ML20140B645
| ML20140B645 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/10/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-774, NUDOCS 8601270069 | |
| Download: ML20140B645 (10) | |
Text
Georgia Power Company
+ 3, Route 2. Box M9A Waynesboro. Georg'a 30830 Telephone 404 554-9961. Ext. 3360 404 724 8114, Ext 3360
- MPl 16 Geo laPower
- o. o. roster Vice Presider.t and Pro 3ect Generai t. tanager Ite soutem electnc system vogt:0 Project January 10, 1986 United States Nuclear Regulatory Commission File: X7BG10 Region II Log:
GN-774 Suite 2900 101-Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
Vogtle Electric Generating Plant - Unit 1, 50-424; NRC Inspection Report 50-424/85-51 Attantion:
Mr. J. Nelson Grace The l'o11owing information is submitted, as requested by NRC in report number 50-424/85-51, to enable NRC to finalize conclusions regarding, and issue a report for, NRC review of Readiness Review Module 2, Operations Training and Qualification.
Georgia Power Company is pleased with the NRC assessment team's observations presented at-the egit interview regarding the apparent commitment of GPC employees to the company, to Plant Vogtle, and to the training programs.
Georgia Power Company agrees with the NRC assessment team that having employees who are highly supportive of the training programs in which they have participated speaks well of the quality of training.
Inspection Report 50-424/85-51 identified a nurber of inspector followup items. Georgia Power Company believes it is important to note that a majority of the concerns and recommendations identified in the report had.
already been identified by GPC for correction or resolution either through our Readiness Review process or in training schedules and through plans to achieve INPO accreditation. It should also be noted 'that many of the concerns and-recommendations expressed by NRC are not necessarily indicative of deficiencies in the training programs or in the Readiness Review process.
Areas of concern and recommendations-that were listed as NRC followup items can be broken'down into 4 broad categories. Attachment 1 to this letter
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delineates which areas of concera are in each category and indicates those i
that had already been identified by Georgia Power Company for resolution, j
Where more than one followup item addressed the same area of concern, they I
are grouped together to address the area of concern as a whole. A summary of the categories and the previously identified activities is' presented i
below.
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0601270069 860 j24 PDR ADOCK O PDR G
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Number of activities Category already identified by GPC 1.
Followup verification of activities 12 of 12 already planned or in progress by CPC 2.
Training administrative activities 3 of 6 3.
Examination administrative activities 1 of 4 4.
Other NRC questions or requests 0 of 6 Analysis of the inspection report concerns and recommendations that had not been previously identified by Georgia Power Company allows sorting the remaining concerns into two (2) categories:
1.
Those items where NRC requests GPC to evaluate certain activities:
a.
(IF1 424-85-51-17) Evaluate current course waiver criteria.
b.
(IFI 424-85-51-20) Evaluate length of hot participation experience.
c.
(IFI 424-85-51-21) Evaluate instructor qualification and requalification programs.
d.
(IF1 424-85-51-23 and 28) Evaluate mitigating core damage training programs.
e.
(IFI 424-85-51-27) Fialuate SER item regarding ANSI 18.1-1971 commitment.
2.
Activities indicative of deficiencies not previously identified:
a.
(IFI 424-85-51-30) Upgrade quality assurance department continuing training, b.
(IFI 424-85-51-31) Upgrade quality assurance department examination controls, c.
(IFI 424-85-51-01) Two deficiencies noted in Readiness Review Module 2.
d.
(IFI 424-85-51-03 and 04) Proceduraliza exam retention requirements and evaluate historical records.
e.
(IFI 424-85-51-06, 07 and 08) Improve examination grading and regrading controls, evaluate historical records.
f.
(IFI 424-85-51-12) Improve examination security.
GPC believes that identification of these administrative problems in this early stage of plant-life will enable timely resolutions to be made. GPC is.
totally committed to high quality training programs which will be of great value during startup_and operation of our nuclear units.
NRC requested a response to specific followup items delineated in the cover 1cteer to Report 50-424/85-51. The detailed discussion of these particular items is included as Attachment 2 to:this letter.
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GPC will submit additional correspondence regarding further evaluation of NRC concerns and recommendations under separate cover at a later date.. It is noted that some of the comments made by the NRC, in our view. go beyond regulatory requirements. Notwithstanding this observation, GPC appreciates any observation that will improve our programs and will continue to positively evaluate these recommendations and implement programs as appropriate.
This response contains no proprietary information and may be placed in the NRC Public Document Room.
/
Very ru ur.
D. O. Foster PDR/GB/DOF/kss xc:
U. S. Nuclear Eagulatory Commission Document Control Desk Washington, D.C.
20555 R. J. Kelly J. A. Bailey D. L. Kinnsch (BPC)
R. E. Conway O. Batum F. B. Marsh (BPC)
J. P. O'Reilly G. Bockhold C. S. McCall (OPC)
G. F. Head C. E. Belflower J. L. Vota (W)
J. T. Beckham H. H. Gregory E. L. Blake, Jr.
R. H. Pinson E. D. Groover (Shaw, et. al.)
P. D. Rice L. T. Gucwa J. E. Joiner B. M. Guthrie J. W. Hayes (Troutman, et. al.)
D. E. Dutton G. A. McCarley D. C. Teper (GANE)
R. A. Thomas R. W. McManus L. Fowler (LEAF)
D. R. Altman W. T. Nickerson T. Johnson (ECPG)
NRC Sr. Resident D. S. Read
ATTACHMENT 1 A.
FOLLOW-UP VERIFICATION OF ACTIVITIES ALREADY PLANNED OR IN PROGRESS PREVIOUSLY IFI#
SUMMARY
IDENTIFIED REFERENCE 51-09 Proceduralize grading criteria Yes 60002-C 51-10 Document, standardize remedial training Yes 60002-C 51-16 Validate computerized training records Yes RR-2 (6.2.3) 51-18 Modify simulator to match plant Yes 60203-C 60200-C 51-19 Continue walkthrough and on-shift Yes N/A experience training 51-22 Conduct instructor evaluations Yes 60100-C 51-24 Conduct training on technical Yes N/A specifications 51-25 Conduct emergency plan training Yes RR-2 (6.2.3) 51-29 Implement maintenance department Yes NUREG 0737 operational experience feedback I.C.5, 00414-C, 00405-C 51-34 Maintain objectivity in selecting Yes N/A training methods 51-35 Establish course evaluation procedures Yes INPO Accred.
Criteria 51-36 Incorporate commitments only in Yes 00405-C controlled documents B.
TRAINING ADMINISTRATION PREVIOUSLY IFIf
SUMMARY
IDENTIFIED REFERENCE 51-02 Proceduralize courses of study Yes RR-2 (5.1) 51-33 INPO Accred.
51-03 Proceduralize exam retention No 51-04 requirements and evaluate past records 51-13 Document simulator control manipulations Yes Draft 00710-C 00714-C 1
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B.
TRAINING ADMINISTRATION (CONT)
PREVIOUSLY IFIf
SUMMARY
IDENTIFIED REFERENCE 1
51-14 Formalize controls over training Yes 60005-C and 51-15 materials INPO Accred.
Criteria i
51-17 Allow waivers based on examination only No 51-20 Evaluate Jength of hot participation No experience C.
EXAMINATION ADMINISTRATION PREVIOUSLY IFIf
SUMMARY
IDENTIFIED REFERENCE 51-05 Examination regrading controls Yes RR-2 (6.2.3) and HNP 51-06 Management evaluation of past No 51-07 examinations and grading 51-08 51-11 Establish policy on reuse of questions No 51-26 on subsequent examinations 51-32 51-12 Improve exam security No D.
OTHER ITEMS NOTED IN NRC REPORT PREVIOUSLY IFI#
SUMMARY
IDENTIFIED REFERENCE 51-01 Readiness Review module weaknesses No 51-21 Instructor qualification and No requalification concerns 4
51-23 Evaluate mitigation of core damage No 51-28 training 51-27 Resolve SER item regarding ANSI 181-1971 No commitment 51-30 Upgrade Quality Assurance department No l
continuing training 51-31 Upgrade Quality Assurance department No exam controls 2
ATTACHMENT 2 IFI 424-85-51-01 The NRC assessment team noted that Readiness Review confirmed the inclusion of CET commitments in lesson plans rather than the implementing document, procedure 00700-C, and considered that this circumstance should have represented a finding and had not.
GPC acknowledges that failure to incorporate GET commitments into procedure 00700-C should have been part of Finding 2-9, in which 11 other examples of procedures were cited as lacking or not adequate-ly implementing commitments. The current policy of Readiness Review is to issue findings regarding operational commitments whenever commitments are inadequately addressed by approved proce-dures, are not identified for implementation in planned procedures, or are not in the Nuclear Operations commitment tracking system..
Further, it is the policy of Georgia Power Company to implement commitments in controlled documents. The GET commitments will be incorporated into the procedures.
With regard to the Readiness Review acceptance of the Project's response to Finding 2-8, GPC believes the acceptance was justified.
Readiness Review's stated purpose is to conduct a self-assessment of work processes and verification of compliance with regulatory commitments. The only regulatory guidance governing records of training and qualification simply states that records of training and qualification shall be maintained. Records were evaluated by Readiness Review and weaknesses were identified as stated in Finding 2-8.
Resolution of the finding was considered adequate to encure that records of training and qualification were maintained and were identifiable and retrievable. Record retention require-ments of the scope and magnitude indicated by the NRC assessment team were not considered necessary by Readiness Review to document training and qualification in view of the existing regulatory guidance. Further discussion of records retention is provided in the response to IFI 424-85-51-03.
IF1 424-85-51-02 A course of study which consists of a detailed schedule of lectures and examinations is prepared prior to the commencement of each operator training class. These course schedules were originally based on the broad requirements delineated in the FSAR. As plant construction, definition of work processes and development of procedures has progressed, improvements were made in the training programs.
It was already noted by GPC that standardization of
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training courses would be highly desirable. Work on training and qualification procedures has been in progress as outlined in the Readiness Review Module 2.
As efforts toward INPO accreditation proceed, standardization of training courses will be accomplished.
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IFI 424-85-51-03 Training record retention requirements are clearly delineatedLin j
plant procedures. Established plant procedures require retention i
of class attendance records, grade reports, and course schedules and outlines. These records are sufficient-to determine what-1 -
course of training was conducted, when, and the performance of each-l student in the course.
In addition, master copies of examinations i
and associated answer keys are kept. Copies of examinations l
completed by trainees representing completion _of major sections of training are generally retained.
I VEGP has retained individual comprehensive examinations completed' i
by students' at the end of courses of study. However, VEGP did not have procedural controls in place to require retention cf these i
examinations. The NRC assessment team indicated that all examina-tions used to determine qualification status should be retained.
j Current training records retained amount to approximately 12,000 pages per year. Keeping all student examination answers, as re-i quested by the NRC assessment team, would increase the number of pages retained to well over 100,000 per year. VEGP does not feel that keeping the additional records would contribute to improved training. VEGP agrees that retention of comprehensive examinations
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should be proceduralized. Accordingly, VEGP procedures will be modified to require retention of selected examinations. 'We would I
be pleased to discuss this matter with you at a special meeting if you desire.
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I IF1.424-85-51-04 i
l Since there has not previously been a procedural requirement to-
-retain student comprehensive examination answers, VECP will review l-individual training' records of each license applicant, and evaluate j
their adequacy to justify the satisfactory completion of training.
l Corrective actions will be taken if appropriate.
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l IFI 424-85-51-05 Regrading of examinations by training instructors and supervisors has always been authorized to ensure fairness and ' accuracy. - -Since these are the persons responsible for writing the examination and-answer key and subsequently grading the examination, it appears i
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appropriate that they should have the authority to adjust grades.
Students are afforded the opportunity to provide feedback to i
training staff members on their examinationsand the grading of-their examinations.- In some cases, trainees point out areas.where I
the grading of an examination was unfair.to them. Most regrading ~
occurs as a result of this mechanism. NRC' license examiners make use of the same feedback mechanism by allowing utility staff'_
members to review and comment on license examinations. This has been an accepted industry practice and should, in our view, be continued in the interest of being fair to students. Any grade 2.
IFI 424-85-51-05 (cont.)
adjustments made are initialed by the training staff member making the adjustment. The training staff had recently decided to further require that the reason for exam grade adjustments be documented.
As suggested by the inspectors, these documentation requirements will be added to the existing exam administration procedure.
IFI 424-85-51-06 and 51-07 The assessment team pointed out that regrading of examinations without substantiating the reasons for grade adjustments casts doubt on the integrity of the examination process.
In order to ensure the integrity of the training examination process, an audit of all major examinations on file for licensed operator candidates will be conducted. A sample of at least 20% of these exams which were administered to each class shall be regraded. The results of the regrade shall be compared to specified cr1teria for acceptable deviations from original grauing.
If the regrading indicates significant deviations from the original grading, then additional examinations shall be subject to regrading until the integrity of examination grading has been established.
Additionally, to ensure the integrity of future examinations, procedural controls will be established to improve the examination development process and the examination grading process. These measures will ensure that the need for regrading will be minimized and that any regrading necessary will be adequately documented.
IFI 424-85-51-08 The grading of the examination in question was checked and found to be 79.8% instead of the indicated 80.1%.
Passing criteria for the examination is 80.0%. The individual was notified of his ex-amination failure and was disqualified from teaching licensed l
operators.
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IFI 424-85-51-09 Course completion criteria are already specified by procedure 60002-C, " Training Administrative Policies and Procedures".
Successful completion of a course requires a score of 80% unless specified otherwise.
In the case of licensed operator training, r
i 80% is the only criteria used. The inspection report states that l
one individual was given credit in March 1985 for a course without l
meeting the 80% criteria. VEGP could find no instance where this occurred. We will discuss this matter further with your training staff.
It la not and never has been the intention to give credit for course completion when the procedurally-established completion criteria have not been met.
VEGP shall review past training records to ensure that no course completion credit has been given 3
7 IFI 424-85-51-09 (cont)
I without the individual meeting the established ~ criteria.- The l
function of the review committee is to evaluate student perfor-mance, identify student weak areas, and recommend remedial train-1 ing.
Credit for course completion is granted upon completion of j
the remedial training.
IFI 424-85-51-10 i
'If an individual fails to meet the established course completion criteria, no credit is given for completing the course.
In most cases, the individual simply repeats the course. In these cases, the criteria for satisfactory completion of the training is the same as for the first attempt. In some cases a review committee, I
j comprised of. management personnel, reviews the training record of i
the individual and makes a determination as to appropriate remedial-l training requirements, including the criteria for satisfactory j
completion of the remedial training. The review committee thus has j
the flexibility to tailor specific remedial training activities to i
particular trainee weaknesses. Standardization of remedial train-j-
ing could result in trainees attending remedial training that was not appropriate for their needs.
i IFI 424-85-51-11, 26, 32 i
Each of these followup items noted a lack of consistent policy governing reuse cf exam questions. GPC acknowledges this deficien-cy and will establish policies governing reuse of questions on j
examinations.
i IFI 424-85-51-12 The inspectors noted a weakness.in examination security. GPC i
acknowledges the need to enforce tighter security measures'for l
examinations.
In cases where a large number of questions and
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answers in a particular subject area exist, access to the bank of questions and answers will not be withheld from students. - Correct -
l answers to questions are considered a useful tool to aid students in learning. We understand that the NRC supperts this approach
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where a large number of appropriate questions and answers resides in the data base.
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IFI 424-85-51-15
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Procedural controls over training materials are being developed on i
a schedule consistent with efforts toward INPO~ accreditation.
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IFI 424-85-51-17 GPC agrees with the inspectors that examinations are a good crite-F ria to use for course waivers. GPC also believes that an l
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j individual who completes a cou'rse at another facility, eg. Hatch, 4
should not have to repeat the course upon transfer.to VECP if'the course is the same. GPC does agree that a reasonable time frame following course completion should be a requirement for waivering a course without examination. Acceptable criteria will be estab ~
lished and used.
i IFI 424-85-51-23 l
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CPC is'avare of and will ensure that all license candidates com-j plete the required training, including mitigating core damage training, prior to sitting for license examinations. The licensed operator mitigating core damage course will be evaluated in compar-ison with other mitigating core damage training for adequacy. Any corrective action deemed appropriate will be taken.
IFI 424-85-51-31 The examination that had been released to an individual after he I
completed his lead auditor certification requirements was being kept in a locked file drawer at his desk. The examination was l
recovered and placed in the individual's training file, which is maintained by the QA Training Coordinator. A pool of test ques-tions has been developed for the Phase III examination and-is presently being developed for the Phase V examination and is expected to be completed by February 15, 1986.. Each question in the pool is assigned a number and numbers will be raridomly selected to put together new examinations as required to ensure adequate control of auditor qualification testing.- Since most QA personnel have completed their certification requirements, it is unnecessary j
to construct new examinations on a regular basis. Therefore, a new 3
examination will be developed as deemed necessary by the Training-Manager and/or the QA Site Manager.
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IFI 424-85-51-33 l'
A memorandum dated January 9, 1984 and follow-on discussions between the training department and the Superintendent of Engineer-l ing established the criteria for passing the course.
Individual performance in the course was used as a basis for conducting annual personnel performance evaluations and for making job assignments.
Individuals making below 70% were not given credit for the course.
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IFI 424-85-51-36 VEGP policy is to implement coemitments in controlled documents.
Failure to incorporate GET program requirements into procedure 00700-C was an oversight. The commitment tracking program would have identified the oversight at a later time. The commitments
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will be incorporated into the procedure.
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