IR 05000457/1987040

Insp Repts 50-457/87-40 & 50-457/87-38 on 871026-30.No Violations Noted.Major Areas Inspected:Effectiveness of Licensee Training Program for Licensed Operators & Nonlicensed Staff

ML20236U389
Person / Time
Site:	Braidwood
Issue date:	11/23/1987
From:	Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236U201	List: IR 05000456/1987040 IR 05000457/1987040
References
50-456-87-40, 50-457-87-38, NUDOCS 8712030002
Download: ML20236U389 (11)

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U.-S. NUCLEAR REGULATORY COMMISSION

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REGION III:

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Reports No.~50-456/87040; 50-457/87038(DRS)

' Docket Nos. 50-456; 50-457 Licenses No. NPF-72; CPPR-133

Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL .60690 .

Facility Name: Braidwood Station,. Units 1 and 2

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Inspection At: .Braidwood Site, Braidwood, Illinois  !

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Inspection'Conductedi October 26-30, 1987 Inspector: R.' S, Love -///A3 9 g, - Date Approved By: Mo te P. P llips, Chief // /23/F7 Operational Programs Section Date

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Inspection Summary Inspection on October 26-30, 1987 (Report Nos. 50-456/87040; 50-457/87038(DRS))- j 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 i I

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8712030002 DR 871125 ADOCK 05000456 PDR I

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-DETAILS 1. - Persons' Contacted Commonwealth Edison Company (CECO) .j

• E.'Fitzpatrick, Station. Manage '*G. A. Schieber1, Maintenance. Training Group Leader i

• S. Houston, Lead Instructor,-. Licensed Operator Requalification E. McGee, Training Supervisor '

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• * E. O'Brien, Services Superinten'dent

• E.'Paquette, Assistant Superintendent Maintenance

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• W. Raney, Supervisor, On-Site Nuclear Safety

• Nelson, Projects Supervisor, Technical Staff

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W. Simkins, Regulatory Assurance, Operating Group

• D. Kyrovac, Quality Assurance Superintendent a

• Takaki, Regulatory Assurance j

• L.- M. Kline, Regulatory Assurance G. Vanderheyden, Licensed Operator Group Leader R. C. Bedford, Regulatory Assurance 1 W. . Shear, Non-Licensed Operator Group Leader F. Brinker, Operations Department Training Coordinator  ;

P. Barnes, Regulatory Assurance Supervisor l M. Hoffman, Instructor (PTC)

D. Burton, Instructor (PTC)'

M. Lindeman, Instructor (PTC) )

R. Plante, Instructor-in-Training (PTC)  :

T. Chasensky, Classroom Supervisor (PTC)

D. Selph, Simulator Supervisor .(PTC) 1'

J. Harris, Operation Administrator (PTC)

R. Wright, Maintenance Training Manager (PTC)

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W. Chandler, Instructor (PTC) j C. Jensen, Instructor (PTC)

R. Koncar, Instructor (PTC)

M. Olson, Instructor (PTC)

J. Hamilton, Instructor (PTC) .

R. Kolo, Instructor (PTC) I The inspector also contacted and interviewed other licensee personnel during the inspectio * Denotes those present at.the exit interview on October 30, 198 . Training The objective of this inspection was to evaluate. the effectiveness of the licensee's training program for licensed operators, non-licensed

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operators, maintenance personnel, and management, and whether the training (c_lassroom and on-the-job) received-before.an event / occurrence was adequate to have either prevented the. occurrence or mitigated its affects. The inspector also evaluated whether lessons learned from-

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operating events were factored into the training program. The licensee's 4 training program is evaluated by the Institute for Nuclear Power Operations l (INP0) as part of their training program accreditation proces At the time of this inspection, INP0 had performed their site inspection with accreditation expected in December 1987 for the following training programs at Braidwood Station: (1) Senior Reactor Operator (SRO); (2)

Reactor Operator (RO); (3) Non-Licensed Operator (NLO); and (4) Shift 1 Technical Advisor / Station Control Room Engineer (SCRE). The remaining i training programs are scheduled for self-evaluation and submittal to '

INP0 in March 1988. These training programs are: (1) Instrument an Control Technician (IM); (2) Electrical Maintenance Technician (EM); (3) .

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Mechanical Maintenance Technician (MM); (4) Radiation Protection Technician; (5) Chemistry Technician; and (6) Technical Staff and Manager l

The objectives of the inspection were accomplished by: reviewin i applicable training procedures, 63 Licensee Event Reports (LERs)g , i personnel qualification records; observing classroom shop, and simulator j

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training; and interviewing licensed operators, non-licensed personnel, I

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and instructor l Licensed Operator Training  ;

(1) Review of Procedures BwTP 600-9, Revision 0, Operations and Training Review Board j BwTP 600-10, Revision 1, Licensed Operator Initial '

Training Program BwTP 600-17, Revision 2, Training Program Evaluation l BwTP 600-26, Revision 3, Training Feedback Program )

BwTP 600-41, Revision 0, SCRE Training Program BwTP 600-3, Revision 3, Training Records BwTP 600-4, Revision 4, Licensed Operator Requalification Program BwTP 600-19, Revision 4, Personnel Qualification Review BwTP 600-6T15, Revision 3, Licensed Operator Requalification Checklist BwTP 600-6T18, Revision 1, R0/SR0 License Holder Annual Review BwTP 600-6T19, Revision 2, Training Feedback For During a review of the above procedures / forms, it was noted that the Licensed Operator Requalification Checklist requires an annual written examination and an annual plant evolution on loss of condenser vacuum, while 10 CFR 55.59 only requires this event / evolution to be performed biennially. In that loss of condenser vacuum is not an uncommon occurance, Braidwood management directed this evolution to be performed annuall Based on several factors, it was also decided to require an annual written test. No violation or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ g

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(2) Review of LERs Of the 63 LERs. reviewed (100% of the LERs prepared by Braidwood),. J

.the inspector selected the below listed reports for further J

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(a) LER 87041 addressed Technical.' Specification Surveillance (Axial Flux Difference (AFD) Monitor Alarm Inoperable Surveillance) that were not performed when the Unit 1 computer was inoperable. At various times (five) on

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August 6, 7, and 8, 1987, the Unit 1 computer'was inoperable, causing the AFD Monitor Alarm to be

' inoperabl This requires an operating surveillance to  ;

be. performed hourly.for the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the alarm '

has been returned to operable status. The root cause of y the event was a' programmatic deficiency in that licensed personnel.were not trained to recognize that th surveillance'was required. The Production Training Center (PTC) recognized this potential problem in April 1987. At that time, lesson plans were updated and this supplemental training was provided to all new licensed operator trainees. Before the previously licensed-operators could be retrained during their requalification -l training, the event described above occurred. ~ The daily or.ders alerted all licensed operating-shift personnel of the Technical Specification surveillance requirements for the AFD Monitor after .the Unit 1 Computer is returned to operability following failure or rebootin (b) LER 87040 addressed missed surveillance tests that i demonstrate operability of remaining AC sources of )

electrical power when Emergency Diesel Generator No. 1B was taken out-of-service to troubleshoot load oscillation The Limiting Condition for Operation (LC0) requires these  ;

surveillance tests be performed within the first hour- '

after an Emergency Diesel Generator (D/G) is taken out-of- i service and every eight hours thereafter. During this one outage of the D/G, the operating crews were late twice in performing the surveillance tests. In the first instance, the SCRE failed to assign personnel the task of. performing the required surveillance in a timely fashion. In the second occurrence,'the cause was an incorrectly calculated completion time by the-Licensed Nuclear Station Operator and the Non-Licensed Equipment Operator (i.e., not allowing ,

sufficient time to' complete the test). This resulted in '

the surveillance test being completed nine minutes lat A. ' personnel involved with the late surveillance wer cot.nseled on the requirements for _ operating' Braidwood Station in accordance with the Technical Specifications which are part of the facility operating licens In addition, Operating Department management has directed

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surveillance be performed in a more timely fashion to t

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allow corrective actions to.be completed prior to the' i expiration'of the time requirements. Also, the H surveillance coversheet.was revised to allow. identification of critical' times for surveillance with a frequency of. less than 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (c) LER 87023 is:the' result of an effective " Lessons Learned Program." At approximately 3:00 a.m. on April 18,-1987, d Mr. L. Guthrie, Shift. Engineer, was' reviewing LERs fro Byro'n Station as part of Braidwood Station's Lessons Learned Program. During his review, Mr. Guthrie noted ;

'that -in one instance Byron shift personnel had incorrectly permitted valve' packir.g adjustments to two containment ,

' isolation valves without first' evaluating the-effects of i packing adjustments.on stroke times and entering the LC0 action statement as appropriate. Based on this information, Mr.'Guthrie recognized the potential for a similar situation.at Braidwood. Mr. . Guthrie then reviewe ;

the work packages' awaiting post-maintenance testing an ;

L identified four containment isolation valves as having had their packings adjusted without the proper LC0 entrie Mr..Guthrie immediately entered the appropriate LC0 actio statement for these valves. Mr. Guthrie then initiated a review of. active Nuclear Work Requests (NWR) to identify similar situation None were foun Mr. Guthrie is to be commended for his diligence and i dedication to dut i Station management initiated an immediate review of NWRs pertaining to containment isolation valves that were ;

completed since February 15, 1987, the date Unit 1 first l entered Mode 4. This corresponds to the time when i containment isolation valve operability was first. required at Braidwood. From this review,-two additional valves were identified as having had packing adjustments made without entering the applicable LC0 action statemen ;i

.The root cause of this event is. attributed.to a programmatic flaw in the processing of NWR packages prior to authorizing the commencement of work. Station procedures requires all out-of-service (005) requests to be reviewed by the SCRE for impact on Technical Specification compliance. Valve packing adjustments do not;normally require an 00S request and-therefore, a review by the SCRE is not mandated. .To prevent recurrence, the.0perating Department Daily Orders: informed all' shifts of the event and provided interim guidance for handling i NWRs not associated with 00S requests. Standing Order 011'

was issued by the Operating Department to provide permanent guidance for handling NWRs not associated with l OSS request l 5 .

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(d) During a review of Braidwood's Lessons Learned Program, it was noted that all LERs/DIRs (Deviation Investigation Report) for Braidwood and Byron Stations are reviewed by -

the Training Department (PTC) for incorporation into the training program. In addition, the LERs are included in the required reading fil In many instances, based on Management decision, a written examination on-the required reading material is given to the operating crew (3) Training and Requalification During this inspection, the inspector reviewed the training requirements for initial training and for requalificatio The R0 and SR0 candidates received the same initial training. This initial training consisted of: .

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Nine weeks - High Voltage Switching Training Ten weeks Fundamentals Training j Ten weeks - Systems Training 1 Seven weeks - Simulator Training Twelve weeks - On-The-Job Training Five~ weeks - Simulator Training ,

One day - Nuclear-General Employee Training (N-GET) with j an annual refresher i For 1987, the requalification consisted of five cycles and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on the simulator. An additional training session was conducted to define the differences between Unit 1 and Unit 2 in preparation for the NRC administered Unit 2 operating tes !

The Braidwood licensed operator requalification program started January 1987. During this inspection, the inspector monitored initial R0/SR0 classroom training, initial simulator training, final simulator training prior to NRC licensing examination, and reviewed 13 of 63 hcensed operators' training records. These record packages contained a history of training received, cycle quizzes, annual requalification examination (if taken), quiz / test key, and a record of the required reactivity manipulations (annual and biennial). No deficiencies were identified. During R0/SR0 personnel interviews, the only area of concern was that in 1987, simulator time was limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During interviews of training management, the inspector was informed that simulator training is scheduled to i be increased to 60+ hours in 198 ,

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The licensee is presently giving the first requalification examinations at Braidwood. As of October 30, 1987, 18 licensed operators from Crews A and B have been tested with all operators obtaining a minimum of 80% in each area. Crew F operators (7)

were being tested on October 30, 1987. In addition, the NRC administrated a Unit 2 operating test to four R0s and eight

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SR0s during the week of September 14, 1987. All 12 operators passed the test.

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

BwTP 600-7, Revision 3, Non-Licensed Operator Initial Training Program BwTP 600-8, Revision 2, Non-Licensed Operator B Level l Initial Training Program '

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BwTP 600-23, Revision 3, Non-Licensed Operator Continuing Training i Several procedures reviewed under licensed operator l training are also applicable under this sectio (2) Review of LERs

During the review of LERs and DIRs, the inspector did not l observe any event that reflected on the training of Non-Licensed Operators (NLO).

(3) Training i During this inspection, the inspector reviewed the training I requirements for Non-Licensed Operators (NL0s). During the l inspection, no NLO specific training was in progress. The NLO l initial training consisted of:  ;

One week - New Employee Orientation Program I Five weeks - Generic Equipment Attendant Twenty-eight weeks - Site Specific Training Classroom Plant Familiarization 1 On-The-Job Training (0JT)

Walkdowns Fire Brigade l Mid-Term and Final Exams  ;

One week - Radwaste/ Fluid Systems

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Two weeks - Radwaste/ Fluid Systems - OJT

One week - Radwaste/ Fluid Systems Final Walkdown Five weeks - High Voltage Switching - Classroom Two weeks - High Voltage Switching - 0JT

One week - Board of Review on High Voltage Switching One day - N-GET with annual refresher During the inspection, the inspector reviewed ten of 78 NL0s training records. These record packages contained a history of training received, quiz / test, and quiz / test key. No deficiencies were identified.

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c. Maintenance Personnel Training

(1) _ Review of Procedures ]

e During the inspection, the inspector reviewed procedure 1

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'BwTP 600-38, Revision 0, " Maintenance Training Program" and I several ' Instrumentation Procedures. - During a review of training- J

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and instrumentation procedures, it was observed that little or.

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no distinction was made between " Notes," " Cautions," and .

" Warnings" in that all three are-boxed with asterisks in i accordance with Administrative Procedure BwAP 1300-2A ]

However, human factors. considerations,'and. technical writing'

guidance suggests that visible differentiation should be made -

between Cautions / Warnings and Note NUREG-0899, " Guidelines #

for the Preparation of Emergency Operating Procedures," provides

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guidance in the use of these three statements. Braidwood has used NUREG-0899 in the preparation of Emergency Operating' d Procedures and for. consistency, these guidelines should be s

applied to all other types of procedure i l

During the Exit Irterview on October 30, 1987, the' inspector expressed a concern to senior management with the way NOTES are emphasized and the use.of CAUTIONS and WARNINGS in- 1 procedures. The licensee. stated that CECO would take the-inspector's concern under consideratio (2) Review of LERs During the inspection,' the inspector identified the following LER that resulted from a lack of training of maintenance personne LER 87025 describes the inadvertent opening of'a Main Steam Isolation Valve (MSIV) during. maintenance activities due to )

procedural errors. A maintenance crew was scheduled to repair a hydraulic leak on a MSIV. The crew was accompanied by a valve manufacturer representative and had an approved work package (procedure with appropriate sign-offs).in their possessio Because the Operating Department had blown down the MSIV_ accumulators, the crew erroneously believed that the

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entire hydraulic' system had been depressurized. An.l' inch- )

wire rope and a Come-a-Long were used'to maintain the valve in a closed position. When the crew loosened a: fitting on a solenoid valve, this created _a vent path for the pressurized:

hydraulic fluid trapped on top of the actuator piston. 'The ;

fluid sprayed the maintenance crew. The crew exited the area-

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and awaited medical attention. The Shift Foreman arrived on ,

the scene and made a superficial' inspection of the area, noting 8  :

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that the Come-a-Long was in position. The following morning, a maintenance crew entered.the area to complete the repair on the MSIV and observed that'the i inch wire rope had broken and ;

the MSIV was open. The MSIV was secured in the closed position by a specially fabricated hydraulic assembly and two 3/4 inch

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wire ropes with Come-a-Longs.

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Subsequent calculations performed by the licensee determined I that the i inch wire rope had a capacity of 8,000 pounds and i

the main steam pressure (1075 psig) exerted an opening force i of 17,000 pounds on the valve. The licensee also verified

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the adequacy of the two 3/4 inch wire ropes that were used I

to hold the MSIV closed.

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. Maintenance procedure was deficient in that it did not i provide any guidance for depressuriz'ation of the actuator ,

cylinder. prior to maintenance on the actuato !

The i inch wire rope was selected based on judgement rather than engineering calculatio There had been no specific training for the maintenance

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department in the last two years on the theory of operation of the MSIVs. This may have led to the erroneous belief that depressurizing the accumulators would depressurize the entire hydraulic syste Corrective actions included:

The maintenance procedure was revised to provide the proper guidance for depressurizing the MSIV actuator and proper wire rope sizing for blocking the MSIVs close This event was reviewed with all operating shifts and the Mechanical and Instrument Maintenance Department The Mechanical Maintenance Department was trained on the )

theory of operation of MSIV For personnel safety, the importance of protective eyewear was included in Station Quarterly Safety Meetings and in Station Safety Tailgate Session As applicable, Braidwood and Byron LERs and DIRs are factored into the training for SR0s, R0s, NLO, and maintenance personnel by the PTC.

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(3) Training l During the inspection, the inspector reviewed the requirements I for generic, initial, and specific training for Instrumentation and Control Maintenance Technicians (IM), Electrical Maintenance

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Technicians (EM), and Mechanical Maintenance Technicians (MM).

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and mms at the PTC and a shop class on Anchor-Darling valves that was conducted by an Anchor-Darling Representative at the Braidwood training facilities. The inspector selected six training record packages (2 IMs, 2 ems, and 2 mms) for revie Those records contained a history of training received, quiz / test, and quiz / test key. No deficiencies were identifie Management Training During the inspection, the inspector selected the top management positions that could affect reactor operations for a review of their training and qualifications. The management positions selected were Station Manager, Services Superintendent, Production Superintendent, Assistant Superintendent for Technical Services, Assistant Superintendent for Operations, Assistant Superintendent for Maintenance, and the Training Supervisor. Three of these positions are being filled with individuals that hold a current SR0 license at Braidwood. The other four individuals have held SR0 license at other facilities or have received SR0 training, but have not taken an NRC license examination. Training records indicate that management has been receiving periodic training (annual) in generic areas such as: (1) N-GET; (2) Out of Service Protection Program; (3) Generic Emergency Planning; and (4)

Hazardous Material Incident Reportin During interviews of training personnel, the inspector was informed that Management supports the training effort at Braidwood Station. Also, during interviews of management, they 4 were proud of the fact that all of the SR0s/R0s passed their Unit 2' operating test administered by the NRC and as of October-29,1987, all SR0s/R0s that had taken their annual written requalification examination had passe . Production Training Center (PTC)

The CECO Production Training Center is located approximately five miles from the Braidwood Station. This facility opened in late 1982 and houses the PTC staff, LaSalle and Byron /Braidwood simulators, twenty-four classrooms, several mechanical, electrical, and instrumentation laboratories, and a learning resource center. The PTC provides l . operational training (R0, SR0, and NLO) for LaSalle, Byron, and Braidwood Stations, and maintenance and technical training for CECO personnel assigned to fossil and nuclear generating station ,

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During the inspection, the inspector monitored classroom, laboratory, and  :

Byron /Braidwood if mulator training. It was noted that the instructor to student ratio wa's very good during laboratory and simulator trainin The instructors interviewed were very knowledgeable and communicated well with the student d /

a 4. Exit Interview The inspector met with the licensee representatives (denoted under )

Paragraph 1) at the conclusion of the inspection on October 30, 198 The inspector summarized the scope and findings of the inspection and also discussed the'likely informational content of the inspection report i with regard to documents or processes reviewed during the inspectio The licensee acknowledged this information and did not identify any such document or process as proprietar !

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