ML20214M645

Insp Rept 50-302/86-21 on 860623-27.Violation Noted:Failure to Follow Training Procedures as Required by 10CFR50,App B, Criterion V

ML20214M645
Person / Time
Site:	Crystal River
Issue date:	08/21/1986
From:	Moore P, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214M628	List: ML20214M625 ML20214M634 ML20214M645
References
50-302-86-21, NUDOCS 8609110209
Download: ML20214M645 (9)

See also: IR 05000302/1986021

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UNITED STATES

fpm08709*o NUCLEAR REGULATORY COMMISSION

[" n REClON11

g ,j 101 MARIETTA STREET.N.W.

• ATLANTA, GEORGI A 30323

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Report No.: 50-302/86-21

Licensee: Florida'- Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

Docket No.: 50-302 License No.: DPR-72

Facility Name: Crystal River 3

Inspection Conducted: June 23-27, 1986

Inspector 4: +. - ++td m f40-96

E . R. McCoy ( Lead)' Date Signed

P. B. Moore -

T.'J. O'Connor

Approved by hu . hm

B./A. Wilson, Acting Section Chief

i[96

Date ' Signed

0$erational Programs Section

Division of Reactor Safety

SUMMARY

Scope: This special, announced inspection was conducted in the areas of licensed

operator replacement training, requalification training, general employee

training and management training. This inspection was conducted as a followup

inspection to those delineated in NRC inspection reports 50-302/85-01 and

50-302/85-22.

Results: One violation was identified - Violation 302/86-21-01, Failure to

Follow Training Procedures as Required by 10 CFR 50, Appendix B, Criterion V.

This item is discussed in paragraph 5.

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8609110209 860829

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• B. J. Hickle, Nuclear Plant Operations Manager

• R. M. Bright, Nuclear Licensing Manager

• L. C. Kelley, Nuclear Operations Training Manager

• V. R. Roppel, Technical Support Manager

• R. T. Wittman, Nuclear Operations Superintendent

• J. G. Smith, Nuclear License Operator Training Supervisor

• S. E. Blake, Non-License Training Supervisor

• W. P. Ellsberry, Nuclear Technology Training Supervisor

• T. W. Catchpole, Senior Nuclear QA Specialist

• J. L. Bufe', Nuclear Compliance Specialist

• D. L. Watson, Academic Specialist

• D. E. Porter, Senior Nuclear License Engineer

• M. H. Jacobs, Area Public Information Coordinator

Other licensee . employees contacted included technicians, operators, and

office personnel.

Other Organization

G. Carlson, ERC, Inc.

NRC Resident Inspectors

T. Stetka, Senior Resident Inspector

• J. Tedrow, Resident Inspector

• Attended exit interview

2. Exit Interview

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l The inspection scope and findings were summarized on June 27, 1986, with

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those persons indicated in paragraph I above. The inspector described the

areas inspected and discussed in detail the inspection findings. The

question of proprietary information was discussed at the exit interview.

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, Although some proprietary material was reviewed, none of the material was

( transmitted, nor is it incorporated in this report. No dissenting comments

l were received.

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3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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4. Unresolved Items

Unresolved items were not identified during the inspection.

5. Evaluation of Simulator Performance for License Candidates

Inspector follow-up Item 302/85-01-03 delineated concerns on replacement

operator simulator training in the areas of completeness of training

records, and evaluation of operator's simulator performance.

A review of TDP-202, Replacement Operator Training Program, indicated that

an extensive revision of the procedure had been issued which delineated

responsibilities, requirements, and evaluation standards for replacement

operator candidates. The inspector reviewed a random sample of records for

current licensed operator candidates. This review reflected establishment

of adequate requirements and, that with the exception of the violation

identified below, these requirements of the procedure are being met.

Inspector followup item 302/85-01-03 is considered closed.

During the review of simulator records it was noted that nine individuals

had received overall unsatisfactory simulator performance ratings on one of

three drill evaluations. These individuals were members of the October 25,

1985 and November 29, 1985 requalification groups. Procedure TDP-203,

Rev. 3, which was in affect at the time of these particular requalification

periods, required that upon any unsatisfactory evaluation, management

evaluate the operator's overall performance and determine whether the person

should be removed from license duties. If removed, remedial training shall

be prescribed and completed including a reevaluation on the simulator for

satisfactory performance prior to being reassigned to license duties. If

not removed, written justification shall be provided delineating the factors

which allowed the individual to continue performing license duties. The

inspectors noted that none of these actions were implemented as required

and consequently, this is a violation for failure to follow procedure

pursuant to 10 CFR 50, Appendix B, Criterion V, and is identified as

Violation 302/86-21-01.

As a result of the inspector's concern with this issue, the licensee evaluated

the overall performance of the subject operators and concluded satisfactory

overall performance such that the operators were not required to be removed

from licensed duties. The licensee's justification for this was

subsequently documented.

The inspectors expressed a concern that this failure to properly address

unsatisfactory simulator performances could be generic in nature and could

exist within the replacement operator program. Since this area was not

reviewed by the inspectors during this inspection, the inspectors consider

that the licensee should review the replacement operator program for similar

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occurrences. This matter will be reviewed during future inspections and is

identified as an inspector Followup Item (302/86-21-04).

In reviewing TDP-203 with respect to simulator performance, the inspectors

noted that the simulator training syllabus had been incorporated into the

procedure. The pages of the syllabus did not delineate procedure number,

revision number, page number, or date of latest revision. Consequently,

maintenance of adequate document control over this portion of the procedure

during change or revision would be difficult and could result in an

inadequate procedure. The licensee was informed of this concern.

6. Requalification Program Review

The inspectors reviewed the licensee's current requalification procedure,

TDP-203, Licensed Operator Requalification Training Program against the

requalification program submitted on March 15, 1985, for NRC approval. The

following comments were noted.

a. The submitted program and the FSAR, Appendix 12C, commit that the .

training manager will review and evaluate each licensee's entire '

training record. Procedure TDP 203 requires that the operations

training supervisor will review the licensee's entire training record,

evaluate the indicated level of knowledge, and complete a requalifi-

cation training checklist. Based on this evaluation, the training

manager recommends license renewal or additional training. The -

procedure does not delineate the manager's documentation review.

Although the program appears to conform to-the procedure, the procedure

may not be completely consistent with the program commitments. This

inconsistency does not appear to be a program reduction, as recognized

by 10 CFR Part 50.54 paragraph i-1, however, action should be taken to

ensure compatibility between the program description and procedure - 'u

requirements.

b. The inspectors noted that the requalification program states that the

plant drills implement training required in areas of major significance

including normal, abnormal, and emergency procedures, radiation

protection, design changes, and emergency plans on an annual basis. m

The program implies that an extensive number of drills are performed on -

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an annual basis. TDP-203 delineates, under the plant drill section,

that as a minimum, an abnormal and/or emergency walkthrough drill shall

be conducted on a quarterly basis. The scope of drills delineated in

the procedure appears to be somewhat less than that implied by program

description. The inspectors noted, however, that semi-annual

evaluations require the licensed operators to be evaluated periodically

on several emergency, abnormal, and plant operating procedures.

Recognition of these portions of the semi-annual evaluations as part of <

the drill program would clarify this concern. Resolution of this

, issue is identified as inspector followup item (302/86-21-05).

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c. The inspectors expressed a concern regarding the scope of the quarterly

review and evaluation of the on-shift reading and review ' activities.

TDP-203 states that if operational activities included in the quarterly __

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review requirements are not performed, they shall be walked through

using appropriate procedures. The walk through may be performed'on the

simulator in accordance with the control manipulations record. The

requalification program does not recogniv: use . of the simulator to

accomplish the quarterly review. Since the simulator is not site

specific, and .since the control manipulations are required to be

performed anyway, taking credit for the quarterly review requirements

by completing the control manipulations at the simulator could 'be

corsidered to be a reduction in program scope. A selected review of

records did not reflect cases where this practice had been implemented,

however, it is considered that revisions 'to the procedure or to the

j program are necessary in order to preclude ~ this possibility of program

i scope reduction from occurring.

d. The inspectors expressed a concern that the ,requalification procedure 7

lacks a formal mechanism to notify and document in an operators

training file that they are being removed from licensed duty as a ^ -

result of an unsatisfactory evaluation. Commensurate with this, the

procedure also lacks a formal mechanism to document reinstatement upon

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successful completion of accelerated training iand re-evaluation.

Resolution of this concern is identified as an inspector followup item

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(302/86-21-02). 9

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, 7. Implementation of Corrective Actions Associated with Confirmation of Action

i . Letter (50-302/85/02) dated Janua'ry 29, 1985

Inspector followup item 302/85-01-061 addressed verification of implementa- ,

tion of actions taken in response to the Confirmation of Action Letter

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(50-302/85-02) dated January 29, 1986. . This letter confirmed the

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understanding that Florida PowerqCorporation would (.omplete the following

• . actions for the Itcense replacement group that applied for NRC licenses in

December, 1984:

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Recertify to the~ NRC that the operator and senior operator applicants i

k examined by the NRC in December 1984, were qualified pursuant to

fN - - 10 CFR 55.10(a)(6). This recertification would be based upon verifi-

( A' cation of the completion of all applicable hot license training and

experience requirements; review and evaluaticn of hot license training

- and experience requirements; review and evai,bation of all written and

oral audit examinations; and resolution oRall identified straining

J;!eficiencies. Licenses for individuals who" passed the NRC examinations

woulg.bewithheldpendingreceiptofthisrscertification.

Cond'uct a quality assurance review of Crystal River operator training

I procedures and activities and meet with NRC-in Region II to dipeuss the

w s>results of this review. '

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""In i' letter dated April 4,1985, the licensee stated that the recertifica-

tion was' complete and documentation was 'available fpr review. In an

inspection of April 29 - May 1,1985,'.as documented'in inspection report

50-302/85-22, the NRC found the licensee's recertification to be inadequate.

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As documented in a licensee letter dated June 21, 1985 and in a management

meeting summary dated June 28, 1985, the licensee committed to augment and

formally document additional training for these license candidates. This

consisted of providing 14 additional hours of training in heat transfer /

fluid flow and thermodynamics; four additional hours of training in the

mitigation of core damage; providing verification of at least five

documented reactivity changes; providing comprehensive oral boards for each

of the candidates; providing walkthrough exams to include, but not be

limited to, immediate action steps to emergency ,nrocedura s , abaargal

procedures, equipment locations, and 390 Rindigetes aullity in git into

protoq;iva getf an_ quideligas t and prGviding an additional three weeks time

on snitt for all SRO candidates and selected time on shift for two of the R0

candidates. Additionally, the '.icorts ree-fit-4 ~ estew NRC form 398

traieteg atsr> sections and identify to the NRC differences hotween the

NRC 398 forma previously filed and that training which can be supportsd by

clear documentation.

In letters dated September 27, 1985 and March 17, 1986, the licensee stated

that eight individuals had completed the additional training, had been

recertified and were qualified pursuant to 10 CFR 55.10(a)(6). The

inspectors reviewed the records of these licensee candidates to determine

that all actions required of the licensee during the recertification were

satisfactorily accomplished. Areas reviewed by the inspectors were

classroom records, attendance sheets, tests, on-shift training records, oral

exams, remedial training, additional classroom instruction, R0 and Shift

Supervisor logs, and NRC 398 forms. The applicable training procedure at

the time that the above candidates received training was TDP-202, Rev.1.

The inspector compared the classroom records against this procedure and

found that each individual had received the requisite training. A review of

records reflected that all of the additional classroom training, oral

evaluations, additional time on shift, and walkthrough examinations were

adequately completed for all individuals. Additionally, a review of records

for each of the individuals reflected that the on-file NRC 398 forms supple-

mente( by the recertification letters dated September 27, 1985 and March 17,

1986, accurately reflected the training received by these individuals. The

inspectors interviewed two of the licensee candidates under review in order

to confirm that training had been accomplished as documented. These inter-

views confirmed this to be true. Three individuals were interviewed to

determine their perspective on changes in the training program over the past

eighteen months. These individuals considered that management had become

more responsive to their needs and more responsive in ensuring that both

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training and documentation of training was accurate and complete. Also, the

individuals interviewed indicated that they were aware of and had received

i training pertaining to the loss of Auxiliary Feedwater event at Davis-Besse

l and the loss of ICS power at Rancho Seco. The inspectors conclude that the

l licensee has adequately implemented commitments in the area of additional

! training and recertification provided to this licensee group.

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With respect to the second portion of the Confirmation of Action Letter, the

inspectors examined the April 22, 1985 quality assurance review of the

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license operator training programs. The inspectors noted the following

comments with respect to the quality assurance review.

. Item QPDR 85-QAS-0116 indicated the ' licensee's quality assurance

closure of the finding associated with instant SR0 training. The

inspectors expressed a concern that the 1984 instant SRO program did

not ensure participation in a training program equivalent to that of a

cold senior operator applicant as required by NUREG 0737, Item 1.A.2.1,

in that two applicants were presented for licensing while lacking

portions of formal training that would have been required in the cols

license training program, The inspeatner geted ingt fr une c52c , t?w

individual was not recertified and Pti 49al+eds9 43 s not resubmitted

and in the othew <a v e , vem >1(nhie h)piication was withdrawn.

Consequently, the concerns with this finding are not related to

licensing of personnel without requisite training, but are programmatic

in nature.

, The specific concerns include the fact that one 1984 instant SR0

candidate was tested at the R0 level rather than SRO level by the

licensee. This resulted in his not being tested in Category 8 for

administrative procedures. The licensee had evaluated this issue and

concluded it was acceptable based on the fact that he was in an R0

class which the licensee stated was identical to the equivalent SR0

class and the fact that the licensee had determined that the subject

matter of category 8 had, in fact, been tested through other sections

of tho individual's examination. The inspectors consider that it is

unacceptable for an individual applying for SRO license to be tested at

an R0 level and informed the licensee that, in all cases, individuals

are required to be tested by the licensee at the level for which they

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are applying in order to demonstrate suitability to sit for an NRC

examination. A review of the latest changes to TDP-202 and 1DP-106,

, reflected that procedures now require individuals to be tested at the

level for which a license is being sought and consequently for present

and future application, this item is considered resolved. Addition-

ally, the specific concerns included the fact that another license

candidate did not have the equivalency of ten hours of reactor

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shielding training or three weeks of nuclear instrumentation training

l that was previously required in cold license training. It is

l considered that the licensee should address formally to the NRC the

( equivalency of instant SR0 training with respect to cold license

training to preclude problems in the future. This matter will be

reviewed during future inspections and is identified as an inspector

followup item (302/86-21-03).

I Item QPDR SS-QAS-046 reflected the licensee's quality assurance closure

of the finding concerning instructor qualification and requalification.

Certified instructors who teach systems, integrated response, transient

and simulator courses are currently enrolled in only selected portions

of the requalification training program dealing with current operating

history, problems, and changes to procedures and administrative limits.

This is pursuant to the licensee's procedures and proposed program but

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is contrary to NUREG-0737, item 1.A.2.3. As noted in the Safety

Evaluation Report (SER) dated June 12, 1986, this practice is not

considered acceptable by the NRC. The licensee indicated that actions

are being taken to resolve certified instructor requalification program

inadequacies and that this will be addressed in response to the SER.

It was also noted by the inspectors that revisions are being made to the

audit scope statement for FPFseshdi n.* ining and qualification to

incargarath tr.c fulfe-leg e'.crasuis th cider to enhance future audits:

provide more explicit criteria for replacement and requalification

licensed operator training audits.

provide more explicit criteria for personnel qualifications versus job

requirements audits.

require that an SRO be a member of the audit team.

It is the inspectors' understanding : hat these revisions will be issued

prior to initiation of the next scheduled audit.

The inspectors considered that inspector followup item 302/85-01-06 is

closed.

8. Management Training

Inspector Followup Item 302/85-01-11 addressed concerns with incomplete

management training. After a review of the management training program and

discussion with licensee personnel, in both the Training and Human Resources

Departments, the inspectors determined that there exists an adequate program

for management training.

The program is directed by the Corporate Management Development Plan. This

plan consists of three steps of training: Phase 1 Supervisory; Phase 2

Management; Phase 2 Executive. Each plan is designed to develop the skills

necessary to fulfill the responsibilities of each management position. The

plan also establishes processes and procedures for nominating and scheduling

participants. For example, once a year, the managers of Phase 1 Supervisors

submit a list of nominees from their departments to their Senior Vice-

President for review and approval . .Upon receiving the approved list from

senior management, the Management Developement Section schedules partici-

pants for the entire year's programming. A review of selected records

indicated that Crystal River employees have participated in :.nis program in

the past although this participation has been minimal for some departments

and that the program is implemented in accordance with the development plan.

The inspectors consider that inspector followup item 302/85-01-11 is closed.

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9. General Employee Training

Inspector followup item 302/85-01-12 addressed concerns on General Employee

Training (GET). The following observations were made with regards to item

302/85-01-12:

Training has beer revised to reflect plant policy for when and how

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individ W e Md report observed potential problems to quality

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6!.id t e.T.Cs .

Training has been revised to reflect that if a safety concern is noted,

which plant organization should receive the notification.

Examinations have not been revised sufficiently to reflect an accept-

able level of diversification. Examination questions were essentially

the same and were simply reordered. Merely revising the order in which

the questions are arranged on a page is not sufficient for establishing

examination diversity.

Inspector followup item 302/85-01-12 remains open pending res.. . ation of

concerns with examination diversification.

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