ML18101B021

Forwards Request for Addl Info Re Requalification Training Program Insp Repts 50-272/95-08 & 50-311/95-08.Corrective Actions:Barrier Analysis Used to Determine Root Cause Based on Guidance Provided in Util Procedure NC.NA-BP.ZZ-0002(Z)

ML18101B021
Person / Time
Site:	Salem
Issue date:	09/28/1995
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N95162, NUDOCS 9510020209
Download: ML18101B021 (11)

Text

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• Louis F. Storz Senior Vice President - Nuclear Operations Public Service Electric and Gas Company Public Service Electric and Gas Company SEP 2 8 1995 P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 LR-N95162 United States Nuclear Regulatory Commission Document *control Desk Washington, DC 20555 Gentlemen:

REQUALIFICATION TRAINING PROGRAM INSPECTION INSPECTION REPORT 50-272/95-08 AND 50-311/95-08 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In NRC Inspection Report Nos. 50-272/95-08 and 50-311/95-08, dated June 2, 1995, the NRC expressed.concern over the manner in which, during the development of the annual operator examinations, an individual- signed an examin~tion security agreement which the individual and his supervisor did not fully

• comply .

Public Service Electric & Gas (PSE&G) was requested to provide it's evaluation of this incident, including the root cause, and corrective actions to address this concern. Accordingly, in the attachment to this letter, PSE&G has provided the requested information.

Should you have any questions regarding this submittal, we will be pleased to discuss them with you.

Sincerely,

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• 9510020209 950928 PDR ADOCK 05000272 n ono

Document Control Desk SEP 2 8 1995 LR-N95162 Attachment (1)

C Mr. T. T. --Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. D. H. Jaffe Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. S. Marschall (S09)

USNRC Senior Resident Inspector - Salem Mr. R. W. Summers (S09)

USNRC Senior Resident Inspector - Hope Creek Mr. K. Tosch, Manager IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 95-4933

Document Control Desk LR-N95162 ATTACHMENT 1 REQUALIFICATION TRAINING PROGRAM INSPECTION I. BACKGROUND While preparing for the Salem Operator Requalif ication exam, it was identified that recent personnel assignments and staffing changes had created a condition where two normally exclusive tasks needed to be accomplished by one ind_i vi dual. The two tasks were the development and validation of operator requalif ication exams and instruction of the requalification class.

Identification of this condition prompted a meeting between the Principal Training Supervisor and Principal Trainer - *operations Training. They discussed current personnel assignments and qualifications. It was determined that one instructor could perform both tasks without compromising examination integrity. The following actions were taken:

The instructor would validate several examination scenarios for the requallfication cycle. The instructor would not kno~ specifically what scenarios would be given to which crew .

• The instructor was provided verbal instructions on which modules and activities he could teach. The instructor was told that questions on material not identified for him to teach would have to be referred to other individuals on the instruction staff.

The above solution was proposed to the Manager - Nuclear Training who agreed to the arrangement. The Manager - Nuclear Training based this decision on a *review of ES-601 NRC Examiners Standards.

• I t was known that this document did not apply but, it was reviewed for guidance purposes. A review of form ES-601-1 was not part of this review. Additional considerations by the Manager - Nuclear Training included his knowledge of similar arrangements in use at other utilities and that the proposed plan was reasonable for preventing a compromise of examination security.

During the NRC inspection of the Requalif ication Training Program, an NRC Inspector noted the situation where the instructor was involved in validation of operator requalification exams and instruction of the requalification class. However, the inspectors discovered that the ES-601-1 security agreement form (which was signed by the instructor) specifically prohibited an individual from participating in the validation and training process.

• Page 1 of 7

Document Control Desk LR-.N95162 Until noted by the NRC inspector, the Principal Training Supervisor, Principal Trainer - Operations Training and the instructor were not aware of any restrictions on form ES-601-1 which specifically precluded an individual from participating in the validation and training process.

• II. ROOT CAUSE/CORRECTIVE ACTIONS The Barrier Analysis method was used to determine root cause based on the guidance provided in PSE&G procedure NC.NA-BP.ZZ-0002(Z),

Root Cause Analysis Guideline. Barrier Analysis was chosen because people committed inappropriate actions relative to procedural controls.

A. ROOT CAUSE Repetitive use of the ES-601-1 security agreement form for non-NRC administered requalif ication exams has resulted in a casual acceptance of the intent of the form. This helped to promote an atmo$phere where specific form content was not thoroughly reviewed when making decisions concerning examination security.

This event is categorized as a procedure noncompliance issue due to overconfidence by the individuals involved with respect to the form content and intent.

1. Supervisory personnel did not review the ES-601-1 security agreement when deciding on their course of action concerning the responsibilities of the instructor.

2. Several personnel stated they knew that they could not discuss exam content with individuals as part of the ES-601-1 security agre~ment. However, at the time of this event, they could not have specifically identified the ES-601-1 security agreement for instruction restriction after test validation. *some of these individuals had signed recent security agreements as part of the requalification examination administration.

3. Current practices require some individuals to sign the ES-601-1 security agreement several times during the conduct of the requalification cycle. This may help promote an atmosphere where only a cursory review of specific form content is done.

Page 2 of 7

Document Control Desk LR-.N95162 CORRECTIVE ACTIONS TO AVOID RECURRENCE

1. Public Service Electric & Gas (PSE&G) Nuclear Training Center (NTC) Management will discuss this event with all NTC instructional staff and their supervision.

Discussions will emphasize expectations for attention to detail, proper record keeping and documentation, significance of an individuals signature and the need for a questioning attitude. This discussion will include emphasis on the need for increased vigilance on tasks of a repetitive nature. Emphasis will also be placed on the need for a review of applicable guidance documents (e.g.

procedures, guidelines, regulatory documents, etc.) when making decisions that alter current established practices.

This action will be completed by October 26, 1995.

2. Training for all operations training instructors on examination security requirements will be completed prior to the .next operator requalif ication examination. This training will be based on the requirements from training center procedures for licensed operator requalif ication examination development and administration. This action will be completed by October 27, 1995 .

• 3.

4.

The instructor and his supervisor were counselled for their failure to identify and initiate corrective actions for an administrative deficiency in the exam security process. This action was completed on May 18, 1995.

A security agreement was generated to document the requirements that were verbally agreed upon between the instructor and supervisor. This was completed on April 19, 1995.

There are no previous occurrences of this event or similar events concerning instructor violations of operator requalification examination security requirements. This event is generic to the extent that Hope Creek Operations Training uses this methodology for examination security.

III. CONTRIBUTING CAUSAL FACTORS/CORRECTIVE ACTIONS The following are the contributing causal factors along with corrective actions:

A. Based on a review of applicable procedures, it was determined that there was a lack of guidance on examination security requirements for operator requalification examinations.

• Page 3 of 7

Document Control Desk LR-N95162 CORRECTIVE ACTIONS TO AVOID RECURRENCE

1. The NTC will develop a common (Hope Creek & Salem Generating Station) procedure for the development and implementation of Licensed Operator Requalif ication examinations. This procedure will ensure exam security requirements required by 10CFR55.49 and present industry standards are met. Specific training will be required for all licensed operator instructors prior to the implementation of this procedure. Training will also be required for initial operations instructor qualifications and be a requirement for members of an examination development team. This procedure also meets our commitment to a previous Hope Creek NRC Licensed Operator Inspection and response (see Contributing Cause III.B).

This will be completed by October 18, 1995.

B.. Inadequate implementation and tracking of an NRC commitment (reference NLR-N89228) resulted in a previou$ly issued document, "Guideline for Developing and Conducting Licensed Operator Requalification Exams" becoming outdated and ineffective. This document was issued in response to an NRC Requalification Program. Evaluation, Report Number 50-354/89-12.

1. The above guideline was initially issued in 1989 to

• provide specific guidance to NTC staff to aid in the -*

development of examination materials for requalif ication examinations. It was subsequently revised and reissued as Revision 0 in March of 1991. However, this guideline '!Vas never proceduralized or identified as fulfilling an NRC commitment. Apparent causes for the failure to properly implement and track this requiremen.t include:

This document was not incorporated into the NTC procedure system and therefore was not tracked.

There was no identification of this guideline as fulfilling an NRC commitment, either in the document or by reference in an approved training procedure.

Several personnel involved in development and initial piloting of the methodology in the guideline have been .

transferred to other positions or temporarily reassigned.

Page 4 of 7

Document Control Desk LR~N95162 CORRECTIVE ACTIONS TO AVOID RECURRENCE

1. The NTC will develop a common (Hope Creek & Salem Generating Station) procedure for Licensed Operator Requalification examinations *(This is noted in Corrective Action III.A.1). This procedure will include sample plan development, open reference test item requirements and Job Performance Measure (JPM) development to meet current industry standards and *NRC requirements for a satisfactory requalification program. Specific training will be required for all licensed operator instructors prior to the implementation of this procedure. Training will also be required for initial operations instructor qualifications and be a requirement for members of an examination development team. This will be completed by October 18, 1995.

2. The NTC will develop a specific qualification task in ~he Licensed Operator Instructor's training matrix. This task would require knowledge and understanding of .NRC requirements for requalif ic.ation exam development and implementation. The training qualification will also include all required exam security requirements. This task will be based on the procedure referenced in Corrective Action III.A.1. This will be completed by October 18, 1995.

3. The procedure noted in Corrective Action III.A.1 will be noted as an NRC commitment. In addition, NTC procedure ND.TQ-TC.ZZ-OlOO(Z) Revision 1, Development and Revision of Training Procedure, will be revised to include a requirement to identify commitments in training center procedures. This will be completed by October 18, 1995.

C. Inadequate NTC Management follow-up to ensure proper implementation of expectations on licensed operator requalification examination security.

1. The instructor's supervisor recognized that the arrangement in question was unusual and had not been used in the past. However, no attempt to document the specifics of the arrangement were made until the NRC raised a concern.

2. The Manager NTC reviewed ES-601 and it was realized that this document was not applicable to the examinations to be given. However, a review of other procedural guidance to determine what requirements existed or practices were in

• Page 5 of 7

Document Control Desk LR-.N95162 place was not performed. Also, the ES-601-1 form was not noted during the review of the ES-601 document.

3. Operations Training Supervision modified the standard practices used for examination security without ensuring these modifications did not conflict with the ES-601-1 form.

4. The guidance provided to the instructor by his supervisor helped to provide ~ mind set that examination security issues were adequately addressed. Also, failure of the instructor to identify a difference between the ES-601-1 security agreement and the verbal instructions indicates a lack of a questioning attitude.

CORRECTIVE ACTIONS TO AVOID RECURRENCE Corrective actions for II.A.l, II.A.2, II.A.3, II.A.4, II.A.5, III.A.l, III.B.l, III.B.2 and III.B.3 address this issue.

D. Less than adequate training for examination team members.

1. The Instructor Training Program which provides training on examination security, as defined in ND.TQ-IP.ZZ-0017(Z)

Revision 2, Examination Security, does not provide ~

guidance on requalification examination security measures . ' ___,,..

or security agreements.

2. No specific training or qualification requirements are identified for those individuals tasked with overall assembly, generation and administration of licensed operator requalification examinations.

CORRECTIVE ACTIONS TO AVOID RECURRENCE Corrective actions for III.A.l, III.B.l, III.B.2 and III.B.3 address this issue.

E. Less than adequate resource planning by management resulted in an insufficient manning level of qualified instructors in the Salem Operations Training Group.

1. Four instructors were transferred to Salem Operations and adequate replacements were not in place for the NTC. This created a situation of over-reliance on one instructor for licensed operator requalif ication training due to his ca*pabilities and qualifications.

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Do~ument Control Desk LR-N95162

2. The class requests and their sizes placed additional staff requirements on the Salem Operations Training Group.

CORRECTIVE ACTIONS TO AVOID RECURRENCE Additional permanent staff is currently being qualified. This will be completed by April 1996. In the interim, supplemental staff is in place to ensure adequate .resources are available for operator training.and requalification.

IV. SIGNIFICANCE OF EVENT PSE&G management considers this issue to be important in that an evolution in the continuing evaluation and qualification of operations personnel was not adequately controlled. Although there was no compromise of examination security in this instance, the appearance of impropriety is unacceptable. Establishing and

• enforcing performance standards which meet or exceed industry* and regulatory requirements are key ini_tiatives within the NBU.

Completion of the corrective actions identified herein, as well as other performance improvement initiatives currently underway at the NTC and within the NBU are a necessary first step towards this objective .

• Page 7 of 7

3

• Distribution:

PUBLIC S. Quinn, Vice President - Nuclear Power P. Eddy, New York State Public Service Department State of New York

• Regional Administrator Secretary, RI Deputy Regional Administrator Secretary, RI DRP Division Secretary, RI DRS Division Secretary, RI DRSS Division Secretary, RI DRMA Division Secretary, RI Region I Receptionist Distribution by fax:

Honorable Sandra Galef, New York State Assembly

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• ~

October 27, 1995 Licensee:

U.S. NUCLEAR REGULATORY COMMISSION REGION I .

NOTICE OF SIGNIFICANT MEETING No. 95-96*

Consolidated Edison Company of New York, Inc.

Facility: Indian Point Unit 2 Docket No.: 50-247 Time and Date: 9:30 a.rn., November 8, 1995 Location: Indian Point Unit 2 Station Energy Education Center Broadway and Bleakley Avenues Buchanan, New York 10511

Purpose:

SALP Managment Meeting NRC Attendees: W. Kane, Deputy Regional Administrator C. Cowgill, Chief, Reactor Projects Branch 2, DRP Licensee Attendees: S. Bram, Senior Vice President, Central Operations S. Quinn, Vice President - Nuclear Power J. McAvoy, Plant Manager NOTE: Th.is meeting is open to the public. Attendance by additional NRC

• personnel should be made known by November 6, 1995, via telephone

• call to Mr. Curtis J. Cowgill~ Region I, at 610-337-5233. Handicapped persons requiring assistance to attend or participate in the meeting shall make their requests known to Mr. Curtis J. Cowgill, USNRC, Region I; 475 Allendale Rd., King of Prussia, PA 19406, (610) 337-5233, no later than two business days prior to the meeting.

Prepared by: