View source for NRC-90-0139, Responds to NRC Re Memorization of Immediate Operator Actions in Abnormal Operating Procedures (Aop). Definition of Immediate Action Under Review to Provide Mechanism for Consistent Application to All AOPs

{{Adams
| number = ML20059D110
| issue date = 08/31/1990
| title = Responds to NRC Re Memorization of Immediate Operator Actions in Abnormal Operating Procedures (Aop). Definition of Immediate Action Under Review to Provide Mechanism for Consistent Application to All AOPs
| author name = Orser W
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-90-0139, CON-NRC-90-139
| document report number = NUDOCS 9009060096
| title reference date = 07-06-1990
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 2
| project = 
| stage = Request
}}

=Text=
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August 01, 1990                          :
NRC-90-0 M9 i
f           U. S. Nuclear Regulatory Commission Attention: Document Control Desk i           Washington, D. C. 20555                                                                           ,

==References:==
: 1) Fermi 2
* NRC Docket No. 50-341 NRC License No. NPF-43
: 2) NRC Examination Report No. 50-341 OL-90-01, dated July 6, 1990                                         ;

==Subject:==
Response to NRC Concern on Memorization of Immediate Operator Actions in Abnormal Operating Procedures This is Detroit Edison's response to your request in Reference 2 to i           inform you of our action plan to address immediate action statements l           in our procedures which need to be memorized by the licensed operators and the use of memorandums to identify those procedures.
During the May 1990 Licensed Operator Requalification (LOR)'
examination, at least one candidate was graded unsatisfactory by the'
;           NRC examiner because he used a procedure, an Abnormal Operating Procedure (AOP), to perform an freediate action rather than performing                            '
the action from memory. The operator believed this'to be acceptable since there existed a memorandur, that specified which AOP immediate actions were required to be memorized and this AOP was not identified on that list. This memorandum contained only a limited number of AOPs. A revised memorandum was issued immediately which superceded the prior memorandum and required that immediate actions in all AOPs be committed to memory by all licensed operators. This memo served as temporary notice of these requirements until an administrative procedure was revised to further define the scope to which these requirements apply.
A Deviation Event Report (DER 90-0378) was written to address the issue of licensed operator memorization of immediate actions in AOPs.                            .
Corrective actions involve the cancellation of both memorandums, a revision to the operations administrative procedure, and reviews / revisions to AOPs and Job Performance Measures (JPMs) discussed later in this letter.                                                                   <
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  -                                                                                            i
    .*     U. 5. Nuclear Regulst:ry Commissicn
        ,  WRC-90-0139                                                                         :
August 31, 1990                                                                     i Page 2 The exit meeting also addressed a related issue; the use of a memorandum is not an accepted way to control the use of procedures.                 ,
Specifically, newer procedures containing immediate actions would not be listed on the memorandum. A review of operations.nemoro*as was performed and revealed that there were no other memorandums e d to control other operating activities.      Subsequently, an operat4cns administrative procedure (NPP-PR1-01) was revised to include the requirements that all licensed operators commit to memory all immediate actions in all AOPs. This places Fermi 2 in compliance with               '
NUREG-1021. The memorandum previously discussed, that contained these same instructions, was then cancelled. This effectively eliminated                  ,
the use of memorandums to direct operating activities.
4 Currently, the definition of immediate action is under review to provide a mechanism for consistent application of the definition to all AOPs. It should be noted that only AOPs contain."immediate action" statements. Changes to AOPs will be made, if necessary.
JPMs have been reviewed by licensed operators as part of their licensed operator requalification class. The areas addressed included a preliminary reference review, a critical step review, and a plant walkdown. Revisions to the JPMs will be made, if necessary, upon completion of AOP reviews and revisions. The revisions to the AOPs could affect other areas of training material, such as, task analysis, objectives, student descriptions, lesson plans, and examination banks.
An ongoing evaluation of operator knowledge of the revised AOPs will be conducted. This evaluation will continue with each subsequent AOP revision and until all AOP revisions have been completed. The expected completion date for all actions is February 20, 1991.
Should you have any questions regarding this response, please contact Barbara Siemasz, Compliance Engineer, at (313) 586-1683 Sincerely, cc     A. B. Davis R. W. DeFayette l                 W. G. Rogers J. F. Stang
                , Region III i
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