IR 05000298/2004009

NRC Inspection Report 05000298/2004-009 Biennial Licensed Operator Requalification Inspection - Final Significance Determination for a White Finding

ML040860031
Person / Time
Site:	Cooper
Issue date:	03/24/2004
From:	Chamberlain D Division of Reactor Safety IV
To:	Edington R Nebraska Public Power District (NPPD)
References
EA-04-026 IR-04-009
Download: ML040860031 (5)

Text

rch 24, 2004

SUBJECT:

COOPER NUCLEAR STATION - NRC INSPECTION REPORT 05000298/2004-009 BIENNIAL LICENSED OPERATOR REQUALIFICATION INSPECTION - FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING

Dear Mr. Edington:

The purpose of this letter is to provide you the final results of our significance determination of the preliminary White finding identified in the subject inspection report dated February 11, 2004.

The inspection finding was assessed using NRC Inspection Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP), and was preliminarily determined to be White, a finding with low to moderate increased importance to safety, which may require additional NRC inspections. As indicated in the subject inspection report, testing results failed to demonstrate satisfactory licensed operator requalification program performance as described in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 8, Supplement 1, Examination Standard 601, Section E.3.a(1), Evaluation of Requalification Programs.

Examination Standard 601 E.3.a(1) specifies, in part, that for a requalification program to maintain satisfactory performance, 75 percent or greater of the participants must pass all portions of the biennial examinations. Failures during the biennial cycle included a 36 percent failure rate on the biennial written examination.

In a telephone conversation with Mr. Anthony T. Gody, Chief, Operations Branch, on February 20, 2004, with Messrs. Jerry Roberts and Paul Fleming, your staff indicated that Nebraska Public Power District was not requesting a regulatory conference but would submit a written response. We received your written response on March 12, 2004.

In your written response, you indicated that (1) it was inappropriate to conclude that the operator licensing program is unsatisfactory and then use that perceived problem to execute the SDP flowchart; (2) your assessment of the significance of the finding was Green; and (3) should the NRC conclude that the final significance determination was White, you expected that our inspection efforts would be limited to those described in NRC Inspection Procedure 95001, Inspection for One or Two White Inputs in a Strategic Performance Area.

Nebraska Public Power District -2-After considering the information developed during the inspection and the additional information you provided in your letter dated March 12, 2004, the NRC has concluded that the inspection finding is appropriately characterized as White, an issue with low to moderate increased importance to safety, which may require additional NRC inspections.

With respect to how the finding was processed through the SDP, we considered your comments and concluded that we properly implemented the intent of the SDP contained in NRC Inspection Manual Chapter 0609, Appendix I. The SDP provides guidance for stepping through the various sections of the chart and specifically states that the SDP looks at the overall requalification program by questioning if less than 75 percent of the operators passed.

This determination is consistent with the guidance contained in NUREG-1021, Revision 8, Supplement 1, Examination Standard 601. The discussion in the subject inspection report requires no further clarification. As noted in your response, the NRC did identify some enhancements to the guidance in NRC Manual Chapter 0609, Appendix I, and will be making those changes in the next revision.

You have 30 calendar days from the date of this letter to appeal the staffs determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.

Because plant performance for this issue has been determined to be in the regulatory response band, we used the NRC Action Matrix to determine the most appropriate NRC response for this finding. Accordingly, we have determined that the supplemental inspection will be conducted in accordance with NRC Inspection Procedure 95001 during the week of April 5, 2004.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dwight D. Chamberlain, Director Division of Reactor Safety Docket: 50-298 License: DPR-46 cc:

Clay C. Warren, Vice President-Nuclear Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

Nebraska Public Power District -3-John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing and Regulatory Affairs Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366

Nebraska Public Power District -4-Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, IA 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601

Nebraska Public Power District -5-Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (SCS)

Branch Chief, DRP/C (KMK)

Senior Project Engineer, DRP/C (WCW)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (KEG)

Dan Merzke, Pilot Plant Program (DXM2)

RidsNrrDipmLipb Rebecca Tadesse, OEDO RIV Coordinator (RXT)

CNS Site Secretary (SLN)

OEMAIL OEWEB Gary Sanborn Jennifer Dixon-Herrity, OE Rani Franovich, NRR Victor Dricks Bill Maier ADAMS: : Yes * No Initials: _ATG_____

Publicly Available * Non-Publicly Available * Sensitive * Non-Sensitive DOCUMENT: R:\_CNS\CN2004-09lt-Final SDP for White C:OB C:PBC C:IOLB D:ACES OE D:DRS ATGody/lmb KMKennedy DTrimble GFSanborn JDixon-Herrity DDChamberlain RA RA RA(E) RA(E) /RA/ E /RA/

3/17/04 3/17/04 3/17/04 3/17/04 3/19/04 3/18/04 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax