ML20147H138
| ML20147H138 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/22/1988 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| AEP:NRC:1049, NUDOCS 8803080399 | |
| Download: ML20147H138 (7) | |
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E ENDCANA A80CN00AN 90WER AEP:NRC:1049 Donald C. Cook Nuclear Plant Units 1 and 2 gatn R0 86 Docket Nos. 50-315 and 50-316 j gg g
License Nos. DPR-58 and DPR-74 L
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Attn:
A. B. Davis
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January 22, 1988
Dear Mr. Davis:
This refers to Mr. Hubert J. Miller's, Region III letter of December.3, 1987, which forwarded the results of the special safety inspection conducted from September 8 through October 23, 1987.
The inspection was conducted by Messrs. S. M. Hare and J. A. Hopkins of your staff, of activities at D. C. Cook Nuclear Plant Units 1 and 2.
In that letter you requested we submit our planned corrective actions on the following deficiencies:
1.
Level of knowledge tested in the written examination process, 2.
Level of SRO training, and 3.
Potential for exam compromise Planned corrective action for the above noted deficiencies are contained in Attachment 1.
We also wish to note a comment, clarification, and exceptions to the content of the special safety inspection report.
These items are addressed in Attachment 2.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, j/ '
M.
. Aledich Vice President MPA/ add ce; D. H. Williams, Jr.
W. C. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspeccor - Bridgman 7
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'P, A.;Barrett/B. P. Lauzau S. H. Horowitz/T. : O. Argenta/R. C. ' Carruth -
.J. J. Markowsky/S. H. Steinhart/P. G. Schoepf R. W. Jurgensen
- J. G. Feinstein R. F. Kroeger M. L. Horvath - Bridgman.
.E. A. Morse - Bridgman J. F. Kurgan J. B.-Shinnock J. F.'-Stang, NRC. Washington, D. C.
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~. s ATTACHMENT 1 Planned Corrective Action for Identified Deficiencies Not Addressed in IMP Letter Dated November 5, 3987 1.
Level of knowledge tested in the ~ written examination process As outlined in our November 5th letter, one requalification instructor has received extensive training in examination preparation, administration'and review by attending a seminar conducted.by the Industrial Training Group (ITG) in September, 1987.
Since that time, this instructor has conducted a training seminar on the same topic for ten (10)
Operations Training Staff instructors.
This additional training enhances the Operations Training Staff's ability-to-develop higher quality examination questions which will test for true understanding of concepts.
As noted on Page 14 of the Inspection Summary (Reports No.
50-315/87027 (DRS); No. 50 316/87027 (DRS)), the inspectors-noted an improvement in the quality of examinations,_
examination answer keys and the grading of the examinations.
The improvement in exam quality is an indication of our commitment to this area. The additional training provided to i
the Operations Training Staff is evidence that a high level of attention is and will continue to be devoted to exam quality. We feel that these actions and the continued attention will correct the noted deficiency.
2.
Level of SRO Training our analysis of the annual requalification exam results concurs with that of the inspectors, in that it revealed weaknesses in System Design, Thermodynamics and System Instrumentation.
Based on this finding, a heavy emphasis (approximately 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />) has been placed on these topics for the current requalification year.
In addition, mandatory lecture attendance has been implemented for all areas of the Requalification Program, for all licensed operators.
These actions, in conjunction with the program improvements detailed in our letter of November 5,1987, will correct this deficiency.
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3, Potential for exas compromise.
-Strict controls are in place to ensure exam security.
Each student is apprised.that compromise'of the' examination process in any way will not be tolerated. A written statement of policy to this effect is prominently posted in examination rooms. These. preventive measures have been in-
-place for some time. To reduce the potential for exam compromise as measured by the number of duplicate questions used in subsequent exams, we have established a goal of 50t non duplicate' questions on subsequent exams for,the current requalification year (year 13). 1This represents an increase-of 150% over the current (204) program requirement.
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Comment 1
Ve appreetate and are' responsive to well intended comments / criticisms of our licensed personnel.
Certain comments / criticisms were offered in the NRC inspection report
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which apparentir emerged from interviews with requal-candidates. These comments / criticisms appear to us as being-based on a nonrepresentative sampling technique.
The' technique was nonrepresentative in that all of the interviewed operators (of which we are aware) had just failed a requal exam.
2.
Clarification Section'(3), Examination Security, of the inspection report states. "...the licensee indicated that in general, duplication (of exam questions in subsequent exams) did not exceed 304...".
(pg. 12).
This statement can only be the result of an unfortunate misunderstanding of whatever statement (s) were made in this regard by licensee representatives. Our administrative policies of record require at least a 20% difference (i.e., use of 204 non duplicate questions) between exams.
This issue was the point of specific and extensive discussion during the INPO Accreditation Board hearings (October 1986). At.those hearings we explained that the size of our exam question banks (at that time) would guarantee no greater than a 20%
difference. However, we were committed to the continued upgrade and expansion of the exam bank in order to increase the opportunity to have more than 20% non. duplicated questions.
We feel that the use of at least 30% non. duplicate questions on the first round of requal exams subsequent to that hearing demonstrates the seriousness of that commitment.
The 20%
L minimum requirement is common to all operator training i
programs at Cook Nuclear Plant, and is widely known to the Training staff. We regret any inconvenience caused by this misunderstanding.
l 3.
Exceptions 1
a)
Pages 9 and 12 of the inspection report contain the i
statements (based on percent of duplicate exam questions l
used in subsequent exams and on review of the increase L
in grades from exam 2 to exam 2):
"Examination security may have been compromised..." and "...is indicative of exauination compromise.." Our analysis of the results of the R.O. Requal Exams 2 ane 3 (i.e., those exams to which the quoted statements commonly apply) does not substantiate these statements.
Specifically, our analysis shows:
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Page 2 of 3 There was a 14 increase on scores on duplicate questions from R.O. Requal Exam 2 to R.O. Requal Exam 3, which is not significant.
Scores on Exam 3 were actually less on nine (9) of the twenty one (21)-duplicate questions used in Exam 3, as compared to scores in Exam 2 on these questions.
The difference (increase) in scores on non duplicato questions in Exam 3, as compared to Exam 2 scores, account for the higher average grades on Exam 3.
Our analysis is available for your review at your convenience.
b)
Statements made on pages 4 and 5 of the inspection report contain direct and indirect implications that safe operation of the plant at all times was not assured based on results of written examinations, interviews with licensed personnel and inspector observations or conclusions. We take exception to these implications.
This issue was addressed, specifically, in the teleconference preceding issuance of C.A.L.
- R III-87 012 (July 15, 1987, Mr. N. J. Chrissotimos and other Region III personnel attendant).
During this teleconference NRC Region III personnel concurred that there was no operational safety concern at that time. A concern was expressed for the strcngth/ effectiveness of the D. C. Cook Nuclear Plant Operator Requal Training Program, in view of the examination results, and the status of the specific cperators who had not passed a portion (s) of the NRC requal exam.
The apparently incongruous results of the written exam, in view of the strong (100% pass) performance of our operators on the NRC adminiatered oral exams (walk throughs) was also discussed.
In the referenced September 9,1987 meeting, the continuity and qualifications of the operating shifts were addressed directly. We showed that the operating shifts were manned, in excess of the minimum required shift complement, with R0/SR0s either qualified by recent license examinations or by R0/SR0s who had passed the nost recent requalification examination.
The effects of examination failures were accommodated without significant perturbation to the existing operating shifts.
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Based on the above, we disagree with any implication of.
- concern for sufficient and adequately qualified licensed operators to, at all-times, assure : safe operation ~ of the Cook Nuclear Plant, a
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