ML20137K616

Insp Rept 50-320/85-13 on 850731-1031.No Violations Noted. Major Areas Inspected:Adequacy of Requalification Program to Certify Presently Licensed Senior Reactor Operators to Directly Supervise Defueling

ML20137K616
Person / Time
Site:	Three Mile Island
Issue date:	01/08/1986
From:	Dudley N, Keller R, Kister H, Ruscitto D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137K573	List: ML20137K566 ML20137K616
References
50-320-85-13, NUDOCS 8601240145
Download: ML20137K616 (6)

See also: IR 05000320/1985013

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U.S. NUCLEAR REGULATORY COMMISSION

Region I

Report No. 50-320/85-13

Docket No. 50-320

License No. DPR-73 Priority --

Category C

Licensee: GPU Nuclear Corporation

Post Office Box 480

Middletown, Pennsylvania 17057

Facility Name: Three Mile Island Nuclear Station, Unit 2

Inspection At: NRC Region I, King of Prussia, PA

Inspection Conducted: July 31 - October 31, 1985

Inspectors: 1/ (f 40 SP //- /5- 85

N. F p Reactor Engineer (Examiner) date

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L h. Oudie ,it!1/W utirfcf

@.Ruscitt ~ ,; a' tor Engineer date

Reviewed By: flkh

R Keller, Chief, Projects Section 1C date

Approved By:

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H. Rister KChief, Projects Branch No. 1

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I date

Summary:

This inspection found the requalification program conducted by TMI-2 to be

adequate for a basis of certification of presently licensed Senior Reactor

Operators (SRO) to directly supervise defueling operations. The evaluation

included monitoring training sessions at the facility and at the Pennsylvania

State University Reactor, observing on-the-job training sessions, auditing

training records, and inspecting the written and oral examinations given by the

licensee. The evaluation extended over four months and involved 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> of

direct inspection effort. The training provided and the evaluation made by the

licensee are adequate for insuring that SR0s, who successfully complete the

program, .have the requisite knowledge and skills to safely direct defueling

operations.

Even though there is a rapid evolution of procedures and equipment, a formal

system for identi fying and incorporating changes into the requalification

program has not been developed.

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Details

A. Scope

This inspection consisted of a comprehensive review of the requalification

program. Some requalification classes, which presented defueling system

designs and operations, were attended. Specialized training conducted at

the Pennsylvania State University Reactor Facility was evaluated. On-the-

job training sessions on the Defueling Training Assembly (DTA) were at-

tended. A review of the comprehensive examination, the training attend-

ance records, the on-the-job training cards and the final grades on the

comprehensive examination was conducted. Observations were conducted of

some licensee administered oral examinations. Discussions were held with

training staff and licensed SR0s at each phase of the evaluation.

B. Findings

Requalification lectures were attended on June 19 and 24, 1985 and the

following lesson plans were observed being taught.

• Canister Positioning System

Lesson Plan: 12.2.01.156

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Control System, Cable Management System and Jib Cranes

Lesson Plan: 12.2.01.159, .163, .161 -

• Canister Handling Trolleys

Lesson Plan: 12.2.01.160

• Canister Handling Tools

Lesson Plan: 12.2.01.166

All lectures were presented by the contractor engineers who were directly

responsible for the systems. The technical quality of the lectures was

acceptable. The interest generated by each lecture was directly related

to the personality of the instructor. The instructors were knowledgeable

and able to answer all questions. Good use was made of the audio-visual

equipment. The students were attentive and asked many questions concern-

ing the possible improper operation of the systems. The lectures pre-

sented an adequate coverage of the defueling systems and the operators

took an active role in understanding and learning the material being

presented.

Training was observed on June 25, 1985, at the Pennsylvania State

University's Reactor Facility. Dr. S. Levine of Penn State University had

designed six experiments, using the test reactor, to simulate different

conditions in the TMI-2 core, ranging from deboration to collapse of the

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fuel in the core. The operators were given an introductory lecture before

each experiment, conducted the experiment, recorded and plotted data, and

were provided with a summary of what information could be derived from the

readings.

Some operators expressed difficulty in relating the detector readings,

which they recorded, to the expected responses they would see at TMI-2.

An effort was made at each lecture to tie the observed reading directly

back to the TMI-2 core. This unique training provided the operators with

direct exposure to a critical reactor in off-normal configurations and,

as such, was found to be an acceptable means of heightening operator's

awareness of criticality concerns.

On-the-job training was observed on September 27, October 1 and 2,1985.

The procedures conducted during the observation included vacuuming rubble,

removal and replacement of a canister top, dewatering of a canister,

grappling of a canister, operation of the hydraulic system, and operation

of the audio visual systems. The candidates for fuel handling SRO licen-

ses conducted training, for the operators, on the procedures and on the

applicable limitations and precautions for each evolution. The system

engineers conducted training, for the operators, on the hardware associ-

ated with each evolution. This training provided hands on practice with

the equipment which would be used in the reactor building. The opera-

tional problems and difficulties not addressed in the classroom became

obvious one morning when the visibility of the water in the DTA was

limited. The operators were forced to cooperate and depend solely on

underwater cameras to conduct the planned defueling operations. The

operators were able to conduct the planned evolutions but at a reduced

speed.

The practical training conducted on the DTA allowed operators to gain

proficiency with the defueling equipment they expect to use in the reactor

building. The evolutions conducted on the DTA were found to be adequate

to meet the intent of the on-the-job training portion of the requalifica-

tion program.

Review was made of the on-the-job qualification cards of all licensed

SR0s. Only Phase 1 of the qualification cards was inspected. Phase 2,

Canister Handling Bridge and Transfer System had been delayed due to

equipment unavailability, and is being conducted as the systems become

available.

Some items from the FHSR0 on-the-job training cards were deleted from the

SRO requalification on-the-job training cards. The deletions were made

due to line items being assigned to the Recovery Systems and Support group

for completion, or due to line items being repetitive such as attachment

of end effectors to long handle poles.

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The safety of personnel and equipment would have been enhanced if the

rigging qualification card had been completed prior to beginning the

defueling on-the-job card, since a significant amount of rigging is

performed durir.g defueling training.

Three oral examinations, administered by three different instructors, were

observed. The oral examinations lasted an average of lis hours and met the

requirements of the facility training procedure. Some instructors did not

make use of the DTA or canister handling bridge for hands on demonstration

of areas being examined. One instructor did not visit the fuel handling

building to conduct discussions of canister handling bridge and canister

transfer system. Some instructors did not examine the SR0s in the direct

usage of procedure and allowed the SR0s to discuss procedures from memory.

The oral examinations were found to be adequate. However, this portion of

the requalification program was also determined to be the weakest.

The NRC reviewed the two comprehensive examilations which had been pre-

pared by the licensee. The examinations cond ained well written questions

which provided adequate coverage of defueling systems and procedures. The

two examinations contained a limited number of duplicate questions so that

security on the second examination was ensured. However, the NRC found

that the examination did not adequately cover core criticality concerns.

Prior to administration of the examinations, additional questions were

added which examined the area of criticality theory.

A review of the grading of the comprehensive examinations was made. Four

of the sixteen SR0s taking the exarrination failed with grades less than

80%. The grading and subsequent facility regrading was found to be

acceptable.

A review was made of the training records. It was found that liberal use

had been made of the provisions in the training procedure to allow indi-

viduals to miss requalification lectures if the weekly quizzes were com-

pleted. Of the sixteen SR0s, only six had attended all 1985 requalifica-

tion lectures. Two SR0s had failed the weekly quizzes for Cycle 85-3 and

had not taken a reexamination. All SR0s were responsible for completing

requalification requirements by October 31, 1985, even though the compre-

hensive written examinations were administered October 21 and 28,1985.

These findings indicate that attendance at requalification lectures and

completion of requalification program requirements are not given high

priority. However, no direct correlation can be found between attendance

at lectures and comprehensive examination scores.

An audit of the on-the-job training qualification cards was completed. i

All operators were signed off for completing all items on the initial

phase of the qualification cards. However, the records were located at ,

two separate locations and controlled by two separate work groups. The i

responsibility for the completion and control of the records was unclear. '

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On one SR0's qualification card, all performance items were signed off the

day before the inspection. The licensee stated that the individual had

not signed for attendance at the training sessions on the DTA and that his

completion of the qualification items had to be reconstructed from

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instructors' memory. These findings indicate that the licensee does not

have an administrative system for tracking and documenting training

received by individuals. Also, there is no established system for audit-

. ing the training records. This issue is addressed in the Resident

Inspector's monthly Inspection Report Number 85-21 and was resolved by the

assignment of a Site Operations Engineer to establish a system for ongoing

review of training records of operators performing defueling tasks.

6.. A check of the training program was made to see how information contained

in the October 10, 1985 SER for Early Defueling, Revision 4, was to be

incorporated into the training program. The training department had not

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received a copy of the SER as of October 30, 1985. The training depart-

ment has an informal tracking system for identi fying information which

needs to be incorporated into the requalification program. Information is

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received and evaluated as to its applicability to a system and as to the

type of report which contains the information. The information is then

reviewed for content and an instructor is assigned to make any required

changes or additions to lesson plans. The latest update to this system

was October 5, 1985. These findings indicate that there is no mechanism

for timely identification of equipment, procedure and programmatic

changes. Also, there is no mechanism for providing timely training and

, distribution of this information. The licensee is to explain how changes

to equipment and procedures will be identified and how operators will be

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informed of the changes. (0 pen Item 50-320/85-13-01)

j Exit Meeting Held October 31, 1985

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NRC personnel

N. Cudley, Lead Reactor Examiner

i' W. Travers Acting Director, IMI-2

C. Cowgill, Chief, TMI-2 Project Section

R. Cook, Senior Resident Inspector

Licensee Personnel

T. Demmitt, Deputy Director, TMI-2

R. Rogan, Director, Licensing and Nuclear Safety

A. Miller, Manager, Plant Operations TMI-2

F. Perry, Operator Training Manager

R. Maag, Supervisor, Licensed Operator Training

J. Auger, Licensing Engineer

M. Press, QA Lead Auditor

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Summary of Comments

The NRC stated that, as a result of the inspection of the requalification

program, the program could be used as a basis for the NRC to accept tne

licensee's certification that presently licensed SR0s were qualified to

directly supervise defueling operations. Minor deficiencies which were

identified during each aspect of the program inspection were discussed

with the appropriate licensee staff personnel and corrective actions were

taken.

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1 The NRC stated two concerns resulting from the inspection. First, was the

ability of the training department to identify changes in procedures and

equipment, and to disseminate that information in a timely manner. Second,

was the ability of the licensee to maintain and audit individual's train-

ing records.

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The NRC requested that the licensee supply the comprehensive retake exam-

ination and retraining program for the SR0s who failed the comprehensive

examination. This information would be used to support the NRC's accept-

ance of the licensee certification of those SR0s.

The licensee acknowledged that the NRCs concerns were valid and that their

importance had been brought home by events that had occurred earlier in

the week. The licensee expressed an appreciation for the NRC support

provided during the certification of operators to direct defueling opera-3

tions.

Summary

The licensee's requalification program is adequate to train and certify

1 presently licensed SR0s to directly supervise defueling operations. The

25% failure rate on the comprehensive examinations is indicative of an

evaluative process which provides good differentiation between knowledge-

able and unknowledgeable operators, however, it calls into question the '

motivation of individuals to assimilate the material which is presented in

the training program. Also, the attendance and timely completion of  :

requalification requirements indicates SR0s place a low priority on

training responsibilities.

Even though the requalification program adequately covered the present

p body of knowledge, it is questionable whether the program can respond to

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the rapid evolutionary changes in equipment and procedures. An informal

management system is in place which would eventually identify and provide

training for plant changes. This process would take three to four months,

which is an unacceptable delay considering the rate at which changes are

made and implemented.

There is no established program to track individual's qualifications on

individual tasks or pieces of equipment. This has lead to problems in

, assignment of indiv sals to tasks for which they had not been trained.

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