ML20081L719

Responds to Weaknesses Noted in Requalification Program Evaluation Rept 50-271/91-09 Conducted During Wk of 910225. Corrective Actions:Job Performance Measures Revised to Upgrade Performance Stds & Content

ML20081L719
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/28/1991
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9107080026
Download: ML20081L719 (5)

Text

VENMONT YANKEE

1. NUCLEAR POWER CORPORATION Ferry Road, Brattleboro. VT 05301-7002 BVY 91-63 j ENGINEERING OFFICE 580 MAIN STREET

.- June 28,1991 ou 'oN urone 150 0 779-6711 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: - Document Control Desk

References:

a) License No. DPR-28 (Docket No. 50-271) b) Letter, WNPC to USNRC (BW 91-49), dated 4/30/91 )

c) Letter, USNRC to WNPC, (NW 9170) Report No. 50-271/91-02 (OL), dated 4/19/91

- d) Letter, USNRC to VYNPC (CAL 91-007), dated 3/11/91 e) Letter, WNPC to USNRC (BW 91-027), dated 3/8/91 -

f) Letter, VYNPC to USNRC (BW 9125), dated 3/8/91 Dear Sir; 4

Subject:

Vermont Yankee Response to Report No. 50-271/91 02, Requalification Program Evalu:: tion and Operational Evaluations During the week of February 25, 1991 the NRC conducted licensed operator l requalification examinations at Vermont Yankee. Based on the results of those examinations, the Vermont: Yankee Licensed Operator Requalification (LOR) Program was determined to be unsatisfactory. Following this determination,. Vermont Yankee Initiated a number of corrective Eactions and performed a comprehensive root cause analysis of the unsatisfactory examination results. The results of this analysis and additional corrective actions were provided to you vla Reference b).

Inspection Report No. 50-271/9102 (OL) [ Reference c)] provided a further discussion of weaknesses that yc observed during the LOR evaluation process. This letter provides, in the  ;

Attachment, our peispective on those weaknesses and a discussion of actions taken or planned to correct them.

We trust that- the above information is satisfactory; however, should you have any questions or desire any additional information on this issue, please do not hesitate to contact us.

Very truly yours, Vermont Yankee Nuclear Power Corporation n n% s gR Warren P. Mur y Senior Vice President, Oper '

cc: USNRC Regional Administrator, Region l USNRC Resident inspector, WNPS

' USNRC Project Manager, WNPS 9107080026 910628 I II

~( PDR -ADOCK 05000271 V PDR G-

i- .

Attachment A summary of the weaknesses identified in NRC Inspection Report 50-271/91-02 [ Reference c)) is given below with a corresponding discussion of our corrective actions:

Proaram Weakness 1 The quality of licensee developed examination materials was inadequate based on the following excerpts from Reference c):

"The sample plan submitted by the facility did not meet the standards of NUREG 1021 for use in preparation of the examinations." (Section 3.2)

"The examinations that were originally proposed by the facility ud not contain enough questions to meet t1e guidance of NUREG 1021 for number of points on the examination." (Section 3.3)

"All of the facility proposed JPM's required changes to upgrade the performance standards for the Individual steps required to perform the tasks." (Section 3.4)

"Many of the ISCT's identified in the scenarios pro, posed by the facility did not meet the guidance of the Examiner s Standards."

(Section 3.5)

Response

We have reviewed the above identitled weaknesses and have concluded that your findings are consistent with the causal factors identified in our root cause analysis of unsatisfactory examination results [ Reference b)]. Our conclusion is that these weaknesses were a result of the following factors:

o There was a lack of direction within Vermont Yankee regarding requirements for administration of the LOR Program and hence, for maintaining and submitting examination matnrials consistent with the latest revision of NUREG 1021.

o information available to the industry regarding recent NRC requalification examination failure was inadequately disseminated within Vermont Yankee. Much of this information further amplified NUREG 1021 guidelines.

o Revision 6 of NUREG 1021, which was published on June 6,1990, included substantial changes to the definition of Individual Simulator Critical Tasks (ISCT's). The Vermont Yankee examination team was aware, but did recognize the significance of, these revisions.

Therefore, no specific effort was initiated to review existing simulator scenarios for the effects of the revisions. This resulted in many of the initially proposed examination scenarios not meeting NUREG criteria.

To assure, on an ongoing basis, that Vermont Yankee examination materials and submittals are consistent with the most recent NUREG guidance, the following corrective actions have been completed or are ongoing:

a) Vermont Yankee Training Department Management will develop written duties and responsibilities for the administration of the LOR program. This effort will be completed by July 1,1991.

b) The Training Department will develop a specific training module covering the requirements of NUREG 1021 which will be presented to all LOR instructors. In addition, a pre-exam checklist will be developed for use in preparir,g for NRC examinations to ensure all required items are accomplished in a complete and timely manner.

This checklist will include an example format for the sample plan submission, review and validation of Job Performance Measures (JPM's) and written examination material, and review of Simulator Exercise Guides used to develop ISCT's. Both the training module and the checklist will be available to allow for training to begin by October 1,1991. In addition, a program has been initiated to assure that future NUREG revisions are incorporated into the above programs in a timely manner.

c)

Examination materials have been or are being revised to assure all NUREG 1021 requirements are satisfied as follows; o Job Performance Measures (JPM's) have been revised to upgrade performance standards and content.

o Simulator Exercise Guides (SEG's) will be reviewed and revised as necessary by October 1,1991 to ensure that they meet the requirements of ES-604.

o Written examination questions will be validated for time, validity, and accuracy. The validation will be completed prior to the submittal of material to the NRC in preparation for the 1992 LOR examination.

Program Weakness 2 The adequacy of rotation practices for Reactor Operators (RO's) was an identified weakness based on the following excerpt from Reference c):

"The facility trains operators in all positions permitted by their licenses, but does not ensure that all RO's are evaluated in all positions during the dynamic simulator port!on of the tsxam."

i.

Response

. Although our practice has been to ensure all licensed operators receive training in all' positions permitted by their licenses, we concur that _we do not  ;

always rotate RO's into all positions during dynamic simulator evaluations. l Rather, in some cases, we have verified knowledge and ability in alternate l positions through other portions of the exam. To assure that we completel examine all license holders in the future, we have taken the following action:y In conjunction with the actions discussed in response to Program  !

Weakness #1 above, we will specifically address simulator rotation practices for all licensed operators when developing the NUREG 1021 training module for LOR instructors. Further, we have already modified our ongoing LOR training program to assure expanded personnel rotation in both simulator training and simulator evaluation scenarios.

Proaram Weakness 3 Evaluation techniques on the dynamic simulator portion of the exam were weak in the following areas discussed in Reference c):

"The facility evaluators did not closely observe control board manipulations, and very seldom followed operators to the back panels to c,bserve activities."

1 "In several cases, the facilitity's evaluation of ISCT performance or pass / fall decision basis differed from the NRC's evaluation or basis."

"Even though the NRC and facility overall pass / fall results for individuals were Identical, it appearec that the facility evaluators had a tendency to downplay the safety significance of the performance errors."

Response

We have taken the following actions to assure appropriate and consistent evaluation of all licensed perscnnel; a) During LOR simulator training and evaluation, all operators are observed during back panel operations and control board /EOP usage is much more closely monitored.

b) Further training in the evaluation techniques contained in NUREG-1021 will be presented to all simulator instructors by October,1991.

4 Proaram Weakness 4 The remaining weaknesses identified by Reference c) were related to -

operating crew communications and control as follows:

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J e "During administration of the dynamic simulator examinations, the NRC identified a safety concern that the roles and responsibilities of the crew members did not 3rovide independent evaluation of plant operations to assist anc advise shift supervision during abnormal and emergency events. Poor communications and coordination of activities contributed to the weaknesses noted in crew performance."

Response

We have reviewed the above identified weaknesses and have concluded that your findings are consistent with causal factors identified in our root cause analysis of unsatisfactory examination results [ Reference b)). As discussed in Reference f), we took actions immediately following the subject LOR examination to pursue correction of those weaknesses. Those actions consisted of clarifying the division of duties of the control room staff and present!ng training to all licensed operators covering control room command and control, and shift staff communications.

In our further evaluation of this issue, we recognized the need to develop and implement an operating crew communications policy. This policy, which is currently being developed, will ensure a consistent command and control philosophy and w!Il also allow for more objective evaluations of crew performance during ongoing requalification tralning. Our develoamont of the aolicy will be completed so that training can commence by the aeginning of tie third LOR cycie, currently scheduled to begin August 6,1991. In addition, to further improve control room communication and to enhance consistency among operating crews, a program has been initiated to allow control room supervisors to observe other operating crews during simulator training.

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