ML20127J834
| ML20127J834 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/20/1993 |
| From: | Mascari C GENERAL PUBLIC UTILITIES CORP. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| C321-93-2017, NUDOCS 9301250271 | |
| Download: ML20127J834 (6) | |
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GPU Nuclear Coqxwstion Nuclear rvsipceny. New Jersey 07054 201 316-7000 TELEX 136 482 Wnters Dvoct DW Numbcf I
January 20, 1993 C321-93-2017 Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission g-Washington, DC 20555 Gentlcmen:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 3
Supplemental Information in Support of Request for Schedular Exemption from Requalification Testing Requirements Raf:
GPUN Letter C321-92-2347 from C.A. Mascari to Director, Office of NRP., dated January 4,1993.
in the letter referenced above, GPUN requested a schndular exemption from the requirements of 10 CFR 55.59(a)(1) and (c)(1) to allc't the current requalification program duration to be extended from 24 to 3? months.
This would allow both the written and operating pertions of the raqualification exam to be jointly administered by the NRC and GPUN in August 1993 when the new plant referenced simulator will be available for all aspects of operator evaluation.
In a telephone conference with the NRC on J;nuary 15, 1993, GPUN provided additional information in support of the exemption request.
This information is documented in Atta:hment 1.
This exemption is requested to resolve a unique one-time situation.
As stated previously, we believe this exemption is the most logical and efficient resolution to the scheduling challenges in meeting 10 CFR 55.59 operator requal;fication requirements during this transitional period when the new plant referenced simulator is being integrated into our operator training programs. Attachment I describes additional compensatory actions that will be takea in our licensed operator requalification training program during the period of exemption in the event that our request is granted.
The attachment specifically addresses the issue of operator stress.
Based on past experience, we believe the exemption would relieve a significant amount of undue operator stress bj allowing administration of all portions of the requalification exam in a short tire interval.
Further, we strongly believe the exemption would allow GPUN to prepare a botter quality written exam that will produce a more meaningful assessment of our operator skills and their training program. Without this exemption Operations and Training Department
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4 C321-93 2017 Page 2 of 2 personnel and resources would be significantly diverted from ongoing 14R refueling outage activities, simulator site acceptance testing, and simulator training scenario development and validation, if there are any questions regarding this matter, please call Mr. Michael lleller, Licensing Engineer, at (609) 971-4680.
Sincerely, b.
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C.A. Nascari Vice President & Director Nuclear Assurance Attachment cc:
NRC Document Control Desk Mr. L. Bettenhausen, NRC Region I Senior NRC Resident Inspector Oyster Creek NRC Project Manager r
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Attachmeq1_1 The following information is provided in support of the subject exemption request:
1.
One ra t.py_S_t_r.nl The exemption would relieve a significar.t amount of undue operator stress.
Previously, the use of the Nine Mile Point Unit I simulator for the dynamic simulator portion of the exam necessitated delays between the administration of the writttn and operating portions of the exam of several months.
Feedback from both operators and examiners indicated that being in an " examination inode" for such an extended period was stressful.
Additionally, the few operators who failed in the initial phases of the exam could not be remediated until the exam process was complete and a determination made on the adequacy of the requalification training program. This resulted in some operators being off shift in an unqualified status for months and this in turn seemed to affect some individual's attitudes regarding self-image and esteem.
This is another aspect of stress related to a-protracted exam process.
Administration of a writt xam in March / April with an operating test in August creates the samt,a tuation as above.
It is our objective to minimize this type of stress and we believe our' efforts are in keeping with the spirit and intent of SECY-91-391 (NRC staff letter to the Commissioners) entitled "Results of the Study of Requalification-Examination Stress", dated December 3, 1991.
2.
Exam Quality The exemption would allow for a more complete and systematic development-of a static simulator exam for the following reasons:
a.
Simulator Modifications - The cutoff date for modificttions that were included with the simulator was 1988. Allowing the written exam to occur with the operational exam in August 1993 will. provide 5 months to add as many modifications as1possible. A better quality static simulator exam would result if the exam is conducted after these modifications are in place.
b.
Validation of Simulator Scenarios - Understandably, the simulator is notEscheduled to support.the development and validation of static and dynamic simulator scenarios until after Site Acceptance Testing (SAT). -There would be little time to complete and thoroughly review and validate the static exam bank prior to a March / April 1993 exam.
Here again, overall-exam quality would be impacted.
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C321L93-2017-Page-2 of 4 j
c.
Emergency Operating Procedures (E0Ps) - An upgrade of the E0P flowchart format, climination of the text version of E0Ps and the addition of E0P support: procedures is in progress.
This effort is expected to-be completed.
conenreent with the end of our 14R refueling outage in mid-February.
Additionally, the E0Ps have been significantly impacted by several 14R modifications.. There would be little time to develop and validate new E0P based questions for a March / April exam.
We believe that the benefits of the roqualification em process include identifying areas for individual' operator upgrade as well as those
- i portions of our requalification training 3rogram for enhancement. Our-plant referenced simulator will provide.t To cornerstone for this c
process, however the quality of a static simulator portion of a written i
exam dona on the machine in March / April will be significantly less than that of the same effort conducted later in the year.
In.all probability, some opportunities for improvement will be missed if the exemption is not granted, 3.
Other factatt 1
Without the requested exemation, comprehensive written exams would have j
to be administered in Marc 1/ April 1993.
In order:to accomplish this, 1
Operations and Training department per.onnel and resources would have to
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be significantly redirected. This is highly undesirable for the following reasons:
a.-
14R Refueling Outage - The outage began on November 27, 1992 1
and is scheduled to be' completed by mid-february 1993.
Redirecting certain key operations personnel at this time to.
. prepare for a comprehensive written exam-in March / April may impact the progress of the outage to some extent.
b.
Simulator Development 4 6 operations training. instructors
- are currently participating in Site Acceptance Testing (SAT) of the simulator which is scheduled to.be cwoleted by January 31, 1993.
Redirecting these instructors during~this ef fort to prepare for a compreheresive written exam:in March / April 1993 will have a direct :iinpact on the progress of simulator. development, c.
Training Impact - As. described above in item _b,'a slippage in the simulator development schedule caused by a March / April comprehensive written exam will have a spill-over effect in the area of simulator training scenarlo-validation and development. This effort is set to
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m-4 C321-93-2017 Attachment.1 Page 3 of 4 dramatically increase upon completion of Site Acceptance-Testing. Any significant impact on the validation and development effort will adversely impact the quality of-simulator training in the initial months of operator exposure to the machine - a time when initial operator perceptions of the machine will be fully estchlished.
This exemption is requested to resolve a uniquc one-time situation.
The plant referenced simulator was certified on December 31, 1992 and is scheduled to be-available for conducting an'opcrating test in August 1993.- This schedule reflects the need to ccaduct 3 cycles (6 months) of training on the simulator _ before a test is conducted.
During this-interim period when the new plant referenced simulator is being lategrated into our training programs, we are striving to. provide our-operators with the best possible raqualification training, q
4.
6.dditional Information the following schedule identifies the number of operators needing a written exam in 1993:
Ban 1h No. of Operators March 15
- April 15 May 19 June 14 In addition, therc are 9 operators whose licenses expire _before _ the endl of 1994 and who have not had a comprehensive requalificatlon written exam and operating test administered by the-NRC during the: term of their.
six-year licenses as required by 10 CFR 55.57(b)- for. license renewal. -
License expiration dates for the next-two years are-as follows:
Qperator license No.
Docket No1 10g). Date E. Irizarry OP5695-3 55-7694 10/27/93 -
D. Pietruski SOP 10073-2 55-7124 11/03/93 4
G. Voishnis S0P10712 55-60537 11/11/93 J. Costic OP5906-3 55-7564 03/27/94 B. Anderson OP10698 55-60526 05/14/94-W. Reilly OP10701 55-61052-05/20/94 J. Boyle-50P10213-2 55-7562
- 09/11/94 G. Cropper SOP 10216-2 55-7690 09/11/94 N. Boulware 50P3403 55-4338 12/13/94 i
As a minimum, it is planned to have all the above-personnel examined by
-the NRC in 1993.
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C321-93-2017-
-Attachment 1 Page '4 of 4 5.
Addit _ignal Comognatory Actijm1 I-During the exemption period, we will administer cyclic written quizzes that cover both the current training cycle subjects and previous biennial training.
At least 20% of the written quizzes will cover previous biennial training.
Thus, they will be comprehensive in nature.
Additionally, at least a portion of the weekly quiz will be either in a t
Section A or Section 8 format as defined in the NRC Examiner _ Standards (NUREG 1021). Also, we will administer a dynamic simulator-scenario as-part of each training cycle's evaluation.- Any identified individual or crew weaknesses will be appropriately addressed in the following week-(relief week) for the individual / crew involved.
This is in addition'to our prioritized plan of areas for simulator training emphasis that will be finalized by January 31, 1993.
These areas for improvement were identified by review of past requalification exams, INP0 audits, Oyster Creek vs. Nine Mile Point Unit I simulator differences, Oyster Creek operating experience, other utility operating experience and selected-industry reports. These areas will be covered in our simulator training efforts over the period of the requested exemption.
Any additional identified areas will be factored into training utilizing the framework providea by our systematic approach to training.
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