IR 05000382/1986025

Insp Rept 50-382/86-25 on 861117-21.No Violations Noted. Major Areas Inspected:Nonlicensed Staff Training,Licensed Operator & Requalification Programs.Potential Violations Include Failure to Retrain within Required Time

ML20212E983
Person / Time
Site:	Waterford
Issue date:	12/19/1986
From:	Jaudon J, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212E917	List: IR 05000382/1986025 ML20212E912
References
50-382-86-25, NUDOCS 8701050545
Download: ML20212E983 (8)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NP,C Inspection Report: 50-382/86-25 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

142 Delaronde Street i New Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana I'

Inspection Conducted: November 17-21, 1986 Inspector: [8, [/e#w ////5/G E. A. Plettner, Resident Inspector, (RI) D(te/

Approved: u /du & /J 8 J/P.Jfdon, hief, PFcject Section A, Date Retrctor Troj t Branch  ;

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b 8701050545 DR 861231 ADOCK 05000382 PDR

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-2-Inspection Summary Inspection Conducted November 17-21, 1986 (Report 50-382/66-25)

Areas Inspected: Routine, unannounced inspection of the licensee's non-licensed staff training, licensed operator, and requalification training program Results: Within the three areas inspected, three potential violations were icentified (failure to retrain within required time, paragraph 2; decreasing frequency in requalification program, paragraph 5.a; failure to maintain adequate records, paragraph 5.d). In accordance with Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147), these potential violations will be treated as unresolved items.

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DETAILS n

' Persons Contacted Principal Licensee Employees .

• P. Barkhurst, Vice President, Nuclear Operations k' * L. Brewster, Lic. Eng., Operational Licensing

.- * S. Carns, Plant Manager

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• W. Cook, Nuclear Safety & Regulatory Affairs Manager

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• R. Gaines, Operations Interface

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• T. F. Gerrets, Nuclear QA Manager

• J. R. McGaha, 0&M Assistant Plant Manager

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*D. F. Packer, Training Manager

\ *J. G. Dewease, Senior Vice President, Nuclear Operations

• G. E. Wuller, Operational Licensing NRC Personnel

• R. A. Caldwell, Physical Security Specialist

• C. A. Hackney, Emergency Preparedness Analyst

% *J. G. Luehman, . Senior Resident Inspector

• R. C. Stewart, Reactur Inspector J * Denotes those present at exit meeting on November 21, 1986.

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--The NRC inspector also contacted other plant personnel, including g operators, technicians, and administrative personne '

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, General Employment Training (GET)

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'/s The purpose of this inspection was to determine if the licensee met the i general training requirements of 10 CFR 19.12,10 CFR 50 Appendix B,

Criterion II, and ANSI 1 The NRC inspector participated in classroom instruction for access to the

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facility. Several observations were made during classroom instructio These observations are listed in Paragraph 5 of this repor .

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Personnel interviews of plant personnel with various employment times and

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occupational classifications revealed a good general knowledge in the areas

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of quality assurance and control, security, and radiological contro Review of the GET records for 29 personnel selected at random revealed that these records provided an auditable and documented history. On January 31, 1986, a review of all Waterford 3 badged employees for General Employee

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Records were audited by the-QA Department. The results of that audit

- revealed that 13 employees had exceeded the annual retraining requirement s

by greater than 3 months. On May 29, 1986, the licensee issued a letter

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~t outlining the corrective steps necessary to prevent reoccurance of the -

problem. Since the issuance of the corrective actions on May 29, 1986, one individual in the random sample had not completed the requalification y training within the required time frame. Training Procedure UNT-03-003, 4%

Revision 4, dated July 22, 1986, requires requalification training to be completed within 12 months with a tolerance of 3 months maximu Although ,

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the licensee.had identified this potential violation, the corrective action had not-been completed within a reasonable time. Accordingly, this is considered to be a potential violation, which will be carried as an 4 unresolved ite (382/8625-01)

The licensee. received Certification for Radiation Worker II' Training from i the Institute of Nuclear Power Operations (INPO) in July 198 I'

No violations or deviations were identified in this are *\ Other Non-Licensed Staff Training  ?

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The licensee submitted Self Evaluation Reports (SERs) to INP0 in the areas of Electrical Maintainance, Mechanical Maintainance, Instrumentation and Control and Onsite Technical Staff and Managers in August 1986. The licensee had an accreditation visit from INP0 on October 1, 1986, for ,

accreditation of the following programs: Shift Technical Advisor, .

' Radiological Protection Technician, and Chemistry Technician. The licensee is currently waiting for the written report from INP0 on.its findings. The licensee is planning for final INP0 Board approval during the first quarter of 198 No violations 'or deviations were identified in this are . Licensed Operator Initial Training The NRC inspector reviewed the initial licensed operator training program to verify that the program being implemented by the licensee complied with ,

the licer.see's NRC-approved training program and 10 CFR Part 5 During i performance of this review, the NRC inspectors verified that the following program elements were properly implemented by.the license . Required lectures by the licensee's NRC-approved training program were attended

. Simulator training center certification of training was completed

. . Required time onshift was performed

. Records were maintained by the training department to document participation by each licensing candidate in the above activitie L No violations or deviations were identified in this are '1 - -

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' Licensed Operator Requalification Program o

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!{ ,Thi m NRC inspector reviewed the licensee's operator requalification program I -- to verify that the program being implemented'~by.the licensee complied with

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-l10 CFR Part 55 and Technical Specifications Section 13.2. During

performance of this review, the NRC inspector verified that the following program elements were properly implemented by the license *

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{. , c given to theJoperating staff in each two year requalification

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. Documentation was~available to indicate thai, staff supervision

, personnel (licensed individuals not< assigned:to an operations crew)

U reviewed facility design changes, procedure changes, facility license :

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changes, and abnormal.and emergency operating procedure All licensed individuals who had scored low in any particular

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'g y category were required to attend appropriate lecture , . All licensed individuals received performance evaluations during simulator and ? rill exercises as specified by the licensee's training

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. Each licensed operator completed an annual requalification g examination prepared'by the license et ,

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. Records were maintained by the training department to document part~icipation by each licensed operator in the above activitie :

, ,Requalification Program Review

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Tre NRC inspector reviewed the licensed operator requalification tvaining program presently used by the licensee against the original training program to verify that revisions made by the licensee had

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not lessened the requirements'of the program in accordance with

~, Appendix A, of 10 CFR Part 50, and Part 50.54 Section 3.I- P.aragraph 50.54 Section 3.I-1' states:

"Notwithstanding the provisions of 50.59, the licensee shall not excepteas-~specifically authorized by the commission make a change in an approved opera, tor requalification program by which the

, s scope,' time allotted for the program, or frequency in conducting

~d ifferent parts of the program, is decreased."

During the review two items of decreased frequency in the NRC approved Requalification Training program were noted as follows:

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.f Administration. Procedure UNT-3-005, Revision 0, dated October 1, 1981, Section 5.1.4 contained the phrase "within 12 weeks" used in

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-6-the statement: " Attendance shall be recorded and absence shall be made up within 12 weeks by rescheduling lecture attendance or by utilizing self-study. . . "

In Revision 3, dated February 6, 1985, Section 5.1.2 of the same procedure and discussion topic, the phrase "within 12 weeks" was dropped from the statement quoted abov Administrative Procedure UNT-3-005, Revision 0, dated October 1, 1981, Section 5.5.3 contained the word "immediately" used in the statement: "He shall immediately be administratively removed from licensed duties and be assigned to an accelerated requalification program."

In Revision 3, dated February 6, 1985, Section 5.2.1.5 of the same ;

procedure and discussion topic, the word "immediately" was removed from the statement quoted abov The licensee's removal of the phrase "within 12 weeks" and the word

"immediately" are a potential violation which will be considered as an unresolved item. (382/8625-02).

During review of the licensee's implementation of the NRC approved training program, the NRC inspector noted three problems. These problems are discussed below. Items b and c are the result of the licensees removal of time requirements referenced abov b. Preplanned Lecture Series Attendance Review of licensed operator requalifications records for lecture series attendance for 12 personnel selected at random revealed that these records provided an audible and documented histor The results'of the audit revealed that one individual missed a lecture on June 27, 1986. The same individual completed the required lecture on November 19, 1986, a time span of 21~ week c. Licensed Operator Accelerated Requalification Training i Review of written licensed operator requalification test records for l 16 personnel selected at random revealed that these records provided an audible and documented history. The results of the audit revealed that one individual failed the exam overall. The individual was allowed to stand watch for five days after being notified of his test results. Then he was removed from watch, placed on accelerated regulaification training, and passed another written exam before he was allowed to return to watchstanding duties as require d. Watchstanding Proficiency l The NRC inspector noted problems associated with maintaining proficiency requirements as required in Section 5.2.3.4 of

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Administrative Procedure' No.. UNT-3-005, Revision 3, dated February 6, 1985. The NRC inspector reviewed the personnel records which were maintained in the control room to document satisfactory completion of this requirement. The review of 18 personnel records revealed that 14 individuals had either not stood the watch, or had not documented the watch properly in the training record. In discussions with the licensee the inspector was-informed that the watch shall be logged in the Station Operating Log, an official record in the plant. This information is then transferred to the individual's training record and collected by the instructor or training clerk, and neintained in the individual's file The requirements for maintaining requalification program records are stated in Appendix A, Section 5, of 10 CFR Part 55 and in

Section 4.3.2.2 of the licensee's training manual. The licensee's training procedure contains the licensee's NRC-approved training program. These requirements state that records shall be maintained to document the participation of each licensed operator in the requalification program. The licensee's failure to maintain adequate i- requalification records is a potential violation, which will be considered an unresolved ite (382/8625-03)

Inspection Observations

. The NRC inspector participated in the licensee's classroom instruction.

In GET the following observations apply:

. Multiple choice questions need four viable choices from which to choose a correct answe i

. Wording of the questions should be short, consise, and a single

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sentence, not two or three long sentences.

! , Key words in questions should be underlitet or highlighted, especially when the word not, first, and most are use '

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. Matching questions need at least one more answer choice than questions being asked to remove the process of elimination in getting l the last question right.

. Use of negative and fill-in-the-blank questions should be avoided.

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In Requalification Training the observations noted above plus the following apply:

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. Establish a range criteria in answers that require it, e.g. math answer . Place later accepted correct answers caused by question ambiguity on the answer key.

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-8-These observations are neither violations nor unresolved items. These items were noted for licensee consideration for program improvement and have no specific regulatory requirement. The licensee acknowledged these observations and will. consider them for-revie . Unresolved Items An unresolved item.is one about which additional information is required in order to determine if the item is acceptable, a violation, or a

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deviation. The following unresolved items were identified during this inspectio Item Paragraph Subject 382/8625-01 2 Failure to conouct GET requalification training 382/8625-02 Changes.to the requalification training plan without prior commission approval-382/8625-03 Records of requalification proficiency withstanding Exit Meeting An exit meeting was conducted'at the conclusion of the inspectio The NRC inspector summarized the scope and findings of each inspection segment at the meeting.

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