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Special Safety Insp Repts 50-254/86-19 & 50-265/86-20 on 861110-21.No Violations or Deviations Noted.Major Areas Inspected:Requalification Exam Results & Requalification Training Program Review.Significant Deficiencies Identified
	ML20207P231
Person / Time
Site:	Quad Cities
Issue date:	01/06/1987
From:	Burdick T, Clark F, Damon D, Hare S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20207P226	List: ML20207P225; ML20207P231;
References
	50-254-86-19, 50-265-86-20, NUDOCS 8701150269
	Download: ML20207P231 (9)
	v • d • e

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U.S. NUCLEAR REGULATORY C0t9tISSION

REGION III

Reports No. 50-254/86019(DRS);50-265/86020(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30

Licensee: Commonwealth Edison Company

P. O. Box 767

Chicago, IL 60690

Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2

Inspection At: Cordova, Illinois

Inspection Conducted: November 10-21, 1986

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S. Hare

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Inspectors:

Date

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D. Damon

Date

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F. Clark ~

Ifa~te'

Approved By:

K0

T. Burdick, Chief /'6'8)

Operator Licensing Section Date

l Inspec_ tion Sumary

Inspection on November 10-21, 1986_(Rep _ orts No. 50-254/8_6019(D_RSh

! No. 50-265

Areas Tnsp/86020(DRS))Special

ec ted_:

safety inspection by regional inspectors of the NRC

requalification exam results and requalification training program review (41701).

Results: No violations or deviations were identified, however, significant

l deficiencies were identified in the requalification training program. Subsequent

to a November 13, 1986 Management meeting (Paragraph 4) a meeting was held at

the Quad Cities station between NRC and Station Management on November 21, 1986

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i to discuss the problems identified in this report.

8701150269 870108

PDR ADOCK 05000254

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DETAILS

1.- P_ersons Contacted

CECO

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+ N. Kalivianakis, Division Vice President

+ R. Bax, Quad Cities Station Manager

+ R. Roby, Quad Cities Services Superintendent

+ C. Norton, Quad Cities Quality Assurance

- +J. Neal, Quad Cities Training Supervisor

R. Kelley, Quad Cities, Training Specialist

,

W. Graham, Quad Cities Training Specialist

+L. Gerner, Regulatory Assurance Support-

+R. Holyoak, Training Manater Production Department

+R. Klemm, Ph. D., PTC Program Development Administrator

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+D. Farrar, Nuclear Licensing

' +J. Marshall, Quality Assurance

+1. Johnson, Nuclear Licensing

+P. LeBlond, Nuclear Licensing

+R. Gaylord, GE Operator Training Services

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NRC

+1. N. Jackiw, Section Chief, Division of Reactor Projects

+M. P. Phillips, Operational Programs Section Chief

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+W. G. Guldemond, Chief, Projects Branch 2, Division of Reactor Projects

+T. M. Burdick, Operator Licensing Section Chief

- +C. W. Hehl, Chief, Operations Branch, . Division of Reactor Safety

! +C. E. Norelius, Director, Division of Reactor Projects

i .+ C. J. Paperiello, Director, Division of Reactor Safety

+N. J. Chrissotimos, Deputy Director, Division of Reactor Safety

+D. E. Hills, Operator Licensing Examiner

Denotes those attending the exit interview on November 12, 1986.

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+ Denotes those attending the Management Meeting in the Region III office

- on November 13,-1986.

Denotes those attending the exit interview on November 21, 1986.

2. Rev_iew of NRC Re, qualification Exam Results

Region III administered a requalification examination (written and ,

oral) to licensed Reactor and Senior Reactor Operator personnel at

Quad Cities the week of September 15, 1986. Due to the high initial ,

failure rate (63%) and NRC examiner standard (NUREG-1021) requirements,

additional examinations were scheduled and administered the week of

! October 13, 1986. The results of both sets of examinations are

sumarized below: :

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Total Passing

Category Administered Passed Failed Rate (1%)

SR0 13 7 6 53.8

R0 11 7 4 63.6

Total 7 T4 T6 E

The results of these examinations resulted in a determination by the

NRC that the Quad Cities requalification program was unsatisfactory

in accordance with the criteria identified in NUREG-1021. This NUREG

states a requalification program is unsatisfactory when less than 60

percent of evaluated operators pass all portions of the examination.

The licensee was informed of this unsatisfactory program determination by

telephone on November 7, 1986. During this telephone conference, the

licensee committed to certain interim actions and to meet with the NRC on

November 13, 1986, to discuss their plans for upgrading the Quad Cities

licensed operator requalification program. These cannitments were the

subject of a Confirmatory Action Letter (CAL-RIII-86-007) dated November 10,

i 1986, issued to Commonwealth Edison.

Simultaneous with the issuance of the CAL, regional inspectors were

dispatched to the Quad Cities station to perform a performance-based

requalification training inspection to determine the root cause of the

unsatisfactory requalification test results. This report documents the

findings from this inspection and summarizes the licensee's commitments

made during the November 13, 1986 Management Meeting.

3. L_icensed Reacto_r Opera _ tor,Requali_fication Program Review

Initial NRC review of the examination results identified, operator

knowledge in the following areas as weak:

Technical Specifications

Abnormal Procedures (Q0A)

Emergency Procedures (QGA)

Normal Procedures (QOP)

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In the November 13, 1986 ManagementMeeting(Section4),thelicensee

identified additional weaknesses in general procedure knowledge, reactor

theory and selected plant systems.

The inspectors performed interviews with station management, training

personnel and licensed operators to determine the root cause for these

weak areas. The inspectors found, as delineated in the following

paragraphs, deficiencies in all of the required requalification program

! areas as contained in 10 CFR 55, Appendix A.

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a. Schedule

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To satisfy the requirements of the licensee's requalification

training program, 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months of lecture training was performed

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(2 week period) once a year which culminated in the administration

of a "requalification exam." This does not appear to be in

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accordance with the.requiren'ents for a requalification program

training schedule. Specifically 10 CFR 55, Appendix A, requires

that lecture be performed on a regular and continuing basis

throughout the license period. The performance of 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months lecture,

once a year, while perhaps meeting the law, may not meet the intent

of the law. This potential disparity will be tracked as an

unresolved item (254/86019-01(0LS); 265/86020-01(0LS)) pending NRC

resolution. The licensee's new requalification training program

should satisfy this requirement. The licensee is implementing a

six shift rotation with their licensed personnel which will allow

for training each shift every fif th or sixth week. This will

enable them to perform training on a regular and continuing basis

and satisfy the requirements of the regulation.

b. Lecture

Formal classroom lectures are an integral part of any requalification

training program and are a requirement of 10 CFR 55, Appendix A. The

lectures should be performed on a regular and continuing basis

throughout the license period and include those areas where the annual

exams indicate a need for more coverage.

The licensee's fomal classroom lecture portion of the

requalification program occurred over a two week period in which 64

hours were spent in lecture. Exceptions were noted however, where

classroom time was as little as three days and as much as three

weeks in one year. For all exceptions identified, the lecture time

exceeded the 80 hour9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months in two year requirement of their program. The

inspector's felt the 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months requalification classroom training,

in light of the NRC requalification exam results, was insufficient

to adequately cover the required information. This was conveyed to

the responsible individuals in the training department in addition

to station management at the exit interview. The licensee concurred

with the inspectors and outlined their plan to increase

requalification lecture time from eight to 22 days per year.

e

One area from the NRC requalification exam results which was

identified as being deficient was procedure knowledge and

comprehension, particularly in the Emergency (QGA), Abnormal

(Q0A) and Normal (QOP) procedures. The inspectors determined that,

although, some procedures were covered in training, they were

generally not covered during formal lecture periods and were

addressed primarily by inclusion in required reading (see

Paragraph 3.c). An exception to this was the Emergency procedures.

The licensee had held initial fomal training on the Emergency

procedures when they were written and introduced in late 1985.

The subject of fonnal procedure training was discussed with

instructors and licensed individuals during the interview process.

The general consensus of those interviewed was that procedures

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could not be taught and attempting to do so would be non productive

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and a waste of time. Because of the pervasive opinion that

procedures cannot be taught, the inspectors noted to the licensee

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that the quality of the procedure training that has been performed

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to date may have been inadequate. During the November 13, 1986,

Management Meeting the licensee explicitly addressed training on

procedures during classroom lecture and during simulator sessions

and stated that more emphasis would be placed on procedural

training in their revised requalification training program.

Technical Specification knowledge was also an identified deficiency

from the NRC administered requalification exans. Further review

revealed that a significant portion of licensee training on

Technical Specifications was through the required reading process

and that this process was deficient (see Paragraph 3.c). Only the

sections of Technical Specifications that readily lend themselves

to review of a system or component oriented basis were covered in

a formal classroom environment. Additionally, the inspector noted

that the licensee examination content (see Paragraph 3.d) in the

area of Technical Specifications was weak. The inspectors informed

the licensee of these identified deficiencies. The licensee's

corrective action plan should resolve these identified deficiencies.

c. On_ _the-Job-Training

The requalification training program in large part relies upon

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on-the-job training to ensure the operators maintain familiarity

and understanding of the plant control systems, design changes and

abnormal and emergency procedures.

The regulation requires a minimum number of plant manipulations

during normal, abnormal and emergency situation every year. The

licensee satisfied these requirements by having their licensed

staff participate in simulator training every year. Due to problems

identified during the NRC requalification audit with the practical

use of abnormal and emergency procedures, the inspector's reviewed

the simulator training program.

Through interviews with personnel, a review of the simulator training

program, and NRC requalification test results the following problems

with simulator training were noted:

(1) Training was limited in scope because of time limitations on

the simulator which limited casualty drill training.

(2) Simulator was not plant specific.

The simulator training program consisted of an annual three day

training session at the General Electric " Morris Simulator" for

each group going through requalification training. The three days

were divided into six hours of classroom and 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months " hands on"

simulator time, the majority of which was spent going through the

required manipulatior.s. The inspectors and the licensee were in

agreement that simulator training time must be increased to improve

operator's skills, specifically in the use of Emergency Procedures

(QGAS). The licensee is increasing simulator training time from

three to five days which should help overcome some of the difficulties

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associated with using a non-plant specific simulator and increase the

number and scope of casualty drills to better familiarize the operators

with the use of abnormal and emergency procedures.

The licensee depended in large part on the required reading program

as a requalification training tool. Several problems were identified

with the program as follows:

1. Inadequate / questionable documentation of required reading.

2. No monitoring of the effectiveness of the required reading

program was performed (i.e., testing, audit, etc.).

In several cases, the inspectors identified improper documentation

of individual required reading. These situations involved

individuals making a single entry to record completion of all

reading assignments for the entire year which consisted of 103

various procedures and Technical Specification changes. Individuals

are required to make separate entries for each item of required

reading that is completed throughout the year. These instances of

improper documentation are not consistent with the significant

emphasis the licensee places on the required reading process.

The primary problem with required reading, the resolution of

which could go far in addressing the above documentation problem,

is that the program did not contain a means of monitoring the

effectiveness of the required reading process. The licensee needs

to monitor the required reading process, be it by examination,

quizzes or audit and address the method of monitoring in their new

requalification training program,

d. Evaluation Process Review

The accepted evaluation method for operator knowledge and the

effectiveness of a requalification training program is the annual

examination. An annual examination is required by 10 CFR Part 55,

Appendix A, and should be designed to determine areas where

retraining is needed to upgrade operator knowledge. While the

licensee did administer yearly examinations, they did not appear to

completely meet this requirement. During the review, the inspectors

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identified the following deficiencies:

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(1) Examinations were administered imediately after the eight day

training session.

(2) Examination security may have been compromised.

(3) Questions on the Quad requalification exams were not

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comprehensive and were narrow in scope.

(4) Poor quality control of answer keys and the grading of

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examination.

The annual written examinations were administered after the annual

eight day training session. The examination in effect, was deter-

mining how well the students were absorbing the material presented

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to them in class. It was not detennining which areas the operators .

were weak and needed retraining as required by 10 CFR Part 55,

i Appendix A. While the licensee did perfonn statistical analysis on

4 the test results to determine weak areas, the effectiveness of

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their statistical analysis was hampered severely by the inherent

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weaknesses within the program as described below.

Through personnel interviews and review of training records, the

- inspectors determined that examination questions may have been

compromised after the first examination was administered in 1986.

Specifically, the licensee " exam bank" consisted of three

examinations, A, B and C. Examinations A and B were distinct

exams and exam C was a combination of A and B (iA +1B). Because

the first exam administered in 1986 for the Senior Reactor

Operators was the C exam, which was generated from exam A and B, '

l, examination security may have been compromised immediately. Since

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there was affectively only two distinct exams and ten exams were

administered, each exam was administered approximately five times

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over the 1986 calendar year.

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The potential problems created when exam question integrity is

challenged is serious and has the following ramifications:

(1) The instructors could " teach the exam" either consciously

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or. unconsciously.

(2) The students could know what to learn, disregarding other

y material.

While these examples are extreme, and the probability of it

happening is strongly discounted by the licensee, the practice of r

repeatedly administering identical examinations is not acceptable

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to the NRC.

The Quad Cities requalification exam questions were reviewed by

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the inspectors and compared with NRC generated requalification

questions. The inspectors found in areas that the Quad Cities

generated questions in some areas were not as comprehensive and

were narrower in scope. The questions did not require answers

+

that demonstrated in-depth operator knowledge and understanding

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of the subject area. The licensee should review their

examinations in the future to ensure the comprehensiveness of

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their exams.

1 The inspectors reviewed the answer keys for the Quad Cities -

requalification examinations and found disparities in answers on

different answer keys for identical questions on different exams.

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Other answers on the answer keys were not completely correct or

lacked the complete depth required.

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In addition several completed examinations were brought back to the

regional office for regrading. While a review was perfomed on only

a few because of time limitations, disparities in grading were found.

The general impression from the NRC regrading, was that the Quad

grading was at times lax, resulting in complete credit for answers

that weren't completely correct. The regrading resulted in generally

five to ten less percentage points (out of 100 ) per examination.

Due to these apparent deficiencies in the quality control of the

examination answer key and the grading of the examination, the

licensee's attention to quality control in these areas should be

improved.

e. Records Requirements Review

_

The inspectors reviewed a large number of records associated with

the documentation of operator participation in the Quad requalifica-

tion program. In general records were complete and participation

was well documented. However, numerous examples were found where

student attendance records were not well documented.

(e.g.,no

instructor signatures, no subject matter delineation). Licensee

attention in this area should be increased to ensure training is

adequately documented, especially since a new requalification

program is being developed.

f. Summary

The inspector's identified weaknesses in all required areas of the

licensee's requalification training program. These weaknesses,

which may have contributed to the observed perfomance on the NRC

administered requalification exam were due in large part to;

insufficient time spent in fomal classroom instruction, use of a

non-plant specific simulator only three days a year, problems with

licensee examination content, preparation, and administration, and

the poor monitoring of the required reading process.

The licensee's corrective action plan for the improvement of their

requalification program, part of which is delineated in Section 4 of

this report, should place emphasis on these identified weaknesses.

The effectiveness of the licensee's corrective action will be

monitored by Region III Operator Licensing personnel through their

periodic administration of requalification examinations.

4. Manageme_nt_ Me_e_t_ing_ Commi tments

The following commitments were made by the licensee for their

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Requalification Training Program in the November 13, 1986 Management

Meeting held at Region III:

a. Implement an accelerated requalification program for all Quad Cities

Station licensed R0's and SR0's who have not either passed one of

the recent NRC administered requalification exams or passed an NRC

license exam since October 1, 1985. This accelerated requalification

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program will at a minimum consist of four weeks of intensified

training addressing the following topic areas.

QGA-(EOP) Theory and Usage

Selected Normal Procedures (QAP, QOP, QRP)

General Integrated Procedures (QGP)

Technical Specifications and Bases

Selected Abnormal Procedures (Q0A)

Reactor Theory and Thermodynamics

Selected Plant Systems

The above accelerated requalification training will be evaluated

for effectiveness by' a ' written examination and oral walk-through

on the QGA's (E0P's).

Additionally, the accelerated program will be expanded to include

a simulator training portion if simulator time can be procured.

Implement a long term requalification improvement plan with the

beginning of the next requalification cycle that includes as a

minimum the following:

Increase Training Staff fonn 16 to 23.

Lengthen Requalification Classroom Training from 8 to 22 Days / Year.

Lengthen Requalification Simulator Training from 3 to 5 Days / Year.

Modify Training to Increase Depth of Procedure Knowledge.

Upgrade QGA (EOP) Training and Procedure with Flow Charts and

Increased Practical Application.

For additional information, pleap reference Confirmatory Action

Letter CAL-RIII-86 007, Amendment I where this information and

other commitments regarding control room staffing is contained.

At the conclusion of the licensee's review of their Requalification

Training Program, the licensee should review and update their

Requalification Training Program Topical Report and submit the

updated report for NP.C approval.

5. Exit Interview

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

throughout the inspection period and at the November 12, 1986 exit

interview, the November 13 Management Meeting in the Region III office

and at the conclusion of the inspection on November 21, 1986. The

inspector informed the licensee of the likely informational content

of the report to the licensee. The licensee did not identify any

documents / processes documented in the report as proprietary.

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ML20207P231

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