ML20070G487

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Forwards Operating Requalification Training Program Justification for Continued Operation,Per 910304 NRC Request.Concludes That Sufficient Number of Licensed Personnel Are Fully Qualified to Operate Plant Safely
ML20070G487
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 03/08/1991
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-91-25, NUDOCS 9103120104
Download: ML20070G487 (6)


Text

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VENMONT YANKEE NUCLEAR POWER CORPORATION BVY 91-25 Ferry Road, Brattleboro. VT 05301-7002

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g Senior Vice President. Operanons s

(802) 257-5271 March 8,1991 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attn:

Document Control Desk

References:

a)

License No. DPR 28 (Docket No. 50 271)

Dear Sir:

Subject:

Operator Licensing Requalification Training Prograrn, Justification for Continued Operation As requested at the March 4,

1991 meeting with NRC Region I, provides our. Justification for Continued Operation.

Based on the assurances identified in the Attachment, we conclude that a sufficient number of licensed personnel are fully qualified to operate the plant safely and protect the health and safety of the public.

Should you have any additional questions, please do not hesitate to contact us.

Very truly yours, Vermont Yankee Nuclear Power Corporation

/

Warren P. Murphy &,

fM Senior Vice President, ations

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USNRC Regional Administrator, Region l USNRC Resident inspector, VYNPS USNRC Project Manager, VYNPS Fb0

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ATTACHMENT 1 LICENSED OPERATOR REQUALIFICATION (LOR) TRAINING PROGRAM JUSTIFICATION FOR CONTINUED OPERATION DESCRIPTION OF CONDITION AND EVENTS:

During the observation by the NRC of Vermont Yankee's LOR examination process, the NRC determined that the VY LOR training program is unsatisfactory.

Of the twelve individual licensees examined, ten received a Satisfactory grade (83% success rate). However, two of the three crew examinations resulted in Unsatisfactory grades.

Therefore, based on the results of the crew examinations, the LOR training program was determined to be unsatisfactory in accordance with the requirements established in NUREG 1021, Section ES 601,

" Administration of NRC Requalification Program Evaluations."

The above NRC examination results are consistent with the VY training program results, with the exception of the rating given for the staff crew's Simulator Dynamic Demonstration.

SAFETY SIGNIFICANCE AND JUSTIFICATION FOR CONTINUED OPERATION:

This condition has minimal safety significance in the short term, because there is reasonable assurance that a sufficient number of licensed operators are fully quallfled to safely operate the facility and protect the health and safety of the public. This determination is based on the following:

1.

Prior to th.s event, there had been no observation of significant deficiencies in the LOR training program by the NRC.

2.

Those Individuals (2) and crews (2) who were deemed deficient by the NRC were relieved of their licensed duties.

None of the Individuals involved will be reinstated until they receive remedial training and satisfy the program requirements of NUREG 1021.

None of the NRC identified crew deficiencies or weakness resulted in a safety significant condition that was outside the bounds established by Vermont Yankee's EOPs.

3.

Within the past six weeks 24 Individuals and six crews (including two staff crews) were examined and all received Satisfactory ratings. One crew was deemed marginal in passing, and ccmpleted remedial training prior to resuming licensed duties.

4.

The LOR examination process consists of three functional areas.

In two of these areas [ written exam and Job Performance Measures (JPMs)] there l

was a 100% Satisfactory rating. Both the NRC and Vermont Yankee were in full agreement with these ratings.

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5.

In NRC's evaluation of the larevious LOR training program, all Individuals (12) and crews (3) examinec received Satisfactory grades. Both the NRC 1

and Vermont Yankee were in full agreement with these ratings. Since that time, there has been no relaxation in our operator training program standards, nor was there a substantial difference between Vermont Yankee E

and NRC standards with regard to the necessary scope and content of the training program.

6.

All o aerator training

programs, including the Licensed Operator j

Requa Ification. Program, were extensively reviewed and reaccred ted in 1

June of 1990 by the National Academy fc,r Nuclear Training.

7.

Within the past few weeks, during the NRC's examination of the 1990/1991 Licensed Operator Initial (LOI) candidates, all Individuals (4) e::amined received Satisfactory grades and licenses were granted.

8.

As documented in the NRC's Systematic Assessment of Licensee Performance (SALP) since May of 1983 (5 SALP periods), Vermont Yankee has consistently achieved a SALP rating of 1 in the areas of Plant Operations and Training.

9.

During the 1989/1990 time period, the lleensed operators safely operated

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the facility, as evidenced by operator performance records that included a good level of knowledge, adherence to licensed conditions, and adherence to procedures.

The noteworthy performance by the operators of their licensed duties have been documented in the following NRC audit and inspection reports:

a)

SALP Report No. 50 271/88 99 "Several licensee strengths were evident during this SALP period.

Plant operating history, which included a successful refueling outage and a low plant translent rate attest to good overall management involvement, good operational oversight, a good training rogram, and a strong orientation at all levels toward nuclear safe y "The licensee continued to demonstrate strong and effective management controls that assured safe facility operations, as evidenced by a good plant performance record, adherence to license conditions and - safe operating practices, and a demonstrated commitment to safety by operators and superviser personnel."

"In general, operator performance during plant transients and routine operations was noteworthy and reflects the success of the operator training program."

" Plant staff, management, and operators performed well during event identification, classification, and emergency plan Implementation."

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1 Page 3 "The current requalification training program for licensed operators made a positive contribution to safe operation of the 3' ant, as evidenced by operator performance records that includec a good level of knowledge, adherence to licensed conditions, and adherence to procedures."

b)

NRC Inspection Report No. 50 271/90 02

" Plant operatnrs were observed to display proper attention to detail and a good questioning attitude in carrying out their licensed responsibilities. Plant evolutions were observed to be conducted in accordance with approved plant procedures."

c)

NRC Inspection Report No. 50-71/90 03 "On June 1 at 1:53 p.m., an automatic reactor trip occurred from 100% power... Recovery operations were observed by the inspector.

Control room personnel and plant support staff response was good.

Proper command and control was demonstrated by control room supervisory personnel.

The monitoring of plant and equipment conditions was performed in a diligent manner and communicated well between t1e members of the operating crew.

The Shift Engineer was involved and properly integrated into the process. The development by the VYNPS Operations Department of an atmosphere in which licensed operators identify deviations from expected performance is viewed as a strength."

d)

NRC Inspection Report No. 50 271/90 15 "A reactor trip during perfc,mance of weekly turbine emergency governor trip test was handled well by operators and followup maintenance actions were timely and effective."

"The inspector concluded that the control room operators and I&C personnel adeptly handled the out-of normal AOG operation and responded appropriately to mitigate the effect on plant operations."

e)

NRC Inspection Report No. 50-271/90-07 "The Shift Supervisor / Plant Emergency Director (SS/ PED) displayed excellent command and control.

He tracked accident information closely and assigned, or reassigned, personnel to follow up new developments."

10.

The Plant Operations Review Committee concluded on March 2,1991, that there is sufficient confidence in the qualifications and abilities of the licensed operators and their crews to protect the health and safety of the public.

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The following immediate corrective actions have already been completed:

a)

Based on the NRC Region I assessment of control room staff functions during abnormal and emergency conditions, the following divit,:on of duties was initiated on March 1,1991:

1.

The Shift Engineer's sole

duty, during abnormal and emergency conditions, was reinforced so that he provides continual Irhendent technical assessment for the Shift Supervisor.

2.

An additional

N

' (i.e., communicator) not currently required to r

,,,, operating shift compliment (2 SRO's, 2 F'

_, wa, designated to perform the following dulles during,,onormal and emergency conditions:

a)

NRC and state notifications; b) data collection; and c) any similar non licensing activities, as directed by the Shift Supervisor.

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3.

Doth the Shift Engineer and Communicator are capable of responding to the Control Room within 10 minutes notification, b)

The management directive on Shift Supervisor command duties and responsibilities was revised and reissued on March 4,1991 and discussed with the Senior Licensed Operators and Shift Engineers during a meeting on March 5,1991, included in that directive was the following:

"The Shift Supervisor is responsible for ensuring that his crew performs as a team and adheres to the concepts of team work, particularly during off normal conditions.

Specifically, he is responsible for stressing and practicing this concept in the simulator during training exercises."

12.

The following short term corrective actions will be completed:

Vermont Yankee will develop and implement an Instructor Guide (IG) to address lessons learned during the 1991 LOR examination

process, relative to command and control functions and communications of shift supervision.

Classroom training will be concluded by March 23, 1991. Simulator crew exercises to reinforce that training will be conducted for all operators with active licenses and be completed by March 31, 1991, 13.

The following long term corrective actions will be completed:

Page 5 a)

The VY President and Chief Executive Offleer; Senior Vice President, Operations; Plant Manager; and Operations Superintendent will each observe each crew's aerformance during the 1991 Operator Requalification cycle end ng February 1992.

b)

A detailed root cause analysis for the failure rate in this NRC monitored exam will be conducted at, completed by April 15, 1991, followed by a report to the NRC by April 30, 1991.

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