination efforts, yielded a significant reduction in the use of resprators-from 2,600 resperators during 1992 Unit 2 outage to less than 300 during 1994 Unit 2 outage, and no intomal dose was received during this period (this strength was noted in the 1994 WANO evaluation report). In j

i March 1994, an NRC inspector reviewed lesson plans, handouts and examinations administered to RPM's dunng

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their continuing training on the revised 10 CFR Part 20 changes and based on this review, observations of RPM's j

performmg work and discussions with plant personnel, the inspector reported that overall "the RP technecian staff appeared knowledgeable and well trained",

Freemal evaluatinns (NRC? INPO: WANO)

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The 1992 SALP report noted that the maintenance training programs were strong citing in particular the " training j

I faciuties and programs in the area of motor operated valves were good... training materials in tive area of service water were thorough and of high quality... also the training program was well presented and i

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comprehensive". In May 1994, the World Association of Nuclear Operators (WANO) report cited two strengths j

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(see introduction) and noted some weaknesses. Some of the training observed failed to address all the root causes of performance deficiencies that the training was designed to address and some of the instructors were l

coaching during the conduct of task performance evaluations (TPE). Corrective actions were immediately taken including issuing plant policy guidance for developing training designed to address performance deficiencies or ne l

specific plant events, and specific improvements to ensure the effective conduct of OJT/TPE (see Objective 6 for details on the latter).

Quality assurance audes

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In June 1994, a OA audit of the three maintenance programs was conducted. The auditor observed training i

classes that covered QA findings related to main steam safety valve testing and BAM pump repairs. The auditor 4,

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(y concluded that the training programs met the goal of establishing performance-based training programs that j' ;

" asset maintenance personnel in achieving the skills and knowledge necessary to perform assigned duties,in a I

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Y professional enanner and promote sata cnd rIliable operation cf St. Luch Plant". A OA audit conducted in October 1994 resulted in reporting several strengths (see " Training Quality and Effectiveness" section in the Introduction).

- Evaluating Operating Experience Lessons leamed from operating experience are evaluated for training applicability employing the training relevancy review process specified in AP 0005766 Training Resources, Infortnation and Material Control. If determmed to be traimng relevant, operating experience is incorporated into initial and continuing training using the rev6servdevelopment process specified in the same procedure. The following are some examples of program improvements or traitung provided as a result of evaluating in-house and industry operating experience, in-house events (IHE)

During a continuing training session in 1993,180 specialists discussed an in-house event involving the misidentification of a module in a Foxboro " nest" in the control room and reviewed how to locate the correct module, and an in-house event involving MOOG safety valve repair including safety precautions to preclude personalinjury from parts propelled by high electro-hydraulic pressure. In 1993, EM personnel reviewed lessons 4

loamed as a result of LER 93-006 on an unplanned start of the 2B emergency diesel generator, IHE 93-031 on an 2

SCR failure and lHE 93-035 on the oxidation of intemal wiring in Westinghouse protection relays. In 1991, they revn,wed an in-house event on the 1 A containment spray pump's failure to start. Lessons leamed from a May 1993 event involving incorrect installation of the bearing housing reservoir oiler on the Unit 1B low pressure safety injection pump have been incorporated into the initial training module on lubrication that is presented during the

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Mecharucal Fundamentals segment of the program.

4 Human Performance Evminnen System (HPES)

Eight days after a near rniss occurred on September 14,1994 caused by a f ailure to self-check, continuing

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training was provided for EM personnel that was observed by the maintenance manager, EM department head and an operations training supervisor who reported that the instructor's performance, students' performance and training effectiveness all met management expectations.

l Job performance trends Based on observations of job performance, the maintenance manager requested an informal seminar be provided j

just prior to the Unit 1 refueling outage. Within a week, a seminar on rework and plant equipment clearances was presented to maintenance personnel that included job relevant examples provided by the manager and emphasized attention to detail and the importance of ensuring the job is done right the first time.

industry Ooeratino Exoerience During 1994, l&C specialists reviewed lessons leamed from Westinghouse OMM 016-1 regarding the substitution

. of SAF-T EZE for FEL PRO C-5A lubricant and SER 17-93 regarding undetected loss of shutdown cooling.

J Among the industry events that EM personnel reviewed in 1992 were NRC Notice 9213, inspection Report 92-04 98 -

y and three notices of violations, as well as INPO OE-5095 and OE-5607. In 1991, they reviewed lessons leamed from INPO OE 4521,4591,4594, O&MR 384, and SEN-80 on a blown control fuse were covered, as well as NRC Special Report L-9155 on the 2B emergency diesel generator. Some examples of industry operating experience covered in MM continuing training include NRC Information Notice 90-46/ FOP 90-085 on unplanned radiation exposure to personnel extremities, INPO O&MR-392 on improper assembly of vertically oriented check valves, SER 891 on testing of turbine overspeed trip devices. SOER 92-1 on reducing the occurrence of plant events through improved human performance, and INPO SEN 104 on recurring events.

Enhancing Safety and Reliability of Plant Operations improvements and chan0es to training prograrns that could enhance the safety and reliability of plant operations are solicited from plant personnel during several ongoing evaluation practices. Post-trair:ing interviews and surveys provide feedback from job incumbents and supervisors that sometimes reflect plant safety and reliability llems. During PTAB and TRC meetings, management provides feedback to training. The training relevancy review process establishes a mechanism that ensures all change actions and operating experience documents are systematically reviewed. The contractor training evaluation process ensures any items that could affect plant safety and reliabihty are addressed in the training if applicable. The plant uses a St. Lucie Action Report (STAR) monitoring system that would include any training activities related to plant safety and reliability. Needs assessments conducted to prepare annual training plans is another mechanism. The following are some examples of these evaluation activities.

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Trainino Plan needs assessments Each year as annual training plans are prepared, program staff and plant department supervision assess their target populations

training needs and use this information to select continuing training content and/or make improvements or changes to training programs. Each program's TRC approves training schedules and program changes. This process ensures that training which could enhance plant safety and reliability is solicited annually.

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St. Lucie Action Recort (STAR) monitorina Continuing training for RPM's on a PC/M involving configuration conflicts and minor enhancement rnodifications to the containment radiation process monitor was an action item menitored through the STAR system to ensure all personnel were updated immediately following the outage when the nadifications were made.

Onacino PTAB and TRC Meetinas in 1993 when the plant initiated a self-checking program, the Chemistry TRC approved continuing training for all technicians that oriented them to the principles and practices of Stop-Think-Operate-Prove (STOP). At l

management's request, training on shutdown risk and outage management was provided during ESP continuing training just prior to a refueling outage. MM continuing training was used to " field test" plant procedure changes made in 1994 involving threading and unthreading reactor head studs. This field testing done prior to the Unit 2 f

refueling outage identified some deficiencies in the revised procedure that were addressed before the procedure was implemented during the outage. j

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L To ensure safe and competent job performance of utilityworkers (a recertly established job classification), an.

initial training and qualification program was designed and uses approximately 126 hours0.00146 days 0.035 hours 2.083333e-4 weeks 4.7943e-5 months of classroom instruction, _

in-plant training and task pe 1ormsTe evaluations from the joumeyman's initial program including maintenance N

fundamentals topics, rigging, forklift, scaffolds, equipment clearances, working in confined spaces and operating experience.

Post-training feednack During post-training interviews, some of the comments provided by job incumbents indcated how trairung has i

enhanced their performance and the safety and reliability of plant operations. For example, ESP students have noted that the training has helped them to understand better how the plant operates, how the non-safety and j

4 safety systems work together and which non-safety systems are still critical to keeping the plant online.

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Chemistry students have noted that because of the knowledge they gain during training: they make better j

decisions, they have much more confidence that what they are doing is correct, and they can challenge analysis j

i results.' RPM Job supervisors commented that the plant is safer as a result of medical and emergency drRI training because RPM's wosk safer, are better at monitoring radiological conditions, and have reduced radwaste and l

square foot contamination.

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initiating. Tracking and incorporating Changes to Training Programs l

The Training iniormation Management System (TRIMS) provides a computerized mechanism to initiate, track and incorporate improvements and changes into initial and continuing training programs. The system generates h[

monthly status reports indicating program activity and performance for training management monitoring. AP 0005766 Training Resources, frWbrmation and Material Controloutlines the training relevancy review and j

revistorVdevelopment processes. These processes have been identified as strengths during intemal and extemal

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2 evaluations. The relevancy review activities ensure accountable, documented responses to any potential change

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initiative. The revisiorvdevelopment activities ensure the incorporation of changes into initial and continuing training.

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i Change actions, operating experience and program feedbadc are evaluated to determine their relevancy to specific initial and continuing training programs. Each document is assigned a Training System Action Request (TSAR) that is used to initiate and track the relevancy review. It determined to be relevant, a Resource Action Request (RAR) initiates the revisiorVdevelopment process. An RAR is like a training work order that is used to j

track incorporation of improvements or changes to training materials. TRIMS provides for computerized

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recordkeeping of the historical and in-progress relevancy review and revisiorVdevelopment activitin. The system has proven to be an effective work planning and tracking method for training management and supervistort

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Ongoing and Comprehensive Reviews of Training Programs The methodology used to conduct ongoing and comprehensive reviews of individual training programs is -

j described in the introduction to this repott (see Self Evaluation Metnodology section on page 5) and as a strength 5

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i at the Obpective 8 summary. This critical self evaluation process his resulted in improvements to training l.

programs and processes, whch are described throughout this report. For example, an irnprovement effort was l

initiated to upgrade the quality of training materials (See Objective 1 ? Program improvements in Progress").

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These irrprovements are resulting in rnore consistent delivery of instruction, more active leaming by students and positive feseack from students as well as management who observe training in-progress. Critical self evaluation has resulted in increased management observation of trairung in-progress (see Objective 2) and improved communication and practices regarding OJT/TPE (see Obtective 6). Other examples of improvements as a result of ongoing accreditation reviews and the independent team evaluation are identified throughout this report.

Accomplishments are also identified during self-evaluations including strengths regardin0 academic credit for l

initial training programs (see Objective 1), enhanced technical and educational qualifications of training staff (see -

i Objective 3), and increased use of creative traming techniques and advanced technologies (see Objective 5).

j Finety, crtlical sell 4 valuation has identified irrproved personnel and plant performance resulting from trainin0 and examples are also descussed throughout this report.

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ATTACHMENT 2 POLICIES AND PROCEDURES NUCLEAR POLICIES (forTraining)

NP-900 Systems Approach to Training NP-904 Operating Experience Feedback Program NP-911 Training Examination Standards NP-914 Management Observation of Training and Qualification Programs ST. LUCIE PLANT QUALITY INSTRUCTIONS Ol 1-1 Site Organization 011 2 Operations Organization Ol 1-3 Maintenance Organization 011-5 Technical Staff Organization Ol 1 10 Training Organization 012-2 Indoctrination and Training of St. Lucie Piant Personnel ST. LUCIE PLANT ADMINISTRATIVE PROCEDURES AP 0005728 Reactor Engineering Department Training Program AP 0005730 l&C Departmental Indoctrination Guidelines AP 0005732 Outage Management Training Program AP 0005735 Training Instructor Qualification and Requalification i

AP 0005737 Health Physics Training Program AP 0005741 Nuclear Training Center File Management AP 0005742 Exemption from Training i

AP 0005743 Chemistry Personnel Training Program

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AP 0005748 Nuclear Maintenance Joumeyman/ Specialist Training Program AP 0005749 Engineering Support Personnel Training f

AP 0005754 Written Examination Adrninistration and Control AP 0005755 Processing and Distribution of Training Bulletins AP 0005756 Systematic Training Developrnent AP 0005757 Systematic Evaluation of Training Effectiveness AP 0005766 Training Resources, Information and Material Control AP 0005767 On-the-job Training and Performance Evaluation

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AP 0005821 Maintenance Supervisor Training ADM-17.03 Operating Experience Feedback i

PMAl#Jem Version: 0 Corrective Action Form p

PMAl Site:ESL Source fN Number: PM96-03-022 Document: STAR 95QA23 Originatog Due Date: 6/30/96 Aseigned Deptment: ti2 HP/ BUCHANAN Q

implementor Name Unit Outage Mode SNO NCR OWA Deecription: ADDITIONAL MANAGEMENT ATTENTIOf 4 ISr NEEDED TO CORRECT RADIOLOGICAL WORK PRACTICES THAT INCREASE THE POTENTIAL FCR ADOrnONAL DOSE. THE SPREAD OF CONTAMINATION TO CLEAN AREAS AND THE UNPLANNED INGESTION OF RADIOACTIVE MATEfilALS.

DEVELOP DSCIPUNARY ACTION FOR RDR/RlRs METHODOLOGY, i Acceptance Section i Status / Comments:

I understand and accept responsibihty of the above hsted action and due date kW Department Manager Signature

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4 NUCLEAR DIVISION NP 404 NUCLEAR POLICY Rev.

3 PROCEDURAL NON-COMPLIANCE Date May 15,1995 F

L 2

e, 2

e REVISED THROUGHOUT Backcround:

The operation and maintenance of our nuclear stations are carried out in accordance with controlled processes detailed in literally hundreds of written procedures.

Any time the requirements of a l

procedure are not carefully followed, there can be undesirable consequences to personnel safety, equipment integrity, and/or health and safety of the public.

Heightened attention must be paid to

valve, switch, and breaker lineups due to their importance in maintaining critical plant systems operational.

These are the systems which are important to eiper nuclear safety,, plant reliability, es industrial safety) M a

ok

(

Reouired Action:

N l

Personnel charged with the responsibility to perform valve, switch, or breaker lineups or independently verify that others have performed this function correctly must follow the written procedural requirements (lineup sheets) step by step in a careful methodical fashion taking the extra time and attention needed to do it correctly.

Ideally we want and expect to see these functions carried out without error.

If an error is uncovered during the verification process the valve, switch, or breaker sh.ould be realigned to its correct position and duly noted on the lineup sheet and reported to cognizant supervision.

No one will be disciplined for committing an honest error provided upon discovery it is promptly reported to cognizant supervision.

Intentional concealment of mistakes, on the other hand, will not be tolerated and anyone involved in such practices is definitely at risk for disciplinary action.

Careful consideration will be given to any mitigating circumstances which may have contributed to the failure to perform or maintain a proper valve, switch, or circuit breaker aligr.ent.

Each case will be judged on its own merit by the Site Vice President.

/

Approved:

I i

President, NuQr Division i

3

~

9 Int r-Office Corr 0: pond:rno 3

JstPst FR Ltr. Bk. #96-033 To:

All Plant Personnel cate:

May 31,1996 From:

J. SCarola Department:

Plant General Manager subject:

RC A ESS Effective June 1,1996, the following policy will take place.

Any individual violating Radiation Protection Procedures, RWP's, will have their RCA access removed. This includ;s personnel contammations that are caused by poor work practices.

Restoration of access will require a meeting with supervision. The level of supervision will be progressive. First offense will involve the individuals department head and the Health Physics department head. A second offense will require a meeting the appropriate manager and the Health Physics department head. A third offense will require a meeting with the aforementioned and the Plant General Manager.

JS/dac 1

I O

9

i

.)

Four months of observations of radiation worker practices.have confirmed the INPO finding.

As a start, NP404 should be revised to include a statement on - Radiation 'saf ety.

This should be followed by a letter from Plant Management defining expectations in the area of radiological protection.

Finally, the health physics department should revise the RDR/RIR to include more definitive steps in the area of discipline.

l 9

j.

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_. _ - _~

. _ _ _ _ _ -. _ _ _. ~ _ _.. _. _.. _

riervena.MI s e June,1996 Page 74 of 83 PNBURE 1 (circle one)

HMPORARY CHAN9E/ PROCEDURE CHANGE REQUEST TC #

t 1, Psoonewe Tne: n DEnfrCrine An.A Mac, win WFAshknLied/12MM r

V Proceskse Nwieer Hf /0 /

Curmrw Mewman. /

2, RoguestType:

M Pmoedwo Cmenge U Tertiporary G e U One Trne use Orey

~

C Penode Revteur Done (If a TC, saech a completed TC CheckSet)

TCs incorporated

3. R esoneear w

1. Response to 990. QA, or NRC Regidromerne,

5. PC48 or Concedon Report

2. Cycle specianidocumereed assene Reviaen.

s. Procedwel avyowement

3. Tech ftpec. Reuuoensing Regnemores T. Tech.Manuel ' ;

.Z. a (Wet Tech. Spec. Amendmert No. below) 8.Teenkapyinoones O 4. Assens Piens operabe WAvesammiy

e. omer a out osocs 4) 1

4. Desents Deense FMAT fM A-os -022.

fegg,r;7g f

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yee r No

5. a. Does tus eengo aflect me adher Unfra A?

if yes, PCR for sie onpoene uret ehed be s@rtstead

! No Yes

b. le tes change to a Q.l.7 if yes. cesan QA Mgr/Deepee approval Signease

c. Does tus TCMCM reference any new chemsel?

Yes

/ No if yes. Chenecel Consul iksw. Rowtow

d. Does See TCSCR change me onder of eusseng spiele of a seet?

Yes V No Review if Yes. Enyneertng rev6ew ter poJerdlel e adversely snpact design twumans a regured AM/

M Date: 7/ d

s. Or6plneled O

Subcomndamed IIy-

/

Date:

/

/_

/

Dees:

/

Departnant Head Pnorey O1 0

Os O 4 (Pric% NA for TC's)

YE5 NO i

7. 50.55 Rowan l

A. Does tus criange represent a criange e tie lectity as deserted in me safmy Analyes Report?

B. Does sie dienge represent a change to procedures as descrbed in me l

Safety Aneryus Report?

C. Is me change =wwah a test or expenment not descrteed in me Seley Anafyus Report?

l D. CevJd me change affect nucleet safety n a way not previously evalustw n me l

g Safoy Analyes Report?

E. Does me criange recure a eenge to me Technal Speedcenons?

c r

lei (Ff yes a crescred br any guesecne acovo, mort a wreen Sakty Enniusson a recurred.)

h Let FUSAR Sectone reviewed 8

Ust T.S. hrearis revowed 2

Date

/

/ _.,

g; STAOueided Revewer Mnor Procedure Cnange Screervng (NA for TC's)

O FRG Rowow Remored O FRG Revew NOT Recurred Mnor Change Cnenne Not Met)

(Mwtor Change Crmona Met)

Date

/

/_,_

Quairhed Reviewer 8 Piara Genered Manger or Sne Vee Pressoent Authorusson (NA for PCR's) l This aumorusson necessary W an Operator Work Arotsid arters me cornpocon of an evolunon.

DJ.

/

Sognes.we

9. Temporary Change ApproveJ Pnor FRG Review RegtAred Yes U No U (NA for PCR's) 11 Yes, a PCR s regured Ret.wn t) Or9nesor for procesesng Date

/

Approved by Wemper of Plant Managemen' SegnatJre Pnnt Name Date

/

Approved by NPS Signetse Pnnt Name F'RG Teatrecian Forwstd 3) Informaton Services FRG Numoet 1

,r-

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r June,1996

~

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)

FIGURE 1 INSTRUCTIONS (Page 2 of 2)

For a Reauested Procedure Chance or Periodic Procedure Review:

A. Originator / Reviewer shall complete Blocks 1 through 6 and attach the procedure 4

change.

B. Block 7 completed by STNQualified Reviewer.

C. If any YES is checked in Block 7, a written safety evaluation shall be performed and attached to this form in accordance with 10 CFR 50.59. If the change is a result of a PC/M or Setpoint Change and the PC/M or setpoint change safety evaluation specifically addresses the attendant procedure change (s), this written safety l

evaluation from the PC/M or Setpoint Change shall be referenced in Block 3. If it is determined that the activity will require a change in the Technical Specircations or if it is determined that the activity involves an unroviewed safety question, then the proposal is required to be authorized by the NRC prior to implementation.

D. Block 8 shall be completed for Temporary Changes ONLY.

4 E. Block 9 shall be completed for Temporary Changes ONLY.

L l

F. Block 10 is completed by the FRG Chairman. Approval is required prior to implementation.

J i

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S_ OPS E PaOCeouae RMM NMR & LEM DOCN HPP-101 SYS PSL COMP COMPLETED ST. LUCIE PLANT g

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d u PREVIOUSLY ISSUED AS HP-101 '

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HPP-101 REVISION 1

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U U-IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS HEALTH PHYSICS PROCEDURE REVISION REVIEWED BY APPROVED BY DATE 4

FRG ON l

l 0

12/04/93 C. L. Burton 12/23/93 Plant General Manager 1

8/10/95 C. L. Burton 8/10/95 Plant General Manager HEALTH PHYSICS p

m MD 08/10/95

. - - ~

l i

REvts40N NO -

PROCEDURE Tm.E.

PAGE:

L*

1 IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS 2 of 11

- uo.:

V HEALTH PHYSICS PROCEDURE HPP-101 ST. LUCIE PLANT

1.0 TITLE

IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS

2.0. PURPOSE

The purpose of this procedure is to provide guidance in the l

l 2.1 Recognition of a radiological event 2.2 Classification of the event 2.3 Documentation of the event 2.4 Reportability of the event 4

The events described in this procedure are separate frorn and do nr.

implement the St. Lucie Emergency Plan.

3.0 REFERENCES

l 3.1 6 indicates that the text contains a Regulatory commitment made by Technical Specification, Condition of License, Audit, LER, Bulletin, etc.,

and should not be revised without Facility Review Group approval.

3.2 indicates a management directive, vendor recommendation, plant

)

practice or other non-regulatory commitment that should not be revised without consultation with the plant staff.

3.3 9' indicates a step that requires a sign off on a data sheet.

)

3 9,

3.4 10 CFR 20, Standards for Protection Against Radiation.

6, 3.5 Health Physics Procedure HP 2, 'FP&L Health Physics Manual.'

i

@3 3.6 Administrative Procedure AP 0010721, 'NRC Required Non-Routine Notifications and Reports.'

/R1 63 3.7 NRC Information Notice No. 90L-48, Enforcement Policy for Hot Particle Exposures 9.

3.8 10 CFR 50.75 (g) (1) Reporting and Recordkeeping for Decommissioning Planning.

/R1 b.

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e IDENTIFICATION AND REPORTING 1

OF RADIOLOGICAL EVENTS dCf11 PROCEDURE No HEALTH PHYSICS PROCEDURE-t HPP-101 ST. LUCIE PLANT 5.0 PRECAUTIONS / LIMITATIONS: (continued) 5.3 (continued) 3.

Shallow dose equivalent to the skin or extremities in excess of 50 roms.

4.

The release of radioactive material, inside or outside a restricted area, so that, had an individual been present for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the individual could have received an intake in excess of one occupational annual limit on intake. Ref.10 CFR 20.2202(b)(2).

Corporate Health Physics should be notified prior to notifying the NRC.

Su 5.4 The NRC shall be notified in writing within 30 days of an event that causes:

/R1 1.

That is described in 5.2 and 5.3 above.

2.

A total organ dose equivalent in excess of 50 rems.

3.

The exposure to a minor in excess of the occupational dose limits of 10 CFR 20.1207.

4.

The dose to an' embryo / fetus in excess of 500 mrem during the entire pregnancy.

5.

Exposure to any member of the public in excess of the limits contained in 10 CFR 20.12.1301.

l 6.

Exposure in excess of any applicable limit of the license.

r.L w.~ e. O,r:n "

A rrum.wu- @, a ~:.

A 5.5

" t is the vehicle to document Radiological Occurrences and Significant Radiological Occurrences.

5.6 Skin and clothing contamination (excluding noble gas contaminations) in excess of 100 counts per minute per probe area, but not meeting the criteria of 7.2.2. or 7.3.1, are documented on Health Physics Form t

HPP-70.1. They are tracked and trended separately from this procecure.

i i

5

REVIS40N NO.:

PROCEDURE TITLE:

j' AGE:

1 IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS 5 cf 11 pnocoovneuo.

HEALTH PHYSICS PROCEDURE o

HPP-101 ST. LUCIE PLANT 5.0 PRECAUTIONS / LIMITATIONS: (continued) 9, 5.7 If the event may result in significant contamination remaining after any cleanup procedures or when there is reasonable likelihood that j

contamination may have spread to ina== Ale areas as is the case of

^ h,por./ possible seepage into porous materials such as concrete, a cop lunor/ic n.. 7 :-7:-e' Ex:.9:;:1 shall be sent to Plant Licensing Manager.

1 Plant IJoensing Manager will forward the report to the Assistant Comptroller, Regulatory Accounting. The forwarding of the report signifies that the event should be evaluated for inclusion in plant decommissioning decisions.

/R1 4

6.0Jf 6

, f) i RECORDS REQUIRED:

6.1 Records shall be maintained in the plant files in accordance with i

Ol 17-PR/PSL-1, " Quality Assurance Records.'

ATrAc..me-d 4 i

1.

mmh 46*A," Radiological Event Report.#

ATrA<.wed E) 2.

HPP-101.2, Radiological Deficiency Repo.1 2.. & N Crn' ot).9y/orti, % g. 9 9,3 i

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REVISION NO.:

PROCEDURE TrrLE:

PAGE:

1 IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS 6 ef 11 emoccovas No..

HEALTH PHYSICS PROCEDURE e

HPP-101 ST. LUCIE PLANT

7.0 INSTRUCTIONS

7.1 Radiological Deficiencies - Events of the least radiological significance that are tracked and trended on a routine basis. The Health Physics Supervisor is briefed on these events on a regular basis. Radiological deficiencies are documented on.9,"."e.... IT;iGi.2 and are defined as follows:

% chum,: A grreu.cc y &

f Car cM pu sp,y 1.

Non-deliberate violations of

~,

A.

Radiation Work Permits B.

Postings C.

Health Physics Procedures D.

Verbal Health Physics Instructions 2.

Poor Radiological Work Practices that include A.

Unnecessary spread of contamination B.

Unnecessary increase in worker radiation exposure j

C.

Unnecessary generation of liquid or solid radioactive waste D.

Careless damage to Health Physics instruments, protective clothing, etc.

E.

Other poor work practices,7 hat in the opinion of Health Physics, should be documented.

G: Et211dTW.i ci f7:r 4pg.y,c,L

?'i W Radiological Occurrences are 6f greater s gnificaric65han radiological 7.2 1

deficiencies. The Health Physics Supervisor is notified of individual events and he may notify plant management and Corporate Health Physics if he determines notification is necessary. Radiological occurrences are as follows:

1.

Unplanned whole body exposures in excess of:

A.

10 percent over any limit requiring a TLD readout.

1

~

newsonwo ecaouns mu:

paae:

, IDENTIFICATION AND REPORTING pmoceouna No..

OF RADIOLOGICAL EVENTS

- 8 of 11 -

p.

HEALTH PHYSICS PROCEDURE HPP-101 ST. LUCIE PLANT n

7.0 INSTRUCTIONS

(continued) l 7.2. (continued) 8.

Unplanned intakes of radioactive materialin excess of 2% of an ALI.

7.3 Significant Radiological Occurrences are of a more severe nature than radiological occurrences. Significant radiological occurrences require the notification of the Health Physics Supervisor, Plant Management and Corporate Health Physics staff. Significant radiological occurrences are:

1.

Unplanned whole body, skin or extremity exposure in excess of 25 percent of any annual or extended annual guideline.

2.

Locked high radiation area found to be unlocked and not controlled as required by Technical Specifications.

j 3.

Falsification of personnel exposure records.

4.

Unplanned intakes of radioactive materials in excess of 10% of an All.

7.4 Radiological incidents are the most severe category and notification of the NRC is required by regulation. Plant management and the Corporate Health Physics staff shall be notified. These events are detailed in Sections 5.2, 5.3, and 5.4 of this procedure.

1 s Gwci-;r G,xx.- (ta,,,,,M./x,sk,. /B :.k!k <m t,, ;

7.5 Document radiological occurrences and significant. radiological

% %. w,,:.

occurrences on.RadiologicaLEvent-Report, FormHPP-101.1.

/

j Personnel contaminations are documented on Personnel Skin / Clothing Contamination Report, Form HPP-70.1. Radiological incidents as i

detailed in 5.2, 5.3, and 5.4 will be documented as prescribed by Reference 3.3. Assistance in the documentation and reporting can be obtained from the Technical Department.

. x ; u.i i,... /

1.

Attach supporting documentation to liPNC1.1 as necessary to i

accurately and completely describe the event occurrence and actions taken.

arvsou No.:

enoceovae m u:

~ ~ e:

1 IDENTIFICATION AND REPORTING paocuovas No.:

OF RADIOLOGICAL EVENTS 9 of 11 HEALTH PHYSICS PROCEDURE HPP-101 ST. LUCIE PLANT d'

7.0 INSTRUCTIONS

(continued)j jf4 A copy cola Qg %El* b '#

7.6 [ M completed Nadioiogical Event Repohe=Tik boeH

/

A

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' " 101.1 and associated documents)should be forwarded to the HP Technical Staff for tracking and trending. The package should then be forwarded to the dosimetry section, when applicable, for inclusion in the individual Health Physics file.

A thp<. J jbf Wu,/ a d 4& Ac y./~

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7.7 ( De cdmp.-&.6 nap { logical Deficiency Report Fd.j f,/g )

leted Radio c:40h2 should be forwarded to the HP Technical Staff for tracking and trending. The package should then be forwarded to the Dosimetry section for inclusion in the individual Health Physics file.

1 a

e

REVISION NO.:

Pfu.A. OURE TTTLE.

PAGE:

1 IDENTIFICATION AND REPORTING Pnoceoune No..

OF RADIOLOGICAL EVENTS 10 of 11 s

HEALTH PHYSICS PROCEDURE HPP-101 ST. LUCIE PLANT

-fGidiUGp.;(,i,1- /}7/AC&n!jf s

RADIOLOGICAL EVENT REPORT l.

Date

/

Time RWP#

Report #

Name PID#

Dept.

Location of event 11.

Descript6on of the Event 1.

Unplanned deep oose in excess of 10% of TLD read requirements 2.

Shallow Dose equivalent in excess of 5000 mrom 3.

Spill or unplanned release or radioactive material 2

a. >100,000 dpm/100 cm and > 100 ft' f,

b.

To an area not designated to be contaminated and residual contarnnation remains post decontamination. (See 5.7 & 7.2.3.0)

/R1 c.

To an area not designated to be contaminated and no detectable I

contamination remains post decontaminabon.

4.

Unauthorized dosimetry relocation 5.

Deliberate disregards of HP instrucuons, procedures or RWPs 6.

Unauthorized removal of contaminated tools from the RCA 7.

Unplanned intake of radioactive material > 2% of an ALI 8.

Unplanned deep or shallow dose > 25% of guidelines g.

Locked or Very High Radiation Area not controlled as required by T/S or Procedure

10. Falsification of exposure records

11. Unplanned intake of radioactive material > 10% of an All 111.

Event Description Attach detatted desenption if necessary

~

IV.

Action Taken to Prevent Recurrence V.

Review Person involved in event Date

/

Health Physics Shrft Supennsor Date

/

Health Physics Operations Supervisor Date

/

Health Physics Department Head Date

/

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1 IDENTIFICATION AND REPORTING OF RADIOLOGICAL EVENTS 11 of 11 pagoung 30; HEALTH PHYSICS PROCEDURE

.; 1 HPP-101 ST. LUCIE PLANT Hpp-iGi.2 - fiMura m? 6 HEALTH PHYSICS FORM RADIOLOGICAL DEFICIENCY REPORT 1.

Date

/

Time Report #

Department

//ljn/0ify RWPs Location where deficency ocaarred 2.

Category of Deficency 1.

Non delberate violations of:

RWPs Postings Health Physics Procedures Verbal Health Physcs instructions 2.

Poor Work Practces Unt-ary Spread of Contamination increased Worker Radiation Exposure Needoes Generation of Uquid/ Solid Rad Waste Careless Darnage to Instruments, P.C.s etc.

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3.

Desenption of Deficiency Cit g, y a, Nuda p1~

4.

Immedate Corrective Actions S.

I have discussed the causes of the event and will assist the workerts) in preventing recurrence.

HP Technician Date

/

HP Shift Superwsor

,, Date

/

6.

Revwwed Date

/

HP Operauons Supervisor Comments:

7.

Revwwed Date

/

HP Department Head

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PSL-LIC-96-013 e

Enclosuro

/

materials.

Status A self-assessment of radiological work practices and policies was recently completed. The self-assessment resulted in establishing clearly defined responsibilities and accountabilities for the Health Physics (HP) Department for material condition and control'in the Radiation Controlled Area (RCA). The control of work within, and the material condition of, the RCA is now vested in the HP department. HP controls all material entering the RCA to ensure, among other things, that the production of low level waste within the RCA is minimized. To ensure that the plant's radiological work practices are followed, a progressive discipline process has been established for violation of HP practices and rules. The progressive discipline process includes informing increasingly higher levels of management of repeated violations by specific individuals.

Additionally, HP process changes.related to radiological event reporting were made to implement the Condition Report process (described in Finding OP.1-1, above) for such events. The use of Condition Reports as'a means of. identifying radiological controls issues and events will permit the trending of HP problems and 4

discrepant work practices to ensure that proper msnagement attention is placed on putting in place the proper corrective actions.

The identification of HP discrepancies will continue to improve through the use of Condition Reports.

Specific indicators of the performance of the radiological control program at St. Lucie are provided by the plant's indicator set which is presented to senior FPL management on a i

monthly basis and includes indicators such as contaminated s quare-footage, personnel contaminations, and radioactive dose received.

70' j

0 g q-The plant has also revised its Radiation Work Permit (RWP) pre-i a go 4 job brief video to emphasize proper work practices. Dose and dose rate alarm settings for electronic dosimeters, which are used on

,.,ggy0 general and specific RWPs, have been lowered. The original completion date for this finding was delayed from February 1996

'. A*} c to March 1996 to permit completion of this radiological work 3

practices self-assessment.

I',q fcFft N@.M. 6'TAUS ?

CY.2-2 Honitoring and control of steam generator impurities needs to be improved to prevent the formation of B

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C orrective A ction Fo rm PMAI Site:23L Sourse Number: PM96-03-597 Document NRC EXfT 03/01/96 Originator.N.8C Due Date: 5Lil26 Assigned C,11.1.C 11 2 HP/ BUCHANAN Q

implementor Name Unit Outoge Mode SNO NCR OWA

==

Description:==

REVIEW REQUIREMENTS OF HPP-41 REGARDING CONTAMINATION LEVELS FOR TOOLS. ENSURE MEASUREMENT CRITERIA 15 SPECIFIC. REFER TO NRC EXIT MINUTES.

Acceptance Section W

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ADMINIS~' ATIVE PROCEDURE NO. 0006129, REVISION 0 PMAI CORRECTIVE ACTION TRACKING PAOGRAM APPENDlX A l

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COMPLETED BY:

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REVIEWED BY:

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.NRC -EXIT MEETING MINUTES i

3 4

DATE:

Marc'h 1,1996

SUBJECT:

- HP/ Rad Protection Inspection (To be contained in 96-01) i INSPECTION DATES:

February 26,1996 to March 1,1996 Ins.pectors: Fred Wright INSPECTION

SUMMARY

I This was a core inspection which focused on occupatiend radiation exposure.

There were no violations or deviations identified during the inspection. There was one non cited violation proposed which is discussed below.

j

' NCV - The inspector'p,roposed an non-cited violation related to control of contaminated to'ois in the hot tool room. HPP-41 contamination limits for these 4

2 tools are less than 10 mr/hr fixed and less than 1000 dpm/100cm. The inspector

)l -

found'two examples which were slightly in excess of the limits. Due to the minimal safety significance of the condition, the inspector has proposed a NCV.

Action - Maintenance to ensure the tool room is staffed in the future and locked when it is not.

i Observation - The inspector noted several examples of tools in the hot tool room which were not painted purple as described in the procedure.

),

Action - Maintenance to ensure all contaminated tools are painted as described in plant procedure.

Observation - The inspector noted that due to unplanned maintenance activities in l

1995, personnel dose goals were exceeded. He suggested that the plant needs to improve our planning in this area so that we can meet our goals in the future.

Observation - The inspector noted that there appeared to be more radioactive material stored around the site than he has seen in the past. FPL responded that g

the plant was cognizant of the condition and a clean-up effort was planned prior to the Unit 1 outage.

Observation - Overall, the inspector noted that control of contamination and RAB housekeeping was very good. He also felt the current ALARA goals for the plant were challenging and commendable.

Attendance:

H. Buchanan -

J. Fulford J. Danek

. R. McCullers S. Sandin M. Miller

{

F. Wright :

E. Weinkam E.Benken J. Vorhees

.1)

'i TO: FILE-FROM:

R'. M. McCULLERS DATE': 4-26-96' I

SUBJECT': PM96-03-597

~During a HP/ Rad Protection inspection conducted by Region-2 NRC inspector Fred Wright on February 6 through March 1,

1996, several issues were raised.concerning the use of contaminated tools in the Radiation Control Area. This particular...PMAI addresses a proposed Non-cited violation as a resulf ci a tool found by Mr. Wright that was slightly above the contamination limits of 1000 dpm/100cm2.as specified in Procedure #HPP-41.

Additionally,.the procedure was unclear as to the method of i

satisfying the fixed contamination limits of 10 mr/hr in that it j

was not specified Whether the reading'was to be made with the detector window open or closed.

A procedure change to HPP-41 was submitted, and subsequently approved by the FRG #96-100 on 4/23/96 to address these issues.

It.is now specified.that the correct method for determination of

.the fixed contamination level is to perform the survey with a

' closed window' reading. Also, a section was.added that allows surveying the tools.with a frisker type instrument for fixed contamination prior to them being put on the shelf for reissue.

e This is a more responsive type instrument as compared to a dose l

rate meter, and this survey method will result in a more conservative approach towards satisfying the procedurally specified limits. Additionally, this issue has been discussed.n detail with all HP personnel, and routine surveys in the' hot tool room are now done more thoroughly than in the past to ensure this problem has been corrected.

Other issues raised by the inspector regarding tools in the Radiation Control Area are being addressed in a separate PMAI 2

PM96-03=598.

R.M. McCullers 1

l l

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Desenphon: ENSURE ADHERENCE TO HPP-4 WHICH INCREASED THE FREQUENCY OF SURVEYS IN THE DESIGNATED SECONDARY SIDE TOOL STORAGE AREA FROM MONTHLY TO WEEKLY, WITH EMPHASIS ON ITEMS KNOWN TO BE USED IN THE RCA RESPOND TO LICENSING BY THE ABOVE DATE.

Due Date Extension / Transfer Responsibility Requests Extend To Date Request by /Date imp 6ementry Cept.

Onginating Dept.

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Supervisor /Date iDate Manager

/Date Edend To Date Request by /Date impiemenung Dept Onginating Dept.

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ST. LUCIE PLANT ADMINISTRATIVE PROCEDURE NO. 0006129, REVISION 1 PMAl CORRECTIVE ACTION TRACKING PROGRAM i

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St. Lucw Units 1 and 2 i

Docket Nos. 50 335 and 50-389 Reply to's Notice of Violation -

Insnection Resort 9609 1

B.

To address the matter of tools found above the procedural limits in' the RCA tool rooms, the following corrective actions were taken:

4 4

1.

Extensive surwys were perfanned to ensues that the canen-ameiaa levels of all tools locased in the tool issue areas were within procedural linuts. All toohng found to be above these limits were returned to the appropnase d=aenauame=a area. His actice was completed by July 1, i

1996.

2.

A plant Coodition Report was generated which resulted in RCA tool 4

room personnel being instructed not to place any tooling back on the i

shelf far reissue, regardless of whether the tool was used in a clean or -

cantammanal area. A lay down area was designaaed in each tool room to be used as a bolding area for returned toohng until health physics surveys can be performed.

4 j

3.

Work stand down meetags were held with health physics personnel to j

ensure that the new tool return pobey was sanctly enforced.

1 4.

CORRECTIVE STEPS TO AVOID FUiitn== VIOLATIONS A.

This violation was docussed at the Unit 1 outage critique meetag held on August 8,1996. As a result, the mechantal maintenance tooling supervisor will be working with the Health Physics Department to develop written policies 3

governing tool i=== and responsibilities. His action will be completed by December 15, 1996.

j B.

St. Lucie Health Physics Department will work with the Maintenance Department to reduce the amount of tooling located in the RCA. This will j-allow more thorough and efficient surveys to be performed. This action will be j

completes by D= na-i 15, 1996.

C.

A task team will be formed to generically address the issue of site tool control.

The team will address both outage and non-outage control of tools. Additional long term correcdve acdons will be evaluated to enhance the positive control 1,

measures for tooling both inside and ouuide the RCA. This action will be completed by Decernber 15.1996.

e 17

MAINTENANCE RULE EXPERT PANEL MEETING MINUTES S..;

1 [1e.

DATE: 7 June,1996 CHAIRMAN: Mike Snyder

]

MEMBERS: Jim Porter (SCE/ Systems)

CONSULTANT: Gerry Crowley (JPN/CSI)

Brien Vincent'(PSA)

CONSULTANT: Bud Elder (SCE/PM Basis)

Chuck Wood (SRO)

CONSULTANT: Tom Krienberg (Contracts /Purch)

CONSULTANT: Lee Rogers (DME/ Services)

(NOTE - At least one of the members should be from the PSA Groep, at least one have held a 4

SRO license or certificate at PSL.)

TOPICS REVIEWED

'l. The purpose of the meeting was to complete the review and dis'cussion of the St. Lucie history of RCP seal failures from an earlier panel discussion on 24 May,1996 Mike Snyder started the meeting with a review of the first meeting's outcome and action items

2. Bud Elder provided results from bench marking against Millstone 2 and Waterford 3. (These plants with N9000 seals have the closest operating characteristics to St. Lucie) The operating conditions for these sites essentially mirror PSL. They have not had operating problems with N9000 seals for six years.

3. The RCP seal change out strategy was discussed with Gerry Crowley. Several options were I

discussed, two each refueling, all four at once, all at once during the Unit I mid cycle SG outage.

These technical issues will be resolved outside of the Expert Panel meeting process.

4. Cost considerations were discussed using a draft comparison of expenditures of N9000 seals versus SU seals. The drat 1 review indicated that the replacement schedule and inventory costs were approximately the same for both seal types. After the meeting, Tom Krienberg obtained a more precise figure for inventory costs which showed a clear cost advantage to the N9000 seals.

Lee Rogers was also able to help quantify the cost considerations for SU seal inventory costs.

5. All expert panel members agreed that the N9000 seal has proven to be superior in reliability to the SU seals, and that the N9000 seals should be installed at St. Lucie at the earliest opportunity to reduce the occurrence of seal failure, and to minimize unit unavailability as occured in 1995..

6. Considerable discussion was given to the need to place the RCP seals in a(1) classificatior.

NEI 93-01 was reviewed by the panel members, and different opinions were explored. The performance criteria of unit unavailability based on FPL Nuclear Division goals was briefly discussed. Since consensus was not achieved by the panel members, this will be the focal point of the next panel meeting on RCP seals.

o ACTION ITEMS

1. Gerry Crowley contacted Byron Jackson to determine what the vendor expected seallife of an SU model seal. The verbal answer provided was one operating cycle.

2. Bud Elder confirmed that the FSAR for PSL 1 & 2 was phrased as RCP seallife being AT LEAST 24 months.

P

3. Mike Snyder to check with Outage Managemer: about the possibility of changing out all four RCP seals with N9000 seals during the mid cycle refueling if RCP work is to be prohibited during the SG change out refueling.

4. The panel will convene once more to finalize the decision on classifying the RCP seals into the

. a(1) status.

W4d Si sv.ly < e n gS4.,

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t MAINTENANCE RULE EXPERT PANEL MEETLNG MINUTES

~ DATE: 27 June,1996 CHAIRMAN:

Mike Snyder MEMBERS: Jim Porter (SCE)

SYSTEM OWNER: Ed Hollowell Brien Vincent (PSA)

Bob Czachor (SRO)

(NOTE - At leait one of the members shall be from the PSA Group, at least one have held a SRO license or certificate at PSL) l TOPICS REVIEWED In The first items on the agenda was a review of the St. Lucie Structures Scoping Document as presented by Ed Hollowell. -The panel members reviewed the scoping matrix methodology for structures. The panel members were told that there were no exceptions taken to the NEI i

guidance, and that the St. Lucie scoping was done by bench marking against at least four other sites, including Turkey Point. As a result, the St. Lucie scoping document incorporated the lessons learned from'those sites, as well as the NRC pilot inspections shown in NUREG 1522.. Based on this top level review, the ex' pert panel approved the scoping matrix and three year historical review of structures at St. Lucie.

2. 'Ihe primary purpose of the meeting was to complete the review of Summaries for those systems included in the scope of the Maintenance Rule.

Mike Snyder began this discussion by reviewing the scoping matrix in a handout form with the panel members, and stating the purpose of such a summary for each system. The methodology for applying the MRule functions was discussed, which was based on the scoping for a given system. The System Summaries presented to the panel members was a revision to the previous draft descriptions.

established by the previous Maintenance Rule coordinator. The panel then provided feedback for a top level critique of the summaries for systems 37 through 75.

3, With Mike Snyder committing to incorporate the detailed comments that the members provided, system summaries for 37 through 75 were approved. This completed expert panel review and approval of the system summaries.

4. As a final review item, the panel reviewed a rough draft of the second Maintenance Rule Quarterly report for 1996. The members pointed out some discrepancies related to unavailability tracking for A side systems. Additionally. Bob Czachor pointed out the definite need to specifically address in the report the reason for many systems exceeding their performance criteria in the late 1994 time frame. Mike Snyder mentioned that the primary reason for this unavailability ' spike' was that in the absence of performance criteria for unavailability in 1994, SSCs were removed from service voluntarily to perform preventive maintenance. The panel members agreed that a prior exceedence of the unavailability criteria

6 1

FIGURE 4 (Page 1 of 2)

Goal Setting and Monitoring Unit: 1&2 Date:

1/4/96 Risk Significant:

+ Yeso No SSC: System 59 - Emergency Diesel Generators Reason for Goal Setting:

X Performance Criteria Not Met Which criteria were not met?

Repetative MPFFs within a 36 month period.

Description of Events:

1) Failure of the iB2 EDG to carry load on surveillance dated 5/17/95.

2) Failure of the 2A2 EDG to load on surveillance dated 12/14/94.

X Repetitive MPFF (attach Figure 3 for each failure)

Explain how failures are r'epetitive.

Although the exact nature of the problems were dissimilar, both problems were reliability oriented and concerned inadequate Preventive Maintenance.

Were previous corrective actions inadequate?

j Previous corrective actions did not address comprehensive preventive maintenance of the governors.

References (attach): SSC Performance Indicator, NRC Special Reports: FPL L-95-007 and FPL L-95-176.

Does this SSC require (a)(1) status?

Roger Kulavich

+ Yes o No System Owner 1

Yes - signature of Expert Panel Member Mike Snyder Maintenance Rule Coordinator No - signature and reason why not Lee Roaers Expert Panel Chairman

-~

i

(

FIGURE 4 (Page 2 of 2)

Goal Setting and Monitoring (continued)

Root Cause Analysis:

Assigned to: R. Kulavich

!B2 event of 5/17/95: Fatigue crack in an oil line (see STAR 950529).

2A2 event of 12/14/94: Gear weak (See STAR 950059). Both of these events are aging issues internal to the governor actuators. Common cause is " inadequate preventive maintenance".

Corrective Actions and Responsibilities:

Assigned to:

1. Develop Procedures for Unit 1/2 to require R Kulavich Periodic overhaul. (Complete U2)

2. Implement during 1995 outage on U2 (complete)

Electrical Maintenance

3. Implement during 1996 outage on U1 (STAR Electrical Maintenance 950529: Conective Action due date 12/31/96)

Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitoring for a follov-up period to verify success, and a discussion to show how PSA and industrywide operating experience were used in the process.

Goal Monitoring method & frequency Date PSA/ industry Exp

1. No U1 failures

1. Monthly surveillance-U1 IThru

1. Governor of gov. Actuators OP 2-2200050A/B.

Dec Actuator mfgr due to aging 2.

Monthly surveillance-U2 1996 recommendation.

problems.

OP 2-1200050A/B.

2Thru

2. Standard

2. No U2 failures

3. Monthly Surveillances Ul&2:

Jan Practice Tech Spec of gov. Actuators Criteria added to Operations 1996 Surveillance.

due to aging procedure (Acceptance criteria 3 Dec

3. Govemor problems developed and documented in 1996 Actuator mfgr

3. Gov. control:

STAR 951228) recommendation.

I stable load while operating.

Prepared by:

Roaer Kulavich 1/4/96 Component Owner Date Review and Concurrence:

Mike Snyder 1/4/96 Maintenance Rule Coordinator Date Review and Approved:

Mike Snyder 5/9/96 Expert Panel Chairman Date

FIGURE 4 (Page 1 of 2)

Ref: ADM 17.08 "The Maint Rule" Goal Setting and Monitoring Unit: 1 Date:

5/23/96 Risk Significant:

+ Yes 0 No SSC: System 59 - Emergency Diesel Generators 18EDG X

Performance Criteria Not Met Which criteria were not met?

l. The performance criteria for Unavailability hours were exceeded by the IB EDG.

Performance criteria: less than 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months unavailability /12 months IB EDG for last 12 months:lfd)

(Measured as Unplanned plus Planned actual hours OOS. WANO report data)

Description of Events; IB EDG OOS hours due to:

5/17/95 -gosernor actuator replacement. (load-run failure due to gosernor actuator failure);

9/1/95 -replacement of failed piston and cylinder head ; (load-run failure due to broken valve);

9/5/95 - Governor alignment & MOP replacement. (unacceptable performance; electronics alignment requiredh 10/5/95-repair of fuel line leak, (load-run failure due to broken fuel line);

Repetitive MPFF (attach Figure 3 for each failure)

N/A for this Fig. 4.

References:

This Figure 4 is associated with Condition Report %1028.

M,J A

k b A bM6 Does this SSC require (a)(1) status?

+ Yes O No R. K'ul'avich. EDG Syster'n dwner Yes - signature of Expert Panel Member 4/

6 '/' f/

i l

M. Snyder, IQainte6ance Rule Coordinator No - signature and reason why not AV b6 f f4

/ x'p6rt Panel Cliairman E

i

d-j t

FIGURE 4-fPage 2 of 2)

Goal Setting and Monitoring (continued)

Root Cause Analysis:

' Assigned to: R. Kulavich The 1B EDG exceeded the goal for unavailable hours NOT due to any one single cause or event but the summation of several distinctly separate failures and 4

maintenance activities.

Each event contributing to the excessive unavailability hours is listed on page one of this Figure 4. All events have been addressed individually as noted in the reference list below:

5/17/95 -- 12 cyl gov actuator failure: STARS 1950059 and 1-950529.

9/1/95 - failed piston and cylinder head ; STARS 1951021 and I-951031.

l 9/5/95 -' Govemor alignment & MOP replacerhent. STAR 951228; Elec NPWO 65/1326.

10'5/95. Fuelline leak. STAR l 951322.

Assioned to:

Corrective Actions and Resoonsibilities:

3 1.

Monitor and trend the unavailability hours for the R. Kulavich l

1B Diesel Generator. Report to management on monthly i

l basis ur.til the performance criteria for unavailable hours are met.

R. Kulavich j

2.

For any trend encountered on the 1B Diesel Generator that may jeopardize the goal of meeting the "less than 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months " unavailability for a rolling 12 months; convene a multidiscipline team to review, develope corrective actions, and implement.

i Goal Setting and Monitoring for each corrective action.

i faQal Monitorina method & freauency Qata PSA/ industry Exo 1

1. Trend less than

1. Unavailability hours report.

Dec WANO / INPO 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months for.

Monthly.

Planned and 31, data j

rolling 12 months.

unplanned unavailability 1996 hours0.0231 days 0.554 hours 0.0033 weeks 7.59478e-4 months only.

2. Team to

2. AP 0010022

Emergency NUMARC 87-00.

address trend Diesel Generator Reliability Dec 10 CFR 50.63

r problems Program", Attachment 1.

31

" Station Blackout" identified.

As-needed.

1996

// 9/o, Prepared by:

~

EDG Sys Engineer Date NI 4

f[

Review and Concurrence:

M4nterdnce Rule Coordinator.

Efate c

Review and Approved:

/*/

4 68b Edertpanel Chairman Date r

t w-

FIGURE 4 (Page 1 of 2)

Ref: ADM 17.08 "The Maint Rule" Goal Setting and Monitoring Unit: 1 Date:

6/14/96 Risk Significant: Yes X No SSC: System 59 - Emergency Diesel Generators 1 A & 1B EDG

~

X Performance Criteria Not Met Which criteria were not met?

1. The performance criteria for Start / Load-Run Demand failures were exceeded.

Performance criteria: less than 5 failures in last 100 demands I A & IB EDG for last 100; 5

(Measured as Unit total Failures per 100 demands: AP 0010022. *EDG Reliability" )

Description of Events: All failures are IB EDG but Reliability is counted at the unit level:

10/28/94: wire connection overheating' (load-run failure due to loss of Voltage Regulator )

5/17/95 -loss of engine control. (load-run failure due to governor actuator failure);

9/l/95 - loss of engine (load run failure: valve broke; destroyed piston and cylinder head );

10/5/95 fuel line leak, (load-run failure due to broken fuel line);

5/ 2 / 96 breaker would not close,(load-run failure due to failed breaker permissive relay 27YJ Repetitive MPFF (attach Figure 3 for each failure)

N/A for this Fig. 4.

References:

This Figure 4 is associated with Condition Report 96-1028.

A/ i/ /

/?

Does this SSC require (a)(1) status?

b A$.dCL'M f/Y 6

+ Yes 0 No R. Kulavich. EDG System Owner

1. I[

8 7!f6 Yes - signature of Expert Panel Member M. Snyder, dainter(ance Rule Coordinator M

I6

/ 4 No - signature and reason why not Expe'rt Panel Ch' airman

D FIGURE 4 (Page 2 of 2)

Goal Setting and Monitoring (continued)

Root Cause Analysis:

Assigned to: R. Kulavich The five 1B EDG failures exceeded the goal for 1 A/18. failures because of several distinctly separate failures.

l Each event contributing to the five failures is listed on page one of this Figure 4.

All events have been addressed individually as noted in the reference list below:

10/28/94. Voltage Regulator Wire connection overheating: STARS 19410372 and I 950067.

5/17/95 - Loss of engine control / gov actuator failure: STARS 1950059 and l-950529.

9/1/95 - Loss of engine / valve failure: STARS 1-951021 and I-951031.

10/5/95. Fuel line leak: STAR l 951322.

5/2/96-Breaker would not close: CR 96-0621.

Correctrve Actions and Resoonsibihties:

Assioned to:

1, Monitor and trend the reliability failures for the I A and R. Kulavich ID Diesel Generator. Repon to management on monthly j

basis until the performance criter'. for demand failures are met.

2.

For any failure of a I A or IB diesei generator, convene a R. Kulavich multidiscipline team to review, develop corrective actions, and implement.

Goal Setting and Monitoring for each corrective action.

Q. gal Monitorino method & frecuency Dalg PSA/industrv Exo

1. Less than G

1. AP 0010022 " Emergency Dec NSAC 108.

failures per 100 Diesel Generator Reliability 31, NUMARC 87-00, j

1 A and 1B Program", Section 8.2 1996 Reg Guide 1.155.

demands.

Monthly until goal met / quarterly.

2. Team to

2. AP 0010022 " Emergency Dec NUMARC 87-00.

address trend Diesel Generator Reliability 31, 10 CFR 50.63 problems Prograni", Attachment 1.

1996

" Station Blackout" identified.

As-needed.

Prepared by:

Cff EDG Sys Engineer Dat '

Review and Concurrence:

/8/ [

d Madtengf6e Rule Coordinator Date c

o Review and Approved:

N/dd d

h Expfrt P36el Chairman ate i

FIGURE 4 l

(Page 1 of-2)

Goal Setting and Monitoring 1

Unit: 1 Date:

6/17/96 Risk Significant:

+ Yeso No SSC: System 01 - R,esetor Coolant i

Reason for Goal Setting:

X Performance Cnteria Not Met i

Which criteria were not met?

j Unevailabiky - Bo6 PORVs won OOS for approxanamty nine mon &s.-

i Description of Events:

Refersecs CR %I347. Sign 5 cant MITF with ads-assembled PORVs. RCS component failures have contributed greedy to Unit I lost avadabday (s5ecting E.U)

Repetitive MPFF (attach Figure 3 for each failure) 4 Explain how failures are repetitive.

\\

Were previous corrective actions inadequale?

References (attach): CR 96 1347 whid incendes IER 95-005-00, STAR 950872, NRC I=&

Rapon No. 50 33585 16 and 50 38995 16, several procedures, and test desa.

Does this SSC require (a)(1) stctus?

Tom Sanders

+ Yes 0 No Component Owner Yes - signature of Expert Panel L. ember Mdce Snyder Maintenance Rule Coordinator No - signature arid reason why not N

/

Expert prieiChairman 1

4

-- - m.-

a t

,+iw

-m

=-p-

-e F

T

i l

FIGURE 4 1

(Page 2 of 2)

' Goal Setting and Monitoring (continued)

Root Cause Analysis:

Assigned to:

Cognitive personnel error.

Joel Kagan Main disc guides were misoriented even though procedure 1-M-0037 was correct I

and mechanics had specific training.

Corrective Actions and Responsibilities:

Assigned to:

i

1. Post Maintenance Test Program strengthened.

Jon Hallem - Complete

2. QC holdpoint has been assigned to guide Joel Kagan - Complete installation steps in PORV procedure.

3. Test added to maintenance procedures to verify Joel Kagan - Complete main disc actuates.

4. Improve testing steps in procedure 1-M-0037.

Tom Sanders (CR 96-1347 action)

5. Improve testing to ensure solenoid and circuitry is verilled acceptable after installation & before LTOP.

Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitonng for a followtup period to venfy asww=ma, and a discuest : ta iw how PSA and industrywide operating experience were used in La process.

Goal Monitonng method & frequency Data PSMndustry Exp 1.Two

1. PWO's that perform work

1. PSA indicates n'vv=aaful

2. PMT Ql's PORVs are very bench, Post

3. OP-1-0010125A, Data Sheet important for Maintenance, 24 once thru cooling, and surveillance

2. Vendor tests after Frequency : After two outages (Dresser) rebuild on Unit when the PORVs have been contacted about 1.

rebuilt.

rebuild, PMT.

Prepared by: Tom Sanders

h June 17,1996 Component Owner Date Review and Concurrence: Mike Snvder June 17,1996 Maintenance Rule Coordinator Dale Review and Approved:

40 d' bI) 4 7 fd Expiert PdfhVrman Date

i FIGURE 4 (Page 1 of 3)

Goal Setting and Monitoring Unit: 1&2 Date:

4/18/96 Risk Significant:

+ Yeso No SSC: System 52 - 4.16 kV Swgr. & Bkrs.

Reason for Goal Setting:

X Performance Criteria Not Met Which criteria were not met?

Reliability - MPFF Description of Events:

' MPFFs with safety related breakers i

i i

X Repetitive MPFF Explain how failures are repetitive.

Breaker floor tripper adjustments resulted in demand failure of the 1 A HPSI to start on two occasions 7 months apart.

Latch check switch adjustments resulted in two breaker demand failures between the l AB and 2B3 bus components 2 months apart.

Were previous corrective actions inadequate?

Floor tripper corrective actions were inadequate to prevent reoccurrence. However, the corrective action's for latch check switch adjustments may not have had enought time to be implemented.

References (attach): ssc Performance Indicator Does this SSC require (a)(1) status?

____ John Camobell

+ Yes o No System Owner Yes - signature of Expert Panel Member Mike Snyder Maintenance Rule Coordinator No - signature and reason why not Mike Snyder Expert Panel Chairman

D FIGURE 4 (Page 2 of 3)

Goal Setting and Monitoring (continued)

Root Cause Analysis:

Assigned to:

Failures attributed to breaker component aging and inadeqate PM to compensate for aging.

John Campbell (i.e. floor tripper, latch check switch.)

Corrective Actions and Responsibilities:

Assigned to:

1. Revise EM PM breaker procedures to provide J. Campbell (Completed) a NOTE prior to floor tripper and latch check switch adjustements to heighten awareness of journeymen / supervisors on previous failures.

2. Use PSA to prioritize the PM of safety related J. Campbell (& B. Vincent) 4.16kv breakers to ensure new style adjustments (IIPSI, EDO. AFW) of floor tripper and latch check switch are made to PMAI 96-06-332 risk significant breakers in shortest time possible.

Due 8/30/96

3. Notify Training Department to review floor tripper Maintentance Training assembly mounting screws and latch check switch PMAI 96-06-333 adjustments w/ EM personnel.

Due 8/30/96 i

i

~

Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitoring for a follow-up period to verify success, and a discussion to show how PS A and industrywide operating experience were used in the process.

i Goal Monitoring method & frequency Date PSA/ Industry Exp

1. Meet System

1. Continue monitoring system NPRDS data Performance Performance goals on a was used by a Criteria Monthly & Quarterly basis.

task team to -

benchmark.

2. Less than 2

2. Monthly monitoring after each PSA used to PMT failures on 4.16 kv safety breaker PM.

prioritize upcoming both units due to breaker Pms, floor tripper or latch check sw.,

and bkrs w/new PM.

IP3 & Davis Bessie

3. No demand

3. Monthly monitoring ofin identified as good failures on both service demand failures for every performers and units due to floor 4.16 kv safety breaker PM.

contacted.

tripper assembly mounting screws and latch check switch, on brks w/new Pms.

Dec

4. All SR breakers

4. Tracking breakers remaining for

'97 PM'd w/new floor new PMs.

tripper & latch check switch methodology.

Prepared by:

John Camobell 4/25/96 System Owmer Date Review and Concurrence:

Michael Snyder 4/25/96 Maintenance Rule Coordinator Date Review and Approved:

/bD 4/f7[ff, Ex' pert Fanel dhairman Date k

C i

( S n

Attacnrn@nt 0 I

CR # S 7 %

FIGURE 4 Page

/

cf I

(Page 1 of 2)

Goal Setting and Monitoring Unit: 1-Date:

6/25/96 Risk Significant:

+ Yes o No SSC: System 9b - Auxiliary Feedwater Reason for Goal Setting:

X Performance Criteria Not Met Which criteria were not met?

"-H'hy

< 2 MPFFs per train per 18 month period.

A uolellt Description of Events:

Reference CR 96-1276. I 9/15/94 - MV-09-12 would not open. MOV blown fuse was not correct size.

2 10/4/94 - Pump tnp on overspeed, controller had a defective actuator due to corrosion. 3 - 8/1/95 -

MV 09 !! would not close, torque switch contacts diny.

Repetitive MPFF (attach Figure 3 for each failure)

Explain how failures are repetitive.

Were previous corrective actions inadequate?

References (attach): CR 96-1347 which includes: Attachment 1. System Owner Root Cause Assessment: Attachment 2-System Engineer report 1-AFW: Attachment 3-NPWOs 63/2512. 65/0038.

64/1105: Attachment 4 Electrical Maintenance Procedure 0940077, Limitorque Motor Operated Valve Torque Switch Testing.

l Does this SSC require (a)(1) status?

Mark Wolaver

Yes o No System Owner i

Yes - signature of Expert Panel Member Mike Snyder i

Maintenance Rule Coordinator No - signature and reason why not v&/J [

Eipert fne/ Chairman i

f

..enme

- bh ',

- l'1% '

E of I sge o,

FIGURE 4 (Page 2 of 2) f Goal Setting and Monitoring (continued) i Root Cause Analysis:

Assigned to:

See Attachment Corrective Actions and Responsibilities:

Assigned to:

1. An inspection of the remaining DC MOVs was Jeff Cook conducted to verify correct fuses.-

COMPLETE 2a. Six month PM instiuted to verify clean connector Bob Coleman in the EGR.

COMPLETE t

2b. PMAI assigned to SCE for PCR to l&C PM proc.

Mark Wolaver for measuring EGR coilimpedance during PM.

2c. The EGR oil was changed from Vaportec Light to Bob Coleman to R&O 32.

COMPLETE 3a. PMAl assigned to EM for "ac found and as-left" Jeff Cook i

contact resistance trending during torque switch 2~

PM...also, inclusion of a CAUTION in this proc.

indicating the importance of contact cleaning.

I Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitoring for a follow-4 up period to verify success, and a discussion to show how PSA and j

l industrywide operating experience were used in the process.

4 a

t J

q t

T

-s s

4 FIGURE 4 (Page 1 of 2)

Goal Setting and Monitoring Unit: 1&2 Date:

6/26/96 Risk Significant:

.+ Yeso No SSC: System 01 - Reactor Coolant Reason for Goal Setting:

X Performance Criteria Not Met Which criteria were not met?

Unstailability Seven Days lost availability on Unit i due to I A2 RCP seal cartndge failure. Root Cause was venting. However, intiator was due to first stage seal failure.

Description of Events:

LER 95-004. I A2 RCP seal stage failure and subsequent manual venting caused failure of remaining stages. Seal replacement resulted in 7 days lost unit availability. (Affecting EAF) i Repetitive MPFF (attach Figure 3 for each failure)

Explain how failures are repetitive.

i Were previous corrective actions inadequate?

References (attach): LER 95 335-04.

Does this SSC require (a)(1) status?

Brian Kelly

+ Yes o No Component Owner Yes - signature of Expert Panel Member Mike Snyder Maintenance Rule Coordinator

.No - signature and reason why not xF 7

/ xpep4)anefChairman E

.~ _

4 FIGURE 4.-

(Page 2 of 2)

Goal Setting and Monitoring (continued) i i

Root Cause Analysis:

Assioned to:

A plant and industry historical review indicates that -

Brian Kelly i

^

the SU 'model seals do not have a reliable service j

[

life beyond 2 operating cycles. Past practice has been to try and operate up to 6 years with SU seals.

i l

i Corrective Actions and Responsibihties:

Assioned to:

1. PMAI issued to change the PM basis and frequency. Mike Snyder t

for SU seals refurbishment to each refueling.

'2. Submit and track'to completion an REA Brian Kelly j

to upgrade RCP seals from SU to N9000 cartridge, which has proven to be more reliable at other utilities.

3, Resolve technical concerns regardir.g N9000 seals.

Gerry Crowley i

Goal Setting and Monitoring: For each corrective action, there should be a goal to be attained that shows the action was correct, monitoring for a follov -up period i

to verify success, and a discussion to show how PSA and industrywide operating experience were used in the process.

fagal Monitorina method & fr'eauencv Qate PSA/industrv Ero j

1. For SU seals

1. RCP seal component engineer Until 1.NRC has recently that have been will monitor all RCP seal pressure 3/98 classified complete installed 5 2 cycle, breakdowns on both units once per RCP seal failure as no stage failures month.

possible accident due to aging.

precursor.

2. At the down power prior to Until

2. Begin SU seal refueling outage, the component 3/98

2. Industry wide changeout to at engineer will monitor the RCP seal experience has least every other pressure breakdowns and evaluate proven the N9000 refueling - OR -

possible continued use for a seal to be superior upgrade to N9000 second cycle.

to the SU seal.

seal by next refueling on Unit

3. The component engineer will Until

3. BJ was 1 and 2.

keep track of unit shutdowns 3/98 contacted about SU during a cycle to help in evaluating seal life & new j

SU potential second cycle use.

N9000.

j i

/W

~7 / @

Prepared by:' Component [wner Date Re' view and' Approved: #4h/,.

MIN ('

Egert Panel Chairman ~

Date i

L

.a

l

+

l

.t-i f

i

~

FOR A LISTING OF PERFORMANCE CRITERIA FOR EACH SSC, PLEASE REFER TO TAB #9, AND SECTION 6 OF THE ST. LUCIE QUARTERLY MAINTENANCE RULE REPORT.

t t

?

FOR A LISTING OF GOALS, PLEASE REFER TO TAB # 7, THE LAST PAGE OF EACH FIGURE 4 FOR THE SIX SSCs IN a(1) CLASSIFICATION, i

i t

t f

1

+

t

e s

FOR A LISTING OF MAINTENANCE PREVENTABLE FUNCTIONAL FAILURES, PLEASE REFER TO TAB # 9, SECTION 6 OF THE ST. LUCIE QUARTERLY MAINTENANCE RULE REPORT.

FOR A LISTING OF REPETITIVE MAINTENANCE PREVENTABLE FUNCTIONAL FAILURES, PLEASE REFER TO TAB # 7, THE FIRST PAGE OF THE FIGURE 4 FOR THE EMERGENCY DIESEL GENERATOR GOVERNO'RS, AND THE VITAL 4.16 KV BREAKERS.

j j

4

.

ML20137M358

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Accreditation Renewal Self-Evaluation Report Maintenance and Technical Training Programs, Jan 1995
Person / Time
ML20137M358
Site:	Saint Lucie
Issue date:	01/31/1995
From:	Fincher P, Sager D, Jason West FLORIDA POWER & LIGHT CO.
To:
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ML20137M358

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