ML18066A202
| ML18066A202 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/17/1998 |
| From: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1021 50-255-98-04, 50-255-98-4, NUDOCS 9806230178 | |
| Download: ML18066A202 (5) | |
Text
Consumers Energy~
A CMS Energy Company June 17, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant 21180 Blue Star Memorial Highway Covert. Ml 49043 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Tel: 616164 2296 Fax: 616 164 2425 11loaus.I. fWnrluao Site Vice President REPLY TO NOTICE OF VIOLATION 50-255/98004 FAILURE TO ADMINISTER A COMPREHENSIVE LICENSED OPERATOR REQUALIFICATION WRITTEN EXAMINATION.
NRC Inspection Report 50-255/98004(DRS) dated May 18, 1998, cited one violation for the failure to administer a comprehensive licensed operator requalification written examination. The examination given did not satisfy all relevant guidance of NU REG 1021, lnterimRevision 8. The response to*the violation is included in Attachment 1.
The operators who were administered the examination remain fully qualified to perform their licensed operator duties. The requalification period for these operators expires in April 1999. Consumers Energy will test these operators using a comprehensive examination which is consistent with the guidance contained in NUREG 1021, Interim Revision 8, prior to the expiration of the requalification period.
Consumers Energy Company agrees with the violation as written.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
~
Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 9806230178 980617 PDR ADOCK 05000255 G
PDR.
ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/98004-01 FAILURE TO ADMINISTER A COMPREHENSIVE LICENSED OPERA TOR REQUALIFICATION WRITTEN EXAMINATION 3 Pages
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-255/98004-01 FAILURE TO ADMINISTER A COMPREHENSIVE LICENSED OPERA TOR REQUALIFICATION WRITTEN EXAMINATION NRC NOTICE OF VIOLATION During an NRG inspection conducted from March 25 through April 1, 1998, one violation of NRG requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 55. 54(i-1) requires that the facility licensee shall have in effect an operator requalification program which must as a minimum, meet the requirements of 55. 59(c).
10 CFR 55. 59(c) stated, in part, that in lieu of paragraphs (c) (2), (3), and (4) of this section, the Commission may approve a program developed by using a systems approach to training (SAT).
The NRG approved Palisades' SAT based licensed operator requalification training program which required the use of NU REG 1021, "Operator Licensing Examination Standards for Power Reactors," Section ES-602, "Requalification Written Examinations. " Section ES-602, Attachment 1 does not allow the use of direct look-up or memory knowledge level questions on open-reference examinations.
Contrary to the above, on January 21, 1998, and again on January 28, 1998, the licensee's annual licensed operator Category 8 written examination was constructed as follows: nine of the 23 questions were determined to be direct look-up questions, primarily because they required simple memory recall of the procedure in which to find the answer; ten of the 23 questions were considered simple knowledge level questions because they required simple recognition, or recall of facts or specifics, rather than demonstration of understanding by using the knowledge to address a problem. The administration of the Category 8 examination with 19 of 23 questions in a direct look-up or memory format failed to comply with the licensee's NRC approved SAT based licensed operator requalification training
- program requirements and resulted in administration of a non-,comprehensive
-written examination. * --~ *- - * - -
This is a Severity level IV Violation (Supplement/}.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-255/98004-01 FAILURE TO ADMINISTER A COMPREHENSIVE LICENSED OPERA TOR REQUALIFICATION WRITTEN EXAMINATION CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with this violation as written.
BACKGROUND On April 1, 1998, during an exit meeting for the NRC biennial Licensed Operator Requalification Program inspection, the Inspector identified that the Category B requalification examination given on January 21, 1998 and January 28, 1998 was not constructed in accordance with the latest published version of NUREG-1021, Interim Revision 8, which prohibits use of direct look-up and memory level questions. The examination was constructed with nine direct look-up questions and ten memory level questions, which constitutes a non-comprehensive written examination.
NUREG 1021, Interim Revision 8, contains a description of direct look-up and memory level questions, including a discussion of Bloom's Taxonomy. Bloom's Taxonomy describes a classification scheme which groups questions by the level of mental thought and performance required to answer the questions.. Level 1 contains fundamental knowledge or simple memory questions, Level 2 contains comprehension questions, and Level 3 questions require analysis, synthesis or application. Direct look-up and memory level questions fall within Level 1, and are not allowed by NUREG 1021, Interim Revision 8 guidance.
Consumers Energy instructor training course "Fundamentals of Instruction" defines a direct look-up question as one that immediately.directs the student to a reference where the answer is readily available. Consequently, a question was considered suitable as long as it did not contain the procedure reference within the question. This definition, taken from NUREG 1021, Revision 7, was more narrowly focused than the revised guidance contained in NUREG 1021, Interim Revision 8. Interim Revision 8 also prohibits questions with answers which can be directly looked up once the procedure reference is recalled.
The questions which were written at the memory level required simple recall of facts or specifics rather than a higher level demonstration of understanding through use or application of knowledge. The examination development team had not recognized that memory level questions were not allowed Qy NUREG 1021, Interim Revision 8.
The two-year requalification period for operators runs from May 1997 through April 1999.
In accordance with 1 OCFR55, prior to the expiration of this two-year period, operators must complete a comprehensive requalification examination. Accordingly, credit will not be taken for the January 1998 written examination as satisfying the requalification 2
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-255/98004-01 FAILURE TO ADMINISTER A COMPREHENSIVE LICENSED OPERA TOR
. REQUALIFICATION WRITTEN EXAMINATION examination requirement. Consumers Energy will test these operators using a comprehensive examination which meets the guidance contained in NUREG 1021, Interim Revision 8, prior to the expiration of the requalification period.
The issues raised by this violation do not invalidate the qualification of any of the affected operators during the current requalification period. The operators who were tested using the non-comprehensive examination remain fully qualified to perform their licensed operator duties.
REASON FOR VIOLATION NU REG 1021, Interim Revision 8 guidance was not appropriately implemented, resulting in a misunderstanding of the definition for direct look-up questions and the failure to realize that memory level questions were prohibited.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The following corrective actions have been taken:
- 1.
Representatives of the Training Department attended a workshop on test question development given by NRC Region Ill on May 27 and 28, 1998. The Workshop clarified the guidance contained in NU REG 1021, Interim Revision 8.
CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS The following additional corrective actions will be taken:
- 1.
A self-assessment of the operator requalification program testing requirements will be completed to ensure thorough and appropriate implementation of NUREG 1021, Interim Revision 8 guidance.
- 2.
Operators who were given the written test on January 21 and 28, 1998, will be tested with a comprehensive written examination which is consistent with the guidance contained in NU REG 1021, Interim Revision 8, prior to the end of the current two year requalification cycle.
DATE Wj,iEN F-ULL COMPLIANCE WILL BE ACHIEVED
- Consumers Energy is in full compliance. Credit will not be taken for the January 1998 written examination as satisfying the requalification examination requirement.
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