IR 05000454/1987021

Insp Repts 50-454/87-21 & 50-455/87-20 on 870526-28.No Violations or Deviations Noted.Major Areas Inspected: Training Program Effectiveness for Licensed Operator Training & Nonlicensed Staff Training

ML20215G577
Person / Time
Site:	Byron
Issue date:	06/16/1987
From:	Eick S, Hasse R, Huber M, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215G571	List: IR 05000454/1987021 ML20215G569
References
50-454-87-21, 50-455-87-20, NUDOCS 8706230304
Download: ML20215G577 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION'III Reports No. 50-454/87021(DRS);50-455/87020(DRS)

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Docket Nos. 50-454;-50-455 Licenses No. NPF-37; No. NPF-60 Licensee: Commonwealth Edison Company Post Office Box 767 ,

Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois

Inspection Conducted: May 26-28, 1987 A bf/6 7-Inspectors: -R. A. Hasse

'Date WbbA c/a/e7 Date Y/Sh?

Date Approved By: M te h1111ps, Chief Operational Programs Section

/6[/7 i Date Inspection Summary Inspection on May 26-28, 1987 (Report No. 50-454/87021(DRS);

No. 50-455/87020(DRS))

Areas Inspected: Routine, announced inspection of the licensee's training program effectiveness for both licensed operator training (IE Module 41701)

and non-licensed staff training (IE Module 41400).

Results: Of the areas inspected no violations or deviations were identifie i 8706230304 870617 4 DR ADOCK 0500 J

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L DETAILS Persons Contacted Commonwealth Edison C *R. C. Ward, Services Superintendent

• Burkamper, Quality Assurance Superintendent A. Chernick, Training Supervisor S. Campbell, Administrative Office Supervisor

• A. Snow, Assistant Training Supervisor

• A. Britton, Quality Assurance Inspector R. Curtis, Management Assistant

• D. Pirnat, Regulatory Assurance

• E. Zittle, Regulatory Assurance

• J. Langan,- Regulatory Assurance

• D. Kruger, EQ Coordinator USNRC

• P. Brochman, Resident Inspector

• Denotes those who attended the exit meeting on May 28, 1987.

The inspectors also contacted other licensee personnel as a matter of routine during the course of the inspectio . Training The purpose of this inspection was to determine the effectiveness of the licensee's training programs for licensed and non-licensed personne The inspection consisted of a review of deviation reports that were issued during the time period from 1985 through the present, to determine (

if lessons learned, industry information, and operating events were '

factored back into the training program. The inspection was not designed to ' evaluate the licensee's overall training programs. The Institute for Nuclear Power Operations (INP0) currently performs the evaluation as part of its training program accreditation process. At the time of this inspection, three of the licensee's training programs had received INP0 accreditation. These programs were as follows: (1) Shift Control Room Engineer (SCRE), (2) Senior Reactor Operator (SRO), and (3) Reactor Operator (RO). The remaining programs have been submitted to INP0 for accreditation. These programs were as follows: (4) Non-licensed Operator, (5) Instrument and Control Technician, (6) Electrical Maintenance Personnel, (7) Mechanical Maintenance Personnel, (8) Radiation Protection Personnel, (9) Chemistry Technician, and (10) Technical Training for Technical Staff and Managers. The licensee 3 indicated that the remaining programs would be accredited on May 28, 198 ]

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a. . License'd Operator' Training Effectiveness (41701)

The. inspectors reviewed the licensee's operational events and interviewed plant personnel to evaluate the. effectiveness of.the training programs for licensed personne (1) Deviation Report Review Approximately 250 deviation reports (DVR).were reviewed. The inspector. chose the three reports listed below for further review.

, Deviation Report Number Description 06-02-87-013 Both essential service water (SX) Make-up pumps-inoperabl , Exhaust Filter Plenum isolated with fan operatin Failure to enter a LC DVR.06-02-87-013 addressed the inoperability of both SX Make-up pumps due to personnel error. The "0A" Make-up Pump was taken-out-of-service for an oil change. Subsequently, the "0B" pum was taken out-of-service prior to retu' sing the "0A" pump to service, rendering both inoperable. The licensee's root cause was a cognitive personnel error. Cperations personnel interviewed were cognizant of the event, but indicated that additional training in administrative procedures might help prevent recurrence of this type of even DVR 06-Q?-87-014 dealt with the failure to return the isolation dampers W 1he Nw. Accessible Auxiliary Building Exhaust Ventilahon to the correct (open) position, rendering the train inoperable. The licensee listed the cause of this event as a cognitive personnel error contributed to by procedural weaknesse The operator interviewed was cognizant of this ,

event and indicated that an error was made in verification of the correct damper position although he knew such was required at the tim DVR 06-02-87-016 addressed the failure to enter the appropriate LC0 while maintenance was being performed on Containment Isolation Valves. The licensee's root cause was personnel error. The operator interviewed indicated that he was knowledgeable of the correct procedures, but thought that additional training on daily administrative procedures would be

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helpful . Operator feedback of possible training and solutions to aid operators in identifying valves whose operability is governed by Technical Specifications were provided to the Operations Departmen In all of the above cases, the inspector determined during the interviews that previous training was adequate to prevent the events. However, additional training on day-to-day administrative procedures might be helpful for the operator (2) Training Update Mechanisms The licensee's training program provided several means of disseminating .information related to operating deficiencies and events to licensed personnel. These mechanisms included required reading, training meetings and seminars, and personnel feedbac The inspector found the required reading program to be well defined and up-to-date. The program provided a method to review facility design changes, procedure revisions, facility license changes, and other events of operational significanc The program was well maintained and personnel were required to complete the required reading packages within six weeks of the routing start date. If a package was not completed within the six week time period a memorandum would be sent requiring the delinquent personnel to report to the Training Department to complete the required reading. All packages reviewed were complete. Additional reading was also provided to on-shift personnel to read at their leisur Training on plant modifications was also provided to the Operating Department personnel when necessary, as directed by the Training Supervisor or his designee. The Training Department reviewed all plant modifications to determine if i training was needed and subsequently implemented the appropriate trainin (3) Licensed Operator Retraining The licensed operator retraining program was meeting regulatory requirements relative to required reactivity control manipulations. The inspector reviewed a sample of the licensed operators' training records, both R0 and SR0, for completeness and the performance of the required control manipulations. All records reviewed were readily retrievable and complet The licensee also provided the pass rates for both the facility .

administered requalification and initial NRC exam results for

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the past retraining cycle, May 1985 through May 198 _

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p ' LICENSEE ADMINISTERED REQUALIFICATION EXAM

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License Exams Given - Pass Rate %

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(Written)

SR0 '

70 100i

.R0 41 95'

(Operational)

SRO- 41 88 RO' 21 100 INITIAL NRC EXAM (Written 1

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License Exams Given Pass Rate %

SR0 14 86 R0 19 84 (Operational)

SR0 19 79 R0 22 82 (4) Reference of Deleted Procedures During the review of BTP 100-16, Revision 6, " Licensed Operator Retraining Program" and BTP 100-22, "Non-Licensed "A" Operator Continuing Training Program," the inspector noted that a procedure that had been deleted, specifically BTP 400-11,

" Continuing Training / Retraining Request," was referenced in the q current BTP 100-16 and BTP 100-22 procedures. Although the requirements of BTP 400-11 were covered by other procedures the possibility existed that a procedure required by reference could be deleted. A mechanism should exist to assure that all requirements addressed by a procedure have been met by other procedures prior to its deletion. This is considered an open item (454/87021-01(DRS); 455/87020-01(DRS)).

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(5) Summary There was a good feedback path between operations and trainin Personnel interviewed indicated that they were confident of their abilities and training, but did indicate that additional training on day-to-day administrative procedures would be helpful, b. Non-Licensed Personnel Training (41400)

The inspector reviewed operational events and interviewed plant personnel to evaluate the effectiveness of the training programs for non-licensed personne (1) Deviation Report Review Of approximately 250 deviation reports (DVR) reviewed, the inspector chose four events for detailed investigation:

Deviation Report Number Description 06-01-86-005 Limitorque Valve 1W0006B Grease Mixin IC Pressurizer Safety Valve Inoperabl Delayed Hourly Fire Watch Due to Lack of Proper Dosimetr Two Trains of Safety Related Component Cooling Inoperabl DVR 06-01-86-005, identified that the wrong type of grease was added to motor-operated valve (MOV) 1W0006B. It was discovered that a Calcium based grease had been added to the motor operator of valve IWOOO68, although previous analysis of the lubricant in this valve determined that it contained 100% Lithium based grease. Mixes of Calcium and Lithium based greases could lead to a degradation of lubrication first through hardening and then separating. The results of this lubrication degradation could result in possible operator failure due to lack of lubrication. The inspector's evaluation of the event disclosed that a personnel error had been made in transferring information from the valve analysis to the work instructions. The corrective ,

actions for this DVR included identifying valves using Lithium i base grease with a label attached directly on the valve. Also, j during an interview with the supervisors of the maintenance i l

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mechanics and fuel handlers, the inspector was told that both groups had been made aware of the grease mixing possibilities-through weekly " Tailgate" training meeting DVR-06-01-86-130, involved the installation of an unrepaired pressurizer safety valve. . Prior to the event, two pressurizer safety' valves were removed due to excessive leakage past their

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' seats. The two valves and their associated Lift Indicating Switch Assemblies (LISA) were removed and moved to a common roped off area in the Hot Shop for repair and testing. Quality Assurance placed hold tags on both valves that referenced the LISA serial numbers only and provided no indication of valve serial. numbers. Later, during valve repair and testing, the-LISAs were removed from the valves and one was. repaired by:the valve vendor. When the fully repaired valve was bench tested, the succe;sful test was incorrectly and inadvertently documented on the test pack' age for the broken' valve. The defective safety valve was installed and because of its unrepaired condition, leaked profusely. The licensee's root cause evaluation was

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attributed to personnel errors from the Mechanical Maintenance (MM) technician,.the MM Supervisor and the Quality Control inspector, all who failed to verify that the serial numbers listed in test package matched those on the tested componen Also contributing to the verification difficulty were work conditions in the Hot Shop and the fact that both valves were '

stored in a common roped off area for an extended period of time (approximately ten months) following testing. The corrective actions for this event included department training discussing the importance of verifying that the equipment being worked on was really the equipment that had been identified in the work package. Also, secure storage cages were constructed to segregate defective parts and quality parts to preclude a similar even DVR 86-01-87-30, involved a 20 minute delay in c Technical Specification hourly fire watch due to personnel error in issuing personal dosimetry. This delay resulted in exceeding the Technical Specification Limiting Condition for Operation Action Requirements. The -inspector's evaluation of the event disclosed no apparent training deficiencies. The licensee's corrective action consisted of a memorandum issued to all Radiation Protection personnel emphasizing the importance of

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timely responses to the needs of firewatches due to Technical Specifications schedule requirement DVR 86-01-87-042, involved two trains of safety related Component Cooling being inoperable due to loss of water I inventory. The inspector's evaluation of the event disclosed that a contracted maintenance crew began work on a motor-operated valve that served as a point of isolation for work on the RHR Heat Exchanger, which required it to be drained of Component Cooling Water (CC). The maintenance crew stroked the valve

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l allowing ~CC water'to back flow to the heat exchanger and out- 1 the drain which caused the CC surge tank to reach the low level 1-CC-Pump Trip. The surge tank is common to both trains, !

. consequently, both trains of CC were inoperable. It was unclear whether the maintenance crew received authorization to stroke the valve. The licensee's corrective action consiste of. requiring the maintenance crew to obtain written authorization I prior to manipulating a valve for work repairs. Also, the LER (

which identified this event was distributed to station departments 1 to be disseminated to appropriate personne In'all of the above cases, .the training given as a resultL of the event was adequate to address.the event and prevent its recurrenc (2) Maintenance Training Safety and general plant information was given to maintenance personnel during weekly " Tailgate" meetings. A. typical

'" Tailgate" meeting may include items.on personnel and plant safety, departmental concerns, and radiological health and safety. Information stemming from past licensee events (Deviation Reports) and . lessons learned from personnel errors were also discussed. The attendance requirement at these

" Tailgate" meetings was mandator Each Maintenance Department had a' Training Coordinator (TC) to serve as a liaison between maintenance and the Training Department. 'The-TCs were considered to be qualified as on-the-job training (0JT) evaluators along with other selected evaluators (typically foremen) who met the same 0JT evaluator experience. The OJT program consisted of lesson plans and guides and was formally documented with the trainee performing lab and field work requiring an evaluator's signature for. steps performed. The TC also maintained a working copy of their department training matrix which provided the foremen easy access for selection of qualified mechanics for specific job Some of the maintenance training consisted of " mock-ups" of jobs performed in high radiation areas. This training familiarized mechanics with the skills and tools needed, thus reducing the time required to set up and perform a work request in a high radiation area. The maintenance personnel were required to attend 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> / year of training at the Byron training facilities. Training was also available and requested from vendor organizations with both management and maintenance personnel attendin ,

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-(3) Summary All the maintenance personnel. interviewed indicated the Training' Department was generally responsive to.their training

'needs. . Review of the DVRs demonstrated that:there was a goo feedback path from maintenance to the Training Departmen I Open. Items

.0 pen items'are matters which have been discussed with the licensee, whic will be reviewed further bytthe inspector, and which involve-some actio :on the'part offthe NRC or licensee or both. An open item disclosed during the inspection is discussed:in Paragraph.2.a(4).

4. . Exit' Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on May 28, 1987 to. discuss the scope and findings of.the inspection. The

licensee acknowledged the statements made by the inspectors with respect to. items discussed in the report. :The. inspectors'also discussed the likely informational content of the inspection. report with regard to ;

-documents.or processes reviewed by the. inspector ~during the inspectio The licensee'did.not identify any such document / processes as proprietar .

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