IR 05000254/1987029

Forwards Safety Insp Repts 50-254/87-29 & 50-265/87-29 on 871019-21.No Violations Noted.Concern Expressed That One Senior Reactor Operator Returned to Duty as Shift Foreman Prior to Completing Required Requalification Program

ML20236V225
Person / Time
Site:	Quad Cities
Issue date:	11/09/1987
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8712040167
Download: ML20236V225 (2)

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N/09 13 L

i Docket No. 50-254 4 Docket No. 50-265 l l'

Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety inspection conducted by. Messrs. R. A. Hasse, J. A. Hopkins and M. P. Phillips of this office on October 19-21, 1987,.

of activities at Quad Cities Nuclear Station, Units 1 and 2, authorized by i NRC Operating Licenses No. DPR-29 and No. DPR-30 and to the discussion of our ]

findings with Mr. R. Bax and others of your staff at the conclusion of the

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inspectio I l This inspection was conducted to determine if you had satisfactorily completed the actions described in CAL-RIII-86-007, Amendment 1, issued on November 14,

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l 1986 addressing your licensed operator requalification program. The inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne The results of this inspection indicated that the CAL had been adequately ,

implemented and no violations of NRC requirements were identified; however, we I did have one concer You returned one Senior Reactor Operator (SRO) to duty as a Shift Foreman'(SF)

prior to his completing the required accelerated requalification progra Since the SF does not normally perform licensed duties, this did not violate the requirements of the CAL. In making this decision you apparently overlooked the fact that the SF automatically succeeds the Shift Engineer (SE) in the event of his incapacitatio The SE does perform licensed duties. Further, the SRO in question failed the NRC administered. operating examination and your i own simulator evaluation on the basis of unacceptable performance in-the role

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of SE. We urge you to discuss the oversights in this decision with your staff

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with special emphasis on potential generic implication In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of l this letter and the enclosed inspection report will be placed in the NRC Public Document Roo ~

8712040167 871109 PDR ADOCK 05000254 G PDR

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., '. W 0 9 gg t Commonwealth. Edison' Company 2 We will gladly discuss.any. questions you have concerning'this inspection.

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Sincerely,

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Original Signed By N; J.'Chrissotimos Hubert.J. Miller,. Directo Division of Reactor Safety.-

Enclosure:

Inspection Reports No. 50-254/87029(DRS);

No. 50-265/87029(DRS)

REGION III==

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Reports No. 50-254/87029(DRS); No. 50-265/87029(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; No. DPR-30 Licensee: Commonwealth Edison Company P. O. Box 767 4 Chicago, IL 60690 j Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2 j i

Inspection At: Cordova, Illinois l

l Inspection Conducted: October 19-21, 1987 I Inspectors: R.fA. Hasse //ff/$7 Date

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J. A. Hopkins #

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Approved By: M. P. Phillips, Chief Operational Programs Section

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l Inspection Summary ,

Inspection on October 19-21, 1987 (Reports No. 50-254/87029(DRS);

No. 50-265/87029(DRS))

Areas Inspected: Special announced safety inspection to determine if the conditions of the Confirmatory Action Letter (CAL) CAL-RIII-86-007, Amendment 1, dated November 14, 1986, has been properly implemented and to '

followup on previous NRC inspection findings in this area.

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Results: No violations or deviations were identified.

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DETAILS l

1. Persons Contacted Commonwealth Edison Company (CECO)

• R. Bax,' Station Manager d

• R. Robey,; Services Superintendent

• R. Hopkins,' Quality Assurance Engineer M. Kooi, Regulatory' Assurance Supervisor ,

• J. Neal, Training Supervisor M. Miller, Quality Assurance Inspector j

• Rodts, Training Instructor ,

U.S. NRC A. Morrongiello, Resident Inspector Other personnel were contacted as a matter of routine during the'

inspectio * Denotes those attending exit interview on October.21, 198 . Followup on Previous Inspection Findings (Closed) Unresolved Item (254/86019-01; 265/86020-01): Conducting Licensed Operator requalification lectures during one two week period each year rather than continuously throughout the license perio Region III (RIII) requested an interpretation from the Office of Nuclear Reactor Regulation (NRR) to clarify the intent of 10 CFR 55 concerning requalification lectures that were administered in " blocks." In a i memorandum to RIII dated August 13, 1987, NRR explained that " block" lecture training for requalification programs was acceptable if.the program content was based on an evaluation of performance on written-examinations, facility operating experience, and personnel performanc i Further, the memorandum stated that a requalification program which is 11 l accredited and based on a Systematic Approach to Traini_ng (SAT) may elect i I

to continue " block" lecture trainin '

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The licensee's current requalification lecture training cycle consists of six sessions of four days scheduled throughout the calendar yea ,

The inspectors believe that this schedule meets the intent o I 10 CFR 55.59(c)(2) which requires preplanned lectures on a' regular and I continuing basi . Licensed Operator Requalification I Purpose '

The' purpose of the inspection was.to determine if the licensee had  :

implemented the commitments documented in the Confirmatory Action  !

Letter (CAL) CAL-RIII-86-007, dated November 10, 1986, and Amendment 1 l

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of the CAL, dated November 14, 1986. .The CAL was issued as a resul of the 58% failure rate on the NRC requalification examination administered during.the weeks of September 15..and October' 13, 198 The CAL detailed additional control. room staffing requirements,-

removed those operators who failed the NRC requalification exam from licensed' duties, gave-a brief outline of the'short-term upgrade program, and required the. implementation of a long term improvement ~

plan beginning in the-next requalification training cycle, Inspection Results-(1) Part One of the CAL' required that while.in cold shutdown.the; Quad Cities Units 1 and 2 control room would be staffed with a-licensed Senior Reactor Operator (SRO) as an advisor who had passed either the NRC administered requalification exam or had passed a NRC license examination since October 1, 1985. The inspectors determined through interviews and a review of training records.and shift log books how the licensee selected l candidates for the SRO advisor. position. .In order to meet these restrictions the licensee conducted an audit of the-licensed operators' reco'rds to select a pool of candidate The licensee wanted to keep a high level- of experience on-shift and decided that since the SRO advisor.would not be in decision making role, on-shift experience was not critica The Shift Engineer (SE), while not necessarily meeting the restrictions outlined in the CAL, would provide this experienc The Station Operating and Training Review Board then approved'

the candidates and assigned them as shift advisors in Cold Shutdow The licensee removed the SRO advisors from shift as'soon as SR0s who had passed the accelerated requalification program and had been returned to licensed duties became available to act as

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SE The inspectors judged these actions to be in compliance with the CAL with no further action require (2) Part Two of the CAL required'that when in other than cold shutdown the Quad Cities Units 1 and 2 control room would'be staffed by a licensed SRO and as a minimum, a licensed Reactor Operator (RO) at the controls of each operating unit who met-the criteria of Part One of the CAL-or had successfull completed the short term upgrade program.- The inspectors determined through interviews and a review of training. record and shift log books how the licensee selected candidates for-the R0s at the controls of each unit. The~ licensee used the process described above to select the SRO advisors. The licensee had adequate R0s routinely assigned to shift duties who met the requirements of Part One of the CAL which obviated the need to put inexperienced R0s on-shift dut _ _ - _ _ _

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The inspectors judged these ~ actions-to bb in compliance with the CAL with no further. action. require .(3) Part.Three of the CAL required the licensee to remove from licensed duties those R0s and SR0s who failed the NRC-administe' red requalification examination until such time that those~ individuals successfully, completed the' accelerated upgrade-training program. The inspectors determined.through a review of .

training. records and shift. log books.thatLthe' licensed operator were taken off-shift.and successfully completed:the upgrad ll program. . Ten licensed operators. (four R0s and six SR0s)

failed the.NRC requalification' exams' administered during the-weeks of September 15 and October. 13, 1986. Those ten licensed operators were removed from licensed duties and placed.in the Short-Term Operator Training Upgrade Program. Two of th licensed operators had successfully completed;the. upgrad training program by the,end of December 1986,'one completed:the program in January 1987, two completed the program in March 1987, and five' surrendered their NRC licenses. With the exception o the SR0 discussed'below, all licensed. operators who successfully completed the upgrade training, were returned to. licensed duties-upon completion of the progra One SRO who failed the NRC administered requalification exam was placed on-shift as a Shift Foreman (SF), his norma position, prior to successfully completing the accelerated upgrade training program. The SF is required by Technica Specification to hold a SR0 license but.does not routinely direct the licensed activities of a licensed. operato However, the SF assumes tLe duties of the SE if the SE is incapacitate The SR0 in question failed both the written exam and operating-test administered by the NRC. Significant concerns from the operating test were the SRO's unsatisfactory . ability to direct plant operations in a casualty while acting as the SE and his failure to utilize Emergency Procedure The SR0 was placed in the-first session of- the accelerate'd-requalification program and passed the written exam but failed the simulator operating test on December 19,.1986. .The simulator operating evaluation stated that his performance as SE was not satisfactory. - The SR0 did not properly respond to or investigate changing plant conditions, his communication and supervisory abilities were unsatisfactory, and he failed to refer to procedures when' required. These were the same basic reasons for his' failure of the NRC requalification.' exa The licensee's Station Operation land Training Review Board evaluated the SR0's performance to determine if he should be-returned to licensed duties. The Review Board determined that the SRO's excellent past record in the control room made him-

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acceptable to perform licensed duties until additional. training could be provided. The Review Board also noted'that he is not assigned the duties of SE. The SR0 was returned to shift duties as a SF on January 14, 1987. The SRO successfully completed the simulator training on January 23, 1987 The conclusions reached by the Review Board did~not. fully consider the reasons for the SR0's failure of.the NRC and licensees' operating examinations in terms of the SF's total responsibilities. In.both cases the SRO failed to ' satisfactorily direct plant operations in a casualty while acting-as SE. :The Review Boards recommendation to' return the SR0 to licensed duties in view of.the fact that he.is not assigned SE duties, apparently did not consider the fact that the.SF automatically succeeds the SE in the event of the SE's incapacitation. While-the SRO performing the duties of SF did not: violate thel requirements of the CAL, the licensee created a situation where

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this.could have occurred. It appears that the Review Board's evaluation was superficial by applying past control-room ..

experience for a position that did not perform' licensed duties

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as justification to allowed the SR0 to be returned to license dutie The inspectors judged these actions to be in compliance with the CAL. With the exception of a thorough licensee review of:

this concern, no further action is require (4) Part Four of the CAL required the licensee.to implement an accelerated requalification program for all-licensed operators who had not passed one of the recent NRC administered requalification exams or passed.a NRC license exam.since October 1, 1985. The inspectors. determined through a review of training records, interviews, lesson plan reviews, and simulator scenarios, that the licensee had implemented the accelerated requalification program. The program consisted of three weeks of classroom training and one week of. simulator-training with the program's major emphasis in' the following areas:

E0P Theory and Usage (QGA)

Selected Normal Procedures (QAP, QOP, QRP).

General Integrated Procedures (QGP)

Technical Specifications (T.S.) and Bases Selected Abnormal Procedures (Q0A)

Reactor Theory and Thermodynamics

. Selected Plant' Systems The licensee used three weeks of classroom lectures to address-some of the areas of major emphasis in the upgrade' progra Below is a list of the topics covered in the lecture series:

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Week One Thermodynamics Review Reactor Theory Review Selected Plant Systems and Procedure Synopsis Weekly Quiz Week Two Selected Plant Systems and Procedure Synopsis Weekly Quiz Week Three Technical Specifications Selected Abnormal Procedures (Q0A)

E0P Theory and Usage'(QGA)

General Integrated Procedures (QGP)

Selected Administration Procedures (QAP)

Radiation Protection (QRP)

Weekly Quiz The fourth week of the accelerated requalification program was simulator training. This training was conducted using the Dresden Station simulator, which is not Quad Cities plant specific. The simulator training consisted of two hours of classroom lecture and six hoJr simulator sessions for three days l followed by a four to six hour evaluation on the fourth da The control room crew in the simulator consisted of two SR0s (a SE and a Shift Technical Advisor (STA)) and two R0s (a reactor operator, and an extra Nuclear Station Operator (NS0)). Each simulator session typically consisted of four different

, scenario Below is a list of the scenarios used during the l upgrade program:

Day One Classroom Introduction to Problem Solving Algorithms Introduction to E0P Flowcharts Preview of scenarios Simulator System Familiarization /Small Leak in Drywell-Plant Startup (with malfunctions)

Loss of Offsite Power / Plant Shutdown (with malfunctions)

Plant Casualty Response familiarization (observation only)

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I Day Two Classroom Simulator session critique Interrelating Flowcharts and Procedures Preview of scenarios Simulator High Conductivity Steam Cooling Loss of both Control Rod Drive (CRD) Pumps /ATWS (with '

malfunctions)

Loss of Normal and Emergency Feedwater (with malfunctions)

Turbine Trip /ATWS Day Three 'I I

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Simulator session critique 1 Interrelating Flowcharts and Procedures  !

Preview of scenarios 1 Simulator Large LOCA (with malfunctions)

Spray Cooling (with malfunctions)

MSIV Closure /ATWS (with malfunctions) ,

ATWS Requiring Emergency Depressurization  ;

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Day Four l

The fourth day of simulator training was a four to six hour evaluation of the licensed operators. The evaluation was performed by independent General Electric (GE) instructors from the Dresden Simulator Training Center. The licensed operators 1 were evaluated in nine categories: j

l Control Board Awareness l Event Diagnosis j Immediate Actions '

Subsequent Actions Console Manipulations Use of Procedures / Reference Data / Communications Supervisory Ability ,

Team Work Each licensed operator evaluation was reviewed by the Dresden Station management and categorized in one of two ways:

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(1) Released to full licensed dutie !

(ii) Remov61 from licensed duties until all training j recommendations are complet <

The licensee has 64 licensed operators (R0s and SR0s). Three

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of the SR0s are Fuel Handling Foremen with limited license and were exempt from the upgrade program. All licensed operators had successfully completed the upgrade progra ,

i The inspectors judged these actions to be in compliance-with '

the CAL with no further action require ;

i (5} part Five of the CAL required the licensee to implement a 'long  !

term requalification program improvement plan at the beginning l

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of the next requalification training cycl The inspectors ottermined through interviews, a review of training records, and a review of the 1987 and 1988 training schedules that the

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im;rovement program was adequate. The five point program to  ;

I enhtnce the requalification program is outlined in the '

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l (a) Increase Training Staff from 16 to 2 )

l The licensee has hired three maintenance and two operations instructors to increase the Training Department staffing to 21. The licensee plans to extend employment offers to one operations and one technical instructor by December 198 (b) Lengthen Requalification Classroom Training from eight to 22 day The licensee has expanded the classroom training to six sessions of four days in each requalification cycl The program, which coincides with the calendar year, schedules the first four sessions consecutively followed by a ten week break for vacations, simulator training,

" walk-through" oral exams, and any required remedial training. The final two sessions are followed by a six week period for record review by the Training Departmen The Requalification Training program operates on a two year cycle with a review day and an annual written exam administered during the fourth session. Each week consists of a review of the previous week's quiz, lectures on selected systems and procedures, theory review, and a weekly quiz.

l (c) Lengthen Requalification Simulator Training from three to five day . _ _ - _-__ A

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The. licensee completed five days of simulator training during the -1987 requalification cycle. -The simulator

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training consisted of two hours in the classroom and six ho,urs on the simulator during each session. The simulator sessions-included the manipulations outlined in Attachment A of CECO Topical Report !'Requalification Program for Licensed Operators, Senior Operators, and Senior Operators (Limited), " February 10,;1987,.recent industry related events, areas identified as weak .i previous exam evaluations, and suggestions from the ,

simulator training staf The 1988 simulator training is. scheduled for two four day sessions.

i (d) Modify Training to Increase Depth of Procedure Knowledge,

The licensee has implemented a four point program to increase the depth of procedure knowledge as outlined below:

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(1) Incorporate procedure synopsi.s in all systems trainin (ii) Review Emergency Procedures (QEPs) .with GESP tra'ining l twice each year.

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l (iii) Conduct E0P (QGA) classroom exercises to familiarize l the operators with using the E0Ps and Flow Charts.

l (iv) Schedule the Procedural required reading to coincide L with the systems taught'in requalification training.

l (e) Upgrade E0P (QGA) Training and Procedures with Flow Charts and Increased Practical Application The licensee developed a pilot program to familiarize the operators with the E0Ps and Flow Charts. The program consisted of an oral " walk-through" of casualty scenario to place the plant in a safe-condition with emphasis placed on entry conditions of various QGA procedure blocks, the basis of principal steps within the QGAs, and guidance on what parameters are important to observ The licensee has incorporated this pilot program into the requalification program as described above (Paragraph 3.b(5)(d)).

The inse ctors determined the above actions satisfie'd the licensee's commitments identified in the CAL with no-further action require (.

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4. Exit Interview The inspectors held an exit interview with licensee representatives ,

(denoted in Paragraph 1) and summarized the purpose,' scope, and findings

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of the inspection. The licensee stated that the likely informational ;

content of the report would contain no proprietary informatio ]

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