ML20236Q448

Safety Insp Repts 50-254/87-29 & 50-265/87-29 on 871019-21. No Violations or Deviations Noted.Major Areas Inspected: Implementation of Conditions of 861114 Amend 1 to Confirmatory Action Ltr CAL-RIII-86-07

ML20236Q448
Person / Time
Site:	Quad Cities
Issue date:	11/04/1987
From:	Hasse R, Hopkins J, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236Q439	List: ML20236Q437 ML20236Q448
References
50-254-87-29, 50-265-87-29, CAL-RIII-86-07, CAL-RIII-86-7, NUDOCS 8711200041
Download: ML20236Q448 (10)

See also: IR 05000254/1987029

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U. Si NUCLEAR REGULATORY COMMISSION

' REGION III-

' Reports No. 50-254/87029(DRS);No.50-265/87029(DRS)

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

Licensee:- Commonwealth Edison Company

P. 0. Box 767

Chicago, IL 60690

JFacility Name: ' Quad Cities l Nuclear' Power Station, Units 1 and 2.

Inspection At: Cordova,: Illinois

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Inspection Conducted: October 19-21,'1987

. Inspectors: R. A. Hasse

h yh/f7.

Date

J. A. Hopkins "h//7

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Approved By: M. P. Phillips, Chief //[f/M '

Operational Programs Section Date

Inspection Summary-

Inspection on October 19-21, 1987 (Reports No. 50-254/87029(DRS);

No. 50-265/87029(DRS))

Areas Inspected: Special~ announced safety inspection to determine if the

conditions of the Confirmatory Action Letter (CAL) CAL-RIII-86-007,

Amendment 1,. dated November 14, 1986, has been properly implemented and to

- followup on previous NRC inspection findings in this area.

Results: No violations or deviations were identified.

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-DETAILS.

p ~ 1. - Persons Contacted

l Commonwealth Edison Company (Ceco)

• R. Bax, Station; Manager

• R. Robey, Services Superintendent

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• R. Hopkins, Quality Assurance Engineer. ,

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M. Kooi, Regulatory Assurance Supervisor

'*J. Neal, Training Supervisor

M.' Miller, Quality Assurance Inspector- q

-*M. Rodts, Training Instructor i

'U.S. NRC 1

-A. Morrongiello, Resident Inspector

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Other personnel were. contacted as a matter of routine during the j

inspection.

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• Denotes those attending. exit interview'on October 21, 1987. l

2. Followup on previous l'nspection Findings

(Closed): Unresolved Item (254/86019-01; 265/86020-01): Conducting j

Licensed 0perator requalification lectures during one two week period

"each year rather than continuously throughout the license period.

. Region III (RIII) requested an interpretation from the Office of Nuclear

Reactor Regulation (NRR).to clarify the intent of 10 CFR 55 concerning

requalification lectures that were administered in " blocks." In a j

memorandum to RIII dated August 13, 1987, NRR explained that " block" j

lecture training for requalification programs was acceptable if the 1

-program content was based on an evaluation of performance on written

examinations, facility' operating experience, and personnel performance.

Further, the memorandum stated that a requalification program which is

accredited and based on a Systematic Approach to Training (SAT) may elect

to continue " block" lecture training.

.The licensee's current requalification lecture training cycle consists

of six sessions.of four days scheduled throughout the calendar year.

The inspectors believe that this schedule meets the intent of

.10 CFR 55.59(c)(2) which requires preplanned lectures on a regular and

continuing basis.

3. Licensed Operator Requalification

a. Purpose

The purpose of the inspection was to determine if the licensee had I

implemented the commitments documented in the Confirmatory Action

Letter (CAL) CAL-RIII-86-007,datedNovember 10, 1986, and Amendment 1 l

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of the CAL, dated November 14, 1986. The CAL was issued as a result

of the 58% failure rate on the NRC requalification examinations

administered during the weeks of September 15 and October 13, 1986.

The CAL detailed additional control room staffing requirements,

. removed those operators who failed the NRC requalification exam from

licensed duties, gave a brief outline of the short-term upgrade

program, and required the implementation of a long term improvement

plan beginning in the next requalification training cycle.

b. Inspection Results

(1) Part One of the CAL required that while in cold shutdown the

Quad Cities-Units 1 and 2 control room would be staffed with a

licensed Senior Reactor Operator (SRO) as an advisor who had

passed either the NRC administered requalification exam or had

passed a NRC license examination since October 1, 1985. The

inspectors determined through interviews and a review of

training records and shift log books how the licensee selected

candidates for the SRO advisor position. In order to meet

these restrictions the licensee conducted an audit of the

licensed operators' records to select a pool of. candidates.

The licensee wanted to keep a high level of experiense on-shift

and decided that since the SRO advisor would not be it a

decision making role, on-shift experience was not criti al. 1

The Shift Engineer (SE), while not necessarily meeting the i

restrictions outlined in the CAL, would provide this experience.

The Station Operating and Training Review Board then approved

the candidates and assigned them as shift advisors in Cold

Shutdown.

The licensee removed the SR0 advisors from shift as soon as

SR0s who had passed the accelerated requalification program and

had been returned to licensed duties became available to act as

SEs.

The inspectors judged these actions to be in compliance with

the CAL with no further action required. '

(2) Part Two of the CAL required that when in other than cold I

shutdown the Quad Cities Units 1 and 2 control room would be

staffed by a licensed SR0 and as a minimum, a licensed Reactor

Operator (RO) at the controls of each operating unit who met

the criteria of Part One of the CAL or had successfully

completed the short term upgrade program. The inspectors b

determined through interviews and a review of training records l

and shift log books how the licensee selected candidates for  !

the R0s at the controls of each unit. The licensee used the

process described above to select the SR0 advisors. The

licensee had adequate R0s routinely assigned to shift duties

who met the requirements of Part One of the CAL which obviated

the need to put inexperienced R0s on shift duty.

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The inspectors judged these actions to be in compliance with

the CAL with no further action required,

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(3) Part Three of the CAL required the licensee to remove from

licensed duties those R0s and SR0s who failed the NRC

administered requalification examination until such time,that.

those individuals successfully completed the accelerated upgrade

training program. The inspectors determined through a review of i

training records and shift log books that the licensed operators

were taken off-shift and successfully completed the upgrade

program. Ten licensed operators (four R0s and six SR0s)

failed the NRC requalification exams administered during the

weeks of September 15 and October 13, 1986. Those ten licensed

operators were removed from licensed duties and placed in the

Short-Term Operator Training Upgrade Program. Two of the

licensed operators had successfully completed the upgrade

training program by the end of December 1986, one completed the

program in January 1987, two completed the program in March 1987,

and five surrendered their NRC licenses. With the exception of

the SR0 discussed below, all licensed operators who successfully

completed the upgrade training, were returned to licensed duties

upon completion of the program.

One SRO who failed the NRC administered requalification exam j

was placed on-shift as a Shift Foreman (SF), his normal i

position, prior to successfully completing the accelerated

upgrade training program. The SF is required by Technical

Specification to hold a SR0 license but does not routinely 4

direct the licensed activities of a licensed operator. j

However, the SF assumes the duties of the SE if the SE is i

incapacitated. '

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The SRO in question failed both the written exam and operating

test administered by the NRC. Significant concerns from the

operating test were the SR0's unsatisfactory ability to direct

plant operations in a casualty while acting as the SE and his i

failure to utilize Emergency Procedures. [

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The SR0 was placed in the first session of the accelerated

requalification program and passed the written exam but failed

the simulator operating test on December 19, 1986. The

simulator operating evaluation stated that his performance as

SE was not satisfactory. The SRO did not properly respond to

or investigate changing plant conditions, his communication and

supervisory abilities were unsatisfactory, and he failed to

refer to procedures when required. These were the same basic

reasons for his failure of the NRC requalification exam. I

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The licensee's Station Operation and Training Review Board 4

evaluated the SRO's performance to determine if he should be 4

returned to licensed duties. The Review Board determined that a

the SRO's excellent past record in the control room made him

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acceptable to perform licensed duties until additional training

could be provided. The Review Board also'noted that he is not ,

assigned the duties of SE. The SRO was returned to, shift

n . duties. as a SF on January 14,.1987. The SRO successfully

completed the simulator training _ on January 23, 1987.

The conclusions reached by the' Review Board did not fully

consider.the reasons for the SRO's failure of the NRC and

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' licensees' operating examinations in terms of the SF's total- 1

. responsibilities' In both cases the SRO failed to satisfactorily

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direct plant operations in'a casualty while acting as SE. The 1

. Review Boards recommendation to return the SRO to licensed

duties in view of the fact that he is not assigned SE duties,

apparently did'not consider the fact that-the SF- automatically -

succeeds the SE in the event of the SE's incapacitation. .While

the~ SRO. performing the duties of SF did not violate-the

requirements:of the. CAL, the licensee created a situation where

this could have occurred. It appears that the Review Board's

evaluation was superficial by applying past control room

experience'for a position that did not perform licensed duties

as justification to allowed the SRO to be returned to licensed

duties.

The inspectors judged these actions to be in compliance with

the CAL. With the exception of a thorough licensee review of.

this concern, no further action is required.

(4) Part Fo'ur of the CAL required the licensee to implement an

-accelerated requalification program for all licensed operators

who had not passed one of the recent NRC administered

requalification exams or passed a NRC license exam since

October 1, 1985. The inspectors determined through a review

of training records, interviews, lesson plan reviews, and

simulator scenarios, that the licensee had implemented the

accelerated requalification program. The program consisted of

three weeks of classroom training and one week of simulator

training with the program's major emphasis in the following I

areas:

E0P Theory and Usage (QGA)

Selected Normal Procedures (QAP, QOP, QRP)

General Integrated Procedures (QGP)

Technical Specifications (T.S.) and Bases

Selected Abnormal Procedures (QOA)

Reactor Theory and Thermodynamics

Selected Plant Systems

The licensee used three weeks of classroom lectures to address

some of the areas of major emphasis in the upgrade program.

Below is a list of the topics covered in the lecture series:

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Week One

Thermodynamics Review

Reactor Theory Review

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Selected Plant Systems and Procedure Synopsis

Weekly Quiz

Week Two

Selected Plant Systems and Procedure Synopsis

Weekly Quiz

Week Three

Technical Specifications

Selected Abnormal Procedures (Q0A)

E0P Theory and Usage (QGA)

General Integrated Procedures (QGP)

Selected Administration Procedures (QAP)

Radiation Protection (QRP)

Weekly Quiz

The fourth week of the accelerated requalification program was

simulator training. This training was conducted using the

Dresden Station simulator, which is not Quad Cities plant

specific. The simulator training consisted of two hours of

classroom lecture and six hour simulator sessions for three days

followed by a four to six hour evaluation on the fourth day.

The control room crew in the simulator consisted of two SR0s

(a SE and a Shift Technical Advisor (STA)) and two R0s (a reactor

operator, and an extra Nuclear Station Operator (NS0)). Each

simulator session typically consisted of four different

scenarios. Below is a list of the scenarios used during the

upgrade program:

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Day One

Classroom

Introduction to Problem Solving Algorithms

Introduction to E0P Flowcharts

Preview of scenarios

Simulator

System Familiarization /Small Leak in Drywell

Plant Startup (with malfunctions)

Loss of Offsite Power / Plant Shutdown (with malfunctions)

Plant Casualty Response familiarization (observation only)

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Classroom

Simulator session critique

Interrelating Flowcharts and Procedures

Preview of scenarios

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High Conductivity

Steam Cooling

Loss of both Control Rod Drive (CRD) Pumps /ATWS (with ,

malfunctions)

Loss of Normal and Emergency Feedwater (with malfunctions)

Turbine Trip /ATWS -

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Day Three

Classroom

Simulator session critique

Interrelating Flowcharts and Procedures

Preview of scenarios

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Simulator

Large LOCA (with malfunctions)

Spray Cooling (with malfunctions)

MSIV Closure /ATWS (with malfunctions)

ATWS Requiring Emergency Depressurization

Day Four '

The fourth day of simulator training was a four to six hour i

evaluation of the licensed operators. The evaluation was l

performed by independent General Electric (GE) instructors from I'

the Dresden Simulator Training Center. The licensed operators

were evaluated in nine categories:

Control Board Awareness

Event Diagnosis

Immediate Actions ,

Subsequent Actions '

Console Manipulations j

Use of Procedures / Reference Data /T.S. .

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Communications

Supervisory Ability i

Team Work j

Each licensed operator evaluation was reviewed by the Dresden

Station management and categorized in one of two ways:

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'(1) ' Released to full licensed duties.

(ii) Removal from licensed duties until all training

recommendations are complete.

The licensee has 64 licensed operators (R0s and SR0s). Three

of the SR0s are Fuel Handling Foremen with' limited license and

were exempt from the upgrade program. .All licensed operators

had successfully. completed the upgrade program.

The inspectors judged these actions to be in compliance with

the-CAL'with no further action required.

-(5):'Part Five of the CAL required the licensee to implement a long.

term requalification program improvement plan at.the beginning

of the next requalification training cycle. The inspectors

determined through interviews, a review of training records,

and a review'of the 1987 and 1988 training schedules that the

improvement program was adequate. The five point program to

enhance the requalification program is' outlined in the

following paragraphs:

(a) Increase Training Staff-from 16 to 23.

The licensee has hired three maintenance and two operations

instructors to increase the Training Department staffing I

to 21. The licensee plans to extend employment offers to '

one operations and one technical instructor by December 1987.

3. (b) Lengthen Requalification Classroom Training from eight to

22 days.

The licensee has expanded the classroom training to

six sessions of four days in each requalification cycle.

The program, which. coincides with the calendar year,

schedules the first four sessions consecutively followed

by a ten week break for vacations, simulator training,

" walk-through" oral exams, and any required remedial

training. The final two sessions are followed by a

six week period for record review by the Training

Department.

The Requalification Training program operates on'a two year

cycle with a review day and an annual written exam

administered during the fourth session. Each week consists

of a review of the previous week's quiz, lectures on j

selected systems and procedures, theory review, and a

weekly quiz.

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(c) Lengthen Requalification Simulator Training from three to I

five days.

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The licensee completed five days of simulator training

during the 1987 requalification cycle. The simulator q

training consisted of two hours in the classroom and ]

six hoprs on .the simulator during each session. The

ulations outlined in

simulator.

Attachmentsessions

A of Cecoincluded the manigRequalification

Topical Report

Program for Licensed Operators, Senior Operators, and

Senior Operators (Limited), " February 10, 1987, recent

' industry related events, areas identified as weak in

previous exam evaluations, and suggestions from.the

simulator training staff.

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The 1988 simulator training is scheduled for two '!

four day sessions.

! (d) Modify Training to Increase Depth of Procedure Knowledge.

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increase the depth of procedure knowledge as outlined

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(1) Incorporate procedure synopsis in all systems 1

training.

(ii) Review Emergency Procedures (QEPs) with GESP training

twice each year.

(iii) Conduct E0P (QGA) classroom exercises to familiarize q

the operators with using the E0Ps and Flow Charts.

(iv) Schedule the Procedural required reading to coincide

with the systems taught in requalification training.

(e) Upgrade E0P-(QGA) Training and _ Procedures with Flow Charts j-

and Increased Practical Applications.

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The licensee developed a pilot program to familiarize the i

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operators with the E0Ps and Flow Charts. The program

consisted of an oral " walk-through" of casualty scenarios

to place the plant in a safe condition with emphasis placed

on entry conditions of various QGA procedure blocks, the

basis of principal steps within the QGAs, and guidance on

what parameters are important to observe.

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The licensee has incorporated this pilot program into

the requalification program as described above

(Paragraph 3.b(5)(d)).

The inspectors determined the above actions satisfied the

licensee's commitments identified in the CAL with no ,

further action required. l

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4. Exit Interview

I The inspectors held an exit interview with licensee representatives

(denoted in Paragraph 1) and summarized the purpose, scope, and findings

of the inspection. The licensee stated that the likely informational

content of the report would contain no proprietary information.

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