PY-CEI-NRR-0921, Forwards Addl Info Re Response to Requalification Exam Rept 50-440/Ol-88-01 Deficiencies.Corrective Actions:Offnormal & Emergency Procedures Will Be Reviewed to Identify Tasks Currently Performed by non-licensed Operators

Forwards Addl Info Re Response to Requalification Exam Rept 50-440/Ol-88-01 Deficiencies.Corrective Actions:Offnormal & Emergency Procedures Will Be Reviewed to Identify Tasks Currently Performed by non-licensed Operators

ML20155G532
Person / Time
Site:	Perry
Issue date:	10/14/1988
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
PY-CEI-NRR-0921, PY-CEI-NRR-921, NUDOCS 8810170175
Download: ML20155G532 (5)

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THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P.O. BOX 97 m PEARY, OHIO 44081 m TELEPHONE (216) 259-3737 m ADORESS-io CENTER ROAO Serving The Best f.ocation in tne Nation PERRY NUCLEAR POWER PLANT Al Kaplan V1CE PAISJOENT PdVCLE AA GROUP October 14, 1988 PY-CEI/NRR-0921 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Additional Information For Our Response to Examination Report 50-440/CL-88-01 Gentlemen:

This letter provides additional information for our response (letter PY-CEI/NRR-0884L dated July 14, 1988) to the two program deficiencies identified in the Requalification Examination Report 50-440/0L-88-01 dated June 14, 1988. This supplemental information is provided as requested during discussions with Messrs. D. Hills and M. Jordan of your staf f on August 17, 1988.

If there are any further questions, please feel free to call.

Very truly y urs, 9

Al Kaplan Vice President Nuclear Group AX/sc Attachment cc: K. Connaughton T. Colburn G. Wright - USNRC Region III

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Attachmtnt PY-CEI/NRR-0921 L Page 1 of 4 Restatement of Deficiency at During development of the examinations, the faci'ity representatives indicated that training is not specifically provided in the licensed operator requalification program on the ability to operate the facility's auxiliary and emergency systems in the plant (i.e. outside the control room) other than the remote shutdown panel. Facility representatives indicated that such operations are performed by non-licensed operators and that these in-plant system operating abilities are, therefore, not included in the licensed operator's job task analysis. This is considered a serious program deficiency per 10 CFR 55.59)a)(ii), 55.45(a) and 55.45(a)(8). It is NRC policy that these tasks be included in the licensed operator's job task analysis and that licensed operators receive training and be evaluated during the requalification program on those tasks with sufficiently high importance ratings.

Restatement of Original Response to Deficiency as CEI agrees that improvement is needed in our handling of training licensed operators for tasks outside the control room. The pilot process made it clear that this is an area vhere the requirements have not been firmly established and where practices differ from plant-to-plant.

Training at Perry is provided to licensed operators on equipment, systems, and tasks outside the control room. The training included systems design details, system and component locations, and system valkdovns including in-plant

procedure usage. The evaluation process, both internally by CEI and formally by NRC, has damonstrated that the licensed operators are fully prepared to 7

perform appropriate tasks outside the control room.

Nonetheless, the training and the job analysis need improving. The training vas provided without a clear identification of the person who is responsible for performing the task. As a result, the training provided too much detail in  :

some areas and not enough in others. Responsibilities vere identified implicitly as a result of the training conducted. The job analysis for licensed operators includes tasks outside the control room but is vague on the level of detail required. In order to improve the training in this area, ve intend to identify those tasks outside the control room for which we hold the licensed operator accountable. This identification vill be made based upon those off-normal and emergency procedure tasks normally performed by a non-licensed operator. Such tasks which have high time sensitivity and high significance relative to safe shutdovn of the plant or mitigation of the consequences of an accident vill be incorporated into the job analysis for the licensed operator. These items vill be identified with an importance rating of 3.5 or higher whleh vill ensure that trainirig and evalur. tion occurs as i appropriate as part of the requalification program.

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- Attachmsnt PY-CEI/NRR-0921 L Page 2 of 4 Supplemental Response to Deficiency at CEI agrees that improvement is needed in our handling of training licensed operators for tasks outside the control room. The pilot process made it clear that this is an area where the requirements have not been firmly established and where practices differ from plant-to-plant.

However, as stated in the original response letter, licensed operators at Perry have received some limited training on outside the control room tasks. These tasks includa remote shutdown panel operation, redundant remote shutdown room operation, and special operations required in emergency procedures. Although the special operations training involves valve and lifted lead manipulations, it is classroom training only.

, In order to provide training to licensed operators on outside the control room tasks, the following actions vill be taken:

1. Current non-licensed operator tasks of significant importance (impc~>ance rating 2 3.5 utilizing NUREG 1123) vill be identified.

2. f',t-normal and emergency procedures vill be reviewed to identify tasks which are currently performed by nor licensed operators.

3. An analysis vill be performed on the tasks identified in steps 1 and 2 to assign specific importance ratings for Perry.

4. Justification and documentation vill be provided for any difference in importance ratings between NUREG 1123 and a Perry specific rating where the Perry rating is lover than 3.5.

5. Identified tasks with a Perry cpecific importance rating 3.5 or greater vill then be incorporated into requalification training.

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Attcchtsnt PY-CEI/NRR-0921 L Page 3 of 4 Restatement of Deficiency b During the administration of the simulator portion of the exam, the NRC did not rotate the individuals in the Unit Supervisor and shift Supervisor positions, because the licensee's requalification program did not rotate individuals in these posisions. The NRC finds this practice to be a serious program deficiency. Moving from the Unit Supervisor position to the Shift Supervisor position results in the SS being one step removed from direct involvement in licensed activities. The Unit Supervisor position on the other hand is at the forefront of licensed activities, and from a proficiency and competency standpoint, examining the SS in this position vould be more meaningful and vould more closely meet the intent of 10 CFR 55.45.

Restatement of Original Response to Deficiency b CEI feels that clarification of our existing program is rr. quired to resolve the identified concern with rotation of individuals to other positions of responsibility during the simulator portion of the requalification training program.

The License kequalification program was reinitiated at Per v on September 8, 1986. The program vas conducted in five-veek (or, after .anuary 1, 1988, six-veek) periods known as "cycles". During each cycle each licensed operator received one veek of trainings the training vas repeated veekly so that all shift crevs could attend. In addition to licensed operators, staff license holders, and recently, some non-licensed personnel (e.g., Shift Technical Advisor (STA]) attended. The sixteenth cycle was completed on June 17, 1988.

The Requalification Program censists of training and etaluation (classroom, simulator, and on-the-job). The two paragraphs which follov describe the portion of the training and evaluation process which involved the simulator.

1. Training Simulator training during the 16 completed cycles was completed 14 times using a three-man crev and twice using a five-man crev. Three-man crevs vere used to prepare personnel for old style NRC exams; five-man crevs were used to make the training more performance-based.

During training sessions using a three-man crev, the positions are Senior Reactor Operator (SRO), Reactor Operator (RO), and Balance Of Plant (B0P).

The SRO position encompasses the duties of both the plant Unit Supervisor (US) and the plant Shift Supervisor (SS), with heavy emphasis on the former.

Each SRO license holder received training in this SRO position during the 14 cycles of three-man training. In addition, during this training, each SP0 vas trained in the R0 and B0P positions to maintain their manipulative skills.

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During training sessions using a five-man crev, the positions are SS, US, RO, B0P, and STA. Training in this configuration vas conducted during Cycles 12 and 16. The focus of this team training was performance-based, with each person performing only in their normal plant job position. Hence, the SS trained only in the SS position, and the US performed only in the US position.

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Attech: Int I PY-CEI/NRR-0921 L l Page 4 of 4 )

2. Evaluation During the 16 completed cycles, simulator eva13 tion occurred in three ways:

1.) evaluation following ecch simulator scesion; 2.) one cycle was devoted to the anrmal operating exam (pursuent to 10 CFR 55.50 a2ii), and 3.) one

• week vas devoted to the "pilot" requalification exam. In each instance, operators vere evaluated in each of the positions in which they performed.

The annual operating exam was conducted in three-maa crevs, and the "pilot" '

requal exam was conducted in five-man crevs. During the annual operating eram each SRO vas evaluated in both the SRO position and the R0 position.

During the "pilot" requal exam each person was evaluated only in his normal job position *.

The "pilot" exam was conducted in accordance with the draft guidance in existence at the time which emphasized testing each crev member "appropriate to his/her license".

The only times that plant Shift Supervisors ar.d plant Unit Supervisors did not receive training and evaluation in the opposite SRO plant position vere during periods of performance-based, position-specific, training and evaluation. This occurred during Cycles 12 and 16. Ve hope that this clarifies the concern addressed in paragraph 3b of your letter.

Ve feel that the best way to maintain crev preparedness is to focus the training and evaluation on the objectives involved. On some occasions, this involves training in small groups on specific components or specific activities. On other occasions, this involves the entire control room team controlling the integrated operation of the plant. This approach has been endorsed by INPC and has proven successful for us.

Supplemental Response to Deficiency b In the future, Perry vill continue to provide plant Shift Supervisors (SS) and Plant Unit Supervisors (US) training and evaluation in both the SS and US positions.

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• (except that accommodations vere made for one person who performs in the

plant as an R0 but who holds an SR0 licensel to accommodate this person, he )

was evaluated during the pilot exam as an R0 and as a US, and likevise one {

US vas tested both as a US and as a RO).

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