ML20205N420
| ML20205N420 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/12/1999 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-98-302, 50-362-98-302, NUDOCS 9904160270 | |
| Download: ML20205N420 (4) | |
Text
-
Dwigllt L Nunu
\\ h e l'temk nt An ll>lv h. *1RN411tl\\Tl *(un.pm>
April 12,1999 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Subject:
Docket 50-361 and 50-362 Response to Training Weaknesses San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
NRC Inspection Report 50-361/98-302: 50-362/98-302 to Harold B. Ray from John 1.. Pellet, dated January 4,1999 l
Gentlemen:
As requested in the referenced correspondence, attached is Southern California Edison's reply to the weaknesses in the examination meterial used for senior and reactor operator license training.
Any actions listed are intended to ensure continued compliance with existing commitments as discussed in applicable licensing documents; this reply contains no new commitments. If you require any aaditional information, please so advise.
Sincerely,
(
cc:
E. W. Merschoff, Regional Administrator, NRC Region IV J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 and 3 L. Raghaven, NRC Project Manager, San Onofre Units 2 and 3 Institute of Nuclear Power Operations (INPO)
V
/
\\
l' o Ibn 12e
%n ( ico a:. ( \\ u2074 t> l 2r w49 it a i4xo I s.
aN ~,t,r14m>
Reply to inspection Report 98-302 Page 1 of 3 EVENT _DESCRIPTIQN; in order to support Operation's need for additional licensed personnel, Southern Califernia Edison (SCE) voluntarily developed a license examination using the guidance in NUREG-1021, " Operator Licensing Examination Standard for Power Reactors," Interim Revision 8. SCE had limited training staff and did not have pnor experiente with implerranting the most recent version of the regulations and hence this
)
effort was contracted to an outside vendor with prior experience in license examination development and construction. The consultant was contracted to produce the deliverables in accordance with NUREG-1021 and based on his experience, the deliverables were expected as a turn-key product requiring very minor modifications from draft reviews.
Contrary to expectations, the materials supplied by the vendor were initially incomplete and required extensive revision due to technical inaccuracy and psychometric inadequacy. This caused the SCE personnel to assume the role of exam'. nation devciopers with the consultant, and there was no longer autonomy between the development and review aspects of exam material preparation. As a result, modifications made to exam materials did not receive independent review, and the effect of these modifications on the overall exam was not adequately anaiyzed prior to the submittal of examination materials to the NRC. In addition, a time validation of the written portion of the examination was performed using an incomplete exam draft rather than the final NRC approved version.
Candidates performance was also potentially impacted by the simultaneous conduct of license and certificatico training. Tiaining for the November,1998 license class overlapped training for both the June,1998 license class and a facility SRO certification course. Instructor and facility availability at times necessitated the inerger of the November class of license candidates with the SRO certification class. This merger resulted in increased class size and strained the ability of the training program to be responsive to the candidates' individual needs.
The type of periodic examinations administered during the training program did not adequately prepare the candidates for NRC type written examinations. The periodic examination test items were typically not designed to assess trainee competence at the higher cognitive levels. In addition, the trainir g material contained weaknesses in the Health Physics limits, Technical Specifications (including bases) and administrative procedures portions.
Reply to inspection Report 98-302 Page 2 of 3 Training division written exam administration could have also adversely impacted candidates performance. During the first hour of the written examination, the Reactor Operator or Senior Reactor Operator (RO/SRO) exam question correlation was not available in the examination room. Consequently, when a clarification was rnade to a candidate's question on one exam (either RO or SRO), the same clarificatlon could not immediately be promulgated to candidates taking the other examination. Thus, some candidates could have misinterpreted the question (s) without benefit of a clarification.
Also within the first hour, a reference page was not included in the RO examination material causing some candidates to answer without the benefit of the required reference. Candidates indicated these distractions increased the stress level during the exam.
ROOT CAUSE:
The root cause associated with technical inaccuracies of the examination was ineffective examination development, review and validation process employed by SCE.
The apparent root cause associated with training deficiencies, as represented by applicant performance, was attributable to ineffective change management.
CORRECTIVE ACTIONS:
Examination Development Process:
SCE formed a joint team with outside experts to determine a formal root cause for this event.
The process for development, review and validation of future exams was revised. The procedure used to direct the initial examination development activities was revised to include the following items:
Maintain distinction between exam developers and reviewers; Time validation by licensed operators of examination material prior to and subsequent to NRC approval; Provide specific guidance for exam complexity levels consistent with requirements of NUREG-1021; Submittal schedule of examination material to NRC Regional Offices; Enhance the written examination administration guidance; Exam review by a team composed of Operations Management prior to administration.
r Attechm,ent i Reply to inspection Report 98 302 Page 3 of 3 In addition, a new Training Manus! Administrative Guideline was developed to provide examination developers with explicit guidance regarding appropriate review and validation of both pre-license audit and NRC examination materials.
The post examination feed back process was enhanced for the current remedial trainirig program to include candidates comments on both the test and examination administration as part of a continuing improvement process.
Process enhancements will be developed to ensure review of draft examination materials identifies and eliminates redundancies within and between the various portions of the examination mateiials. These changes will be implemented prior to the next licensed exam (currently planned for September of 2000).
Initial License Training Program:
A remedial training program was developed and was administered to prepare the candidates who were unsuccessful on the November,1998 licensing examination.
Specific training was provided in the systems and procedures categories.
The initial License Training Programs will be enhanced prior to the next scheduled license class (currently scheduled to begin in April of 2000) to include the following changes:
A review of plant systems at the start of the Pre-License course; Pre-determine impact from the number of candidates and overlaps in classes; Improvement of lesson materials related to Health Physics limits, Technical Specification and Bases, and Administrative requirements; inclusion of more higher order cognitive questions to the Pre-license systems and integrated operations training segments; Additional time to review and practice answering higher order cognitive questions after the completion of the training program and prior to the audit examinations.
The process for planning and scheduling future initial license training classes will be enhanced to consider availabie resources, concurrent activities, and potential restrictions on class size to prevent conflicts and ensure training effectiveness. These changes will be implemented prior to the next licensed class (currently scheduled to begin in April of 2000).