IR 05000346/1987018

Insp Rept 50-346/87-18 on 870706-10.No Violations Noted. Major Areas Inspected:Effectiveness of Licensee Training Program for Licensed Operators (Module 41701) & Nonlicensed Staff (Module 41400)

ML20236M095
Person / Time
Site:	Davis Besse
Issue date:	08/05/1987
From:	Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236M058	List: IR 05000346/1987018 ML20236M055
References
50-346-87-18, NUDOCS 8708100468
Download: ML20236M095 (9)

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U.S. NUCLEAR REG'JLATORY COMMISSION

REGION III

Report No. 50-346/87018(DRS)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse 1 l

Inspected At: Davis-Besse Site, Oak Harbor, Ohio l Inspection Conducted: July 6-10, 1987 Inspector: sW Ray S. Love h 9lf/f7 Data rqN7 Approved By: 'honte P. Phillips, Chief Operational Programs Section 8/f//7 Date Inspection Summary Inspection on July 6-10, 1987 (Report No. 50-346/87018(DRS))

Areas Inspected: Routine, unannounced inspection of the effectiveness of the licensee's training program for licensed operators (Module 41701) and non-licensed staff (Module 41400).

Results: Of the areas inspected, no violations or deviations were identifie PDR ADOCK 05000346 o PDR

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DETAILS 1. Persons Contacted Toledo Edison Company (TED)

• D. C. Shelton, Vice President - Nuclear

• G. Horma, Compliance Supervisor - NLD

• L. O. Ramsett, Director, Quality Assurance

• C. S. Bramson, Nuclear Records Manager

• S. P. Goldstein, Systems and Procedures Manager

• J. K. Wood, Systems Engineering Director

• R. W. Schrauder, Nuclear Licensing Manager  !

• J. Sturdavant, Licensing i

• J. C. Lictzow, Licensing Principal

• J. H. Syrowski, Acting Training Director

• D. Hughes, Acting Operations Training Manager i

• S. J. Smith, Assistant Plant Manager-Maintenance

• E. Schefers, Information Management Director M. A. Schoener, Nuclear Training B. W. Cope, Emergency Preparedness N. Bonner, Maintenance J. L. Freels, Nuclear Support Training Manager J. Kasper, Operations Superintendent

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The inspector also contactea and interviewed other licensee personnel during the insoectio * Denotes those present at the exit interview on July 10, 198 . Training The objective of this inspection was to evaluate the effectiveness of the licensee's training program for licensed operators and non-licensed operators and staff personnel, and whether the training (classroom and on-the-jobi received before an event / occurrence was adequate to have either prevented the occurrence or mitigated its affects. The inspection also determined if lessons learned from operating events were factored into the training program. The licensee's training program is evaluated by the Institute for Nuclear Power Operations (INPO) as part of their training program accreditation proces At the time of this inspection, INP0 has accredited the following training programs at Davis-Besse (DB): (1)SeniorReactorOperator(SRO);

(2) Reactor Operator (RO); (3) Non-Licensed Operator (NLO); (4) Instrument and Control Technician (I&C Tech); (5) Electrical Maintenance Technician; and (6) Mechanical Maintenance Technician. The remaining training programs have been submitted for accreditat:on, and INPO i:ad tentatively scheduled a site visit for July 20-24, 1987. The training programs submitted are: (1) Shift Technical Advisor (STA); (2) Radiation Protection Technician; (3) Chemistry Technician; and (4) Technical Staff and Managers.

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The objectives of the inspection were accomplished by reviewing applicable training procedures, 52 Licensee Event Reports (LERs),

approximately 150 Potential Conditions Adverse to Quality Reports (PCAQR),

personnel qualification records, and interviews of licensed operators and non-licensed personne l Licensed Operator Training '

(1) Review of Procedures During the inspection, the following procedures were reviewed:

AD1828.04.06, " Personnel Training Records" AD1828.08.00, " Instant Senior Reactor Operator Training Program" AD1828.10.05, " Davis-Besse Operator Training" AD1828.15.06, "Requalification" During a review of the above listed procedures, the following concerns were identified:

l (a) Procedure AD1828.15, Paragraph 6.7, references procedure AD1828.04 for training records retentio Paragraph of procedure AD1828.04 in turn references procedure AD1848.00, " Station Records Management," for training records retention. However, it was determined that procedure AD1848.00 had been deleted on December 5,1986, without revising the applicable procedures, including AD1828.04, to indicate that the new procedure for training record retention is NTD-Oll, " Training Records."

Corrective Action - The licensee issued a Procedure Change Request to revise procedure AD1828.04 to correct the Records Retention Reference and to identify all procedures that reference deleted procedure AD1848.00 and make the necessary corrections. Pending a review of these tuo Procecure Change Re open (346/87018-01) quests for proper closure, this item is

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(b) Procedure AL1828.08.0, Paragraphs 6.9.1.c and 7.9.1.c, state, in part, "during this phase, the candidate must complete 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> as an extra person on shift." NVREG-1021, Revision 4, dated May 1987, Section ES-109, Paragraph C. and D. state, " minimum of three months on shift as an extra person in training for an SRO position under the direct supervision of a licensed senior operator assigned to a licensed senior operator position on an operating shift."

Pending a verification that the 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> on shift is under I the direct supervision of an SR0 that is performing the duties of an SR0, this item is open (346/87018-02).

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(c) During the inspection, the inspector was provided a copy of an Intra-Company memorandum from the Nuclear Operations Training Manager to Distribution, dated July 2, 1987. This memorandum states, in part, " Enclosed you will find a list of system engineers who may administer check-outs to you for !

the systems indicated below their nam Certain objectives on some system check-outs deal with operator responses to alarms, abnormal procedures, integrated system responses, et In these instances, the engineer may not feel comfortable completing the check-out. If this r.appens, complete the check-out on the particular system by arranging time with an Operations Training Department licensed operator."

I Procedure AD1828.10, Paragraph 5.5.5, states, "these l check-outs will only be administered and signed off by a l NRC Licensed Operator at Davis-Besse."

l l When this item was discussed with the licensee, the

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inspector was informed that the scope of this memorandum l was limited to Instant SR0s for Phase I training only.

i Phase I training is limited to the duties of a Non-Licensed Operator as described in Procedure AD1828.0 Paragraph 6.12.1.a of this procedure states, in part, " Phase I will be evaluated as described in the Non-Licensed Operator Proficiency Manual." Section 3.0, " Knowledge Requirements,"

of this Proficiency Manual states, "the method of evaluation is ora This will be documented on the Knowledge

)l Requirement Evaluation Sheet by a qualified individual (R0 or SRO Licensed Individual)."

After these conflicts were brought to the licensee's )

attention, the Nuclear Operations Training Manager issued a i memorandum, dated Jul, 10, 1987, rescinding System j Engineers' authority to administer check-outs to Instant l SRO trainee This memorandum also stated that " Knowledge }

Requirement Evaluation Sheets, signed by anyone cther than a licensed operator, are voi The ' check-out' must be administered again in its entirety by a licensed operator."

To determine the " root cause" of the memoranda being issued, the inspector interviewed training department )

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personnel and licensed operators. Several of the I individuals interviewed stated that: (1) in the last twc years no licensed Reactor Operators have been asked or designated to take the training for Senior Reactor Operators; (2) many of the R0s and SR0s are in disagreement with the Instant SRO program in that they (Instant SR0 candidates) are not licensed R0s at Davis-Besse; and I (3) many of the R0s and SR0s are "always too busy" to give check-outs to Instant SRO candidates and this placed a heavy burden on those R0s and SR0s that are available to give check-outs, thus impeding the qualification process of the Instant SR0 candidates. During interviews of NL0s, i

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the inspector was informed that they had no problems in obtaining system check-outs from the R0s and SR0s. The possible friction between various work groups at Davis-Besse was identified during a previous inspr.ction (Reference: Inspection Report Nu. 346/87015(Di.P)) . At Region III Management's direction, the NP.C Resident Inspectors are continuing to investigate the possible ,

conflicts / friction identified in the DRP inspection report j and they will increase the scope of their investigation to include the possible conflicts of interest identified in this repor (2) Review of LERs and PCAQR l

l Of the 52 LERs and approximately '.50 PCAQRs reviewed, the l inspector selected the three reports listed below for further I revie (a) LER 87007 cddressed a missed surveillance test (ST) that would demonstrate operability of remaining AC sources of electrical power when Emergency Diesel Generator No. I was taken out of service for scheduled preventive maintenanc The licensee's root cause was that senior licensed personnel i on shift failed to assign personnel the task of performing

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the surveillance test. All licensed personnel " Turnover Checklists" require written information concerning Technical Specification (TS) Action Statement". The current checklists note the date and time a TS Action Statement was entered, the TS item number, the date and time the TS Action expires, and the equipment or train affected. The Turnover Checklists were revised to include the actions required by the TS Limiting Conditions for Operation (LCO)

and the date and time the next surveillance is due. Senior licensed personnel were tasked with the responsibility for compliance and tracking of all surveillance requirement This contributed to other licensed operators on shift not aggressively monitoring the status of TS ST requirement All licensed personnel responsible for the missed STs were counseled on the requirements for operating Davis Besse in accordance with the TS which are part of the fa'slity operating license. In adcition, STAS will track ST requirements to provide additional awareness and back-up monitoring of STs. Operations and training personnel were cognizant of this LER. During the interviews, one individual made the comment that Shift Supervisors are solely responsible for the ST being performed. It would appear that at least one RO needs to review his/her license that was issued by the NRC. A typical R0 license states, in part, "In manipulating the controls of the above facility you shall observe the operating procedures and ;

other conditions specified in the facility license which authorizes operation of the facility, and . . . "

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I (b) LER 87002 addressed the improper bypassing of a Safety Features Actuation System (SFAS) Containment Radiation Trip Module while performing post maintenance testing. This was in violation of a TS Action Statement which required the module to be tripped. The original failure of this madule placed the SFAS Channel in the TS Action Statement, i

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ubich requires the inoperable channel be placed in the tripped condition within one hour. The channel was placed in the tripped condition and the maintenance activity was accomplished. The I&C technician failed to follow the ST procedure when he obtained the Test Trip Bypass Switch (TTBS) key fro., the Shift Supervisor to perform post maintenance ST on a SFAS Cnannel that is in a TS Action Statement. The Shift Supervisor failed to recognize that the SFAS Channel was in a TS Action Statement when he issued the TTBS key to perform the post maintenance ST. As

a result the channel was placed in the " bypass" condition rather than the TS required " trip" condition. Additionally, l

l when the channel bypass alarm first came in, operators

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responded in accordance with the alarm procedure by l reporting the condition to the Shiit Supervisor. The Shift Supervisor stated that maintenance was being performed on the channel and that was the reason for the alarm. No further questions arose with respect to the condition of the channel until the oncomilg Shift Supervisor realized that the channel did not meet the TS Action Statement. He had i the channel removed from the " bypass" position and placed in the " tripped" position. Operations and training personnel were cognizant of this LER. During personnel interviews the inspector was informed that during normal surveillance testing, the channel being tested is in fact bypassed. This fact may have contributed to these personnel error (c) LER 86C43 - addressed a reactor trip due to feedwater isolation. While at 15% reactor power, R0s were controlling steam generator (SG) levels with the startup feedwater centrol valves in automatic mode as part of a restart tes Testing personnel were trouble shooting a variance in the differential pressure control circuitry of the feedwater pumps. Assuming that the feedwater (FW)

control valves were in the manual mode, I&C personnel removed the RFR relay modul This interrupte' the centrol signal, causina the main and startup FW control valves to start openi ine R0s took prompt corrective action by taking maaual control of the FW valves and returning SG level to norma After the RFR relay module was replaced, the operators verified that the main feedwater control valve would remain closed when placed in the automatic mode. When the startup FW control valve was placed in the automatic mode, the valve closed, isolating feedwater to SG No. 2. The R0 attempted to mar:ually control the SG 1evel, but was unable to open the FW control valve in time to prevent a reactor trip on SG low level. The valve closure had been

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determined to be the result of the ICS auctioneering module remaining in the flow control mode rather than transferring to the level control mode. The auctioneer had not switched !

to level control mode due to an erroneous SG level signal j caused by an unbuffered point on the data logger (being used for testing) having an effect on SG level signal Corrective Action - Two restart administrative instructions have been issued to testing and operations personne Thase instructions outline additional steps to be taken to control testing and troubleshooting activities. Monitoring of the SG 1evel inputs to the ICS will be done with brush recorders, which do not load the signal, until a satisfactory isolation is develope !

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I l (3) Licensed Operator Requalification i The licensee is in the process of revising the licensed j operator training program to meet the requirements of the new 10 CFR Part 55, dated March 31, 198 ]

l During the insnection, the inspector reviewed a sample of {

the licensed operators' training records for completenes The records packages contained a history of training received, written test, test key, operators' answers to the test, znd a record of the required reactivity control ,

manipulation No deficiencies were identifie l The licensee provided the pass rate for the facility j administered requalification examinations for the past j two years:

License Exams Given Pass Rate, %

1985 SRO 18 89 R0 17 88 1986 SRO 19 100 R0 17 94 b. Non-Licensed Staff Training (41400) .

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(1) Non-Licensed Operators During the inspection, the inspector reviewed the detailed training procedure for an Auxiliary Operator (AO) as contained in the Davis-Besse Auxiliary Operator Qualification Manua .

Af ter qualifying as an A0, the individual may progressively I qualify as a Non-Licensed Equipment Operator I, II, and II The next step of qualification would be as a Licensed R0. .No deficiencies were identified during the review of Non-Licensed Operator training a:,d qualification record During the review of LERs and PCAQRs,'the inspector did not observe any events that reflected on the training of Non-Licensed Operators (NLO).

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During the interviews of NL0s, the inspector found that they were knowledgeable of the LERs and several NRC Bulletins and Information Notice (2) I&C Technicians An I&C Technician may qualify in approximately 30 arehs/ system During a review of the qualification matrix, the inspector did not identify any technician that was qualified in all area From this qualification matrix, the inspector selected a sample of qualification records for review. The I&C Technician l

! training and qualification program at Davis-Besse is reasonably new. This has resulted in the training being waivered in areas where the Technician was qualified based on experience at Davis-Besse. No deficiencies were identified during the review of training and qualification records of the I&C Technician Event reports involving I&C Technicians are discussed in Paragraph 2.a.(2) above. During personnel interviews, the inspector was informed that all LERs and PCAQRs that involve I&C Technicians are discussed at the morning meetings. Also, PCAQR 87-185 was prepared tacause various departments have failed'

to notify QC prior to performing surveillance, tests, and maintenance that requires QC verification. The interviewee stated that one of the problems with notifying QC is that no one is there to answer the phone and the individuals get tired of calling; a telephone recorder would help. The inspector conveyed this information to Davis-Besse management during the exit meetin Training Update The licensee's training program provided several means of disseminating information related to operating events, PCAQRs, procedure changes, and field changes / plant modifications. Training update mechanisms included required reading, onshift/ tool box training, formal classroom training, and personal copies of LERs, procedures, policy changes, et If an item or system is revised or modified, operators must be trained in the revised /mcdified item / system before it can be declared operational. Also, all applicable personnel must be trained to a revised procedure before that revision of the procedure becomes effective. Davis-Besse LERs, select LERs from other facilities, and select NRC Information Notices and Bulletins were factored into the formal classroom training program. During personnel interviews of Licensed Operators, Non-Licensed Operators, I&C Technicians, TED instructors, and Contract instructors, the inspector received the following comments and concerns with respect to the training program at Davis-Besse:

f,ll interviewees (12) rated the TED instructors good to very goo .

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One RO rated most of contract instructors as poo Reason for I this rating was that they (contract instructors) had not gone through the training and qualification program at Davis-Besse and were therefore poor instructor The remaining interviewees rated the contract instructors as goo {

Requalifi u tion training - at present is only two days per five week cycle. Most thought this was not enough time to cover the required material (cycle training).

! NLO and Technician training is constantly improvin Due to work load, Technician training, formal, and OJT is limited to one week per month. Also need a better balance l between formal and hands-on trainin . Open Items l Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involves some action l

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on the part of the NRC or licensee, or both. Open items disclosed during this inspection are discussed in Paragraphs 2.a.(1)(2) and 2.a.(1)(b). Exit Interview The inspector met with the licensee representatives (denoted under I

Paragraph 1) at the conclusion of the inspection on July 10, 1987. The inspector summarized the scope and findings of the inspection and also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. The licensee acknowledged this information and did not identify any such document or processes as proprietar l

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