NRC-94-0007, Responds to NRC Re Violations Noted in Insp Rept 50-341/93-19 Re Annual Simulator Exam of Individual Operators Against Established Standard & Documentation of Plant Control & Reactivity Manipulation Training

Responds to NRC Re Violations Noted in Insp Rept 50-341/93-19 Re Annual Simulator Exam of Individual Operators Against Established Standard & Documentation of Plant Control & Reactivity Manipulation Training

ML20063H426
Person / Time
Site:	Fermi
Issue date:	02/11/1994
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-94-0007, CON-NRC-94-7 NUDOCS 9402180047
Download: ML20063H426 (7)

Text

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Douglas Ft. Gipson Senior Wce Pres 6 dent i e Nuclear Generation Detroit re-6400 North Dme Highway Edison ::=y -

fedruery,i, 1994 NRC-94-0007 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.

20555

References:

1)

Fermi 2 l

NRC Docket-No. 50-341 NRC License No. NPF-43 2)

NRC Inspection Report 50-341/93019, dated January 14, 1994 1

Subject:

Response to Notice of Violation 93-019-01 Enc]osed is the response to the Notice of Violation contained in Reference 2.

While Detroit Edison agrees that our Licensed Operator-Requalification examination security controls should be strengthened to reduce the chance of inadvertent disclosure or compromise of annual l

examinations, Detroit Edison does not agree that the weaknesses noted have resulted in a violation. The enclosure to this letter provides the basis for the company position, and it describes our planned actions to strengthen eram security.

Reference 2 also identified two concerns regarding annual simulator examination of individual operators against established standards and document.ation of plant control and reactivity manipulation training.

As requested, a response to these concerns is also enclosed.

l If there are any questions regarding this response, please contact l

Joseph Conen, Senior Compliance Engineer, at (313) 586-1960.

j Sincerely, Enclosure l

cc: T. G. Colburn l

J. B. Martin H. P. Phillips K. R. Riemer Region III 9402180047 940211

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{DR ADDCK 05000341

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Enclo ueo to NRC-94-0007 Page 1 Statement of Violation 93-019-01 10 CFR 50, Appendir B, Criterion V, " Instructions, Procedures, and Drawings, " requires that activities affecting quality be accomplished in accordance with aucumented instructions and procedures.

Licensee procedure CP-OP-232, " Annual Requalification Examination,"-

Rev. 2, section 3.4.2 3, requires annual administration of a simulator-test as described in the Examiner Standards in.NUREG 1021.

NUREG 1021, Section ES-601.C.4.b states, in part,

" Facility representatives who acquire specific knowledge of the NRC examinations will sign Form ES-601-1, ' Examination Security.

Agreement,' or a reasonable facsimile, before their examination.

involvement begins and again after the examination process is complete

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(i.e., the exit meeting). Facility representatives who sign Form ES-601-1 document their adherence to the following security restrictions:

-They shall not participate in any facility requalification' training.

programs (e.g., instruction, examination, or tutoring) involving.the, licensees selected for the examination."

1 Contrary to the above, the licensed operator requalificationLtraining supervisor, who was knowledgeable of the exam, administered practice' scenarios during the week of November 22, 1993, to one operating crew selected for examination the week of November 29, 1993 The i

supervisor avoided giving planned exam scenarios-but purposely selected scenarios that were similar.

Detroit Edison Response While Detroit Edison acknowledges that exam security controls should 1

be strengthened to reduce'the chance of inadvertent exam disclosure or compromise, Detroit Edison does not agree that these weaknesses constitute a violation i

i Basis for Detroit Edison Position l

This violation was issued for failure to implement the requirements of1 form ES-601-1, Examination Security, contained in NRC Examiner Standard ES-601. This was characterized as a' procedural _ violation because Fermi Course Plan CP-OP-232 states in part, " Simulator Performance - developed and administered as described in ES-601."

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Enclosura to

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NRC-94-0007 i

Page 2

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This statement occurs in section 3.4.2 3 of CP-OP-232, a subsection H

from Section 3 4, " Course Content". The context of'this statement is I

that it is a " description" of the Simulator Performance unit,.one of the units which must be' passed "by criteria established in ES-601".

The intent of this statement is that our utility. administered annual j

exam consists of the same type of examination the NRC uses for "NRC

-j Requalification Program Evaluations". ES-601 refers to ES-604 on the required content, conduct, and grading criteria for the Simulator l

Performance examination. CP-OP-232 is not intended to cover the details of the examination process.

Details of the examination process, including examination security, i

are addressed in Nuclear. Training Procedure NTP-TQ1-07, Examinations, and the Operations Training Program Guidelines (OTG's) referenced in.

NTP-TQ1-07 This procedure prohibits disclosure of examination information to trainees, but it does not bar personnel with knowledge 1

of examination material from conducting. training. No disclosure of examination material occurred.

Procedure NTP-TQ1-07 also states that " security agreements shall be developed and completed as necessary for Operations Training. Such.

agreements shall be controlled by the Operations Training guideline."

While security agreements would prohibit anyone with specific' l

knowledge of NRC examinations from instruction of licensees selected for the examination, Operation Training Guidelines (OTG) require the use of NRC security agreements only for NRC administered examinations. This is consistent with NUREG 1021, Section ES-601.C.4.

None

' these documents requires-the use of.the security-agreement for *

.tity administered exam. Security agreements were not used fcc. 2s or any of the other requalification exams which were not administered by the NRC, nor are security agreements used for other examinations administered during the course of the year,.even though instructors remain prohibited from-disclosJng examination information to traineas.

1 Based or the above information, Detroit Edison never intended that the i

security agreement requirement for NRC examinations be applied to utility administered annual examinations. This includes the

-l restriction in the security agreement which prohibits instructors with i

knowledge of examination materials from participating in the l

instruction of exam candidates.

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l Enclosure to NRC-94-0007 Page 3 i

Seconelly, the Notice of Violation states, in part, that "the licensed operr. tor requalification supervisor, who was knowledgeable of the exar., administered practice scenarios during the week of November 22, 1993, to one operating crew selected for examination the week of November 29, 1993." This is a true statement. The Notice of Violation goes on to say that "the supervisor avoided giving planned exam scenarios but purposely selected scenarios that were similar."

It is true that the supervisor selecte'd scenarios to avoid using the planned exam scenarios for the practice session. The second part of the statement, however, could be misconstrued in that it implies that the training supervisor used his knowledge of the exam to select similar scenarios.

The main similarity between the scenarios selected for the practice sessions and those selected for the examination is that most of the practice scenarios included either ATWS or LOCA casualties, and the exam scenarios included an ATWS and a LOCA cas alty. The fact is, however, that over 90% of the evaluation scenarios used during 1993 contained either an ATWS or a LOCA in order to fully test operators' mastery of all legs of Emergency Operating Procedures (EOP's). This was simply a continuation of the same pattern followed throughout the year and was in no way intended to be nor did it result in any revelation to the examinees of the content of the scenarios to be used in the examination.

In fact, the scenarios used for the practice sessions were purposely-selected to avoid using the examination scenarios, which could have been unknowingly used had another instructor conducted the practice sessions. Also, in the scenarios used for the practice session, the events leading up to these major plant casualties were not similar to those used in the exam.

The NRC inspectors concurred at the time of the examination and during the exit meeting that there was not any question as to the integrity of the examination or the intention of the supervisor.

Actions Planned to Improve Examination Security The current procedural guidance on examination security adequately addresses intentional disclosure of the content of an examination to the examinees. However, as noted in the notice of violation and in the other examples of weak exam security discussed in section 2.1.1.A of the referenced inspection report, the potential for inadvertent disclosure of examination material exists.

Enclo;urs to NRC-94-0007 Page 4 In order to prevent training personnel from inadvertently disclosing cramination materials, the applicable training procedures will be ravised to prohibit personnel who prepare the Licensed Operator R qualification annual examinations (or otherwise become knowledgeable of their content) from otherwise examining, instructing, or tutoring licensees who will take the exam once they have obtained specific knowledge of the examination material. Personnel involved in the development, review, or administration of the annual eram will be required to review these procedures prior to gaining specific knowledge of the centent of the examination. We will also brief the examinees on examination security requirements to make them aware of the sensitivity of this issue. This will allow the er.aminees to help ensure that examinations are not compromised. These procedures will also prescribe the actions to be taken if it is believed that a disclosure has occurred. These procedure revisions will be completed by August 31, 1994 to support preparations for the 1994 requalification examinations.

To ensure Operations Training Instructors are aware of the weaknesses identified during this inspection, training will be conducted that will include a review of the events as they occurred during the examination, the expected conduct of the examination, and the procedural changes implemented as a result. This training will be completed by October 31, 1994 to support the 1994 requalification examinations.

Detroit Edison believes that these actions will improve our performance on examination security and will ensure appropriate security controls are in place for annual utility administered licensed operator requalification examinations.

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4 Encloruro to NRC-94-0007 Page 5-Response to Open Item 93019-02 Concerning Control Manipulations l

During routine training and evaluation simulator sessions conducted in the two year requalification cycle, the operators are rotated through the various shift positions required by their operating licenses.'

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Individual operators are challenged in various positions for different combinations of the control and reactivity manipulations.. Critiques of their performance are conducted and comments from these critiques 4

j are entered into a computer data base for tracking. Comments can also be added to the data base at the request of the operators if they feel the need to review any aspect of their performance in'either the simulator or the plant. These comments are periodically reviewed with the operators. Additionally, tracking of these comments allows the instructor to assign licensees to simulator positions which exercise skills or functions that had previously been identified as needing improvement.

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Deficiencies noted in operator performance from operation of the plant 3

are also used to determine training needs. Critiques. Lessons Learned, Deviation Event Reports, and written and.lerbal communication with Operations Department personnel are all mechanisms to inform Nuclear Training of these deficiencies.

The use of the performance tracking data base and review of plant event data allows us to tailor training to address identified needs.

instead of training on evolutions'on a fixed periodicity.

At the end of each year each licensed operator is examined.using a dynamic simulator evaluation and Job Performance Measures (JPM).

3 These two portions of the annual examination ensure mastery in the i

perforaance of a sampling of the control and reactivity manipulations for each operator.

The Licensed Operator Requalification Program ensures the licensed operators can perform all necessary activities through training focused on areas of identified need and evaluation of a sampling of 1

these activities. Implementation of this Systematic Approach to Training (SAT) based program as allowed by 10 CFR 55.59 emphasizes and.

utilizes feedback and evaluation processes to maintain the high operator performance standards required by Detroit Edison and the NRC.

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Prior to adoption of this approach, tracking of the control and reactivity manipulations described in 10 CFR 55.59 was performed. At that time credit was assigned to all members of the crew for

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evolutions included in a given simulator scenario. Currently, the control and reactivity manipulations are not tracked and tallied;.

instead, trainee mastery of control manipulations is evaluated on the i

sampling basis described above. To strengthen this process, Detroit Edison will develop a course plan containing control manipulations.

3 Credit will be given only to those licensees who perform, direct (SRO), or directly participate in'each control manipulation. This course plan will be in place by May 31, 1994.

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Enclosuro to NRC-94-0007 Page 6 '

Response to Unresolved Item 93019-03 Concerning Individual Annual l

Operating Examinations Annual dynamic simulator operating tests are conducted as required by 10 CFR 55.59(a)(2). The selection of the evaluation scenarios to be

'1 used for the eram is based on the sample plan created for the exam.

This sample plan ensures that the licensees are examined on a sample from all the operating skills and abilities required of an operator and the operating crew. This selection of the scenarios ensures a l

sample of the items listed in 10 CFR 55.45 (a)(2) through (13) are l

tested to the extent possible.

l NUREG 1021 Section ES-604 contains provisions for dealing with an l

individ621 who " demonstrates significant deficiencies performing a critical task." These provisions include the possibility of l

conducting an additional scenario or JPM to obtain additional 1

information on the abilities of the licensee. ES-604 goes on to say that individual follow up is conducted if a licensee has significant performance deficiencies linked to a Critical Task (CT) and that upon completion of the evaluation a competency grading worksheet is completed.

Detroit Edison uses a similar process in that during the simulator cvaluation, the evaluators critique the performance of the crew against the performance standards established in each scenario.

If significant individual performance deficiencies are noted, corrective l

actions are taken. This may include removing the licensee from operator duties until he has been properly remediated and reexamined to determine that the deficiency has been corrected.

i The crew's performance during the examination was satisfactory with no noted significant individual performance deficiencies. Therefore the facility evaluators concluded the evaluation as "all pass, team pass." This is a term frequently used to convey to the operators their overall performance in the scenario. Comments on individual performance were still reviewed with the crew and entered into the data base for further tracking and action. This process did not explicitly demonstrate to the NRC inspectors that' objective evaluation of each individual occurred during the dynamic simulator examination.

The scenarios include a matrix which identifies the crew critical tasks that are expected to be observed during the evaluation. The matrix Jdentifies which member (s) of the crew is expected to accomplish the task, and each task has objective success criteria.

During the evaluation, the individual performance of each task, including the critical tasks is evaluated. Also, if a task is not performed by the expected licensee, the instructors consider why this may have happened to determine if further assessment or remediation of that licensee is required. Detroit Edison will revise the appropriate procedures to ensure that the individual evaluations as well as overall crew evaluations are performed and documented during each annual operating examination as required by 10 CFR 55.59(a)(2). This will be completed by August 31, 1994.