IR 05000461/1987023

Insp Rept 50-461/87-23 on 870629-0702.No Violations or Deviations Noted.Major Areas Inspected:Licensee Training Program Effectiveness for Licensed Operators & Nonlicensed Staff

ML20236B542
Person / Time
Site:	Clinton
Issue date:	07/21/1987
From:	Darrin Butler, Hasse R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236B521	List: IR 05000461/1987023 ML20236B518
References
50-461-87-23, NUDOCS 8707290142
Download: ML20236B542 (8)

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O. S. NUCLEAR REGULATORY COMiii1SION I

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REGION III

l Report No. 50-461/87023(DRS) l Docket No. 50-461 License No. NPF-55 l

Licensee: Illinois Power Company l 500 South 27th Street-Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois  !

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Inspection Conducted: June 29 through July 2, 1987 W ~7l /lfy

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Inspectors

R. YA. Hasse / .

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f.2 / $7 Date Approved By: M. P. Phillips, Chief 7/.2/Nf7 Operational Programs Section Date-Inspection Summary Inspection on June 29 through July 2, 1987 (Report No. 50-461/87023(DRS))

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

Results: In the areas inspected, no violations or deviations were Identified, i

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DETAILS l Persons Contacted i

• Illinois Power Company (IP)

W. C. Gerstner, Executive Vice President J. Greenwood, Manager, Power Supply (Soyland/WIPCo) i E. A. Till, Director, Nuclear Training j W. Connell, Manager, NSED J. G. Cook, Assistant Plant Manager  ;

j D. Z. Haltzshen, Director, Nuclear Safety i J. A. Miller, Manager, Scheduling and Outage Management

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K. A. Baker, Supervisor, I&E Interface USNRC P. L. Hiland, Senior Resident Inspector Other personnel were contacted as a matter of routine during the inspectio All licensee personnel listed attended the exit interview held on July 2, 198 l Training Effectiveness l

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 Condition Reports (CRs) to i determine if inadequate training had contributed to the events described {

in the CRs, and if the lessons learned had been factored back into the !

training program. The inspectors also reviewed the methods by which the licensee factored industry information (e.g., SOERs, LERs) into the training progra !

This inspection was not designed to evaluate the licensee's overall training program. The Institute for Nuclear Power Operations (INPO)

currently performs this evaluation as part of its training program accreditation process. At the time of this inspection, none of the licensee's training programs had been submitted to INP0 for accreditation. The initial program submittals for (1) Reector Operator, (2) Senior Reactor Operator, (3) Non-licensed / Rad Waste Operator, and (4) Shift Technical Advisor were scheduled for July 1987. The initial l submittals for the remaining programs were scheduled for January 1988.

These programs were: (5) Controls and Instrumentation Technicians, (6) Mechanical Maintenance Personnel, (7) Electrical Maintenance Personnel, (8) Radiation Protection Personnel, (9) Chemistry Technician, and (10) Training for Technical Staff and Manager.

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a. Licensed Operator Training Event Review (41701)

The inspectors reviewed operational events and interviewed plant personnel to evaluate the effectiveness of training programs for licensed personne (1) Condition Report Review Of approximately 22 condition reports reviewed, the inspector chose two reports for further review as listed below:

• CR 1-87-01-040 Auto Transfer of HPCS Suction

• CR 1-86-02-158 Acid Addition to Turbine Sump Condition Report 1-87-01-040 dealt with the unnoticed auto-transfer of HPCS suction to the suppression pool from a spurious RCIC storage tank low level. The tank low level annunicator was received on January 8,1987. This event was complicated by HPCS having been declared inoperable due to the  !

Division 3 Diesel Generator being inoperable. HPCS was armed in its Standby Condition at the time of the even In l

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addition, there had been a shift change and the analog trip  !

module (EE-N654, which caused the auto-suction transfer) for RCIC Storage Tank level was providing spurious low reading During subsequent investigation of the tank low level, operators failed to notice the HPCS suction transfe The suction transfer was foJnd on January 9, 1987 during an operator's review of CPS 1401.01F002, " Shift Turnover and Relief-Status Report." Night orders were issued to counsel operators on attentiveness on watch. In addition, Senior IP management were currently monitoring the number of lit annunicators in the control room. Operation's Department was further determining if additional corrective action was necessary for operations personnel. Review of this event with operations personnel indicated they were cognizant of this event and the issuance of the night order was effective in detailing their obligation to fully investigate the impact '

of alarming annunciator l Condition Report 1-86-02-153 dealt with the neutralization of the Unit 1 Chemical Waste Tank with the normal acid and caustic injection systems out of servic Acid was directed into the ,

Turbine Building sump without realizing the sump had an oil  !

separator on its inle The oil and acid reacted and created l fumes in the separator for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. This was l not the typical method used to neutralize the Chemical Waste Tank. Original operator and radwaste training did not address this method of acid addition. This event heavily involved l operations and radwaste (non-licensed) personne Plant staff l responded (in the area'of training) by requesting formal  ;

training for operations and radwaste personnel. Operations j

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personnel were briefed on the lessons learned from this event and operations cyclic training periods 86.2, 86.3, and 8 covered the Radwaste Building Sump and Drain in Lesson Plan 33035. Radwaste supervision.provided guidance and training on the conduct of operations for radwaste personne Training on the neutralization process and on the properties of acids and caustics were in process at the time of this inspection. Review of this event with operations, radwaste, and training department personnel indicated they were cognizant of this even (2) In all of the above cases, the inspectors determined that the training given was adequate to address the event and prevent its recurrenc b. Licensed Operator Training The inspector reviewed the licensee's process for incorporating Lessons Learned from past events and changes to the plant were into the training progra The licensee's Training Department was reviewing procedures, .

condition reports, LERs, INPO SOERs, and NRC correspondences for the j incorporation of lessons learned into the classroom training subject matte Plant modifications were reviewed by the Training Departmen The Plant Modification Coordinator distributed minor modification packages (<$10,000) to the Nuclear Training Department -(NTD) according to CPS Procedure 1003.01, " Design Control and Modification." The Plant Modification Coordir.ator had the responsibility to ensure that the NTD provided a training impact assessmen The assessment included: an analysis for training that was required prior to release, not required or deferred; and if the training was needed to support field installation and testin Major modification packages (>$10,000)

were controlled by NSED Procedure K.0, " Modification Control." The NTD received the package from NSED and reviewed it for simulator and training impact. The impact assessment was sent to NSED for inclusion with the modification packag The inspectors reviewed how the licensee disseminated information to on-shift licensed personnel. The Operations Department controlled and issued the Required Reading Packages (RRP). Materials included in the RRP were recent procedure revisions, CPS policy memorandums, NRC correspondences, INP0 SOERs, experience reports, and reportable occurrences. The RRPs were issued to individual shifts and sent to i the NTD for the hot license class to review. Night orders were generated, distributed, and reviewed in accordance with Plant Operations Standing Order D050-00 They are short term instructions from operations management to the operating shift. The operators would initial in the shift log their review of the night order during shift turnove I i

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'The insraectors reviewed the licensee's implementation of 10 CFR 55.59(c)(3)(1). The licensed operator requalification program was meeting the associated reactivity and control manipulation requirements. Review of the licensee's training records' indicated they were completing the manipulations required on an annual basis and those specified on a two year cycle within l their specified interva The licensee provided the following statistics regarding licensee administered exam results for their operators:

Licensee Type Year Number of Exams Given % Passed R0 1985 12 75 SR0 1985 32 84 i

R0 1986 6 83 ;

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SRO 1986 20 60 j

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l R0 1987 18 78 i

SR0 1987 41 95 l l Summary l

l All the operations personnel interviewed indicated that they felt the NTD was providing adequate training. A feedback path was l l

evident between operations and training as indicated in the l

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condition report review. Operation's supervision was aware of their opportunity to request formal training and to input suggestions for revision of the training progra Non-Licensed Personnel Training (41400)

The inspector reviewed CRs, training records, and interviewed maintenance and training supervisory personnel to determine the effectiveness of the training programs for non-licensed personnel.

l (1) Condition Report Review l

l The inspector reviewed a listing of all CRs issued over the l

last two year Twenty CRs were selected for individual review. Three of these were evaluated with respect to training program impact. These were:

l * CR 1-86-05-052 MOV limit switch rotor set to close

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• CR 1-86-05-006 Failure to follow maintenance work i release (MWR) job step ) l

• CR 1-86-05-055 Removal of a TIP drive cover without a /

Radiation Work Permi i Condition Report 1-86-05-052 identified a miss-set MOV limit i switch rotor which caused the valve to trip out on overloa A j review of the procedure used to set the rotor determined that it was j adequate if the procedure was, in fact, followe The j procedure step used to set the rotor was also a QC witness ]

point which had been signed off at the time the rotor se The i root cause of this event appeared to be failure to specifically follow the procedure and lack of attention to detail rather than a training program weakness. However, as a result of this event and other MOV problems, a comprehensive " lessons learned" training program was prepared and given to all personnel {

involved in MOV testin I Condition Report 1-86-05-006 described the failure of a '

contract maintenance craftsman to follow the job steps as presented in the MWR. The job steps directed the craftsman to i troubleshoot a sticking mechanical operated cell switch on a !

i breaker and report the results to Maintenance Engineering ]

(ME). The craftsman actually repaired the sticking switch l rather than report the cause to ME. This bypassed the j ME approval and QA review of the repair effort. Subsequent J review of the repair effort by IPQA determined that it had been 1 properly performed. A review of the craftsman training records determined that he had been trained on the IP MWR procedures

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and should have been aware that he was not to perform work 3

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outside the scope of the MWR. The craftsman was counseled in ]

writing concerning the need to comply with the MWR job step J Condition Report 1-86-05-055 documented an event involving the i removal of a TIP drive cover without the required Radiation i

Work Permit (RWP), personnel dosimetry, or approval of the Shift Supervisor to commence work on the MW The event ;

involved startup personnel, Nuclear Steam Supplier (NSS)  !

personnel, and IP C&I personnel. The root cause of the event was determined to be an inadequate review of the MWR leading to the failure to indicate that an RWP would be required although ,

the startup and NSS personnel involved were aware that an RWP

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had been required to install the TIP detectors (which contain special nuclear materials). A critique held by the licensee following the event failed to identify any training program deficiencies with the possible exception of the requirement to notify the SS prior to starting work on an MWR involving equipment released to startup rather than plant staf The TIP had been released to startup. As part of the corrective action for this CR, additional training was given to all maintenance and startup personnel on the following topics:

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• Contacting the SS prior to starting work on'all MWR j

• Wearing of dosim'etr * Actions to'be taken when radioactive material identification tags are observed on equipmen * Proper review of MWRs for RWP requirement I

• Actions required when working on equipment containing .i special nuclear materia '

After reviewing the three CRs in depth and a more cursory review of 17 others,- the inspector concluded that there was no indication of training program deficiencies._ Further,.

" lessons learned" type training was being'provided as part

! of the corrective action in response to events when appropriate.

l Discussions with Training Department personnel determined that that department does -review all CRs- (as well as: LERs and industry -information).for. inclusion in the . formal training ,

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t While. reviewing the CR listing the inspector noted what .

appeared to be a high incidence of craftsmen working through QC l hold points. Discussions with IPQA. determined that this had _I been identified via a CR trending program and a Management-Action Item (MAI) issued on the subject. The inspector  !

reviewed the evaluation and closure of'the MAI. The cause of t

! the. problem involved the means for identifying and documenting- (

l completion of the hold points rather than inadequate trainin i While this trend did not involve training' deficiencies,:the l inspector gained a degree of confidence'that should generic d training weaknesses result in events documented in CRs, the CR trending program would identify this fac l '

(2) Non-Licensed Personnel' Training The inspector focused on the training for maintenance _ l personnel. Training requirements were documented in the form

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of matrices for each job classificatio Several levels.of matrices might be used: A matrix for generic training  ;

requirements (training generally provided by the Trainin Department) and a matrix for job. specific training such as j specific surveillance procedures (training provided by the '

Training Department of'the Maintenance Department involved).

The matrices were maintained by the Maintenance Department  ;

supervisor A sample of completed training _ requirements was taken from the matrices and compared to the training records., The inspector  :

was able.to verify that the the training had been receive i

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• • i Training history for cach individual was being computerize i Hard copy records supporting the computer data consisted of class attendance records, graded examinations, and other records as appropriat )

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A review of CRs revealed no training program deficiencie i Should such deficiencies develop, the CR trending program 1 appeared capable of detecting the fact. Two mechanisms, existed )

for CR feedback into the training program: (1) Specific corrective action for a given CR; (2) Training Department i review of all CRs for applicability to the training program l (lessons learned).

3. Exit Interview  !

The inspectors met with licensee representatives (denoted in Paragraph 1) ,

on June 2,1987 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 i 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 l

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