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Insp Rept 50-302/85-22 on 850429-0501.No Violation or Deviation Noted.Major Areas Inspected:Verification of Licensee Actions Re Recertification Documentation for Dec 1984 & Operator License Applications
	ML20128L673
Person / Time
Site:	Crystal River
Issue date:	06/03/1985
From:	Gibson A, Guenther S, Julian C, Stadler S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20128L649	List: ML20128L645; ML20128L673;
References
	50-302-85-22, NUDOCS 8507110412
	Download: ML20128L673 (11)
	v • d • e

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p1 Gog UNITED STATES

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Report No.: 50-302/85-22

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: April 29 to May 1, 1985

Inspectors: b A- n 6/M[N

C. A. Julian V

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S. D. Stadler

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SUMMARY

Scope: This special announced inspection involved 48 inspector-hours on site in

the area of verification of licensee actions regarding recertification documenta-

tion for December 1984, operator license applicants per Confirmation of Action

Letter (302/85-02) and Florida Power Company response letter dated April 4,1985.

Results: No violations or deviations were identified. As discussed in the

details, documentation did not fully support that all required training had been

done.

8507110412 850618

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

P. F. McKee, Plant Manager

J. T. Telford, Director, Quality Programs

J. P. Alberdi, Manager, Site Nuclear Operations Technical Services

L. C. Kelley, Manager, Nuclear Operations Training

R. M. Bright, Manager, Nuclear Licensing

M. F. Penovich, Nuclear Operations Training Supervisor

D. D. Betts, Supervisor, Quality Audits

T. W. Catchpole, Senior Nuclear Quality Audits Specialist

J. L. Bufe, Nuclear Compliance Specialist

E. R. Carlson, Consultant to Florida Power Corporation (FPC)

Other licensee employees contacted included training department and office

personnel.

, NRC Resident Inspector

T. Stetka, Senior Resident

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on May 1, 1985, with those

persons indicated in paragraph 1 above. The inspector described the areas

inspected and discussed in detail the inspection findings listed below.

Licensee representatives acknowledged their understanding of the findings.

The licensee did not identify as proprietary any of the material provided to

or reviewed by the inspector during this inspection.

The inspector discussed the status of Inspector Follow-up Item (IFI)

302/85-01-10 Site Engineer Training Status. The licensee has determined the

training status of all site engineers as detailed in a letter dated

March 12, 1985. IFI 302/85-01-10 is closed.

3. Licensee Action on Previous Enforcement Matters

Not inspected.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. New unresolved items identified during this inspection are

discussed in paragraph 6.

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5. Recertification Process

In an inspection conducted at Crystal River January 14-18, 1985, discrep-

ancies were noted in the training records of nine individuals who took and

passed NRC operating license examinations in December 1984 (Inspection

Report 50-302/85-01 Unresolved Item 85-01-05). On January 29, 1985, the NRC

issued a Confirmation of Action Letter (50-302/85-02) in response to these

deficiencies which confirmed that the licensee would complete the following

actions before the NRC would issue licenses to those individuals:

a. Recertify to the NRC that the operator and senior operator applicants

examined by the NRC in December 1984, are qualified pursuant to 10 CFR

55.10(a)(6). This recertification will be based upon verification of

the completion of all applicable hot license training and experience

requirements; review and evaluation of hot license training and

experience requirements; review and evaluation of all written and oral

audit examinations; and resolution of all identified training

deficiencies.

b. Conduct a quality assurance review of Crystal River operator training

procedures and activities and meet with NRC in Region II to discuss the

results of this review.

In a letter dated April 4, 1985, Florida Power Corporation provided the

following response to this Confirmation of Action Letter:

Pursuant to your Confirmation of Action Letter dated January 29, 1985,

to Florida Power Corporation (FPC), this letter recertifies that the

operator and senior operator applicants who were examined by the NRC in

December 1984, and who successfully completed the examination are

qualified pursuant to 10 CFR 55.10(a)(6).

The FPC Nuclear Operations Training Department has:

(1) Verified the completion of all applicable hot license

training and experience requirements;

(2) Reviewed and evaluated all written and oral examinations

given during the hot license training program; and

(3) Resolved all training deficiencies identified during the

accomplishment of Items 1 and 2 above.

The documentation of Items 1 through 3 above is available at the FPC

Nuclear Operations Training Facility for your review if desired.

This inspection was conducted April 29 to May 1,- 1985, to review this

recertification documentation and to verify that all training and experience

requirements are met for each of these individuals prior to issuance of

licenses.

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Licensee representatives told the inspectors that the basis they established

for this recertification effort was 10 CFR 55.10(a)(6), as stated in the

Confirmation of Action Letter, and all commitments they had previously made

to the NRC in the license training area. A Training Department Procedure,

(TDP 210), " Interim Licensed Operator Replacement Certification Program,"

(Rev. 0), dated March 22, 1985, was written to guide this recertification of

the nine license candidates. The inspectors noted that the procedure does

not include all requirements of the approved training procedures that were

in place during the conduct of license training for these candidates, nor

the replacement license training program in Section 12c of the Crystal River

FSAR. The justification provided by the licensee for this exclusion was

that the NRC had pointed out numerous discrepancies in the training

procedures during the January training inspection and therefore they were not

used as input to TDP 210. The inspectors stated at the exit interview that

this does not appear to be a valid or acceptable exclusion.

10 CFR 55.10(a)(6) requires that evidence be provided by the licensee that

an applicant for a license has learned to cperate the controls in a safe and

competent manner. A statement on the license application (NRC form 398),

signed by the highest levels of corporate management for plant operation,

certifies that the applicant has or will have completed by the time of the

examination all the required training, and has learned to operate the

controls in a safe and competent manner.

This required training is not defined in detail in 10 CFR, but within the

licensee's operator training program as contained in approved procedures

and/or the FSAR. The requirements contained in the licensee's training

program should, therefore, be utilized as the basis for recertifying these

applicants prior to issuance of licenses.

In addition, the licensee has an obligation to evaluate the license candi-

dates to ensure that they have learned to operate the plant in a safe and

competent manner prior to examination by the NRC. These evaluation measures

and the minimum acceptable levels of performance are normally defined in the

licensee's training program. At Crystal River, TDP 202, " Replacement

License Training Program", TDP 204, " Senior Reactor Operator Training

Program", and Section 12c of the FSAR contain this information. All of these

original evaluation requirements were not incorporated into TDP 210.

TDP 210 does not address specific evaluation of the candidates on abnormal

and emergency operating procedures. The candidates' knowledge in this area

should be evaluated to properly recertify their previous training. The

inspectors noted that the requalification program contains a semiannual

evaluation form that is of a type which could be used for recertification.

The inspector was informed that few deficiencies were found during the

licensee's review of these operators' training records. The only remedial

training deemed necessary was to give three candidates additional on shift

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training time. The maximum required for any candidate was an additional 18

days on shift.

The inspectors examined the completed TOP 210 procedure and the supporting

records and discussed these documents with licensee representatives to

assess the adequacy of the recertification program. Significant

discrepancies were identified and are detailed in paragraph 6. The nature

of these discrepancies was discussed in detail with licensee representatives

in a meeting on April 30 and again in the exit interview on May 1, 1985.

6. Observed Discrepancies in Recertification Process

a. Classroom Training

TDP 210, paragraph 2.0, " Training Requirements," addresses the

documention of grades made by the candidates on previous written exams.

The acceptance criteria stated in paragraph 2.a. are as follows:

Phase 1 - Classroom Training must be satisfactorily completed by

having at least an 80 percent average overall and 70 percent in

each category when all written examinations are averaged together.

This training shall include 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months of HT/FF/Thermo and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months

of Control and Mitigation of Accidents.

During the January 1985 NRC inspection, it was noted that the number of

written examinations given to this licenss training class had been

reduced from previous classes by approxima'tely 60 percent. Remedial

examinations, when necessary, were exactly the same as the original

examinations. With knowledge of this practice and access to his

original examination, a candidate could invalidate the examination

process. This would be unacceptable. It was additionally noted that

some remedial examinations were never graded prior to the NRC

examination in December.

By letter dated May 5, 1982, the licensee stated that the FPC training

program includes 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months of training in Heat Transfer, Fluid Flow, and

Thermodynamics (HT/FF/Thermo) and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of Mitigating Core Damage

(MCD) training. TDP 210 specifies 42 and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months respectively.

Through procedure revision, however, the license training program now

contains only 28 and 12 contact hours, respectively, in these subjects.

Licensee representatives stated that these candidates took the shorter

courses. TOP 210 includes these items as requirements, and they are

initialed as being complete.

As justification for the acceptability of shortened courses for reactor

operator candidates, the licensee states that the current R0 Replace-

ment Program includes 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months of HT/FF/Thermo (RO-19 through 25) and 2

hours of Natural Circulation training (RO-46). Additionally, as a

prerequisite for RO positions, each candidate must complete the Non-

Licensed Operator (NLO) course or equivalent. As part of that course,

each NLO receives 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of HT/FF (ANA0-10). Thus, R0 candidates do

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receive at least 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months of HT/FF/Thermo. In addition to the above

training for an R0, an Upgrade SR0 candidate receives 28 more hours of

HT/FF/Thermo (SRO-19 through 25) and 2 more hours of Natural

Circulation training (SRO-46). Thus, Upgrade SR0s have at least 72

hours of HT/FF/Thermo training. Instant SR0s, without previous R0

experience, currently receive 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months of HT/FF/Thermo (SRO-19 through

25), plus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of Natural Circulation AT0G training (SRO-46). The

licensee reviewed each Instant SR0 candidate's college transcript and

training hi story to determine if the additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of

HT/FF/Thermo training was received. Both Instant SR0 candidates

were considered by the licensee to have exceeded the 42-hour

HT/FF/Thermo requirement.

The licensee justified the shortened MCD training program in a similar

manner. The current R0 Replacement Program teaches 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of

Degraded Core (RO-44) which was developed by B&W. This is supplemented

with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of Plant Computer training (RO-97), 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of Emergency

Procedures training (RO-74 through 76) on loss of feedwater, loss of

coolant, and inadequate core cooling,12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of transient training

(R0-47 through 49) on loss of coolant and over/under cooling, and 4

hours of Post-Accident Sampling System (R0-105) training. In total,

the R0s receive 38 hours4.398148e-4 days 0.0106 hours 6.283069e-5 weeks 1.4459e-5 months of training in the mitigation and control of

core damage. Upgrade and Instant SR0s receive training identical to

the R0s and, therefore, have also had at least 38 hours4.398148e-4 days 0.0106 hours 6.283069e-5 weeks 1.4459e-5 months of training

(SRO-44,47,49,72,73,74,101,109).

The inspectors stated at the exit interview that the acceptability of

taking credit for previous training outside of the established program

would require further review by NRC management. It appears, however,

that the current training program, as implemented by training

department procedures, does not meet the commitment made to the NRC by

the May 5, 1982 letter. The inspectors stated at the exit interview

that this discrepancy should be corrected promptly by revisions to the

TDPs. This is an unresolved item (50-302/85-22-01).

b. On-Shift Training

TDP 210, paragraph 2.b., states the following acceptance criteria for

R0 candidates:

Phase 2 - On-shift training shall be satisfactorily completed by

having at least sixty (60) work days as an extra person on-shift

in the Control Room in training and must have completed at least

five (5) major reactivity changes and/or plant manipulations as

described in the Requalification Training Program TDP-203. At

least two (2) reactor startups must be performed either as part of

this phase or Phase 3 - Simulator Training.

For SR0 Upgrade candidates the criteria are:

Phase 2 - On-shift training satisfactorfly completed by having at

least sixty (60) work days on-shift as an extra person in training

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and must have directed at least five (5) significant plant

evolutions.

For the Instant SR0 candidates the criteria are:

Phase 2 - On-shift training shall be satisfactorily completed by

having at least sixty (60) work days on-shift as an extra person

in training. During these sixty (60) days at least five (5)

significant reactivity changes must be performed and/or directed.

The March 1980 H. Denton letter on " Qualifications of Reactor

Operators" and NUREG 0737 Item I.A.2.1 require that candidates for an

R0 license spend three months as an extra man training in the control

room, and SR0 candidates spend three months on shift as an extra man

training as an SRO. Item I. A.2.1 was implemented at Crystal River by

an NRC Confirmatory Order dated July 10, 1981.

During the record review conducted as part of this inspection, the

inspectors determined that one SRO Upgrade candidate had not officially

entered the license training program until August 1984. During the

January NRC training inspection there was no record that this

individual had completed the three months on shift as an extra SRO.

The licensee has, as part of the recertification effort, reconstructed

a record of this training. Credit was given, per the control room

logbook, for days on which this individual was assigned as a Chief

Nuclear Operator (CN0) prior to entering itcense training. Although

this position is not required by the facility's Technical

Specifications, it is a normally filled, procedurally required position

with designated duties and responsibilities. The inspectors stated at

the exit interview that this time as CNO is, therefore, not considered

to fulfill the extra SR0 in training criterion.

Two Instant SRO candidates had 60 days of documented on-shift training

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time, however, most of that time was spent as a non-licensed operator

or an RO trainee. Cycling these individuals through these non-SR0

positions for training should have been in addition to, and not in

place of, the required SR0 training.

Other on-shift training records, which were deficient by as much as two

of the required twelve weeks of training, have had new documentation

added since the January inspection. Much of this reconstructed

documentation also assumes credit for on-shift positions which are not

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applicable to RO or SRO training.

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l The NRC inspectors stated that the three months training as

an extra RO or SR0 on shift should include the following attributes:

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The objectives of the training should be established in writing.

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The candidate should be in a training status and supervised by

training department personnel or designated operations personnel.

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The training should be structured and scheduled in advance to the

extent possible (i.e., the program can be broken into segments to

provide simulator training or classroom training on evolutions

conducted or to be conducted during observation training).

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If the training is not continuous, then 3 months equates to 65 - 8

hour shifts (5 days per week, 4.3 weeks per month). l

It does not appear that the on-shift time which the licensee credits

toward recertification meets this guidance. Although the control room

logbook establishes that the candidates were on shift at the credited

times, the candidates were often signed in as filling a role other than

that for which a license is sought. Some entries designate the

candidates as trainees, but most do not.

The records, original and reconstructed, do not clearly support the

contention that the candidates have fully met the requirement to

complete 3 months on shift in training for the licensed position they

seek. The inspectors cannot conclude that this requirement was fully

met.

TOP 210, paragraph 2.b. requires that five major reactivity manipula-

tions be performed by RO candidates and directed by SR0 candidates.

Only four of the candidates had original Reactivity Record Forms to

document their manipulations. Forms have been partially reconstructed

for some of the other five candidates, but they are not specific.

Credit was frequently taken for routine feed and bleed boron

concentration changes. The inspectors stated they do not consider

those to be major reactivity changes.

The on-shift training records for several candidates indicate that most

days were spent in the performance of " normal operations." The

licensee, therefore, utilized the manipulations listed in the control

room logbook as the basis for recertifying that those candidates had

performed the required control manipulations. The records are

contradictory and do not indicate what training was actually done. It

cannot be concluded from a review of the records that the required

reactivity manipulations have been completed,

c. Oral Examination and Walk-through

TDP 210 states that all candidates shall have satisfactorily completed

a walk-through and an oral examination. The description of replacement

operator training in Section 12c of the FSAR requires that areas of

deficiency identified in oral examinations be strengthened as required.

An oral board is defined in TDP 203, " Licensed Requalification

Training," and TDP 202 (Revision 0), " Replacement Operator Training,"

as consisting of at least three members, including a supervisor and two

instructors. The licensee indicated during the January training

inspection that an oral examination, by definition, was the same as the

oral board referenced in TOP 202 and 204, and, therefore, should meet

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l the same requirements. Numerous one and two-man oral examinations were

) conducted for these candidates. Particularly in the case of one-man

l' oral examinations, the grades appeared to increase substantially over

those conducted with the required number of training and operations

, staff. TDP 204 (Revision 0) required that a license candidate pass a

! final oral audit examination to be eligible to take the NRC exami-

nation. This requirement was removed by later revision. The December

1984 license applicants did not receive a final oral audit examination

or evaluation.

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During the recertification process, to date, no new oral examination or

walk-throughs have been conducted. The inspectors examined the records

of previous oral exams and walk-throughs. The oral exams were

conducted with varying numbers of examiners. They were generally short

, and of marginal quality. Candidates took varying numbers of exams,

j ranging from one to four. With one exception, the grades were averaged

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to achieve a grade for documentation per TDP 210.

! One RO candidate was recertified despite an average oral exam grade of

j less than 80 percent. Licensee representatives explained that, for this

l candidate, credit was only taken for oral exam number 3, which he

! passed. The inspectors stated that the same criteria should be applied

to all candidates, rather than varying methods for different candidates.

! The licensee countered that if the scores on oral exams taken prior to

i the 1984 license training class were omitted, the candidate met the

l passing criteria. The candidate had taken oral examinations

previously but was withdrawn from the 1983 license class.

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The candidates' oral exams appeared to have several deficiencies. Oral

exam number 3, mentioned earlier, was conducted by one individual.

There was no weighting of point value with respect to a question's

importance. In the area of normal, abnormal, and emergency procedures

the only question asked was to determine the turbine roll speed for a

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given plant condition. The candidate scored 100 on this question and

thus the area of procedures overall was graded 100. This single

question is clearly inadequate to assess the candidates' knowledge in

this area. Even when there were multiple examiners, they did not each

grade all questions, but rather each graded an area alone. The exam

records often contain multiple comments on sign 'icant candidate

, knowledge deficiencies, but no retraining or other remedial action is

documented.

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The replacement operator training program in Section 12c of the Crystal

River FSAR required walk-through examinations to t:e given at random

i intervals throughout the course of the program. TDP 202 (Revision 0)

! required that each individual pass a final walk-through examination,

normally conducted by an outside contractor, prior to taking the NRC

l examination. Most individuals in this class were administered only one

l or two walk-through examinations. A licensee representative stated

that all walk-through examination scores were averaged to recertify the

j candidates per TOP 210. The inspector noted minor discrepancies in the

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mathematics of this process, but no instances were found in which these

errors resulted in a false determination of satisfactory performance.

One SR0 candidate apparently received no walk-through examination

during his SR0 training. Licensee representatives stated they consider

this acceptable because the candidate had a walk-through during his

previous R0 training. The' TDP 210 evaluation completed for the

candidate reflects that the training staff has waived the requirement

for this candidate. The inspectors stated they do not consider this ,

acceptable since the R0 walk-through was long ago and an SRO

walk-through should test for different knowledge levels and emphasis

than the R0 walk-through.

One SR0 candidate apparently received only a partial walk-through since

only 30 percent of the checklist was complete. The walk-through had

been graded, however, and credit was taken in the TOP 210 evaluation.

Three license candidates received 13 to 15 negative comments on walk-

through examinations including significant deficiencies, such as not

know1ng the required immediate actions of an abnormal operating

procedure or the location of essential plant equipment. Despite these

significant deficiencies, all three individuals passed the walk-

throughs at 81.5 percent. In addition, there was no specific remedial '

training documented, nor a follow-up walk-through examination given, to

ensure that the deficient areas were upgraded.

One individual failed a walk-through examination with a 67 percent

about one week before the NRC examination. No remedial training or

retest was apparently given.

No final walk-through was administered to these nine individuals to

ensure that all deficiencies were resolved, and that they were, in

fact, knowledgeable of the plant and its emergency and abnormal

procedures. TDP 202 (Revision 0) required that each student

demonstrate satisfactory knowledge of all nuclear plant systems and

equipment by completing a system check-off list. This list contained

an instructor signature slot for each major system to verify individual

knowledge and qualification. TDP 202 (Revision 1), which was

implemented near the end of this license class, no longer contained this

system qualification requirement. .

TDP 202 and 204 (Revision 0) required that all license candidates

demonstrate the ability to competently manipulate the controls during

all normal, abnormal, and emergency operations, and to understand the

indications available during each evolution. These abilities would be

certified as part of the simulator training program. Babcock and ;

Wilcox (B&W) certified by letter to FPC only that reactor startups had

been successfully completed by each individual on the simulator. B&W !

also performs evaluations on trainees' abilities to recognize and respond !

to abnormal and emergency conditions. When these evaluations were l

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marked unsatisfactory for an individual in the past, however, the

licensee had elected to ignore them on the basis of the B&W simulator

not being plant specific. 1

In a letter dated June 30, 1978, Paul Collins of the NRC informed FPC

that evaluations of an individual's competence must be made at the

facility, in accordance with paragraph 4.c (10 CFR), since the B&W

simulator does not " closely parallel" the Crystal River control boards.

The only in plant evaluations in the area of emergency and abnormal

operations, as well as systems, conducted for this license group were

the walk-through examinations. These oral exams and walk-throughs do

not appear adequate, however, to assure that the candidates have

achieved all required knowledge,

d. Conclusions

As stated at the exit interview, the inspectors conclude that the

recertification process was not adeauate to ensure that the nine

candidates have successfully completed all the required training.

Problem areas are as follows:

(1) Classroom training in Heat Transfer, Thermodynamics, Fluid Flow,

and Mitigation of Core Damage was shorter than ccmmitted to by the

licensee.

(2) Records do not support that all of the candidates completed three

months on shift as an extra person in training for the license

sought.

(3) Records do not support that all of the candidates have completed

the requirement for performing or directing five major reactivity

manipulations.

(4) No additional comprehensive oral examinations or walk-throughs

were conducted as part of the recertification process. Previous

oral examinations were marginal in scope and of questionable

validity.

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(5) One license candidate received no walk-through examination as an

SRO, and another received only 30 percent of a single walk-

through.

As of the date of this inspection, the inspectors cannot conclude that

the recertification process was acceptable. The licensee has not been

able to adequately demonstrate that all required training has been

satisfactorily completed, and that there has been adequate evaluation

to ensure that individuals have learned to operate the plant in a safe

and competent manner.

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ML20128L673

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