View source for U-602205, Responds to Insp Rept 50-461/93-14 Concern Identified Re Method That Licensed Operators at Plant Are Given Credit for Training on Plant Control Manipulations Specified in 10CFR55.59(c)(3).Details on Requalification Program Encl

{{Adams
| number = ML20059K908
| issue date = 10/28/1993
| title = Responds to Insp Rept 50-461/93-14 Concern Identified Re Method That Licensed Operators at Plant Are Given Credit for Training on Plant Control Manipulations Specified in 10CFR55.59(c)(3).Details on Requalification Program Encl
| author name = Phares R
| author affiliation = ILLINOIS POWER CO.
| addressee name = Martin J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000461
| license number = 
| contact person = 
| document report number = U-602205, NUDOCS 9311160236
| package number = ML20059K889
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

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* Ilknors Power Company   1 Chnton Power Station P.O. Box 678 Chnton. IL 61727        I Tel 217 93s-8881 PGWER U-602205 October 28, 1993 L42-93(10-28)LP I A.120 l
Docket No. 50461                                                                10CFR55.59 Mr. J. B. Martin _                                                                                   '
Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

==Subject:==
Response to Open Item 461/93014-02(DRS)

==Dear Mr. Martin:==
In the cover letter to Inspection Report No. 50-461/93014(DRS), a concern was identified regarding the method that licensed operators at Clinton Power Station (CPS) are given credit for traimng on the plant control manipulations specified in 10CFR55.59(c)(3).
This concern is being tracked as open item 461/93014-02. This letter provides the Illinois            :
Power Company (IP) response to the subject concern.
f The CPS Licensed Operator Continuing Training Program is based upon a systems              i approach to training (SAT), using the guidance ofNational Academy for Nuclear Training document ACAD 91-016, "The Process for Accreditation ofTraining in the Nuclear Power Industry " In accordance with 10CFR55.59(c), a SAT based training program may                    ,
be substituted in lieu of the requirements specified in 10CFR55.59(c) paragraphs (2), (3),          ~
and (4). The CPS Licensed Operator Continuing Training Program has been substituted                 -!
for the requirements contained in 10CFR55.59(c)(2), (3), and (4).
1 Specific details as to how the CPS Licensed Operator Requalification Program ensures licensed operators can perform, or direct as appropriate, plant control manipulations are provided in the attachment to this letter. These details address the concern expressed in the cover letter to Inspection Report 50-461/93014(DRS).
This response was discussed with Mssrs. M. Jordan and M. Bielby ofyour staff on October 21,1993, by Mr. J. Owens of the CPS Nuclear Training Department Licensed Operator training sta!Tand Mr. M. Reandeau of the CPS Licensing Department.                           I
                                                                                 'ncerely purs -             y         I
(                             -'h e       ~-              up i hard w P ares Director, Licensing Attachment cc:      NRC Clinton Licensing Project Manager NRC Resident Office, V-690 lilinois Department ofNuclear Safety 9311igoM PDR h h61-PDR G                                                                                            4@ u u a:O i-

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Open Item 461/93014-02 was initiated to track a concern regarding the method in               '
which licensed operators at Clinton Power Station (CPS) are provided credit for performing or actively panicipating in reactivity or plant evolution manipulations '                  !
performed either in the plant, or on the simulator. Specifically, it is the practice at CPS -          ,
that licensed operators on an operating crew in the simulator are given credit for performing a particular control or plant evolution by virtue of actual or focused                      .
participation during the performance of the control or plant evolution. Written response               ,
was requested to indicate what actions are taken by the CPS Licensed Operator                        .;
Requahfication Program to ensure licensed operators at CPS can perform plant control               .
manipulations in lieu of actual performance.                                                           l The Clinton Power Station (CPS) Licensed Operator Requalification Training                    .
Program was developed based upon a systems approach to training (SAT) as allowed by                    ,
10CFR55.59(c). This the identified concern: program mcludes the following elements which specifically address g
The performance of reactivity manipulations, plant evolutions, and                   !
casualties either in the plant or in the simulator, These activities are designed to maintain operator familiarity with plant control and response.          j Crew training and evaluations which utilize the CPS main control room                 ;
(MCR) simulator to maintain operator proficiency in time critical and plant           '
dependent behavior and to flag individual weaknesses. In-plant training is also provided to include tasks which may be significant contributors to core melt and public risk.
Annual operating exams consisting of simulator dynamic evaluations and individualjob performance measures.
The two basic types of manipulations described in 10CFR55.59(c)(3)(i) are
         " control manipulations" and " plant evolutions " As allcwed by a program developed using a systems approach to training, CPS has developed a list of control manipulations and plant evolutions that better represent the training needs of CPS. This list is utilized in lieu of the manipulations described in 10CFR55.59(c)(3)(i)(A) through (AA).
e The Illinois Power Company Nuclear Program Training Program Description for                    ;
O )erations Continuing Training (OPS /TPD) specifies the control and plant evolutions which each licensed individual shall perform, direct, or panicipate in on an annual or -
biennial basis. fhe current revision of the OPS /TPD does not provide specific guidance as              1 to how credit should be given for performing control manipulations and plant evolutions while performing licensed activities in the plant or while panicipating in training in the simulator. However, the OPS /TPD will be revised to reflect the current practice utilized at CPS for granting credit for performing manipulations. Specifically, for the " control" type manipulation, credit is received if the individual performs, directs, or othenvise directly panicipates in the manipulation. Being a member of the crew does not guarantee credit for the manipulation. An example of this is the CPS manipulation of"any significant
      - (+/- 10%) power changes in manual rod control or recirculation flow."' During an actual plant performance of this manipulation using manual rod control, another licensed                        ;
operator is verify'mg the actions of the licensed reactor operator (RO) who is performing                ;
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  ;.5 Attachment to U-602205 :
Page 2 of 3 the manipulation. This verification includes verifying rod selections and movement and verifying correct plant response to the rod movements. The licensed operator performing verification would receive credit for the manipulation along with the RO performing the manipulation and the senior reactor operator (SRO) directing the manipulation. Only these three individuals receive credit for the manipulation, not other on-shift licensed operators performing unrelated activities. The same principle ofparticipation also applies ~
during training sessions in the simulator.
The " plant evolution" type of manipulation is general in defmition as are the plant evolutions described in 10CFR55.59(c)(3)(i). A specific example described m 10CFR55.59(c)(3)(i)(Z) is " Main steam line break (inside or outside containment)." A        ,
CPS specific example is, " Events which produce the plant symptoms requiring the use of EOP's to control Drywell and Containment pressure." In both cases the actual " control manipulation" required to be performed by licensed operators vary dependent on the nature of the scenano. A SAT based program as allowed by 10CFR55.59(c), permits the           :
plant evolution type of manipulation to be performed using specificjob position tesks         -
identified from performance or industry feedback mechanisms. Participating as a crew member provides the individual with the necessary experience to respond to similar events.    .
Therefore, credit is given for performing the plant evolution to all members of the crew that performed the evolution.
It is routine practice during training and evaluations to rotate crew members        '
through the various shift positions required by their operating license. As part of the       ;
ongoing license evaluation during simulator training, crew members are assigned to specific team positions to routinely cause weaker team members to be challenged. .           1, Routine simulator evaluations are conducted at the end of a scheduled training week and        ;
are monitored by CPS management. At the end of each simulator session a critique of the individual and crew performance is conducted.~ Throughout the course ofthe two year            -
requalification program cycle, licensed individuals are challenged in vvying crew positions     j for combinations ofcontrol manipulations and plant evolutions.
In addition to the minimum requirements of control manipulations, a SAT based requalification program utilizes a specific job task base to identify continuing training needs. The CPS position specific task base is used to provide trammg and evaluation on an as needed basis. This results in a more detailed and focused approach to evaluatmg individual licansee performance.
* The CPS SAT based requalification program provides various feedback                    I mechanisms utilized to identify weaknesses in licensed operator performance. The              j feedback is used to provide either individual rernedial training and/or to design future         '
program training objectives for all licensed operators at CPS. A CPS program requirement exists to place individuals with significant performance' deficiencies in an accelerated retraining program. These performance deficiencies are identified during             ;
routine training and evaluation or during observation of actual plant performance. This          i retraining pmgram may include the removal of the operator from licensed duties.
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Job Performance Measures (JPMs) are additional tools used by the requalification propam to specifically evaluate individuals in the performance of their licensed duties. As        ,
a mmimum, JPMs are used annually to perform a selection of tasks identified by use of a          i sample plan.
The CPS Licensed Operator Requalification Program ensures that licensed                 >
operators can perform all necessary licensed activities through direct and focused operator aarticipation in the requalification program. By implementing a requalification program         ,
               )ased on a systems approach to trammg, as allowed by 10CFR55.59, which emphasizes               i constant feedback and evaluation, the performance and professionalism ofeach licensed             ~
individual and control room team is maintained and enhanced. As a direct result of this           !
cffort, the high operator performance standards required for nuclear plant safety and reliability are achieved.                                                                         l
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