BVY-91-049, Submits Corrective Actions Related to Unsatisfactory Performance of Licensed Operator Requalification Program,Per 910225 Exams.Root Cause Analysis Summary Encl

Submits Corrective Actions Related to Unsatisfactory Performance of Licensed Operator Requalification Program,Per 910225 Exams.Root Cause Analysis Summary Encl

ML20073J077
Person / Time
Site:	Vermont Yankee
Issue date:	04/30/1991
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-91-049, BVY-91-49, NUDOCS 9105080029
Download: ML20073J077 (9)

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VERMO'NT YANKEB NUCl EAR POWER CORPORATION N rerry naad. Brameboro, vT os30 woo 2 ENombb orncr

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) w,umuw lG'ON,n MTo m s. e n April 30,1991 U.S. Nuclear Regulatory Commission Washington, D.C. 205$5 Attention: Document Control

References:

a) License No. DPR 28 (Docket No. 50 271) b) Letter, USNRC to VYNPC, Examination Report No. 50 271/91-01 (OL), dated 3/21/91 c) Letter, USNRC to VYNPC (CAL No. 91007), dated 3/11/91 d) Letter, VYNPC to USNRC (BVY 9125), dated 3/8/91 e) Letter, VYNPC to USNRC (BVY 9127), dated 3/8/91

! f) NUREG 0654, dated November 1980

Attachment:

" Root Cause Analysis Summary"

Subject:

Corrective Actions Related to Unsatisfactory Performance of I

Licensed Operator Requallfication Program Durin0 the week of February 25, 1991 the NRC conducted lleensed l oaerator roqualification examinations at Vermont Yankee. Based on the results i o those examinations, the Vermont Yankee Licensed Operator Requalification

(LOR) Program was determined to be unsatisfactory. Vermont Yankee then

Initiated, per Reference d), a number of corrective actions including an in depth root cause analysis of the unsatisfactory examination results. Those actions were later acknowledged via NRC Confirmatory Action Letter No.91-007 [ Reference c)). This letter provides a confirmation of completion of those actions as well as the- results of our root cause analysis.

Based on the root cause analysis discussed above, it is our determination that the root cause of the unsatisfactory performance of the LOR program was the failure by management to maintain awareness of NRC examination criteria, i

to fully comprehend the increased emphasis placed on command and control

' functions in the conduct of operations, and to translate that emphasis into directives for the operating crews. We have determined that sufficient l Information regarding the NRC criteria existed, tat did not receive an appropriate l level of review and disposition. A more con:prehensive discussion of our l findings and conclusions, as well as a corrective action schedule, are included l In the attached " Root Cause Analysis Summary".

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VERMONT YANKEC NUCLC AR POWER CORPORATION U.S. Nuclear Regulatory Commission April 30,1991 Page 2 in addition to performance of the root cause analysis, Vermont Yankoo committed to development of training for all licensed operators covering lessons learned from the 1991 LOR examination relative to command and control functions and shift supervision communications. We have completed classroom training on these top cs and have also reinforced that training by conducting crow exercises in the simulator for all licensod personnel.

Vermont Yankoo has also further evaluated the dutlos of the on shift and confirmed by Refotonco communicator that were We havo concluded thatdiscussed In Referenco d)dulles should include making the communicator's c)itial in NRC and state notifications and maintaining those commutlications, but should not include data collection responsibilities. The communicator will continue to be an individual who is in addition to those requirod to moet the minimum operating shift com alomont (2 Senior Reactor Operators, 2 Reactor Operators, and the Shift Eng neor) and will be capablo of responding to tho l Control Room within ten m nutes of being summoned during abnormal and emergoney conditions. Non omorgency notifications may be made by members

of the operating shift complomont. We conclude that this division of dutlos l continues to be responsive to your concerns and is consistent with the guidanco l

contained in Reference f).

We are confident that the actions we have taken to dato, in addition to the further correctivo actions discussed in Attachment a), will significantly improvo our LOR program and will provido a firm basis for recortification of the program.

If you have any questions or require additional information concerning our efforts, please do not hesitato to contact us.

Very truly yours, Vermont Yankee Nuclear Power Corporation

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Warron P. f urphy Senior Vice President,

[.erat ns cc: USNRC Regional Administrator, Roglon i USNRC Recideat inspector, VYNPS USNRC Project Managor, VYNPS

ROOT CAUSE ANALYSIS

SUMMARY

A. Root Cause The root cause of the unsatisfactory aerformance of the LOR program  !

was the fallure of management to mainLain awareness of changes in NRC .

examination criteria, to fully comprehend the increased emphasis placed l on command and control functions in the conduct of operations, and to i translate those concepts into directives for the operating crews.

Finding #1 Inadequate response to available industry Information, including Information Notice No. 90 54 and-various INPO and NUMARC publications.

This Information provides insight into the criteria the NRC is using during requallflcallon examinallons.

Corrective Actions

1. Following each industry meeting or workshop attended by the l Training Department Management or Staff a meeting summary will 4 be routed to all appropriate individuals. This summary will include an assessment of the impact the information presented may have on Vermont Yankee. These meeting summaries Will be considered for inclusion on the agenda of the 03erations Curriculum Committee for discussion at the next schedulec meeting. This practice will be implemented by June 1,1991.

2. Methods used for disseminating Industry information within the Operations and Training Departments will be reviewed and revised as necessary to assure appropriate and adequate disposition. For example, if the response to this information concludes that "no other action is required", an explanation as to why this is the case should be included. This review and any identifled revisions will be completed by June 1,1991.

3. The Operations Curriculum Committee will develop a method for tracking action items to ensure that all Items raised receive adequate attention and response. This item will be included in the agenda of the next meeting and implementation will be accomplished before October 1,1991.

4. The - Training Manager will participate. In the Operations Training Instructor meetings. These meetings will be held on a regular basis with an established agenda.

Finding #2 Lack of direction regarding requirements for administration of the LOR Program. Compounding this problem was the use of inexperienced Instructors in the position of LOR program administrator, and the lack of i

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an SRO from the Operations Department dedicated to the requallfication I examination preparation. l Corrective Actions

1. The Operations Training Supervisor has overaH responsibility for administration of the LOR program. When assigning day to day I coordination to a subordinate, the assignment should be made to an experienced instructor. This action will be addressed by July l 1, 1991. l

2. Training Department Management will develop written duties and responsibilities for the administration of the LOR program. These dulles and responsibilities will be available by July 1,1991.

3. The Training Department will develop training on the requirements of the Examiner Standard (NUREG 1021). This training will be 1 provided to all Instructors eligible to teach LOR, the Operations Supervisor, and the Assistant Operations Supervisor. This Training Plan will be ready coincident with the pre exam checklist (as discussed in corrective action 1 under Finding #6) such that  !

training can begin on October 1,1991, i

4. The Training Department will ensure aggressive resolution of Inspection findings. A <

presented to the Sr. plan Vicefor Implementing President, this action Operations will be by June 1, 1991.

5. The Training Department will develop a mechanism to ensure all the requirements of the NUREG, including requirements added by an future revisions are addressed within 60 days of any revision.y

6. An Individual training instructor will be assigned the responsibility for LOR exam preparation. This Individual will be an experienced instructor. Also, it is not necessary that the LOR program administrator be the individual responsible for exam preparation.  !

I This individual will be designated six (6) months prior to the scheduled exam date.

. - 7. During examination -cycles in which the Operations Training l Suaervisor will be a participant, an experienced Operations Instructor wil be assigned responsibility for LOR issues. This item will be included in the pre exam list, developed by corrective action 1 under Finding #6.

l 8. An SRO from the Operations staff will be designated 60 days prior to the NRC exam. This individual's primary responsibility will be exam support for the Training Department.

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Finding #3 Tralning Management failed to maintain accountability for the LOR Training Program.

Corrective Action

1. The Training Manager and Operations Superintendent will review the requirements and objectives of the LOR program. Following this review they will clearly define the responsibilities of the Operations and Training Departments in the LOR Program Description. The Senior Vice President. Operations, will review and approve the LOR Program Description including the description of those responsibilities. The revised LOR Program description will be presented to the Sr. Vice President, Operations by August 1, 1991 for approval.

Finding #4 As the result of the successful 1989 LOR examination, the management of the Training and Operations Departmonts were content with the preparation for the 1991 LOR examination.

Corrective Action

1. Annually, Training Department Management, with Operations Department input, will develop a set of formal goals and objec:lvos for the LOR program. It should also be recognized that the need for program change may occur in mid year, based on foodback from industry mootings and/or workshops, and such changes should be anticipated. The goals for the 1992 LOH program will be established by December 1,1991.

Finding #5 There was a lack of specifically assigned dullos and responsibilities for Control Room personnel with a corresponding lack of a standard crew communications policy.

Corrective Actions

1. The Operations Department developed a description of the duties and responsibilities of crew personnel following the 1991 exam. A clear and consistent crew communications policy will be developed and added to this document. This document will be reviewed and approved by Senior Management by the beginning of the third LOR cycle scheduled to begin August 6,1991,

2. The Operations Training Curriculum Committoo identified a follow item developed at the April 27, 1989 meeting. The recommendations from that meeting regarding the incorporation of 3

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Vermont Yankee management expectations during simulator evaluations in the areas of crew management and communications will be assigned and completed. This will be accomplished by the beginninn of the third LOR cycle scheduled to begin August 6,1911.

3. To'further promote improved command and control functions and to -

enhance crew communic'ations, the spare Shift Supervisor will Be required to observe and comment on simulator scenarios at least once per year during LOR training. The Senior Reactor Operator, Control Room Operator and Shift Engineer will be encouraged to observe simulator training scenarios. This practice will be implemented during the second LOR cycle scheduled to begin June 11,1991.

Finding #6.

Fallure to establish a dialogue with other plants that have recently been examined by the NRC prior to the NRC LOR examination at Vermont Yankee.

Corrective Actions

1. The Training Department will develop a pre ex6m chocklist for use in preparing for NRC exams to ensure all required items are accompilshed in a timely manner. This checklist will include the requirement to call some recently examined plants, including plants that may have recently been determined unsatisfactory, if possible.

To ensure the checklists remain current, the list will be reviewed periodically. This review will- also be conducted following each revision of NUREG 1021. This checklist will be available by October 1,1991.

2. Training Department Management will consider sending Operations Training Instructors to visit other plants in the region to observe simulator training and review results of NRC administered LOR exams at other plants.

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B. Additional Crew Problems it was also determined that another factor contributed to the problems the crews experienced during the NRC LOR exams.

Finding #1 .

Insufficient training in the use of the latest revision of the Emergency Operating Procedures (EOPs).

Corrective Action

1. Annually, Training Department Management, with Operations Department input, will develop a set of formal goals and objectives for the LOR program. These goals will ensure an appropriate amount of time is devoted to EOP training. The adequacy of EOP training will be evaluated on a continuous basis, considering crew and instructor input.

2. Since EOP tralning forms the core of operators emergency response capabilities, their com alete understanding of these procedures is critical. To facilitate tils understanding, Operations will publish a revised basis document and incorporate it into licensed operator training concurrent with the approved revision to the EOPs.

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C. Secondary Causal Factors Some factors regarding the Interfaco betwoon the Vermont Yankoo staff and the NRC cxamination team may have contributod to the overall problem and definitely lod to some discord betwoon the Vermont Yankoo exam team and the .

NRC oxam team. l Finding #1 l

Poor quality examination pre aaration material was sont to the NRC for i their use during the preparat on for the exam.

Corrective Action

1. The chocklist discussed in the correctivo action number i for Item

! A. 6. should include specific requirements for the content and format i of the reference maiorla!s to be sont to the NRC during examination l pr6paration. The NRC should be contacted prior to each oxam to '

discuss their expectations regarding the content and format of refotonen material. This checklist will be available by October ,

1, 1991.

l l Finding #2 1

l A lack of knowledge regarding the rovisions to the Examiner Standard

! (NUREG 1021) In the area of Individual Simulator Critical Tasks (ISCTs).

Corrective Actions 1

1. The Training Department will develop training on the requirements of the Examinor Standard (NUREG 1021). This training will bo l provided to all Instructors eligible to teach LOR, the Operations Supervisor, and the Assistant Operations Supervisor. This training I will be completed by October 1,1991.

2. The Operations Training Supervisor and his staff will conduct a l

thorough review of all LOR training and examination material, with

! omphasis on simulator scenarlos, to ensure this matorial moots tho l existing NUREG regulromonts. This review will be completed by October 1,1991.

l l Finding #3 The defensive nature in which tho Vermont Yankee staff responded to tho I

changes the NRC desired during the exam and simulator scenario review I

process.

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Corrective Action

1. Tral'ning Department Management will standsrdize the method for interfacing with the NRC. Contact- with the NRC -will be the responsibility of the Operations Training Supervisor, or the designee during exams in which he is a candidate. This method will be established by July 1,1901.

- Finding #4 A-difference existed between Vermont Yankee and the NRC regarding the process for validation of simulator scenarlos. l

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Corrective Action

1. The Vermont Yankee simulator scenario validation procedure will be I' aresented to the NRC as part of the 60 day letter Vermont Yankee s required to send to NRC. The Intent of this approach is to seek NRC concurrence-with -our validation process well ;n advance of the .

examination date.

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