ML20006D634
| ML20006D634 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/07/1990 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9002140145 | |
| Download: ML20006D634 (3) | |
Text
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s-e PHILADELPHIA ELECTRIC COMPANY LIMERICK GENElit ATING ST ATION j '
P. O. DOX A ls SAN ATOGA. PENNSYLVANI A 19464 (215) 8271200, EXT. 3000 February 7,1990 I.
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Docket Nos.
50-352 50-353 License Nos. NPF-39 u
NPF-85 W. T. Russell, Administrator US Nuclear Regulatory Casulission Rerion J 47hAllendaleRoad King of Prussia, PA 19406
SUBJECT:
Limerick Generating Station, Units 1 and 2 Licensed Operator Requalification Training Program Justification for Continued Operation
Dear Sir:
F This letter is intended to document our assessment of the adequacy of the
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Licensed Operator Requalification Program and serves as our Justification for Continued Operation. The assessment was conducted as a result of four of 13 licensed operators failing the NRC monitored requalification exams conducted at theLimerickGeneratingStation(LGS)TrainingCenterduringtheweekofJanuary 29, 1990 through February 2, 1990.
l We have concluded that the Program ensures.that licensed personnel currently t:
L on shift are properly trained and qualified to operate the plant safely and in accordance with their licenses. This conclusion is based upon the following.
(1) 21 regularly assigned shift licensed operators have been examined in the first three weeks of the current six week cycle; three of the 21 shift operators have failed, and in each instance that failure was only the written portion of the examination. All shift operators tested have successfully completed the job perfomance measures and simulator portions of the examination, thus demonstrating competency in actual operations.
(2) All shift licensed operators failing any portion of the examination have been removed from licensed operator duties until such time as they have successfully completed required remedial study and re-examination.
(3) The two staff licensed operators who failed the examination will not be permitted to perform licensed duties. Concurrently, we are reviewing.
as a part of an ongoing process, the need to renew these licenses.
(4) All failures during this current examination cycle have been based upon Philadelphia Electric Company's evaluations and these evaluations appear to be in agreement with NRC observations.
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W. T. Russell Page 2 cf 3
- Fchruary 7,1990 (5) The Licensed Operator Requalification Program has recently been extensively reviewed and reaccredited by the National Academy for Nuclear Training.
Our preliminary assessment of the proximate cause for the failures which occurred during the examinations conducted during the week of January 29, 1990, is as follows. The proximate cause for two of the three failures in the written portion of the examination is our inadequate time validation of the test, coupled with the candidates' inability to use reference materials efficiently.
The third failure and one of the previously mentioned failures were related to a weakness in diagnosing static simulator type problems. Our preliminary assessment of the staff licensee failures in the simulator portion of the exam is their failure to properly focus on key parameters during major transients.
q The additional failures by one of the staff licensees in the job performance measures and written portions of the exam is still under review.
A more extensive and detailed root cause for the failure rate in this NRC monitored exam will be conducted by our Training Section staff. We will submit the results of this root cause assessment along with identified corrective actions when the analysis is completed. We expect to complete this assessment by March 9, 1990, and will submit the results soon after this date.
As a result of our initial evaluation of the examination series conducted during the week of January 29, 1990, no " Deficiencies" were identified. A
" Deficiency" is defined as an area in which more than 50% of the candidates fail the test question and the question is one of major safety significance, llowever, our evaluation did identify areas of " Major" and " Minor Weaknesses."
As a result of these weaknesses LGS management commits to the following corrective actions.
All licensed operators will receive a minimum of four hours of simulator training in those areas identified as " Major Weaknesses" by March 15, 1990. One crew has already completed this training. A
" Major Weakness" is defined as an area in which more than 30% of the candidates fail a test question, or demonstrate unsatisfactory or questionableperformanceinasimulatorassessment(thelatterisa moresubjectiveassessment).
All weaknesses identified in the exam report analysis will be reviewed with license holders by May 18, 1990; Major weaknesses - (1st requalification training cycle)
February 26, 1990 - April 6, 1990, and Minor weaknesses - (2nd requalification training cycle)
April 9, 1990 - May 18, 1990.
A " Minor Weakness" is defined as an area in which more than 20 % of the candidates fail a test question or demonstrate unsatisfactory or questionable performance in a simulator assessment (the latter is a moresubjectiveassessment).
Operations management's training observation forms will be revised to specifically list the areas of identified weakness to insure focused observations in subsequent training cycles. This action will be completed by February 26, 1990.
l W. T. Russell
- february 7, 1990 Page 3 cf 3 i
l t
All observation forms filled out by management personnel, plus those provided by instructors during training cycles, will be formed into a l
composite report at the end of each training cycle to highlight concerns and to assess the effectiveness of corrective actions for management review and action.
The areas of identified weakness will be included, in accordance with present practice, into the " Common Student Errors" section of simulator training scenarios, t
We will provide the special Teamork Training Program to all licensed-operators, as previously requested from the Institute of Nuclear Power Operations (INPO), during the fourth quarter of 1990.
If INP0 is unable to meet this schedule, an in-house program will be developed to address this issue.
i The T-200 Series of Emergency Operating Procedures will be upgraded as follows.
v a)
Attach supplemental documentation to selected procedures that will help the operators locate equipment in panels. This action will be completed by February 16, 1990.
b)
Perform a human factors review of all T-200 Procedures and revise them accordingly with appropriate operator aids installed in the plant by May 15, 1990.
A list of Shift Operator crew schedules and a list of the schedule of requalifying exams for the remaining three weeks has been provided to the NRC Region I as requested.
In conclusion, we have determined that the overall program for Operator training is sound. We will, however, vigorously implement the corrective actions noted above to ensure that the weaknesses observed will not degrade the high quality of licensed operator performance that has been characteristic of our operating crews.
Very t yy rs, cc: US Nuclear Regulatory Connission Attn: Document Control Desk T. J. Kenny, USNRC Senior Resident. Inspector, LGS