ML20094M732
| ML20094M732 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/26/1992 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1220 BVY-92-34, TDL-92-07, TDL-92-7, NUDOCS 9204010315 | |
| Download: ML20094M732 (5) | |
Text
hERMONT YANKEE NUCLEAR POWER CORPOllATION s.
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"?)t.'11 March 26,1992 TDL 92 07 BVY 92-34 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North Room 14D7 Mail Stop 14D1 Washington, D.C. 20555
References:
a.
License No. OPR-28 (Docket No. 50-271) b.
Letter, USNRC to VYNPC, inspection Report No. 50-271-91-81, dated 1/27/92
Subject:
Response and Corrective Actions to Deficiencies identified by USNRC During NUREG 1220 Audit
Dear Sir:
During the week of October 21,1991, the NRC conducted a NUREG 1220 Audit inspection at the Vermont Yankee Training Center and identified seven deficiencies in our training programs. Additionally, weaknesses in Training Department procedures (TDDs), Chemistry Technician theoretical knowledge, and instructor training were identified. Vermont Yankee's response and corrective actions to be taken for each item is addressed in the attachment to this letter.
Based on an overall analysis of the 1220 Audit Report and our own internal audits, it is our determination that the common factor that resulted in these L
deficiencies was a failure by management to maintain awareness of the administrative aspects of a systematic approach to training. This resulted in inadequate emphasis being placed on some of the key elements of the Vermont Yankee training system.
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PoDo 2 On March 4,1997, et a macting vvilh NHC roolonal staff, wo discussed the many personnel a::tions we have taken to address those issues, Althou0h the specifics are addressed in the attachment to this lotter, wo want to emphasize that Vermont Yankoo is committed to maintaining a systematic approach to training, We are confident that the actions we have taken to dato, in addition to the further corrective actions discussed in the attachment, will significantly improve our training system, if you have any questions or require additionalinformation concerning our efforts, please do not hesitate to contact us, Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION
+~p op, Warton P. Murphy Senior Vice President,
. tlons Attachment cc:
USNRC Region l Administrator USNRC Resident inspection - VYNPS USNRC Project Mana0er - VYNPS l
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Attachment Wankans; The team noted that now instructurs woro sometimos placed in the classroom prior to recolving !nstructor tralning.
VY acknowled cs this weakness and has boon participating in VY Resnonsm 0
4 a Northeast Training Association (NETA) project to develop a joint instructor training program. The first course will be taught in May 1992 and frequently enough thereafter to prevent a reoccurrence of this weakness. Now VY Instructors, requiring trainin0, will attend this courso prior to assuming classroom assl nments.
0 Wokonal The Chemistry Laboratory at the training facility is not functional and has yet to be used for oither initial cr continuing training This weakness could Impact Chernistry Technician performance, YX. Resp.onin; VY has bud 0eted and approved funds for activatin0 the Chemistry training laboratory. Work on completin0 the facility and ordering equipment will begin in April 1992. We anticipate that the lab will be ready for trainin0 by April 1,1993.
WBkuns; The team noted that theoretical knowledge varios widely among Chemistry Technicians.
VY Resoonse-VY has identified specific areas of knowledge weakness and will be covering these areas in Chemistry Technician continuing i
training in 1992.
Deficiency 271/D1810J; The task analysis are not kept curront. It appears thet a conscious management decision has boon mado not n.
maintain the task analysis data base.
VY RelDan10; VY acknowledges that the task analysis and task-to trainin0 matricos have not been kept up to date. We will conduct a complete review of the task listin0s for all accredited trainin0 programs and updato the task analysis and task-to-training matrices by July 1,1993. Additionally, to ensure that in the future that this deficiency does not recur, we will improve two feedback mechanisms, the Training Change Request (TCR) process by January 1,1993, and the Curriculum Committee process by July 1,1992, to include provisions for task inventory and analysis updates.
_ _ ~. _. -. _.. _ _. _ _. _ _.. _.. _.. - _ _..,.. _, _,. _ _ _ _..._.
Doficiency 271/9_1 81 021 The team noted that the Shif t En0 'ioer training program 1
description did not include trainin0 n Emor00ncy Plan i
implementation, Emer00ncy OperatinD Procedutos implomontation, or use of Emergency Hosponso Facility Information System (ERFIS). The incomplete progra61 description is considered a deficioney.
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VY acknowled es that the Shift En0 neer TraininD Program VY Resngnsm description is incomplete. As was noted in the inspection report, however, Shif t Engineers have received training in all of the above topical areas. VY is currently conducting a validation of the Shift Engineer task inventory and training pro 0 ram. The program description and task inventory will be updated by October 1,1992. Any additional traininD resultinD from this process will also be conducted by October 1,1992.
Deficiency RU/918103:
The loss of Chemistry Technician training completion data was identiflod during an internal audit by the licensoa and confirmed by the team. This Indicates a deficioney in the administration of Individual training records, y1.Eplannsm This problem occurred during a change of personnelin the Training Department. Only one individual's records were lost and that individual has been retrained and rotested in the affected areas. To minimize the possibility of a similar problem in the future, Trainir.0 Department procedures have been revised to require records to be transferred to the records clerks in a timely manner. Both an internal and NRC review indicated that this was an isolated case. VY considers this problem to be resolved.
Deficiency 271/91 81-Q_4; The lack of clearly defined responsibilities and authority of 4
personnelin the TDDs is considered a deficiency.
YY RSSD9nsg1 VY acknowledges that the TraininD Department Directives -
(TDDs) are inconsistent and are Generally in need of improvement. Starting in April 1992, we will improve the quality of the TDDs to address this deficiency and the other weaknesses identified in the inspectlan report. Specifically, the TDDs will be restructured to provide more direct guidance on task analysis and other aspects of a systematic ar.liroach to trainin0. Additionally, inconsistencies between TDDs will be eliminated. All TOD improvements will be completed by October 1,1993.
1 4
Deficiency A
2]EDh0hQD1 The team considers the lack of test items for each learnin0 objectivo to be a deficioney. (This deficiency is in reference to the LOI pro 0 ram.)
VY Resngnsel This deficiency was discussed at lon0th with the NRC at a mootin0 at the regional of ficos on March 4,1992. Based on the discussion from this meeting we will review the Licensed Operator Initial training program and insure that each task /
terminallearnin0 objectivo can be evaluated by either written test questions, OJT guidos, or simulator observations, Additionally, we will revise traininD materials to better distinguish between terminal and enabling objectives. This review will commence in April 1992 and the development of additional objectives and evaluation tools will be completed by October 1,1993.
Deficiency 271/R181-QG1 The lack of prodefined evaluation critoria for SEs performanco in simulator tralninD s considered a deficiency.
i YY Respoluna VY acknowled0es that the Shif t En0 neers (SEs) should be i
formally evaluated in tae simulator and wo will develop ovaluation criteria and an evaluation tool by October 1,1992.
Deficiency:
32)) DES 1-Q21 The team noted that...the annual program ovaluations included recommendations for improvement. Howevor, the recommendations are not prioritized or tracked to completion.
The annual evaluations are bl hly variable in detail. The lack 0
of a systematic method for generatin0 and ucing the pro 0 ram ovaluations is considered a deficiency.
VY Respnnsel VY acknowledges that the program evaluation process has not been fully effective. We will review the previous pro 0 ram evaluation recommendations and prioritize and track tn completion 6ny recommendations of ment that have not l'oen pursued to date. This review will be completed by July 1,1992. Additionally, we will review and improve this process to make it more effective. The review of.he process and any necessary improvements will be completed by January 1,1993 in order to facilitate next year's program evaluations.
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