ML20083A337
| ML20083A337 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/28/1991 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC |
| Shared Package | |
| ML20083A328 | List: |
| References | |
| BVY-91-63, NUDOCS 9109240107 | |
| Download: ML20083A337 (5) | |
Text
_ _. _
1, YERMONT YANKEE
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NUCLEAft POWER COHPOllATION a Iy%
Ferry Road. Brattleboro Vt 053017002 E N'03 k
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June 28,1991 n7 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
References:
a)
License No. DPR 28 (Docket No. 50 271) b)
Letter, WNPC to USNRC (BW 9149), dated 4/30/91
)
c)
-Letter, USNRC to WNPC, (NW 9170) Report No. 50 271/91 02 (OL), dated 4/19/91 d)
Letter, USNRC to WNPC (CAL 91007), dated 3/11/91 e) letter, WNPC to USNRC (DW 91027), dated 3/8/91 f)
Letter, WNPC to USNRC (BW 9125), dated 3/8/91
Dear Slr:
Subjects
- Vermont Yankee Response to Report No. 50 271/91 02, Requalification Program Evaluation and Operational Evaluations During the week of February 25, 1991 the NRC conducted licensed operator requalification examinations at Vermont Yankee. Based on the results of those examinations, the Vermont Yankee Lkensed Onerator Requahfication (LOR) Program was determined to be unsatisfactory. Following this determination, Vermont Yankee initiated a number of corrective actions and performed a comprehensive root cause analysis of the unsatisfactory examination results. The results of this analysis and additional corrective actions were provided to you via Reference b).
Inspection Report No.- 50 271/9102 (OL) [ Reference c)) provided a further discussion of weaknesses that you observed during the LOR evaluation process. This letter provides, in the Attachment, our perspective on those weaknesses and a discussion of actions taken or planned to correct them.
We trust that the above information is satisfactory; however, should you have any questions or desire any additional information on this issue, pleaae do not hesitate to contact us.
Very truly_ yours, L
o Vermont ankee Nuclear Power Corporation Aa_
n1 -
Warren P. Mur y i
Senior Vice President, Oper i 's cc:
= USNRC Regional-Administrator, Region i USNRC Resident inspector, WNPS USNRC Project Manager, WNPS 9109240107 910906 PDR ADOCK 05000271-1 l
G PDR j.
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Attachment A summary of the weaknesses identified in NRC Inspection Report 50-271/91-02 [ Reference c)) is given below with a corresponding discussion of our corrective actions:
Proaram Weakness 1 The quality of licensee developed examination materia's was inadequate based on the following excerpts from Reference c):
"The sample plan submitted by the facility did not meet the standards of NUREG 1021 for use in preparation of the examinations."
(Section 3.2)
"The examinations that were originally proposed by the facility did not contain enough questions to meet the for number of points on the examinaflon." guidance of NUREG 1021 (Section 3.3)
"All of the facility proposed JPM's required changes to upgrade the aerformance standards for the Individual steps required to perform lhe tasks."
(Section 3.4)
"Many of the ISCT's identified in the stenarios pro facility did not meet the guidance of the Examiner, posed by the s Standards."
(Sectlun 3.5)
Response
We have reviewed the above identified weaknesses and have concluded that your findings are consistent with the causal factors identified in our root cause analysis of unsatisfactory examination results conclusion is that these weaknesses were a result of the(Referencefollowing fac]
b).
Our o
There was a !ack of direction within Vermont Yankee regarding requirements for administration of the LOR Program and hence, for maintaining and submitting examination materials consistent with the latest revision of NUREG 1021.
o loformation available to the industry regarding recent NRC requalification examination failure was inadequately disseminated within Vermont Yankee.
Much of this information further amptliied NUREG 1021 guidelines.
o Revision 6 of NUREG 1021, which was published on June 6,1990, included substantial changes to the definition of Individual Simulator Critical Tasks (ISCT's). The Vermont Yankee examination team was aware, but did recognize the significance of, these revisions.
Therefore, no specific effort was initiated to review existing simulator scenarios for the effects of the revisions. This resulted in many of the Inillally proposed examination scenarios not meeting NUREG criteria.
F~
c' To assure, on an ongoing basis, that Vermont Yankee examination materials and submittals are consistent with the most recent NUREG the following corrective actions have been completed or are ongoing: guidance, a)
Vermont Yankee Training Department Management will develop written duties and responsibilitics for the administration of the LOR program.
This effort will be completed by July 1,1991.
b)
The Training Department will develop a specific training module covering the requirements of NUREG 1021 which will be presented to all LOR instructors.
In addition, a pre exam checklist will be developed for use in preparing for NRC examinations to ensure all required items are accomplished in a complete and timely manner.
This checklist will include an example format for the sample plan submission, review and validation of Job Performance Measures (JPM's) and written examination material, and review of Simulator Exercise Guides used to develop ISCT's. Both the training module and the checklist will be available to allow for training to begin by October 1,1991.
In addiflon, a program has been initiated to assure that future NUREG revisions are incorporated into the above programs in a timely manner.
c)
Examination materials have been or are being revised to assure all NUREG 1021 requirements are satisfied as follows; o
Job Performance Measures (JPM's) have been revised to upgrado periormance standards and content.
o Simulator Exercise Guldes (SEG's) will be reviewed and revised as neces.cary by October 1,1991 to ensure that they meet the requirements of ES-604, Written examination for time, validity, and accuracy. questions will be validatedThe validation w o
to the submittal of material to the NRC in preparation for the 1992 LOR examination.
l Procram Weakness 2 The adequacy of rotation practices for Reactor Operators (RO's) was an identiflee weakness based on the following excerpt from Reference c):
"Tne facility trains operators in all positions permitted by their licenses, but does not ensure that all RO's are evaluated in all positions during tho dynamic simulator portion of the exam "
1
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Although our practico has boon to ensure all licensed oporators recolve training in all positions permittod by their licensos, we concur that wo do not always rotate RO's into all positions during dynamic simulator ovaluations.
Rather, in some cases, we havo verified knowledge and ability in alternato positions through other portions of the exam.
To assure that we completel examino a!I licenso holders in the future, we have taken the following action:y In conjunctico with the actions discussed in responso to Program Weaknerd #t above we will specifically address simulator rotation practicor for a.L Ha f ed operators when developing the NUREG 1021 tiaining mocule for 8.0R instructors.
Further, we have already modified our ongolcg 1.OP '.,aining program to assure expanded personnel rotation in both simule,o training and simulator waluation scenarios.
Proaram Weakness 3 tivaluation techniques on the dynamic simulator portion of the exam woro weak in the following areas discussed in Referenco c):
"The facility evaluators did not closely observe control board manipulations, and very soldom followed operators to the back panels to observa activities."
"In several cases, the f acilitity's ovaluation of ISCT performance or pass / fall decision basis differed from the NRC's ovaivation or basis."
"Even though the NRC and facility overall pass / fall results for individuals were identical, it appeared that the facility evaluators had a tendoney to downplay the safety significance of the performanco errors."
Responso We have taken the following actions to assure appropriate and consistent evaluation of all licensed personnel; a)
During LOR simulator training and evaluation, all operators are observed during back panel operations and control board /EOP usage is much more closely monitored, b)
Further training in the evaluation techniques contained in NUREG-1021 will be presor:ed to all simulator instructors by Octobor,1991.
Proaram Weakness 4 The remaining weaknesses identified by Reference c) were related to operating crew communications and control as follows:
"During administration of the dynamic simulator examinations, the NRC Identifled a safety concern that the roles and responsibilities of the crew members did not 3rovide Independent evaluation of plant operations to assist anc advise shift supervision during abnormal and emergency events.
Poor communications and coordination of activilles contributed to the weaknesses noted in crew performance."
Response
We have reviewed the above identifled weaknesses and have concluded that your findings are consistent with causal factors identitled in our root cause analysis of unsatisfactory examination results [ Reference b)].
As discussed in Reference f), we took actions immediately following the subject LOR examination to pursue correction of those weaknesses. Those actions consisted of clarifying the division of dulles of the control room staff and presenting training to all licensed operators covering contiol room command and control, and shift staff communications.
In our further evaluation of this issue, we recogn zed the nood to develop and implement an operating crew communications policy. This policy, which is currently being developed, will ensure a consistent command and control philosophy anc will also allow for more objective evaluations of crew performance during ongelng requalification training.
Our development of the solicy will be completed so that training can commence by the beginning of tie third LOR cycle, currently scheduled to begin August 6,1991.
In addition, to further improve control room communication and to enhance consistency among operating crews, a program has been initiated to allow control room supervisors to observe other operating crews during simulator training.