IR 05000352/1987026

Insp Rept 50-352/87-26 on 871013-16.No Violations or Deviations Noted.Major Areas Inspected:Nonlicensed Staff Training,Training of Station Auxiliary Operations,Nuclear Training Section & Qa/Qc Interface

ML20236V181
Person / Time
Site:	Limerick
Issue date:	11/17/1987
From:	Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236V173	List: IR 05000352/1987026 ML20236V172
References
50-352-87-26, NUDOCS 8712040136
Download: ML20236V181 (10)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-26 l Docket N '

License N NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street

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Philadelphia, Pennsylvania 19101 l

) Facility Name: Limerick Generating Station Inspection At: Limerick, Pennsylvania )

Inspection Conducted: October 13 - 16, 1987 Inspectors: A # .N' . N i~Finkel,SeniorheactorEngineer date l

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Approved by: / l! !8 N. Blumberg, Cfief, Operationa)' Programs date Section, OB, DRS Inspection Summary: Routine, unannounced inspection conducted on

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October 13-16, 1987 (Inspection Report No. 50-352/87-26). i Areas Inspected: Non-licensed staff training, training of station auxiliary operators, Nuclear training section, and QA/QC interfac Results: No violations or deviations were observed.

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8712040136 871125 l'

$DR ADOCK 05000352 PDR E___________ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ >

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DETAILS-1.0 Persons Contacted R. Balmer, Superintendent of Nuclear Training Section (NTS)

• V. Cuietiewicz, Power Generating Engineer

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• J. Poering, Superintendent Operations

• T. Dougherity, Lead Chemistry / Instrumentation Engineer-J. McElwain, Lead QA Auditor

• D. Neff, Compliance Engineer J. Rubert, QA Site Supervisor I During the course of the inspection, the inspector also contacted other I technical and administrative personne United States Nuclear Regulatory Commission

• S. Kucharski, Resident Inspector

• Denotes those who attended the exit meeting on October 16, 1987.-

2.0 Non-Licensed Staff Training The effectiveness of the implementation of the licensee's non-licensed training program was assessed by reviewit.g the following activities.in the operations, engineering and quality assurance areas. Selected areas I

of the maintenance and instrumentation and control non-licensed training were also reviewed by the inspector as defined belo On the job training and qualification of Non-Licensed Operators (NL0s), Health Physicists and Chemistry Technician Training Plans for NL0s; Health Physicists; Chemistry Technicians; Technical Staff; and, Manager and Instructor Certificatio Training records for the above listed personne Three quality assurance audit reports and one surveillance report and their respective corrective action responses concerning trainin Lessons learned from Licensee Event Reports (LERs), NRC Inspection Reports, NRC Information Notices, Bulletins, and other source data used to change or update training lesson plan The selected activities were conducted in accordance with the licensee's procedures by personnel knowledgeable in the requirements of the proce-dures, Technical Specifications, Final Safety Analysis Report (FSAR), and other referenced documents. Working level personnel and management were

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aware of the roles of Quality Assurance (QA), Quality Control (QC) and personnel training in safety-related work activities. Activities affect-ing non-licensed training were conducted in accordance'with the licensee's commitments and procedure No violations or deviations were identified.

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3.0 Station Training l l

The training of NL0s, i.e., Auxiliary Operators (A0s)', Assistant Plant ~ j Operators (AP0s), and Plant Operators (P0s) is cc'iducted in accordance 'q i

with procedure A50, " Conduct of Station Training", and the NLO Training l Program Plan. The station superintendent, and the Nuclear Training l l Section superintendent are responsible for monitoring, reviewing and approving the plant training program. The Fossil Training Section pro-vides support in the areas of company certification of NL0 ;

I The Station Training Coordinator (STC) is the individual responsible for i the day to day training activities in areas such as:

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Developing and implementing the station training progra Developing required training procedure Developing and maintaining the initial training, requalification and !

replacement programs for plant technical staff and non-licensed operator ;

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Ensuring that appropriate NRC, Industry, QA and other recommendations :

are defined in the programs, and  ;

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Ensuring that INP0 accreditation standards are maintained.- j To comply with the above criteria, the training section has issued a l

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Nuclear Training Manual . The scope of the NTS training manual-complies with the requirements of their Technical Specification, Section 6.0, ANSI, N18.1, ANS 3.1, and FSAR Chapter 1 In addition, the licensee has re- l ceived the Institute of Nuclear Power Operations (INPO) accreditation for ten of their training program No violations or deviations were identifie .0 Nuclear Training Section The Limerick Training Branch is responsible to the Nuclear Training Section (NTS) for licensed operator training, NLO training, Chemistry and Health Physics training, General Employee and Special Training and the

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Technical Staff and Manager training. The superintendent of the NTS is also responsible to coordinate all areas of training required to maintain the INPO accredited progra _ __ _ - - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _-_ l

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l The superintendent of NTS is the chairman of the Nuclear Training Review Committee which meets quarterly. 1he Maintenance and Test and Instrumen-tation and Controls Division Training Coordinates are members of tne committe It is the responsibility of this committee to assure that the INP0 accredited program maintains ~its accreditation status. The authority :

of how this committee maintains the present level of program-accreditatio l is not clearly define The. inspector determined that the minutes of l this committee are not issued to management for an overall program status 1 evaluation. This item is to be discussed under the new organization that is presently being established by this licensee and may define this area in a concise manner. This subject was discussed with the 1icensee during the exit meeting on October 16, 1987 and it was indicated by the-licensee j that the new organization that is being developed may address the above J concern j The Limerick Regulatory Engineer (LRE) provides the Training Coordinators with regulatory requirements or information, and other sources such as INPO information, LERs, and industry lessons learned are reviewed by the LRE for their impact on the training program lesson plans. Of the five LERs reviewed by the inspector (See Attachment 1), only LER 87-042 re-quired a lesson plan change. LER 87-042 concerning " Actuation of Engineering Safety Features due to a Personnel Error" was factored into the training progra The inspector reviewed the training records (See Attachment 1) of operations, technical staff, chemistry technicians and General Employee Training. The records were complete, up-to-date and in compliance with ANSI N1 A method that the Nuclear Training Section uses in reviewing the status of their training lesson plans is the Program Revision Action (PRA)

procedure. The PRA provides the licensee a method to effect their

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training program revisions based on internal, external and program source information. The PRA form, when completed, is reviewed by the Training Coordinator / Branch Head to determine the affect of the source input on the associated lesson plan. During a review of LERs by the NRC resident

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inspector, a concern was raised regarding the number of late samples of '

reactor water chemistry identified in the LER During the inspection of ;

the PRA system the inspector selected LER 87-036 and 87-034 which dealt '

with the subject of late chemistry samples. Both of these LERs were identified by the PRA system (item No. 87-1273), and were reviewed by the training section to determine if the training lesson plan required changes. No lesson plan changes were require No violations or deviations were identifie !

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i 5.0 QA/QC Interface With Non-Licensed Training The Limerick site QA Supervisor reports to the General Supervisor of the Audit Section in the Electric Production Department QA Divisio l Similarly the Quality Control (QC) Supervisor reports to the General i

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Supervisor in the QC Section. QA audits are performed in accordance to l l QA Department Procedure (QADP) 5, and QA surveillance are performed in l l accordance with QADR-1 The inspector reviewed three audit reports and one surveillance report dealing with the training of non-operating personnel. Finuings identified in the audits and surveillance reports were. tracked by the QA audit function. The inspector determined that the findings.were answered in a reasonable length of time and actions that required training lesson plan changes were completed and personnel retrained with.the updated information. An example of a training. lesson plan change was identified'

in finding AL-87-12TR. This finding required changes to HP-100 (Health Physics Department Selection Training and Qualification Course). The inspector verified that the plan had been corrected and training given'to i the personnel as listed in the audit findin Surveillance audits are similar to QA audits except there are no formal audit plans or audit checklists and no exit discussions with management if no deficiencies are identified. A surveillance may include the observa-tion of work in progress or special area or location events; requested by managemen Surveillance Audit SL 86-09TR, " Training of Maintenance Division Craftsman Assigned to Limerick Generating Station".(LGS) was performed to assure that their LGS training reflected the latest site requirements. The inspector determined that their. training level and data was acceptabl The QA Audit function just completed an audit of the. LGS "Non-Licensed Operator (NLO) Training /Requalification Program". The purpose of this audit was to verify the adequacy and effectiveness of the administrative controls established for the training and requalification of non-licensed operators assigned to LGS. The audit period was from August 11, 1987 -

October 9, 1987. The inspector reviewed the draft' copy of this report and there was not any significant findings that would affect the present Limerick Station Training Progra No violations or deviations were identifie _ _ _-_-___________-_ _ _ _ __ _ _ _ _ ____ - ____-___ _ _ _ - . _ _ _ . ____ _. _ _ _ _ _ - _ . _ _ _ _ - - _ _ _ _ - - _ _ _ _ -

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6.0 Exit Interview q Licensee manacement was informed of the scope and purpose of the j inspection at the entrance interview on October 13, 1987. The findings '

of the inspections were discussed with licensee representatives during the course of the inspection and presented to licensee management at the October 16, 1987 exit interview (see paragraph 1.0 for attendees).

At no time during .the inspection was written material provided to th l licensee by the inspectors. The licensee indicated that no proprietary information was involved within the scope of this inspectio j i

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ATTACHMENT 1 l 1 Licensee Compliance Documentation Reviewed j

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Technical Specification - Section 6.0' Administrative Controls 1 Paragraph 6.4 training .

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ANSI'N18.1, 1971 " Selection and Training of Nuclear Power Plant i Personnel"

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ANSI /ANS 3.1,1981 " Selection, Qualification and Training o Personnel for Nuclear Power Plants"

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10 CFR 50 - Appendix B, Criterion II

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FSAR - Chapter 13, Conduct of Operation 2. Administrative Procedure Review

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A-50 - Procedure for Conduct of Station Training, Revision 1, January 28, 1987 3 i

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Appendix A of A-S0 - Matrix of Limerick Generating Station (LGS) )

Training Program Guidelines

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Appendix B of A-50 - Licensed and Senior Licensed Operators

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Appendix C of A-50 - Non-Licensed (Floor) Operator Training !

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Appendix D of A-50 - Plant Staff Training l

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Appendix E of A-50 - General Training 3. Nuclear Training Section Procedures Reviewed

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NTS-A-001, Control 7 Revision of the NTS Training Manual, Revision 0, December 3, 1986

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Exhibit 9.1, Training Manual, Revision 2, February 14, 1986

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NTS-I-00?0, Intra-Company Training, Revision 0, February 23, 1987 ;

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NTS-I-100, Analysis, Revision 0, October 24, 1986  ;

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NTS-I-103, Task Analysis, Revision 0, September 4,1986

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NTS-I-201, Objectives, Revision 0, February 5, 1987

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NTS-I-203, Training Plan, Revision 0, February 5, 1987

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NTS-I-302, Program Plan, Revision 0, February 10, 1987-

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ATTACHMENT'l A-2

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NTS-I-303, Lesson Plans / Lab, Revision 0, February 10,-1987 ,j

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NTS-I-306, Training Cross-Reference Matrix, Revision 0,  !

February 10, 1987

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NTS-I-401, Certification of Instructors, Revision 0, ,

February 10, 1987

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NTS-I-402, Conduct of Training, Revision 1, March 9, 1987

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NTS-I-403, Documentation, Revision 0, February. 10, 1987 l l

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NTS-I-500, Evaluation, Revision 0, October 24, 1986 .;

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NTS-I-501, External Evaluation, Revision 0, September 4, 1986

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NTS-I-502, Internal Evaluation, Revision 0, September 4,.1986 j

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NT3-I-503, Program Evaluation, Revision 0, September 4,1986

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NTS-I-504, Program Revision Action, Revision 0, September'4, 1986 Chemistry "A" Technician Lesson Plans Reviewed

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0950, The Corrosion of Carbon Steel, Revision 0, August 9,1985

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0954, Corrosion of Electrochemical Principles, Revision 0, 1985 '

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0980, Direct Current Plasma Spectimeter, Revision 1, June 10,'1987

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8601B, Chemistry Surveillance Test and Technical Specifications, l Revision 0, January 8,1986 j l

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8709, Equipment Trouble Tags, July 7,.1987 i

' Non-Licensed Operator Continuing Training Lesson Plans Reviewed '

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0010, Introduction to Technical Specifications, Revision 0,  :

October 22, 1985 '

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0050, Emergency Plan and Procedures, Revision 0, October 30, 1985

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0110, Safety Related Switch Gear Circuit Breakers, Revision 0, February 1,1986

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0130, General Plant Procedures GP-1 and GP-2, Revision 0, February 3, 1986

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ATTACHMENT 1 A-3

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0250, Fire Protection System, Revision -1, June 6,1986' j

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0260, Loc,al Valve Position Indication, Revision 0, June 13,1986

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0310, A Racking In/0ut Various LGS Circuit Breakers, Revision 0, '1 i

July 22,1986 .i i

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0410, Lubrication and Bearings, Revision 0, December 31, 1986 'l

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0590, DC Distribution, Revision 0, November 15, 1986

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'0735, Limitorques, Revision 0, September 4, 1987 i General Employee Training for the Radiation Worker Reviewed

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0010, Introduction, Revision 3, June 25,1987 l

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0010-0080, Radiation Health and Safety, Revision 3, June 25, 1987

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0110, Quality Assurance, Revision 3, June 25,1987 l

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- Technical Staff and Management Training Courses Reviewed

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2510, Equipment Environmental Qualification Program, Revision 0, _j July 13, 1987  ;

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2530, Safety-Related and Technical Specification Equipment Trouble-  ;

shooting Continuing Training,. Revision 000, September.2, 1987 l l

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2520, Q Listed Procurement, Revision 000,-September 1, 1987 *

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2540, Industry Events / Plant Modification / Procedure Changes,  :

Revision 0, September 1, 1987 l Attendance Records l

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I Attendance records for the above listed lesson plans were reviewed by the '

inspector for compliance with the site requirement attendance procedure . Licensee Event Reports (LERs) Reviewed

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LER 87-042, September 17, 1987, " Actuation of Engineered Safety Features due to a Personnel Error."

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LER 87-041, September 9,1987, " Nuclear Steam Supply Shut-Off System Isolations'due to a Loose Power Supply Cable Conversion."

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ATTACHMENT l' A-4-

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LER 87-039, Atgust 31, 1987, " Noncompliance with Technical Specifi-cation Action Statement because of Late Grab Sample caused .;

by Personnel Error."'

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LER 87-038, August 1,1987, " Nuclear Steam Supply Shut-Off System .i Inboard Isolation due to a Personnel Error."

1 Limerick Training Program (INP0 Accredited) Review  !

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Non-Licensed Operator Training Program

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Reactor Operating Training Program )

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Senior Reactor Operating Training Program ,

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Shift Technical Advisor Training Program

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Chemistry Technician Training Program

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Health Physics Technician Training Program

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Technical Staff and Manager Training Program 1

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' Electrical Maintenance Personnel Training Program j

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Mechanical Maintenance Personnel Training Program

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Instrument and Control Technician Training Program {

l 11. Nuclear Training Review Committee Procedure (NTRC-2), Revision 0, i July 25, 1986 1 I

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