ML020040093
| ML020040093 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/02/2002 |
| From: | Howell A Division of Reactor Safety IV |
| To: | Denise Wilson Nebraska Public Power District (NPPD) |
| References | |
| EA-01-298 IR-01-012 | |
| Download: ML020040093 (31) | |
See also: IR 05000298/2001012
Text
January 2, 2002
David L. Wilson, Vice President of
Nuclear Energy
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
SUBJECT: NRC INSPECTION REPORT 50-298/0112; PRELIMINARY WHITE FINDING
(COOPER NUCLEAR STATION)
Dear Mr. Wilson:
On December 3, 2001, the NRC completed an inspection of your Cooper Nuclear Station. The
enclosed report documents the inspection findings, which were discussed onsite on October 18,
2001, and in a telephone conversation on December 3, 2001, with members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel. The inspection consisted of a review of the licensed operator requalification
program. Findings identified during the inspection are discussed in detail in the enclosed
inspection report.
This report discusses a finding that appears to have low to moderate safety significance. As
described in Section 1.R11 of this report, your process for examination development and
validation combined with the similarity of each examination resulted in an apparent compromise
of your 2000 biennial requalification written examinations. This finding was assessed using the
operator requalification human performance significance determination process as a potentially
safety significant finding that was preliminarily determined to be White; i.e., a finding with some
increased importance to safety, which may require additional NRC inspection. The issue has a
low to moderate safety significance because it represented a failure to recognize an apparent
examination compromise and the resultant failure of operators on the written requalification
examination, a number of whom performed licensed duties without remediation.
The finding also appears to be an apparent violation of NRC requirements and is being
considered for escalated enforcement action (EA-01-298) in accordance with the General
Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy),
Nebraska Public Power District -2-
Before the NRC makes a final decision on this matter, we are providing you an opportunity to
request a Regulatory Conference where you would be able to provide your perspectives on the
significance of the finding, the bases for your position, and whether you agree with the apparent
violation. If you choose to request a Regulatory Conference, we encourage you to submit your
evaluation and any differences with the NRC evaluation at least one week prior to the
conference in an effort to make the conference more efficient and effective. If a Regulatory
Conference is held, it will be open for public observation. The NRC will also issue a press
release to announce the conference.
Please contact Mr. Anthony Gody at (817) 860-8159 within 10 days of the date of this letter to
notify the NRC of your intentions. If we have not heard from you within 10 days, we will
continue with our significance determination and enforcement decision and you will be advised
by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for this inspection finding at this time. In addition, please be advised that the number
and characterization of the apparent violation described in the enclosed inspection report may
change as a result of further NRC review.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter
and enclosure 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/
Arthur T. Howell III, Director
Division of Reactor Safety
Docket: 50-298
License: DPR-46
Enclosure:
NRC Inspection Report 50-298/01-12
cc w/enclosure:
G. R. Horn, Senior Vice President
of Energy Supply
Nebraska Public Power District
1414 15th Street
Columbus, Nebraska 68601
Nebraska Public Power District -3-
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
D. F. Kunsemiller, Risk and
Regulatory Affairs Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
Dr. William D. Leech
Manager - Nuclear
MidAmerican Energy
907 Walnut Street
P.O. Box 657
Des Moines, Iowa 50303-0657
Ron Stoddard
Lincoln Electric System
1040 O Street
P.O. Box 80869
Lincoln, Nebraska 68501-0869
Michael J. Linder, Director
Nebraska Department of Environmental
Quality
P.O. Box 98922
Lincoln, Nebraska 68509-8922
Chairman
Nemaha County Board of Commissioners
Nemaha County Courthouse
1824 N Street
Auburn, Nebraska 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, Nebraska 68509-5007
Ronald A. Kucera, Deputy Director
for Public Policy
Department of Natural Resources
205 Jefferson Street
Jefferson City, Missouri 65101
Nebraska Public Power District -4-
Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, Missouri 65101
Vick L. Cooper, Chief
Radiation Control Program, RCP
Kansas Department of Health
and Environment
Bureau of Air and Radiation
Forbes Field Building 283
Topeka, Kansas 66620
Nebraska Public Power District -5-
Electronic distribution from ADAMS by RIV:
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
Senior Resident Inspector (JAC)
Branch Chief, DRP/C (KMK)
Senior Project Engineer, DRP/C (WCS)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
RidsNrrDipmLipb
Scott Morris (SAM1)
NRR Event Tracking System (IPAS)
CNS Site Secretary (SLN)
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1/02/02 1/02/02 1/02/02 1/02/02 1/02/02 1/02/02 1/02/02
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-298
License: DPR 46
Report No.: 50-298/01-12
Licensee: Nebraska Public Power District
Facility: Cooper Nuclear Station
Location: P.O. Box 98
Brownville, Nebraska
Dates: October 15 - December 3, 2001
Inspectors: Paul C. Gage, Senior Operations Engineer
Ryan E. Lantz, Operations Engineer
Approved By: Anthony Gody, Chief, Operations Branch
Division of Reactor Safety
-2-
SUMMARY OF FINDINGS
IR 05000298/2001-12; on 10/15-12/03/2001; Nebraska Public Power District; Cooper Nuclear
Station, licensed operator requalification report.
The inspection was conducted by two regional operations engineers. The inspection identified
one Green finding, and one finding whose significance was preliminarily evaluated as White.
The significance of each issue was indicated by their color (green, white, yellow, red) and was
determined by the Operator Requalification Human Performance Significance Determination
Process in Inspection Manual Chapter 0609.
Cornerstone: Mitigating Systems
- TBD. The licensee had compromised their 2000 Biennial Requalification Written
Examinations. This constitutes an apparent violation of 10 CFR Part 55.49 for
engaging in activities, which compromised the integrity of an examination.
The finding was preliminarily evaluated as having low to moderate safety
significance because after identification of the compromise, the corrective action
process (compensatory actions) failed to adequately evaluate the requalification
examinations for the effects of the compromise. Had the licensee performed a
detailed question analysis and regraded the requalification examinations by
removing those questions where compromise was indicated, at least two
licensed operators would have failed instead of receiving their original passing
grade. Subsequently, at least two operators were returned to licensed duties
without completion of the required retraining and testing for having failed the
examination (Section 1R11).
- Green. During the 2000 Annual Operator Requalification Operating Test, two out
of seven total crews failed the dynamic simulator portion of their operating test.
The safety significance of this finding was very low because the overall crew
failure rate was less than 34 percent, the crews were not performing licensed
duties, and the failed crews were appropriately retrained and retested prior to
being returned to licensed duties (Section 1R11).
Report Details
1. REACTOR SAFETY
R11 Licensed Operator Requalification
a. Inspection Scope
This inspection evaluated licensed operator performance in mitigating the
consequences of events, since poor licensed operator performance results in increased
risk through increased operator recovery rates and licensed personnel-induced
common-cause error rates assumed in the licensee's individual plant examinations
(IPEs). This inspection effort of the licensed operator requalification program included
the following major areas: (1) facility operating history, (2) requalification written
examinations and operating tests, (3) licensee training feedback system, (4) licensee
remedial training program, and (5) conformance with operator license conditions.
Operator performance since the last requalification program evaluation was assessed to
determine if performance deficiencies have been addressed through the requalification
training program.
Examination security measures and procedures were evaluated for compliance with
10 CFR 55.49. The licensees sample plan for the written examinations was evaluated
for compliance with 10 CFR 55.59 and NUREG-1021 as referenced in the facility
requalification program procedures. In addition, the inspectors: (1) reviewed the
number of applicants and pass/fail results of the written examinations, individual
operating tests, and simulator operating tests; (2) interviewed personnel regarding the
policies and practices for administering examinations; (3) observed the administration of
three dynamic simulator scenarios to one requalification crew by facility evaluators,
including an operations department manager assistant and plant manager, who
participated in the crew and individual evaluations; and (4) observed two facility
evaluators administer two job performance measures in the control room simulator in a
dynamic mode.
The inspectors reviewed the licensee's process for revising and maintaining an up-to-
date licensed operator continuing training program, including the use of feedback from
plant events and industry experience information.
The inspectors verified the adequacy and effectiveness of the remedial training
conducted since the last requalification examinations and the training planned for the
current examination cycle to ensure that identified licensed operator or crew
performance weaknesses during training and plant operations were addressed.
Remedial training and examinations for examination failures were reviewed for
compliance with facility procedures and responsiveness to address areas failed. The
inspectors also reviewed the remediation documented for three individuals, one of which
involved two written examination failures and one a simulator examination failure.
-2-
Maintenance of license conditions was evaluated for compliance with 10 CFR 55.53 by
review of facility records, procedures, and tracking systems for licensed operator
training, qualification, and watchstanding.
b. Findings
Written Examination Administration
The inspectors found that the written examinations developed for the 2000
requalification cycle were adequate; however, the examinations were compromised
during the validation process. This finding was preliminarily determined to have low-to-
moderate safety significance (White). Final significance determination of the apparent
violation is still under NRC review. An apparent violation of 10 CFR 55.49, Integrity of
Examinations and Tests, was also associated with this finding.
The licensees 2000 requalification written examination was developed from the
requalification training program sample plan. From this sample plan, 35 learning
objectives were selected on the percentage of time that the various objectives were
taught. Those same 35 learning objectives were used for each of the seven
examinations that were developed and administered.
The five operating crews were given their respective examinations over the first five
weeks of training cycle 00-20, one crew the first week, the next crew the next week, and
so on. Inactive and other staff active licensed operators were given their examinations
in the sixth and seventh weeks of the cycle. The first-week crew performed validations
of the second-week crew's examination, and the second-week crew performed
validations for the third-week crew's examination, and so on. The fifth-week crew also
validated the examination for the staff crew of the sixth week. The crews were
administered their respective examination the day after completion of validation of the
next weeks examination.
The validation was conducted by the entire crew, with half of the crew taking one half of
the examination to be validated, and the other half of the crew taking the other half of
the examination. The entire crew then met together with members of the training staff to
review comments on each question, if there were any, and gather validation times. This
validation methodology did not continue after the fifth week.
To ascertain if the examination was administered in an equitable and consistent
manner, the inspectors compared each question on each examination to the
corresponding question validated by that crew. The inspectors noted that the
examinations had numerous similarities week to week. First, the order in which the
learning objectives were tested was not changed from week-to-week. The first question
on the examination administered during the first week tested the same objective as the
first question on each of the subsequent weeks examinations. Second, more than half
of the questions on the first weeks examination for both the senior and reactor
operators were very similar and tested the same knowledge as their counterpart
questions on the second weeks examination. The inspectors' analysis showed that four
-3-
of the five senior operator examinations and one of the five reactor operator
examinations contained more than 50 percent of questions that were similar in
knowledge required to answer the question as those that the respective crews validated.
The inspectors' independent analysis of the similarity between requalification
examinations was conducted as follows: Each set of questions was reviewed to
determine what skill or knowledge was being tested, and if that skill or knowledge was
similar to that required to answer the question that was validated by a crew. The
inspectors then compared crew performance week-to-week to determine if: a) any crew
that had validated a similar question performed substantially better than crews that had
not validated a similar question, or b) any crew that had not validated a similar question
performed substantially worse than any crew that had validated a similar question. This
was done for each crew and question set on the examination. There were 35 questions
on each examination, 7 of which were unique to the senior operator examination,
7 unique to the reactor operator examination, and 28 questions common to both
examinations. Therefore, a total of 42 question sets were reviewed.
The inspectors concluded that the validation process combined with the similarity of the
examination questions resulted in a significant potential for inequitable and inconsistent
examination administration. To assess the impact of this finding, the inspectors
evaluated each operating crews performance on the written examination from question
to question.
Of the 42 question sets, the inspectors' analysis determined that at least 8 questions
demonstrated clearly that the examination was not administered in an equitable or
consistent manner. Four of these questions were common to both the senior reactor
operator and reactor operator examinations, 3 were unique to the senior reactor
operator examination, and 1 was unique to the reactor operator examination. Crew
performance on Questions 10, 15, S31, S32, and R35 supported a conclusion that the
examination was not administered in an equitable and consistent manner.
For example, Question S31 on the senior reactor operator examinations administered
during the first three weeks of the examination cycle were determined to be similar by
the inspectors. Each question required the examinee to determine what sodium
pentaborate solution concentration was required for system operability given either
standby liquid control tank temperature or level. This question was answered by
interpreting one of two graphs in Technical Specification 3.1.7. Question S31 on each
senior reactor operator examination administered during the fourth through seventh
weeks of the examination cycle was also similar to one another, but were very different
from the first three weeks questions. These required the examinee to evaluate rod
scram time testing data and evaluate what technical specification action may be
required. Each of these last four questions required reference to Technical Specification 3.1.4. The learning objective being tested by Question Set S31 was
knowledge of entry level conditions for technical specifications. All crews performed
very well on this question, with the exception of Crew 3, which was the only crew that did
not validate a similar question, since they validated the week four question. The
inspectors concluded that the crew performance on this question supported a
conclusion that the examination was not administered in an equitable and consistent
-4-
manner. No evidence supporting that Crew 3 should have done more poorly on this
question than the other crews for any reason other than the validation process was
identified.
During the administration of the 2000 requalification examinations the licensee observed
that the content and structure of the examinations coupled with the validation
methodology, created a potential for pre-conditioning the crews. Problem Identification
Report (PIR) 4-10812 entered this observation into the licensees corrective action
process in August 2000. The inspectors found the resolution of PIR 4-10812 narrowly
focused on adherence to station procedures and did not effectively investigate the
potential compromise. In August 2001, a licensee internal notification again questioned
the potential compromise issue. The root cause report that followed this notification
again failed to address the 2000 requalification examination compromise issue, and
made it a long-term corrective action to investigate the potential compromise and its
effects on the 2000 requalification examination. The licensees final analysis of the
compromise issue, which was entered into the corrective action process in November
2001, concluded that the results of the question analysis did not support a finding of
compromise, and that no further actions were warranted. The facility analysis results
are provided in Attachment 2.
The inspectors reviewed the licensees final examination question analysis that was
provided to the NRC on November 15, 2001. The inspectors noted that for 18 of the
42 question sets, the licensee's analysis of examination question similarity between
crews agreed with the inspectors' analysis. For 9 additional question sets, the analysis
differed by only 1 question of the set, and for 4 others the analysis differed by
2 questions of the set. Therefore, the facilitys and inspectors similarity analyses were
in substantial agreement for 31 of the 42 question sets.
While the licensees analysis was very similar and consistent in many cases with the
inspectors' analysis, the licensees conclusion was nonconservative, in that, it did not
address whether the examination was administered in an equitable and consistent
manner. This nonconservative conclusion appears to have been based on an
inappropriate interpretation of the data. For example, the licensees analysis stated that
there were 6 questions for which an apparent compromise could not be ruled out based
on the results. The analysis also concluded that for 6 questions, where an apparent
advantage should have been realized, the results showed that crews who reviewed a
similar question performed worse than a comparative crew that reviewed a different
question. The licensee analysis stated that this inconsistency supported a conclusion
that no compromise occurred on the examination. The inspectors did not agree with this
conclusion because the validation method itself would produce inconsistent results, in
that, the degree to which any individual in a crew gained benefit could vary significantly,
and that compromise could not be ruled out for at least 6 questions. The inspectors
concluded that if the examinations were regraded with the removal of questions that
showed evidence of compromise, at least two individuals would have failed. These
individuals were returned to shift duties without the retraining and re-evaluation that
would have been required for an examination failure.
-5-
10 CFR 55.49 states, Applicants, licensees, and facility licensees shall not engage in
any activity that compromises the integrity of any application, test, or examination
required by this part. The integrity of a test or examination is considered compromised
if any activity, regardless of intent, affected, or, but for detection, would have affected,
the equitable and consistent administration of the test or examination. This includes
activities related to the preparation and certification of license applications and all
activities related to the preparation, administration, and grading of the tests and
examinations required by this part. 10 CFR 55.59 (a)(2) requires each licensee to pass
a comprehensive requalification written examination which covers a 24-month
requalification program.
Contrary to the above, the licensee developed and administered their 2000 Biennial
Licensed Operator Requalification Examinations in a manner which compromised the
integrity of the examinations for all five operating crews that took the examinations. The
development of similar examinations and subsequent use of the operating crews to
validate the next weeks examination prior to taking their own examination resulted in a
compromise of the integrity of the requalification examinations. The two staff crew
examinations were not compromised during the validation process. This was an
apparent violation of 10 CFR Part 55.49 (AV 50-298/0112-01).
The inspectors determined that the examination compromise was more than minor.
Failure to administer an equitable and consistent requalification examination as part of a
continuing training program had a credible impact on safety because operators were
returned to shift duties without demonstrating an adequate level of knowledge. Failure
of operators to properly conduct licensed duties could credibly affect the operability and
availability of mitigating systems.
This operator requalification written examination security compromise was preliminarily
determined to have low to moderate safety significance (White) using Appendix I to
NRC Manual Chapter 0609, Operator Requalification Human Performance Significance
Determination Process. The inspectors determined that the validation methodology
used by the licensee combined with the similarity of the questions from examination to
examination resulted in the compromise in the security of the examinations. The
inspectors further determined that once the issue was discovered by the licensee in
August 2000, immediate compensatory actions were not taken.
Operating Test Administration
During the 2000 Annual Operator Requalification Operating test, two out of seven
total crews failed their dynamic simulator test. The finding was determined to be
more than minor because inadequate crew performance could adversely alter
expected initiating event frequencies, or given an accident sequence, demonstrate an
inability to carry out expected actions to mitigate the consequences of the accident.
Both conditions would increase the overall plant risk and have a credible impact on
safety (FIN 50-298/0112-02).
-6-
Using the Operator Requalification Human Performance Significance Determination
Process in NRC Inspection Manual Chapter 0609, Appendix I, the inspector determined
the finding concerning crew failures to be of very low safety significance (Green). This
determination was based on the fact that two of seven operating crew failures in August
2000 were Green, as determined by the matrix, the prior year operating test had no
findings of Green or higher, and that the failed crews were appropriately remediated
before being returned to shift work.
No additional findings were identified.
4OA6 Meetings, including Exit
The team discussed preliminary findings and other minor observations with Mr. Wilson,
Vice President, Nuclear, and other members of the licensee's staff, on October 18,
2001. A final telephonic exit meeting was conducted on December 3, 2001, when the
team discussed these findings with members of the training and operations staffs. The
licensee provided no further comment on other findings or issues.
Licensee management did not identify as proprietary any materials examined during the
inspection.
ATTACHMENT 1
KEY POINTS OF CONTACT
Licensee
M. Boyer, Senior Manager, Technical Services
T. Chard, Manager, Radiation
J. Christensen, Assistant Training Manager
D. Cook, Manager, Training
M. Coyle, Assistant Vice President
P. Flemming, Manager, Licensing
J. Fox, Assistant Operations Manager
R. Gardner, Senior Manager, Quality Assurance
M. Gillan, Manager, Work Control
B. Houston, Manager, Quality Assurance Operations
J. Hutton, Plant Manager
D. Kimball, Assistant Manager, Radiation
D. Kunsemiller, Manager, Risk and Regulatory Affairs
D. Linnen, Senior manager, Training
W. Macecevik, Manager, Operations
D. Pease, Operations Supervisor
M. Schaible, Supervisor, Operations Training
D. VanderKamp, Licensing
D. Werner, Lead instructor, Licensed Operator Requalification
N. Wetherell, Assistant Plant Manager
D. Wilson, Vice President, Nuclear
NRC
M. Hay Resident Inspector
ITEMS OPENED AND CLOSED
Opened
50-298/0112-01 AV Licensed operator requalification written examination
compromise involving an apparent violation of
Opened and Closed
50-298/0112-02 FIN Two of seven simulator operating test crew failures
occurred during the 2000 annual requalification operating
test.
-2-
DOCUMENTS REVIEWED
The following documents were selected and reviewed by the inspectors to accomplish the
objectives and scope of the inspection and to support any findings:
Procedures Reviewed:
Operation Desk Guide (ODG) 206, Development of Non-Faulted and Faulted JPMs
Operation Desk Guide (ODG) 210, Operations Department Examination Security
Operation Desk Guide (ODG) 213, Annual Licensed Operator Requal Examination Develpment
PIR OTHER NAIT 4-10812, 8/10/2000
Nuclear Training Procedure (NTP) 4.1, Training Material Development and Revision
Nuclear Training Procedure (NTP) 4.2, Examination Development
Nuclear Training Procedure (NTP) 5.2, Examination
Surveillance Procedure 6.SLC.601, SLC Tank Sampling, Revision 2, Nov 26, 1998
RCR 2001-0715, Potential Examination Compromise (Near Miss) During the Licensed
Operator Requalification Biannual Written Examination - 2000. Aug 6-16, 2001
NPPD: Notification: 10096568, 7/10/2001
Results Summary for 00-20 Requal Written Examinations
Weeks 1-7 Licensed Operator Requalification Written Examinations, Cycle 00-20
ATTACHMENT 2
Facility Analysis Results