ML20058B292
| ML20058B292 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/17/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312020026 | |
| Download: ML20058B292 (5) | |
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Patrick M Donnelly 3
Plant Manager MICHIGAN'S PROGRESS Big Rock Pomt Nuclear Plant.10269 US-31 North. Charlevoix, MI 49720 November 17, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 93-018; REQUAL TRAINING.
During the week of October 18, 1993, the Nuclear Regulatory Commission conducted a routine Licensed Operator Requal Training Inspection at the Big Rock Point Plant. NRC Inspection Report 50-155/93018 concluded that certain of Big Rock Point's activities appeared to be in violation of NRC requirements.
The violation involves a failure to provide all requalification training to all licensed operators for the 1991/1992 requalification training program.
Pursuant to the direction required by the report, find attached a Reply to the Notice of Violation dated November 1,1993.
A Licensee Event Report,93-010; Licensed Operator Requal Training Not Performed in Accordance With Facility Technical Specifications, has also been documented by the Big Rock Point staff.
O hah Patrick M Donnelly Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Peint l
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ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOUTION INSPECTION REPORT 93018 November 17, 1993 1
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RESPONSE TO NRC INSPECTION REPORT VIOLATION 93-018 - REQUALIFICATION TRAINING V10tATION 93-018 10 CFR 50.54(1-1) requires, in part, the licensee to have in effect, within three months after issuance of an operating license, an operator requalification program which must as a minimum meet the requirements of 10 CFR Part 55.59(c).10 CFR Part 55.59(c) requires, in part, a requalification program that is conducted for a continuous period not to exceed two years.
Contrary to the above, as of October 22, 1993, the licensee failed to conduct the 1991/1992 requalification program within the two year requirement, in that all the required requalification training for the 1991/1992 requalification program was not provided to all licensed operators.
- 1) Reason for the violation The causes of this event can be attributed to inadequate tracking mechanisms, informal communication methods, and improper processing of training records.
Summary of causes Verbal Communication Verbal notifications to Licensed Operators (L0s) during the scheduling of make-up sessions were misunderstood or otherwise ineffective; consequently, some make-up sessions were missed.
Verbal communication between the Training Administrator and a requalification instructor for year ending 1992 lead to class packages being processed prior to all individuals attending the make-up sessions, thereby resulting in a belief (and tracking) that all individuals attended the training when actually they did not.
Manaaerial Methods Plant staff licensed individuals missing a large number of scheduled five week training sessions has led to increased tracking problems, overall disruption of scheduled training and extra work load for the training section.
A detailed living training schedule for the Licensed Operator Requal Training (LORT) program and other operator training programs was not provided to enhance LO's ability to schedule their time to attend required training.
Policy guidance / management expectations for Nuclear Training Department (NTD) procedures used by the training section were not well defined and understood.
Work Practices Instructors did not always follow required procedures when processing training records, resulting in some records being lost.
Page 2 RESPONSE TO NRC INSPECTION REPORT VIOLATION 93-018 - REQUALIFICATION TRAINING Ouality Assurance involvement The Nuclear Performance Assessment Department conducted an evaluation to determine why this violation was not discovered by their auditors during a May 1993 Training audit. The most significant cause was the lack of clear procedural guidance. The procedure did not state which training was required.
Administrative Procedure 1.7.2, Operator Training, provides a description of the lecture series courses; however it is ambiguous in stating that it is required.
During the course of the audit, 5 licensed operator requalification records were selected and the requirements in Administrative Procedure 1.7.2 were -
compared against the NUTREC (Nuclear Training Records) printouts. The printouts showed that all areas required by the Administrative procedure were fulfilled. Due to the ambiguity in the procedure the auditor did not realize how many entries should have been included in the Continuing Licensed Operator Training Category.
- 2) The Carrective steps that have been taken and the results achieved Immediate Corrective Action A review of the 1991, If,92 and 1993 Big Rock Point Operator Requalification program records was conducted. An evaluation for each on-shift Reactor Operator and Senior Reactor Operator utilizing the following criteria:
- Basis for the training missed.
- Significance of the training.
- Existence of documented training on specific tasks associated with missed training.
- Existence of simulator training scenarios conducted for missed training topics.
An evaluation was immediately conducted for each on-shift reactor operator (RO) and senior reactor operator (SR0). One SR0 was required to complete a make up training session prior to standing a watch. The remaining Licensed Operators were deemed qualified to perform the task associated with' the missed training, and allowed to remain on shift.
Make-up training sessions have also been scheduled for some L0s because of the lack of training documentation that has also been identified. The training commenced the second week of November and will conclude December 17, 1993.
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RESPONSE TO NRC INSPECTION REPORT VIOLATION 93-018 - REQUALIFICATION TRAINING
- 3) The Corre_tive Steps that will be taken to avoid further violations I.
Develop and implement a LORT program tracking system that will identify individuals whom have missed required training, and to assure that make-up training is conducted for those individuals.
II. Develop and issue a living training schedule for the BRP Operations department that provides details of the two year LORT cycle, an
~i interfacing overview of operator and training instructor resource
- loading, and concurrence and approval of the Big Rock Point's Operations Manager and Training Administrator for the initial schedule and each
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revision, if necessary.
III. Conduct training for BRP training staff on applicable plant and NTD a
procedures. Emphasize the need to have training records processed in accordance with NTD procedures.
IV.
Evaluate the conduct of training at BRP against NTD procedures to ensure compliance with the procedures and that appropriate work control' processes exist.
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Conduct make-up training as required for individuals missing 1991, 1992, and 1993 training sessions.
- 4) The date when full compliance will be achieved The facility is expected to be in full compliance by December 17, 1993. The corrective steps taken to avoid further violations are scheduled to be completed by March 1, 1994.
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