ML20235D962
| ML20235D962 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/14/1987 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| ND3VPN:5135, NUDOCS 8709250424 | |
| Download: ML20235D962 (5) | |
Text
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Be ver Valley Power Station Shippingport PA 15077 0004 I
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September 14, 1987 ND3VPN:5135 i
1 Mr. Edward C. Wenzinger, Chief Reactor Projects Branch No. 3 gg
.s Region I oc c:
631 Park Avenue 43 R3 King Of Prussia, PA 19406 y( gg i
REFERENCE:
Beaver Valley Power Station Unit No. 1
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c3 Docket No. 50-334, License No. DPR-66 u>
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P Report No. 50-334/87-08 (OL)
Requalification Program Evaluation Report N
Gentlemen:
This letter responds to the. Requalification Program Evaluation:
Report No. 50-334/87-08 (OL) dated July'24, 1987.
This report requested our response identifying the root cause of the requalification examination failure rate experienced and submission of a plan for implementing corrective actions.
The basis for the conclusions in Report 87-08 (OL) was an NRC administered written and operating examination in which 9 of 12 licensed personnel failed to receive passing grades on the NRC administered written examination and 2 of 12 operators failed to receive passing grades on the NRC administered (practical) operating examination.
It was on the basis of these examination results that the NRC concluded that the BVPS operator requalification training program was unsatisfactory per the criteria of NUREG 1021, Chapter ES-601, paragraph F.1.
An exit meeting was held at the BVPS site on
~
May 22, 1987 to discuss the preliminary evaluation of the results.
Duquesne Light Company provided comments on the examination and i
answer key by letter dated May 22, 1987.
Subsequent to that exit meeting, copies of the graded written examinations were provided to us for our review, analysis and the development of our corrective actions.
Duquesne Light Company conducted its own analysis of the written examination and submitted copies of the examination to our requalification training contractor, ETC Corporation and its subcontractor, Focus Corporation for independent analysis of the examination.
Our findings and the analysis and findings of our contractors were presented to the NRC staff at a meeting requested by Duquesne Light Company at NRC Region I headquarters at King of Prussia, Pennsylvania on July 22, 1987.
Duquesne Light Company provided documentation of our analysis and findings regarding the NRC examination by letter dated July-28, 1987.
i 8709250424 870914 PDR ADOCK 05000334 tt 0 W
PDR Su o \\
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Boavar Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Report No. 50-334/87-08 (OL)
Page 2 4
In summary, we believe that the written examination administered during the week of May 18, 1987 was sufficiently. flawed so as to introduce uncertainty as to its validity for determining the quality of the BVPS operator requalification training program.
Because of this, the test results could not be adequately reduced to isolate flaws requiring corrective action.
Our root cause determination analysis of the written test, either as interpreted by us or by using the staff's interpretation, did not reveal a root cause or causea for the large number of failures on the written examination.
This agrees with the NRC staff's conclusion stated on Page 6 of the NRC Requalification Program Evaluation Report No. 87-08-(OL).
We are convinced that performance on the examination was effected by the quality of the examination itself.
We also believe that the construction of high quality examinations for all of the~ reactor sites in Region I is a formidable task and that, if improvement in the examination process is to be achieved, such improvement will only come about by the close cooperation of licensees with the NRC.
I Duquesne Light Company is willing to increase its efforts to improve examination quality and offers to become involved in a coordinated effort with the NRC to achieve improved examination quality.
The following corrective actions, while primarily designed to improve the requalification program, may enhance the quality of examinations if the results of these activities are merged into the examination process.
CORRECTIVE ACTIONS I
1.
Identified weaknesses addressed in Report 87-08 (OL) which are considered valid performance based deficiencies will be addressed during the next requalification cycle.
i 2.
We will revise the format of the BVPS License Requalification l
Program to reflect the subject areas as defined in PWR K.A.
Catalog (NUREG 1122) and as verified by the BVPS Job and Task i
l Analysis.
This effort will produce a JTA verified plant specific K.A. catalog for BVPS.
This plant specific K.A. catalog will be l
used to develop specific learning objectives which will be used to develop or revise lesson plans, student handout materials and examination questions.
This effort will be performed coincident with the next two training cycles.
The two year training program consists of ten (10) modules and the plant specific K.A. catalog will be divided into ten (10) sections corresponding to the ten (10) modules. The new completed K.A. catalog will be completed at the end of the two year training program.
We will provide the l
1 new K.A. catalog to the NRC for use in examination development when completed.
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4 Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Report No. 50-334/87-08 (OL)
Page 3 I
CORRECTIVE ACTIONS (continued) 3.
Coincident with development of the new K.A. catalog, we will develop an enhanced validated, performance based question bank based upon the system described above.
Our goal is to develop 300 questions per year with a total of 600 questions at the conclusion of the two year revision period described above.
This question bank will be provided to the NRC when developed, if j
requested.
l 4.
We have begun analysis of the simulator problem relating to two l
phase flow discussed on Page 67 of Report 87-08 (OL).
We have I
determined that the simulator response observed during the examination is repeatable and is caused when RCP's are shifted during two phase flow.
The problem is not related to entering constants.
If the model related to this condition can be improved, such improvement will be implemented by December 31, 1987.
We have been unable to reproduce the problem observed with l
the turbine plant control system after repeated attempts.
Under l
these circumstances, corrective action is not possible for this problem.
We believe that the corrective actions described above are extensive and demonstrate our intent to have a high quality, effective operator requalification training program.
Although these corrective actions are designed primarily to improve the training i
i program, the products to be produced could result in a significant l
enhancement of the examinations administered by the NRC.
l Very truly yours, d&
d' D* Sieber JDS/smf l
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f a-Beaver Valley Power' Station,. Unit No. 1 Docket No. 3343,- License No. DPR-66 Requalification Program _ Evaluation Report Page 4-l l
cc: Mr. F.
I.' Young, Sr. Resident' Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power. Station Shippingport,PA 15077
'U. S. Nuclear Regulatory Commission [
Regional Administrator Region 1 631 Park Avenue King of Prussia, PA
'19406 Mr. Peter S. Tam U. S.. Nuclear Regulatory Commission
{
Project Directorate No. 2 i
Division of PWR Licensing - A Washington, D.C.
20555 j
Mail Stop 316 Addressee Only j
Director, Safety Evaluation & Control Virginia Electric & Power Company P. O. Box 26666 One James River-Plaza Richmond, VA 23261 l
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