ML20059C078

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Submits Supplemental Info to Util 900412 Response to Notice of Violation in Insp Repts 50-295/89-40 & 50-304/89-36.Info Regards Requalification program,180 H of Required Training Through SAT Process & Policy for Remediation of Individual
ML20059C078
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 08/22/1990
From: Chrzanowski R
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF ENFORCEMENT (OE)
References
EA-89-255, NUDOCS 9008310039
Download: ML20059C078 (5)


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\\ Commonwealth Edison d, Downers Crove, Illinois 60515

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August 22, 1990 Director t

Office of Enforcement U.S. Nuclear Regulatory Consnission Washington, DC 20555

Subject:

Zion Station Unita 1 and 2 Supplemental Information for Hotice of Violation (EA 89-255)

Inspection Report 50-295/89040 and 50-304/89036 HEC _p_Qsket Non. 50-295 and_50-304 References (a)

April 12, 1990, letter from T.J.

Kovach to Director, Office of Enforcement (b)

July 6, 1990, letter from E.' Baker to Cordell Reed Gentlemen:

Commonwealth Edison provided a response to the Zion Station Hotice of violation, in reference (a), regarding the two violations pertaining to the senior teactor operator (limited) with an inac,tive license performing licensed duties-without standing the required one shift refresher watch and the failure to revise the requalification program at Zion to include requirements that operators attend preplanned lectures and to establish controls that ensure missed sessions are made up.

A civil penalty was proposed and Commonwealth Edison submitted payment.

Deference (b) requested a response to questions regarding the revised Zion Station requalification program.

This letter addresses those questions.

The normal Zion Station Operating schedule is structured such that one out of every five weeks is designated as a training week for each of the five shifts.

This training week contains 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of available time for training instruction and this cycle occurs 10 times to yield the 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> that are available for training.

Therefore, the licensed operator training material is repeated five times, once for each shift. Of those available hours, the Zion Station licensed operator requalification program consists of 8 of the ten cycles. Therefore, to answer the first question regarding the use of self study as the only means of remediation, page 1 of the attached requalification flow chart shows that if another lecture from the same cycle is availeble, then the first and preferred remediation means is i

to attend another lecture on the same material.

If another lecture is not available, either due to shift assignment conflicts or if the missed lecture was the last of that cycle and will not be offered again, then a second acceptable means of remediation is self-study of the material by the end of the next quarter.

In either case, a weekly quiz must be successfully completed within the bounds of the requalification program that will be described later in this letter.

l The second question pertained to the controls that ensure the specific 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of required training is received on subjects identified through the SAT l

process.

Attendance is required, or makeup is permitted as described above, for each lecture that comprises the 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of required lectures identified through the SAT process. The remainder of the available training consists of out-of-service card training, general employee training, fire brigade training, the l

administration of the requalification examination consisting of JrM's, simulator, and the written test, and some simulator training.

This training is in addition to the required 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of specific lecture material to satisfy the licensed operator requalification program.

In summary, a prescribed 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of lecture material is defined to satisfy the requirements of the requalification program.

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The additional 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> of training consists of additional training time for the L

administration of the examination and non-requalification program training, totaling 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of training per year.

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b The last question pertained to the policy for remediation of individuals who fail required quittes. The process is most easily explained if it is divided into four categories. The first category applies to individuals who pass the quiz with a score of greater than or equal to 80%.

In this case, no remediation is required and the individual is permitted to take the requalification examination.

The second category applies to individuals.that fail the test with a score of less than 70%.

In this case, the Assistant Superintendent of Operating and the individual are notified of the score and the specific weaknesses are identified.

.A remediation quit is scheduled and must be passed prior to taking the requalification examination.

The third category applies to individuals that score less than 80% yet greater than or equal te-70% on.a specific weekly quit.

In this case, the Assistant Superintendent of Operating and the individual are notified of the score and the specific weaknesses are identified.

A remediation quir is not required at-h, this point and the individual is permitted to take the requalification examination.

The fourth and last category applies.to individuals that have a rolling 6 quit average of less than o equal to 80%.

In this case, the individual is removed from shift and the Assistant Superintendent of Operating and the individual are notified of the average and the specific weaknesses.

A comprehensive remediation examination must be taken and a score of greater than of equal to 80% is required prior to returning to shift and being permitted to take the requalification examination.

The attached flow chart depicts the appropriate actions that are taken to.

satisfy the requirements of the licensed operator weekly requalification program.

j If any further questions exist, please direct them to this office Very truly yours, b

NuclearLie[..hrzanowski R. A sing Administrator-Attachment cci C. Patel - NRR Region III office Elon Resident Inspector l

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