IR 05000352/1990001
| ML20042E377 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/06/1990 |
| From: | Conte R, Florek D, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042E360 | List: |
| References | |
| 50-352-90-01OL, 50-353-90-01OL, NUDOCS 9004200697 | |
| Download: ML20042E377 (20) | |
Text
January 29, 1990
SUBJECT:
Limerick Generating Station, Units 1 and 2
'
Licensed Operator Requalification Training Program Justification for Continued Operation'
'
Dear Sir:
,
.
'
This letter is intended to document our assessment of the adequacy of the i
Licensed Operator Requalification' Program and serves as our Justification for Continued Operation.
The assessment was conducted as a result of four_of 13
,
licensed operators failing the NRC monitored requalification exams _ conducted at
the Limerick Generating Station (LGS) Training Center during the week of January
,
29, 1990 through February 2, 1990.
<
.
We have concluded that the Program ensures that licensed personnel currently
.
on shift are properly trained and qualified to operate the plant safely and in i
accordance with their licenses.
This conclusion is based upon the following.
(1) 21 regularly assigned shift licensed operators have'been examined in
-
the first three weeks of the current six week _ cycle; three of the 21 shift operators have failed, and in each instance that failure was only the written portion of the examination.
All shift operators tested have successfully completed the job performance measures and. simulator portions of the examination, thus demonstrating competency in actual
,
operations.
(2) All shift licensed operators failing any portion of the' examination have been removed from licensed operator duties until such time as they have successfully completed required remedial study and re-examination.
(3)
The two staff licensed operators who failed the examination will not be
permitted to perform licensed duties.
Concurrently, we are reviewing, as a part of an ongoing process, the need to renew these licenses.
(4)
All failures during this current examination cycle have been based upon Philadelphia Electric Company's evaluations and these evaluations appear to be in agreement with NRC observations.
,
'
t i
,- ~
.
....
-
. -
.
.,,+
-.
.
.
-
-
. _ _.
.. _ _
- - - - ___.
',..
>
,.
W. T. Russell fcbruary 7,1990 Page 2 of 3'
(5) The Licensed Operator Requalification Program has recently been extensively reviewed and reaccredited by the National Academy for Nuclear Training.
Our preliminary assessment of the proximate cause for the failures which occurred during the examinations conducted during the week of January 29, 1990, is as follows. The proximate cause for two of the three failures in the written
,
portion of the examination is our inadequate time validation of the test, coupled with the candidates' inability to use reference materials efficiently.
The third failure and one of the previously mentioned failures were related to a
.
'
weakness in diagnosing static simulator type problems. Our preliminary assessment of the staff licensee failures in the simulator portion of the exam is their failure to properly focus on key parameters during major transients.
The additional failures by one of the staff licensees.in the job performance measures and written portions of the exam is still under review.
"
A more-extensive and detailed root cause for the failure rate in this NRC monitored exam will be conducted by our Training Section staff.
We will submit the results of this root cause assessment along with identified corrective
,
actions when the analysis is completed. We expect to complete this assessment by March 9,1990, and will submit the results soon after this date.
As a result of our initial evaluation of the examination series conducted during the week of January 29, 1990, no " Deficiencies" were identified. A
" Deficiency" is defined as an area in which more-than 50% of the candidates fail the test question and the que'stion is one of major safety significance.
However, our evaluation did identify areas of " Major" and " Minor Weaknesses."
As a result of these weaknesses. LGS management commits to the following
~
corrective actions.
All licensed operators will receive a minimum of four hours of.
.
!
simulator training in those areas identified as " Major Weaknesses" by March 15, 1990.
One crew has already completed this training. A
" Major Weakness" is defined as an area in which more than 30% of the candidates fail a test question, or demonstrate unsatisfactory or
'
questionable perfonnance in a simulator assessment (the latter is a more subjective assessment).
All weaknesses identified in the exam report analysis will be reviewed
.
with license holders by May 18, 1990; Major weaknesses - (1st requalification training cycle)
February 26, 1990 - April 6, 1990, and Minor weaknesses - (2nd requalification training cycle)
April 9, 1990 - May 18, 1990.
A " Minor Weakness" is defined as an area in which more than 20 % of the candidates fail a test question or demonstrate unsatisfactory or questionable performance in a simulator assessment (the latter is a more subjective assessment).
,
Operations management's training observation forms will be revised to
.
specifically list the areas of identified weakness to insure focused
'
observations in subsequent training cycles. This action will be completed by February 26, 1990.
.
.
-
~
.
..
'W. T. Russell
+
February 7,4 1990-Page 3 of 3
. All observation foms filled out by management personnel, plus those
.
provided by instructors during training cycles, will be formed into a i
composite report at the end of each training cycle to highlight.
concerns and to assess the effectiveness of corrective actions for management review and action.
The areas of identified weakness will be included, in'accordance with j
.
present practice, int.o the "Connon Student Errors" section of simulator-training scenarios.
.
!
We will provide the special. Teamwork Training Program to all licensed
.
'
operators, as previously requested from the Institute of Nuclear Power.
Operations (INP0), during the fourth quarter of 1990.
If INP0 is:
unable to meet this schedule, an in-house program will be developed to address this. issue.
The T-200 Series of Emergency Operating Procedures will be upgraded as-
.
follows.
.
a)
Attach supplemental documentation to selected procedures that will help the operators locate equipment in panels.
This action will be completed by February 16, 1990.
b)
Perfom'a human factors review of all.T-200 Procedures and.
I revise them accordingly with appropriate operator aids-
.
'
installed in the plant by May 15,.1990.
A list of Shift Operator crew schedules and a list of the schedule of.
.
requalifying exams for the remaining three weeks has been provided to-the NRC Region I as requested.
!
In conclusion, we have detemined that the overall program for Operator training is sound.
We will, however, vigorously implement the corrective.
actions noted above to ensure that the weaknesses observed will not degrade the
,
!
high quality of licensed operator perfomance that has been characteristic of our operating crews.
.
'
Very tr y y lrs, i
tl
?
cc: US Huclear Regulatory Comission Attn: Document Control Desk T. J. Kenny, USNRC Senior Resident Inspector, LGS
.
- n,,
A T TACH MEN T 5 c.
,
-/
o UNITED STATES -
..
'
g
[
S NUCLEAR REGULATORY COMMISSION N
'
REGION I
'
f['
475 ALLENDALE ROAD
-
KING OF PRUSSIA, PENNSYLVANIA 164o6 F[g 91990 Docket Nos.
50-352 and 50-353 CAL No.:
I-90-003 Philadelphia Electric Company ATTN:
Mr. C. A. McNeill, Jr.
Executive Vice President Nuclear Correspondence Control Oesk
P.0 Box 7520
,
Philadelphia, PA 19101
,
Gentlemen:
Subject: CONFIRMATORY ACTION LETTER (CAL) 1-90-003 UNSATISFACTORY LICENSED OPERATOR REQUALIFICATION TRAINING PROGRAM The purpose of this letter is to confirm our understanding of those actions which you have taken or will take to ensure that deficiencies / weaknesses in your licensed operator requalification program are promptly corrected : and that adequate proficiency of licensed operators is. maintained at the Limerick Generating Station (LGS) Units 1 and 2.
These problems were identified as a result of licensed operator requalification examinations-administered by Region I during the week of January 29 through February 2, 1990, in which five of 14
,
individuals failed the examination.
Based on these results, the NRC has deter-mined that the Limerick Station Requalification Program is unsatisfactory, t
The examination deficiencies / weaknesses were. discussed during an exit meeting held with the NRC Requalification examination team on February 2,1990, and i
with the Acting Regional Administrator during a management meeting on February
-
'
5, 1990.
Your Basis for Continued Operation was presented at that management meeting and was subsequently documented in your letter of February 7', 1990.
Your Basis for Continued Operation is acceptable pending administration and review of additional NRC Requalification Examinations.
These additional exami-nations will be conducted during the weeks of February 12, 1990, and February 19, 1990.
Based upon the commitments contained in your February 7,1990 letter, it is l
our understanding that you have or will:
L 1.
Remove from licensed duties those individual licensed operators who L
failed or who fail an NRC administered Requalification Examination l
during the weeks of February 5,12, and 19,1990, t
2.
Not allow individuals, including members of the crew determined to be unsatisfactory, failing any portion of an NRC Requalification Examination to resume licensed duties before successfully passing an NRC administered Requalification Examination. This applies during the period that the NRC l
deems the Limerick Station Licensed Operator Requalification Program unsatisfactory.
!
l l
l
!
~ ' ' '~
r4
,
.
.,
,
.
.
.
,
Philadelphia Electric Company
P
k
' 3.'
Identity problems and root causes as to why the requalification program was unsatisfactory.
This analysis will identify a corrective action
+
program with a schedule of milestones.
Submit the root cause analysis with proposed corrective actions to Regioh I-in accordance with your l
1etter of February 7,1990.
The Limerick Station Licensed Operator Requa1'1fication Program shall be
- deemed to be unsatisfactory until further correspondence from NRC changes:
.
that status.
Issuance of the Confirmatory Action Letter does not preclude the issuance of
'
an Order formalizing the above commitments.
If your understanding _dif fers
..
from that set forth above, please call me immediately. The responses directed
,
by the'1etter are not subject to the clearance procedures'of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, PL 86-S11.
Thank you for your cooperation.
Sincerely,
.
William T. Russell Regional Administrator
.
CC:
R. J. Lees, Chairman, Nuclear Review Board G. M. Leitch, Vice President - Limerick' Generating Station D. R. Helwig, Vice President - Nuclear Services
J. Kowalski, Vice President - Nuclear Engineering -
.
J. W. Durham, Sr., Vice President and General Council
,
M. J. McCormick, Jr., Manager - Limerick Generating Station G. A. Hunger, Jr., Director - Licensing Section J Doering, Project Manager - Limerick Generating Station J. F. O'Rourke, Manager - Limerick Quality Division i
T. B. Conner, Jr., Esquire
>
G. J. Madsen, Regulatory Engineer - Limerick Generating Station Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania
bec:
Region I Docket Room (with concurrences)
J. Taylor, EDO
,
-
.