ML20216D852
| ML20216D852 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/28/1997 |
| From: | Terry C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-220-97-04, 50-220-97-4, NMP1L-1246, NUDOCS 9709090438 | |
| Download: ML20216D852 (3) | |
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- NIAGARA MOHAWK G E N E R ATIO N NINNE P INT NWAR HAMWE ROAD. P o box 63 LYCOMING NEW YORK 13093/ TELEPHONE (315)349 7M3 BUSINESS GROUP
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- 5' August 28,1997 CARL o TER m NMPIL 1246 vc P, o.m um.sm Am.um.m no suppon U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine Mile Point Unit 1 Docket No. 50-220 DPR-63
Subject:
NRC Inspection Report 50-220/97-04 Gentlemen:
Mr. Doerflein's letter dated July 30,1997, which transmitted Inspection Report (IR) 50-220/
97-04 states that while Nine Mile Point Umt 1 (NMPI) Licensed Operator Requalification Training Program was implemented acceptably, several noteworthy weaknesses were identified.
The identified weaknesses were that the written examination level of difficulty was low, the reliability of the control rod position indication system (RPIS) in the simulator was degraded to the extent that it could negatively affect training, and NMP1 did not have specific procedural guidance for determining that the reactor is shutdown under all conditions. The purpose of this letter is to provide Niagara Mohawk's (NMPC) position on these issues and our planned actions.
Section 05.1 Unit 1 Licensed Operator Requalification Pregram ofIR 97-04 contains the details -
of the concerns addressed in the July 30,1997 letter. NMPC has reviewed these concerns and agrees with them. At the time of the inspection actions were underway to improve the NMP1 Requalification Training Program. Our letter of May 12,1997 from Richard B. Abbott contains actions to prevent reoccurrence of the violations cited in irs 96-13,96-15 and 96-16. However, those actions began just prior to the implementation of the 1997 Requalification Program.
Therefore, there has not been sufficient time for the actions to be totally effective. In any event, actions are underway to improve the operator requalification programs at both NMP1 and NMP2.
The three specific issues discussed in the July 30,1997 letter are discussed below. Details of cause and corrective / preventive actions are presented.
- sh09090438 970828 gDR ADOCK 05000220 PDR
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Written Examinatinn Level of Difficulty i~
. The cause of the low level of difficulty in some of the written examination questions was I
inadequate management oversight la that the process which was used to develop the written examination, based upon the sample plan, did not reinforce existing standards and
. did not require performance of a critical independent verification that the questions were o
of the proper cognitive level.
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To correct the concern 1) the examination question development guideline will be revised i
to raise the standard and quality of questions including examples of properly written exam '
. questions (i.e., question structure, format distractor plausibility and direct lookup
. questions) by October 31,1997, 2) the examination bank question development and the -
annual / biennial written exam processes will be revised to require the review of each
. question or exam against an established guideline to ensure consistency with learning objectives, clarity, exam format and adequate level of difficulty by November 30,1997,3) the instructors will be trained on the revised examination question development guideline by November 30,1997 and,4) the examination banks for both units will be reviewed and upgraded consistent with the revised examination question guideline by June 30,1998, i
RPIS Degraded on Simulator.
l The degraded condition of the Rod Position Indication System (RPIS) on the Unit 1 simulator was caused by an unreliable connection between the position indication module and the simulator signal cable. The design of this connection used dissimilar metals which oxidized over time, degrading its electrical characteristics. Management was not aware of an adverse repair trend because the connection'was being repaired as minor maintenance without documentation.-
As a short term corrective action, each of the connections was disassembled, cleaned,.
reassembled and verified to provide accurate position indications. In addition, the-simulator technicians have been counseled with regard to identification of repetitive maintenance issues. The connections will be modified by November 30,1997, as part of an approved simulator enhancement to update the position indicatica modules to more
. accurately reflect the actual plant configuration. The modified connections will use hardware which has proven to be reliable in other simulator applications, increasing the reliability of the simulator Rod Position Indication System.-
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Page 3 To address the concern oflack ofmanagement awareness, the process for simulator minor maintenance will be revised by November 30,1997, to track and trend this type of deficiency. This will increase the visibility of hardware related, minor maintenance activities and provide for detection of adverse trends including any associated with RPIS, NMP1 did not have Procedural Guidance to Determine that the Reactor is Shutdown l
NMP1 Operations management has determined that procedural guidance similar to that provided in the NMP2 scram procedure will enhance operator performance therefore, the procedure has been revised. As a result of recent management changes, other differences between the units are being identified. These differences will provide an opportunity _to identify best practices to further enhance procedural guidance for both units.
As a result of the preceding actions and the actions described in Mr. Abbott's May 12,1997 letter, NI.TO has improved and will continue to improve the operator requalification programs at both units.
Very truly yours, Carl D. Terry Vice President Nuclear Safety Assessment and Support CDT/GJG/Imc xc:
Mr. H. J. Miller, Regional Administrator Region I Mr. A. W. Dromerick, Acting Director, Project Directorate I-1, NRR Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management
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