IR 05000313/1987021

Insp Repts 50-313/87-21 & 50-368/87-21 on 870706-10.Two Potential Violations Noted.Major Areas Inspected:Licensed Operator Training & Requalification Programs & Nonlicensed Staff Training Program

ML20236J051
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/28/1987
From:	Craig Harbuck, Harrell P, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236H985	List: IR 05000313/1987021 ML20236H983
References
50-313-87-21, 50-368-87-21, NUDOCS 8708060030
Download: ML20236J051 (9)

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>fH d.S.NUCLEARREGULAT' ORECOMMISSION REGION-IV' 4

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Inspection Report: '50-313/87-21 4 Licenses: DPR-51

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50-368/87-21L , NOF-6 Dockets: 50-313-

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50-368  ;

Licensee: Arkansas Power & LightLCompany (AP.&L):

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P. O. Box 551 l Little Rock, Arkansas! ~72203- 'l Facility Name: Arkansas Nuclear One (AN0), Onits 1 and 2 Inspecti'on At: AN0 Site,'Russellville, Arkansas Inspection Conducted: . July 6-10,31987

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Insp'ectors-

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p .P..H. Harrell, Senior Resident Reactor'

Inspector, Fort Calhoun. Station '

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[fv C. C. flarbuch Res'idtfit Reactor. Inspector 'Ofte /

Arkansas ~ Nuclear One g

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Approved: h D.~ R. Hunter, Chief,'Petfject Section B

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S&te Reactor Projects Branch -l Inspection Summary

, Inspection Conducted July 6-10, 1987 (Report 50-313/87-21)

Areas Inspected: . Routine, unannounced inspection including verification, the

' licensed-operator training and requalification prcgrams, and the nonlicensed l staff training progra l I

l Results: .Within the three areas inspected, two potential viulations (failure to perform annual evaluations, paragraph 4; and failure to obtain NRC approval 8700060030 070728

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prior to making changes to the NRC-approved requalification program that i

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degraded the program, paragreph 4) were' identified. In accordance with the i Commission Policy Statement on Training and Qualification of Nuclear Power l Plant Personnel (50 FR 11147), these potential violations will be treated as j unresolved item I

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Inspection n Conducted July 6-10, 1987 (Report 50-368/87-21)

Areas Inspected: Routine, unannounced inspection including'the licensed-operator training and requalification programs, and the nonlicensed staff training progra Resultsi Within the three areas inspected, two potentia'l violations (failure i To pertorm annual evaluations, paragraph 4; and failure to obtain NRC approval prior to making changes to the NRC-approved requalification program that degraded the program, paragraph 4) were identified. In accordance with the Comission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147), these potential violati6ns will be treated as unresolved item j i

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? i 4 DETAILS -1 f ' Persons Contacted

• J.- Levine, Executive Director of Site Operations D. Barton, Maintenance-Training Supervisor  ;

' *E. Eving,. General Manager, Technical Support. '

• D. Howard, Manager, Special Projects

• L Humphrey, seneral Manager, Nuclear Quality- 1 R. Jschson, Administrative Training Supervisor ,

• 0.:Lomax, Plant Licensing Supervisors' l M. McFarland, Quality Control Training Supervisor s

.*P. Michalk, Plant Licensing Eng!m er

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-*W.' Perks,' Operations Training Supervisor, Unit 2

.*S. Quennoz, General Manager, Plant Cperations

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• J. Taylor-Brown, Quality Control. Superintendent J. Vandergrift, Manager, Training

'*Present at exit intervie The NRC inspectors also contacted other plant personnel, including

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operators, technicians, and administrative personne . Followup on'Previously Identified Items (Closed) Open Item 313/8620-01;_368/8621-01: No evaluation performed ^!

of capabilities to perform licensed dutie ;

This . item was related to the lack ~ of an evaluation .being performed by j licensee management to verify a' licensed individua~1 was capable of )

performing lic6nsed duties if an area of weakness was identified  ;

during requalification trainin _

l The licensee issued a revision to Procedure 1063.08,."Cperations Training. Program," to include a requirement for the_ performance of an  !

evaluation by licensee management. The e' valuation will,be performed 1-to determine whether or not an individual may continue to perform

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licensed duties, The NRC inspector' reviewed selected instances where licensed individuals had failed quizzes during requalification training and verified an evaluation had been performed. In each case reviewed, it appeared that the licensee had appropriately evaluated the quiz 1

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failures.and determined that the individuals-involved could continue to perform licensed dutie I l

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l (Closeci) Open Item 313/8620-02; 368/8621-02: Independent review of )

marginal passing or failing grade l This open item involved the failure of the licensee to independently review examinations that were marginally passing or failing to verify that the grade assigned during ths original review was accurat The licensee revised Procedure 1063.08 to include a requirement that required an inM pendent grad'ng of any examination that was marginally passing or failing. The licensee designated a marginal pass or fail as a grade of 78 to 82 percent overall or 68 to

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/ percent in any specific categor The NRC inspector reviewed selected annual examinecions and trainhg quizzes that were graded and deternir,td to be in the marginal category. For each examination or quiz reviewed, the licensee had iterformed an independent review of the examinations and quizzes. In some cases, the grade was raised and in other cases, the grade was lowered. For the examinations or quizzes that were lowered from a passing to a failing grade, the NRC inspector verified that appropriate actions were take .

1 (0 pen) Open Item 313/8620-03; 368/8621-03: Development and !

iruplementation of a quality control (QC) training progra I This open item involved the development and implementation of a QC l training prograra by the licensee. The licensee was in the process of i

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developing a formal QC training program wit.hin the training-organization to replace the training program conducted.by the QC department and vendor group l l

The NRC inspector reviewec' the status of the development and implementation of the QC training program., At this time, development has reached the stage where the QC lead trainer has submitted the projected program to the QC manager for final input and approval. To complete implemen+.ation of the Program, the objectives, lesson plans, and quer,tien bank still need to be developed. The licensee stated that the program should be fully implemented by the end of 198 This item remains open pending the complete development and implementation of this training progra . Lic osed Operator Initial Training The NRC inspectors reviewed the initial licensed operator training program to verify that, the program being implemented by the licensee complied with the licensee's established training program, as described in Procedure 1063.08, and 10 CFR Part 55. This review was performed to verify that selected individuals that had recently received their initial

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'ltcenses had completed the licensee's training program. During ]

performance of this review, the NRC inspectors verified that the following I program elements were properly completed by each individua !.ectures required oy the licensee's training program were attende )

Simulator training was complete j Required time onshift was performe j Simulator and classroom examinations were successfully passea, i The NRC.1nspectors verified that the licensee had miintained records to-document partir:ipation by each licensing candidate in the above acti"itie '

Based on the review performed by the NRC inspectors, it appeared that the -l

'lichnsee ivas implementing an effective licensed operator initial training progra The licensee received accreditation from the Institute of Nuclear Power Operations (INPO) for the initial operator training program in 198 q j

No violations or deviations were identifie . Licensed Operator'Requalification Program fi The NRC inspectors reviewed the licensed operator requalification program }

to verify that the program being implemented by the licensec complied with )

the licensee's NRC-approved requalification training program and 10 CFR 1 Part 55. During performance of this review, the NRC inspectors verified that the following program elements were implemented by the license Preplanned lectures required by the licensee's NRC-approved training program were given to the operating staff in each 2 year requalification cycl All licensed onshift personnel reviewed emergency and abnorma operating procedures semiannuall Documentation was available to indicate that operations and staff I

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supervision personnel (licensed individuals not assigned to an operations crew) reviewed facility design changes, procedure changes, facility license changes, and abnormal and emergency operating ]

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i All licensed individuals who failed the annual written examination j were placed in an accelerated requalification progra All licensed individuals who scored low in any particular category on

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the annual evaluation were required to attend the appropriate lecture ,

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All licensed individuals received on-the-job simulator training as

.specified by the licensee's NRC-approved training progra ,

Each licensed operator' completed an annual requalification e n mination prepared by the licensee or the NRC

Records mere maintained by the training department to document' s participation by each licensed ope'rator in the'above activitie The licensee's NRC-approved requalification training program was established by the licensee in a letter to the NRC dated July 21, 198 /

Based on the information contained in the licensee's letter, the NRC issued a safety evaluation report (SER) on December 1, 1982. This SER established that the requalification program submitted by the licensee adequately met the requirements stated in 10 CFR Part 55. The NRC s inspectors reviewed the training program currently being used by the licensee, as described in Procedure 1063.08, against the~requalification

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program originally approved by the'NRC. This review was performed to verify that revisions made by the licensee to the NRC-approved program had cot degraded the requirements of the program. During this~ review, the NRC int,pectors noted the followin *

Section 6.8.3 of the licensee's NRC-approved requalification program states, in part, that if an individual receives an unsatisfactory annual evaluation, the individual shall be removed from licensed duties. During revision of the requalification program, tne licensee deleted the requirement that an individual be removed from licensed duties if an. unsatisfactory evaluation was receive Section i-1 of 10 CFR Part 50.54 states, in part, that the licensee shall not, except as specifically authorized by the Conmission, make a change in an approved operator requalification program by which the scope is decreased. The deletion of the requirement to remove an individual receiving an unsatisfactory evaluation is considered an apparent decrease in the scope of the requalification program. The failure to maintain a requirement in the current requalification program that was stated in the NRC-approved requalification training program is a potential violaticn which will be considered an unresolved ite (313/8721-01; 368/8721-01)

The NRC inspectors reviewed selected annual evaluations to determine if an individual had received an unsatisfactory evaluation. No unsatisfactory evaluations were noted. The NRC inspectors discussed this item with licensee training personnel. The training personnel stated that, to the best of their knowledge, no individual had 1 received an unsatisfactory evaluation. Based on this review, it appeared that the licensee did not have an occasion to remove an l individual from licensed duties due to an unsatisfactory annual 1 evaluatio i l

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Section 6.11 of the licensee's NRL approved requalification program states that special training will be conducted in the areas of I significant plant events and topics that the operatinns experience assessment group dt. ems necessary. . The requalification program :

currently used by the licensee does not contain these review l requirement The NPC inspectors reviewed the types of lectures previded ty the licensee and noted that the licensee included many lectur es in the areas of plant events and topics that tha operations experience assessment Croup deemed necessary. The licensee stated that ProcedJre 1061.08 would be revised to include the review requirements to ensure that future compliance with the NRC-approved requalification program is maintalr.ed. This is an open item pending revision of Procedure 1063.08. (313/8721-02; 368/8721-02)

The NRC inspectors noted during a review of the licensee's implementation l of.the requalification program that annual evaluations performed on each '

licensed individual were not complete. The licensee implemented the requirement for performance of annual evaluations by use of an annual evaluation form (Form TF-23A). Form TF-23A contained three distinct sections that are used to evaluate a licensed individual in the areas of simulatea emergency conditions, performance of duties, and training. In two of the nine cases reviewed, the evaltation for the training section of Form TF-23A nad not been completed. In one case, the NRC inspectors noted i that an individual had completed his own evaluation. Completion of one's I own eyeluation does not meet the intent of the evaluation program !

established by 10 CFR Part 5 I Section 4.c of Appendix A to 10 CFR Part 55 states, in part, that the requalification program shall include systematic observation and evaluation of the performance and competency of licensed operators and senior operators. Section 6.6.3.0 of Procedure 1003.08 states, in part, that the performance of licensed operators shall be evaluated at least annually by their supervisors. The failure to evaluate all licensed operators i1 the three areas specified on Form 1F-23A is a potential violation which will be considered an unresolved item. (313/8721-03; 368/8721-03)

Subsequent to the identification of this problem by the NRC inspectors, the licensee evaluated the two individuals in the area of training. No problems were note During review of annual evaluations, the NRC inspectors noted that the licensee's program required that each licensed individual be evaluated by his/her supervisor. During recent organizational changes, licensed individuals were assigned to various departments (e.g. , quality assurance, plant licensing, and work control center) that were supervised by nonlicensed individuals. The NRC' inspectors discussed with licensee training personnel, the appropriateness of having a nonlicensed supervisor perform an annual evaluation of a licensed individual. Training personnel

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1 stated that Procedure 1063.08 would be revised to include a requirement that all licensed individuals be evaluated by another licensed individua This item remains open pending a revision to Procedure 1063.0 (313/8721-04; 368/8721-04)

The licensee has not yet updated the current training program to include the rule change made by the NRC to 10 CFR Part 55 on May 26, 198 The licensee stated that it was awaiting the issuance of the NUREG containing the questions andt answers generated during the regional meetings held by the NRC prior to issuance of the Part 55 rule change. The NRC inspectors stressed that the procedure should have been issued as soon as possible after the rule change became effective. The licensee stated that a revised program, to implement the new requirements of Part 55, would be issued in the near future. This item remains open pending an update to I

the licensee's training programs. (313/8721-05; 368/8721-05)

During this inspection, an NRC in.4pector attended an evaluated simulator scenario and attended the postscenario critique. The performance of the scenario and the critique was done in a professional manner. All operators performed well during the exercise scenari The NRC inspectors performed a review to verify that selected plant events, as described in licensee event reports (LER), were reviewed during lectures given to the licensed operators. It appeared that the licensee had established a program for timely classroom review of LER The licensee's requalification and shift supervisor training programs received INP0 accreditation in 198 No violations or deviations were identifie . Nonlicensed Staff Training The NRC inspectors reviewed the nonlicensed staff training program to verify the program was being implemented in accordance with the requirements of the Technical Specifications and ANSI 18.1. The reviey included examination of training records, discussions with personnel, and a review of the training material used in the classroom. The review also included verification that personnel within specific disciplines had reviewed surveillance tests, equipment repair procedures, system operating procedures, and emergency and abnormal operating procedures, as appropriat The NRC inspectors reviewed the following procedures to verify that the appropriate requirements had been implemente No problems were noted during this revie Number Title 1063.24 Shift Technical Advisor Training Program 1063.09 Technical Staff and Manager Training Sequence

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1063i10 Maintenance Training 1063.14 Health Physics Training Sequence 1063.22 Quality Control Training Program The NRC inspectors reviewed training records of-selected personnel

. performing functions in the dis:iplines covered by the procedures listed above._ The review was performed to ' verify that each selected individual received training as described in the licensee's established program. No problems weresnote Based on the review performed, it appeared that the licensee was implementing effective training programs for nonlicensed staff personne ~

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The licensee received INP0 accreditation for.the seven training programs related to the nonlicensed staff training area in 1986. -The licensee was the-tenth plant in the United States.to receive'INP0 accreditation for all ten: training program No violations or deviations were identifie . Unresolved Items Unresolved items are a matter that requires additional information for determination of whether it is acceptable, a violation, or a deviatio Unresolved items are discussed in paragraph 4'of this repor Item Subject 313/8721-01 and Degradation of the NRC-approved requalification 368/8721-01_ program without prior NRC approval i- 313/8721-03 and Failure to complete annual evaluations of licensed 368/8721-03 operators Exit Meeting The NRC inspectors meet with Mr. J. M. Levine (Executive Director of Site Operations) and other members of the licensee staff at the end of this inspection. At'this_ meeting, the NRC inspectors summarized the scope of the inspection and the finding _

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