IR 05000155/1987017

Insp Rept 50-155/87-17 on 870720-24.No Violations or Deviations Noted.Major Areas Inspected:Effectiveness of Licensed Operator Training & non-licensed Staff Training

ML20236N201
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/06/1987
From:	Darrin Butler, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236N170	List: IR 05000155/1987017 ML20236N168
References
50-155-87-17, NUDOCS 8708110405
Download: ML20236N201 (9)

Text

{{#Wiki_filter:.

      '

l

, .

l l U. S. NUCLEAR REGULATORY COMMISSION REGION III j l,  ! Report No. 50-155/87017(DRS)

      )

i Docket No. 50-155 License No. DPR-06 Licensee: Consumers Power Company l , 212 West Michigan Avenue l Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant I Int.pection At: Charlevrix, Michigan Inspection Cond( ed: July 20-24, 1987 l

     [. !,97
  '

Inspectors: . cgs Df te '

     $0}

l Date Approved By: Monte h s, Chief Operational Programs Section Eate

     [[f7
      ]

Inspection Summary Inspection on July 20-24, 1987 (Report No. 50-155/87017(DRS)) l Areas Insp~ected: Routine, unannounced inspection on the effectiveness of I licensed operator training (IE Module No. 41701) and the effectiveness of non-iicensed staff training (IE Module No. 41400).

Resultsi Of the two areas inspected, no violations or deviations were identifie B708110405 B70808 5 PDR ADOCK 0500 G

      .

F . DETAILS 1. Persons Contacted T..Elward, Plant Manage , R. Abel, Production and Performance Superintendent J. Beer,' Chemistry and Health Physics. Superintendent P. Donnelly, Nuclear Assurance Administrator D. Lacroix, Training L. Monshor, Quality Assurance Superintendent The above persons attended the exit m'eeting on July 24, 198 The inspectors also interviewed other licensee personnel during the course of the inspection, including members of the training staff.and-the Maintenance Departmen . Training The inspection consisted of a review of Deviation Reports (DRs), which were written from 1985 to the present, to determine if personnel had been appropriately trained prior to of the event and that lessons learned were factored back into the training program. The inspection was not designed to be an evaluation of the licensee's overall training program. That evaluation is currently performed by the Institute for Nuclear Power Operations (INP0) as part of the training accreditation process. . At the time of this inspection, five of the training programs had been accredited. These were as follows: (1) Non-Licensed Operator;.

(2) R0/SRO Hot License; (3) R0/SRO Requalification; (4) Instrument and Control Technician; and (5) On-Call Technical Advisor. The five remaining programs had been formally submitted for accreditatio They were as follows: (1) Electrical Maintenance; (2) Chemistry; (3) Health Physics; (4) Management and Technical Support; and (5) Mechanical Maintenance. Accreditation of these programs is expected by the Spring of 198 . Licensed Operator Training Effectiveness (41701)
     \

The inspectors reviewed operational events and interviewed licensee personnel to evaluate the effectiveness of training programs for licensed personne Review of Abnormal Events or Unusual Occurrences

'Of approximately 36 Deviation Reports (DR)/ Event Reports (ER)

reviewed, the inspectors chose the following five reports for further revie .)

* E-BRP-85-11 Potential Loss of Containment Integrity
* D-BRP-85-10 Caution Tagging During Plant Modifications I i

d j

_ _ _ _ _ - _ - _ _ _ -

i

, . j
     :
* D-BRP-85-30 Rod Withdrawal Out of Sequence 1
* E-BRP-87-08 TS Violation During B-3 CRD Replacement

i * D-BRP-87-56 Uncontrolled Release Via Waste Hold Tank j l Event Report No. E-BRP-85-11 dealt with the performance of maintenance on the dirty sump containment isolation valves without performing a pre and post local leakrate tes . Subsequent to the ) l maintenance, fuel bundles were moved in the spest fuel pool with the potential for a loss of containment integrity. h,ot cause analysis i determined that current valve maintenance procedures inadequately addressed pre and post local leakrate testing when performing valve , maintenance. The valves passed local leakrate test TR-39 and I containment integrity was verified. Daily Order No. 24-82 was issued ' by the Shift Supervisor to immediately inform on-shift personnel to ensure pre and post local leakrate tests would be performed on containment isolation valves removed for maintenance. Training was provided in the requalification program on Procedure 50P-44, " Spent Fuel Pool Operations and New Fuel Handling," tc remind operation's personnel that containment integrity must be verified during fuel l move The valve maintenance procedures were to be changed to l reflect pre and post local leakrate testing requirement Deviation Report No. D-BRP-85-10 dealt with the failure to caution tag components that were affected by a plant modification. The purpose of the tagging was to ensure operations personnel did not declare components operable that were affected by a modificatio Root cause analysis determined this was an oversight of operation's personne The plant issued internal correspondence GHRP-20-85,

" Implementation of Facility Modifications," for distribution to plant personne The Training Department was included in the distribution, and lessons learned were factored into the training progra Training conducted a review of administrative procedures in Requalification Cycle 87-02. Procedure 2.1.4, " Plant Status and Equipment Control," was discusse .

l l Deviation Report No. D-BRP-85-30 dealt with the out of sequence l withdrawal of two control rods. Big Rock Point had had two other i events dealing with mispositioneo control rods (e.g., D-BRP-85-14, i and D-BRP-86-07). The plant issued internal correspondence WJT-87-26

     '

to all licensed personnel on the number of errors made while operating the reactor portion of the plant. The Training Department was formally requested to provide training on rod withdrawa Continuing training has been provided to licensed personnel under course title, " Industry Experience and Modification." Information prcvided to the operators included the following: the use of CRD sequence cards; tools available to help identify criticality; when to use alternate sequence cards; and deviation from the specified withdrawal sequence. In addition, the licensee had changed.the

     ;

L

. e sequence cards to include larger type, fewer rod pulls were listed on each card, and only one group of control rods was specified on any one card. The rod withdrawal deviations did not exceed any core safety limits.-

f Deviation Report No. D-BRP-87-08 dealt with the replacement of ' CRD B-3 while the mode switch was in the " refuel" position instead of " shutdown." Root cause analysis determined their was a breakdown in communication between Maintenance Supervisor and the Shift Superviscr, failure to follow procedures, and personnel erro Internal correspondence DPH-87-17 was'istued to operations and l maintenance personne Details were provided on the seriousness of ' the event and the purpose of the TS to ensure no other control rod would be inadvertently withdrawn while the CR0 in question was being remeved from the reactor. The control rod drive changeout ; , procedure, MCRD-1, was to be revised as needed to improve the , ! procedur Training was provided on this event in requalification ! , course BWI-02-87, " Industrial Experience and Modifications." No other control rods were moved and the reactor was maintained in a

    ~

! safe condition during this even Deviation Report No. D-BRP-87-56 dealt with an uncontrolled release of liquid from the radwaste Waste Hold Tank (Wilt). The high level WHT annunciators were already "in" (at 82%) because of the large volume of water contained in the radwaste system. The auxiliary operator's attention had been needed elsewhere. Root cause analysis determined the overflow line may have been restricted by ic This caused the WHT to pressurize and force liquid by the manhole cover gasket. The gasket was found defective and subsequently replaced. The DR recommended instructions be provided to plant operators about operating systems with alarms "in." The Training Department had provided training for the operators en the attentiveness to detail (including alarming annunciators) in Requalification Class 87-07. The Training Department was cogni. 9t of this DR and due to its relative newness had not reviewed the DR for training impact at the time of the inspectio In all cf the above cases, except unreviewed DR-BRP-87-56, the inspectors determined that the training subsequently given was adequate to address the event and prevent its recurrence. The inspectors were unable to determine whether the training provided prior to the events was sufficient to preclude these occurrence b. Licensed Operator Training j The inspectors reviewed the licensee's process for incorporating lessons learned from past events and how changes to the plant were factored into the training progra The Nuclear Training Department (NTD) was reviewing procedures, deviation reports, LERs, INP0 SOERs, industry experience, and NRC correspondences for the incorporation of lessons learned into the i classroom training subject matter. Changes to the plant were l

-___. _ _ _ _ _

_

 . .

t reviewed by the NT Minor facility changes were defined as modifications to the operating nuclear generating plant that were assigned to the plant staff. The Training Department was notified by Form BRP-018, " Modification / Training Notification Form," as i implemented by Procedure 3.1.1.1 " Facility Change, Minor." - The Training Department would review the minor modification for training impact. Major facility changes were defined as modifications that required detailed design changes to the plant. The project engineer had overall responsibility to coordinate training activitie The Training Department was notified of the major modification in accordance with Procedure 3.1.1.5, " Facility Change, Major." The , modification was reviewed for training impact. The Operations ' Supervisor had responsibility to ensure that operators were trained (if applicable) prior to accepting any type of plant modification

      .

I for operatio I i The inspectors reviewed how the licensee disseminated information to ' on-shift licensed personnel. The Operations Department controlled and issued the required reading information. Materials included j were Procedure Revisions, Operations Memos, and Administrative i Memo Information included in Administrative Memos pertained to ! personnel and housekeeping activitic., and as such, did not require special control. The Operations Memos and Procedures Reviews were documented by an individual's signature on Form BRP-069, " Record ! of QA Review for Licensed R0/SR0 and Prospective Licensees." j Completed BRP-069 Forms were forwarded to the Training Coordinator 1 for proper filing. The NTD's licensed personnel received the same j required reading materials as licensed on-shift personnel. NTD's I licensed personnel reviewed the information to keep abreast of ! current on-shift practices end to review the information for training impac J l ! The inspectors reviewed the licensea's implementation of 10 CFR 55.59(c)(3)(i); the on-the-job training requirements for licensed individuals to perform or participate in a combination of reactivity control manipulations. The new requirements on control manipulations became effective on May 26, 1987. The number of required annual manipulations have increased. Previously, the following manipulations were performed on a two year cycle, but would now be required annually:

 * Loss of Instrument Air
 * Loss of Electrical Power
 * Loss of Service Water The licensee completed loss of instrument air and service water during the 1987 requalification cycle. Loss of electrical power remains to be performed. It is the NRC's position, based on discussions between Region III and J. Hannon (NRR - Chief, Operator Licensing Branch), that licensees have until May 26, 1988, to

- - _ _ - - _ _ _ _ _ _ -

--__ _ _ - _ - _ _ _ _ - _ _ _ .  *

complete the annual requirements. Completion of the loss of electrical power scenario may be performed at the plant or performed on a simulator. ~ Verification that all licensed BRP personnel have completed this scenario prior to May 26, 1988, will be tracked as an Open Item (155/87017-01). In addition, the licensee needed to change the Simulator Work Sheets in NTO Procedure 4.1, " Big Rock-Point Operator Training Program," to reflect the new annual' requirements. This will be tracked as an Open Item (155/87017-02).

Review of the licensee's training records indicated they were completing all other manipulations required on an annual basis and those specified on a two year cycle within their specified interva The licensee uses contractor prepared and contractor grades exams in the requalification program. The following statistics regarding these exam results were provided by the training department: License Type Year Number of Exams Given % Passed R0 1985 13 85 SRO 1985 13 70 R0 1986 13 100 SRO 1986 8 100 The individuals who did not pass in 1985 were placed in accelerated requalification classe All of these individuals passed the accelerated class exams. The requalification program appears effective as shown by the 1986 exam result Summary l The review of deviation and event r2 ports revealed no training l deficiencies. A feedback path was evident between operations and j training as indicated in the event revie Operation's supervision j was aware of their opportunity to request formal training and to input suggestions for revision of the training progra l l Non-Licensed Staff Training Effectiveness (41400_1 The inspectors reviewed operational events and interviewed personnel to l evaluate the effectiveness of training programs for non-licensed personnel. The procedures used by the licensee for implementing specific training programs were also reviewe Deviation Report Review l From the deviation reports reviewed, the inspectors chose two i reports, which occurred during the current SALP period, for further review: G

_ _ _ _ _ _ .

,.
 .
 -
 (1) Deviation Report No. D-BRP-86-38 dealt with the incorrect use l

of a flexitallic gaske During maintenance activities to ' replace a gasket on a leaking relief valve, the as-found gasket . was determined to be an incorrect pressure rated gasket. The l licensee root cause determination indicated that the problem

        '

l was due to personnel error in choosing the proper gasket during a previous maintenance activity involving this flang , No training was given as a result of the incident; however, a ' memorandum (WDB 86-22) to all maintenance personnel was issued as a reminder on how to select flange gaskets. The proper

pressure rated gasket was subsequently installed.

!

 (2) Deviation Report No. D-QC-86-04 was issued for failure to document a required inspection during radwaste baling operations, in accordance with Maintenance Procedure

! No. MRWS-3. The licensee root cause determination indicated that the problem was due to personnel error on three separate occasions by five different maintenance repairmen. However, the inspection was documented by the , Radiation Protection Manual Departmental RM-50 Procedure.

! The 12 barrels in question had met the acceptance criteria, in accordance with RM-50. No training was given as a result of the incident. Subsequent actions by the licensee included revising the procedures for baling radwaste, and the issuance of a memorandum (WDB 86-19) to all maintenance personnel. The memorandum was issued as a reminder to be more careful while following procedures and documenting the required activit In the above cases, no formal training was necessary as a result of the even The incidents appeared to be isolated events, due to personnel error, and not a training deficiency, Licensee corrective actions were adequate to address the event and to prevent its recurrenc b. Maintenance Training Program The Mainter.ance Department had two procedures for implementing the training program for maintenance repairmen:

 (1) Administrative Procedure No. 1.7.7, "Mechani al and Electrical Training Program " described the program anchwtlined the required training activitie (2) Administrative Procedure No.1.7.8, " Mechanical and YlMtrical Maintenance OJT Program," outlined the method for providing a formal progression and documentation of the On-The-Jot, Training (0JT).

Revision 0 of the procedures was approved for use on November 21, 1986. The training program was established for evaluation and accreditation by INPO. Deviation Report No. D-BRP-86-40 was written on November 24, 1986, reporting that the Maintenance Department was

      . _ _ _ _ _ _ _ _ _ _ -

- _ _ .
, . .

not in conformance with Procedure Nos. 1.7.7 and 1.7.8, due to insufficient time and manpower. Implementation of all aspects of the training program had not yet been completed by the end of this inspection period. The licensee. plans to be fully implementing the established program in 1988, subsequent to accreditation of the ! training program. The waiver process and the required training should be completed at that time, and the Deviation Report closed out. Discussions with the licensee indicated that until the 0JT portion of the program was complete, senior repairmen would accompany less experienced persons in performing maintenance activitie The new training program will formalize the selection of personnel to perform a maintenance task, by requiring that DJT task documentation be completed prior to performing a maintenance , activit I i Instrument and Control (I&C) Training Program i Three procedures existed for implementation of the I&C training l program: i (1) Nuclear Training Department Program Number 11, "I&C Training Program," outlined the basic training for I&C technicians and listed course description (2) Administrative Procedure No. 1.7.4, " Instrument and Control i 0JT Program," described the method for p oviding a formal

        '

progression and documentation of the OJT for I&C technician (3) Administrative Procedure No. 1.7.3, "I&C Certification Procedure," outlined the program for verifying that I&C technicians obtained the required competence leve The inspectors reviewed the training records for the I&C Department and found that the six technicians were senior technicians. In March 1986, these technicians were waived through the training program based on their experience level at BRP. Discussions with the licensee indicated that the I&C Department was one of the more ! stable groups at BRP, in terms of staff turnover and expertise. No entry level technicians have been hired since the training program j was established in January 198 . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action l I on the part of the NRC or licensee or bot Open items disclosed during the inspection are discussed in Paragraph , Exit Interview

        <

The inspectors met with the licensee representatives (denoted in Paragraph 1) on July 24, 1987. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the statements

_ _ _ _ _ _ - _ _ _ _ _ _ _ . .

..
. ..

made..by the inspectors.with respect to the 0 pen Items and other noted concerns. The inspectors also discussed the likely informational' content

     ~

j of the inspection report with regard to documents or processes reviewed ' l- by the inspectors during the inspection. The licensee did not identify l any such documents / processes as proprietary.

i r

     '

1 \

     !
     'l 1
     ,
     .1
      :

l

     '

I c 9 }}