ML020840474
| ML020840474 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/07/2002 |
| From: | Gody A Operations Branch IV |
| To: | Denise Wilson Nebraska Public Power District (NPPD) |
| References | |
| Download: ML020840474 (42) | |
Text
Aft~ REGC, I-A MAR - 7 2002 David L. Wilson, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321
SUBJECT:
COOPER NUCLEAR STATION - REGULATORY CONFERENCE FEBRUARY 1, 2002
Dear Mr. Wilson,
This refers to the meeting conducted in the Region IV Office, Arlington, Texas, on February 1, 2002. As you are aware, the purpose of this meeting was for you to provide information that would assist in our assessment of a potential White finding and the associated apparent violation involving a compromise of the 2000 licensed operator requalification biennial examinations and corrective action deficiencies addressed in NRC Inspection Report 50 298/01-12. The attendance list and the licensee's presentation are enclosed (Enclosures 1 and 2).
In accordance with 10 CFR 2.790 of the NRC's "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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely, Anthony T. Gody, Chief Operations Branch Division of Reactor Safety Docket: 50-298 License: DPR-46
Enclosures:
- 1. Attendance List
- 2. Licensee Presentation UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8064 Nebraska Public Power District cc w/enclosure:
G. R. Horn, Senior Vice President of Nuclear and Enterprise Effectiveness Nebraska Public Power District 1414 15th Street Columbus, Nebraska 68601 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 0 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
Nebraska Public Power District 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 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 1000 SW Jackson, Suite 310 Topeka, Kansas 66612-1366 Nebraska Public Power District 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 (DPL)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
RidsNrrDipmLipb SLMcCrory/Imb ATGody
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02/07/02 03/07/02 S
- m OFFICIAL RECORD COPY r-- t------
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ENCLOSURE 1 MEETING: COOOPER NUCLEAR STATION
SUBJECT:
REGULATORY CONFERENCE DATE: FEBRUARY 1, 2002 ATTENDANCE LIST NAME ORGANIZATION POSITION/TITLE William Macecevic NPPD CNS Operations Manager David Linnen NPPD CNS Senior Training Manager Dave Wilson NPPD CNS Vice President - Nuclear Jim Hutton NPPD CNS Plant Manager John Christensen NPPD CNS Assistant Training Manager David Kunsemiller NPPD CNS Risk & Reg Affairs Manager Guy Horn NPPD CNS Vice President - Energy Arthur T. Howell NRC Director, Division of Reactor Safety Kriss Kennedy NRC Chief, Project Branch C Anthony T. Gody NRC Chief, Operations Branch Ryan Lantz NRC Senior EP Inspector Pat Gwynn NRC Deputy Regional Administrator Chris Nolan NRC Enforcement Specialist Russell Wise NRC Enforcement Specialist Alfred Sanchez NRC Operations Engineer Karla Smith NRC Regional Counsel Tom Mckernon NRC Senior Operations Engineer Ronald Stoddard Lincoln Electric Sys.
Consultant Douglas Curry Lincoln Electric Sys.
Counsel Robert Slough TXU CPSES Regulatory Affairs D. W. McGaughey TXU CPSES Operations Training Supervisor ATTENDANCE LIST NAME ORGANIZATION POSITION/TITLE Dave Trimble NRC Section Chief, IOHS Richard Eckenrode NRC Sr. Human Factors Specialist Fred Guenther NRC Senior Reactor Engineer, IHOS Tom Harrison McGraw-Hill Journalist Jean Liaw Winston and Strom Paralegal Dr. William D. Leech MidAmerican Energy Nuclear Manager Mohan Thadani NRC Sue Semerena Nebraska Health and Human Services System
ENCLOSURE2 CNS PRESENTATiON
Safety Conclusions Re-grade results for 5 N RC identified question sets and 4 CN S identified question sets ORIGINAL SCORE NRC QUESTIONS REMOVED NRC AND CNS QUESTIONS REMOVED Test I GRADE GRADE SRO 91.40 90.9 90.9 SRO 82.80 84.8 84.8 SRO 91.40 90.9 90.9 RO 88.50 88.2 88.2 RO 82.80 82.3 82.3 Test 2 SRO 80.00 81.8 81.8 SRO 88.60 87.8 87.8 SRO 88.60 87.8 87.8 SRO 91.40 90.9 90.9 SRO 91.40 90.9 90.9 SRO 82.80 81.8 81.8 SRO 94.30 93,9 93.9 RO 94.30 93.9 93.9 RO 85.70 84.8 84.8 RO 88.60 87.8 87.8 Test 3 SRO 85.70 85.7 85,3 SRO 85.70 85.7 85.3 RO 77.10 77.1 77.1 RO 82.80 80.0 80.0 RO 80,00 82.8 82.8 Test 4 SRO 88.60 90.6 90.3 SRO 91.40 90.6 90.3 SRO 85.70 84.4 83.9 RO 85.70 84.4 84.4 RO 71.40 68.7 68.7 Test 5 SRO 71.40 72.7 72.7 SRO 80.00 8 1.8 81.8 SRO 85.70 84.8 84.8 SRO 88.60 87.8 87.8 RO 91.40 91.4 91.4 RO 82.90 82.9 82.9 30
SDP Review OPENBOOK AVERAGES 00*
f"li 100.00 100.00
- 80. 00 93.30 100.00 100.00, 100.00 S...............
PO § 0 0..3 93.30 93.30 100.00 OPERATOR TEST 1 SRO SRO SRO RO RO TEST 2 SRO SRO SRO SRO SRO SRO SRO RO RO RO TEST 3 SRO SRO RO RO RO TEST 4 SRO SRO SRO RO RO TEST 5 SRO SRO SRO SRO RO RO OTHER SRO SRO SRO SRO SRO RO 80.00 93.30 86.70 86.70 86.70 93.30 0 0 80.00ý 86.70 100.00..
93.310
.............. 10.00_....
80.W0 86.70 66.70 80.00 86.70 93.30 86.70 86.70 66.70 80.00 86.70 93.30 100.00 100.00 86.70 80.00.
100.00 80.00 86.70 80.00.
100.00L.
7.........
3 P.30 00-c_ ',,)
73.30 86.70 86.70 80.....
80.00..
73.301 93.30 100.00 93.30 93.301 86.70 86.70 86.70.
100.00 86.70 100.00 80.00 86.70 93.30 80.00 86.70 100.00 100.00 93.30 80.00 93.30 93.30 93.30 80.O00 93.30 80.O00 100.00m 86.70 86.70 86.70 80.10 80.00 00-09 PAST AVG.
93.30!
93.30, 100.001 86.70 86.70 86.70 66.60!
86.70, 93.30; 93.301 100,0-...0 1010-.00',
100.00i 93.30i 100.00 86.70 80.00 73.30 80.00 80.00 93.30.
100.00 100.00 100.00" 80.00 80.00i 86.706 100.00 93.30.
93.30 93.301 93.30; 100.00 100.00 100.00, 10oo.0 80.W00 100.00, 86.70.
86.70; 91.70 93.30 93.30' 73.30 93.30i 100.001 80.00'.
86.70, 100.001 93.30" 100.001
- 80. 00 86.70 100.00o 93.30 80.00 86.70 73.30 80.00 86.70 100.00, 80.001 80.00*
93.30 86.70i 93.30!
86.70ý 80.00 93.30 86.70, 80, 00 6.4180 66...4.7......
88.00 88.00 92.00 72.00 88.00 72.00 88.00 88.00 84.00 92.00 S...........
0 92.00 96.00 92.00 96.00 SP.
100.66 100.00 80,00 80.00 92.00 92.00
- 88. O0
-92.90 80.00 88.00
- 80. O0 96.00 80.O0 84.o0 76.0C 100.00 92.0(
80.0(
80.0(
92.0C 84.00 89.10 91.33 88.68, 83.12 88.85 86.43 S
86.87 82.45 96.43
):
87.55 93.08 93.12.
)*
95.65
),
94.68 90.45 84.4 5
)!
90.00 "87.77 82.22 90.40 91.45
)t 91.33
-. 87.57 I
9 84.00 3t 85.78 85.55*
89.55 Di 83.20*
93.33*
89.77
.. 87.23 oV 85.57 92.300.......
o 79.751 00-20 91.40 82.80 91.40 88.50:
82.80 80.00 88.60 88.60 91.40 91.40 82.80 94.30 94.30 85.70 88.60 85.70 85.70 77.10 82.80 80.00 88.60 91.40 85.70 85.70, 71.40 71.40 80.00 85.70 88.60*
91.40 82.90.
97.10 88.60 91.40i 85.70 85.70 80.O00 31 n
9905
ý 00-91PA T
A GýI 9902 99-0 93.30.
93.30 1...
.00.00 86.60 96.70
.............3
.3 0...
93.30.ý 86.70 86.70 80.00 86.70 86.70 86.70 86.70:
86.60 83.30 86.70' 100.00ý 93O. 30....
.Q.Q.('HS
- Q 1 A qCl.Od.
SDP, Analysi No Yes I No No GrYes Finding Yes Green Finding No Yes 32
Timeline 6/20/00-7/27/00 8/10/00 8/11/00 12/5/00 7/10/01 7/13/01 7/14/01 7/24/01 7/26/01 9/5/01 10/15/01 10/18/01 11/08/01 12/3/01 1/2/02 1/4/02 Exams Administered PIR 4-10812 Written Peer Evaluation Performed PIR 4-10812 closed Notification 10096568 written Industry Expert Evaluation Begins 1st CNS Evaluation Begins Industry Expert evaluation issued 1st CNS Position paper issued 1st CNS Evaluation issued NRC Inspection begins 2nd CNS position paper issued (NRC request) 2 detailed CNS evaluation issued (NRC request)
NRC Exit NRC IR 50-298/0112 issued SCR 2001-1495 issued
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I II Nebraska Public Power District Operator Requalification Exam Regulatory Conference February 1, 2002
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Agenda
"* Introduction
"* Summary of Issue
"* Safety Conclusions
"* SDP Review
"* Root Cause/Extent of D. Wilson J. Christensen J. Christensen D. Kunsemiller J. Christensen Condition
"* Corrective Actions
"* Closing Summary J. Christensen D. Wilson Cooper Nuclear Station I
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Nebraska Public Power District Operator Requalification Exam Regulatory Conference February 1,2002 I
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Agenda
- Introduction
"* Summary of Issue
"* Safety Conclusions
"* SDP Review
° Root Cause/Extent of Condition
- Corrective Actions
- Closing Summary D. Wilson J. Christensen J. Christensen D. Kunsemiller J. Christensen J. Christensen D. Wilson 2
Cooper Nuclear Station February 1, 2002
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Introduction
- Administration of 2000 requalification exams did not meet our expectations and standards.
- Purpose of this Regulatory Conference
- Summarize the exam process.
- Discuss determination of safety significance.
- Summarize root cause analysis and extent of condition review.
- Present corrective actions.
- Condition has been determined to have no or very low safety significance.
- Corrective actions have precluded recurrence and enhanced standards.
Cooper Nuclear Station February 1, 2002 3
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I Summary of Issue John Christensen
Summary of Issue Regulatory Compliance 10CFR55.49 states, "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."
- CNS acknowledges that it did not meet this requirement because exam validation practices could have affected the equitable and consistent administration of the examination.
5 Cooper Nuclear Station February 1, 2002
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Overview of Exam Process
- Seven 35 question exams developed using same objectives for each exam.
- Crews conducted validation by taking half of the next week's 35 question exam.
- Crews took exam and questions evaluated for quality.
- Questions changed when appropriate.
- Crews given their exams next day.
Cooper Nuclear Station February 1, 2002 6
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I Exam Process Issues
- Objectives should not have been the same for successive exams.
- Exam validated by a crew prior to taking own exam.
- Validation of exam occurred 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to taking actual exam.
- Not all individuals exposed to same questions during validation.
- Not all individuals conducted validation.
Cooper Nuclear Station February 1, 2002 7
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Safety Conclusions John Christensen I
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Safety Conclusions
"* Issue first identified in July/August 2000.
- Cooper evaluation placed in corrective action process.
- PEER Review confirmed conclusions.
"* Issue raised again in July 2001.
- Independent Assessment
- Root Cause completed
- Test Adequacy Evaluation
- Additional Test Evaluation
- SCR Root Cause Issued Cooper Nuclear Station February 1, 2002 9
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IIII Safety Conclusions Results of 2000 Evaluation
- No questions duplicated - either new or significantly modified.
- PEER utility review confirmed that questions were adequate and the exam acceptable.
- Exam was valid Cooper Nuclear Station 10 February 1, 2002
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I II I[II Safety Conclusions Results of 2001 Evaluations Independent Assessment
"* Questions were similar
"* Exam valid Test Adequacy Evaluation
"* Did not meet 10CFR55.49
"* Similarity of questions did not impact results
"* Exam valid Additional Test Evaluation
"* More detailed look at question similarity
"* Exam valid
"* Worst-case analysis completed Root Cause 0 Weak procedural guidance for process Cooper Nuclear Station February 1, 2002 I1I
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I Safety Conclusions
"* Analysis of evaluations conclude:
Questions were acceptable.
Timing of validation and actual test not optimum, but did not invalidate exam results.
Inconsistent administration did not invalidate exam results.
2001 evaluations support 2000 evaluation.
"* Operators were returned to licensed operator duties with adequate knowledge levels.
Confirmed by analysis of prior and subsequent exam results.
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I IIII Safety Conclusions
- In hindsight "worst-case" analysis was unreasonable.
Looked at all potentially similar questions.
Removed these questions from exam (27 total questions).
Did not remove if question missed.
Determined that three operators potentially affected.
- Evaluated impact of removing questions identified by CNS and NRC that showed advantage may have been gained.
No additional operators would fail the exam.
13 Cooper Nuclear Station February 1, 2002
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III Safety Conclusions
° All operators qualified when returned to duty.
- Therefore, no or very low safety significance.
- Compensatory actions were not required.
- No impact on safe operation of CNS.
Cooper Nuclear Station 14 February 1, 2002
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SDP Review Dave Kunsemiller
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SDP Analvsis Cooper Nuclear Station February 1, 2002 16
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SDP Decision Block # 13 Could be considered "Quality of Exam" issue.
- More than 20% of questions deemed unacceptable? - NO
- Removing those questions challenged by CNS and NRC would impact maximum of 5 questions on one exam
° "No finding" 17 Cooper Nuclear Station February 1, 2002
SDP Decision Block # 14 Has the security of the written exam been compromised?
- 1. Loss of control of exam material - NO
"* Exam material controls in place
"* No unintended exposure to materials by students
- 2. Was exam validity affected? - NO Cooper Nuclear Station 18 February 1, 2002
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I III SDP Decision Block # 14 Examinations were valid and reliable based on NUREG 1021.
,/Valid
- Content validity (appropriate sampling of knowledge).
- Operational validity (reflect actual operational conditions and decisions).
- Discrimination validity (use of exam banks and exposure to exam banks coupled with confidence in testing knowledge).
v/Reliable
- Consistency and repeatability.
NUREG 1021, Rev. 8, Appx. A Cooper Nuclear Station 19 February 1, 2002
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IIII SDP Decision Block # 14 Other standards applied to ensure exams were valid and reliable.
- Regulatory standard in ES-602 met for novelty of questions.
- Applied regulatory standards in ES-401 for operator initial license exams to duplication and significantly modified questions.
- Requal exams developed for CNS 2000 biennial written exam contained no duplicate questions, and all were either new or significantly modified.
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I SDP Decision Block # 14
"* Evidence of exam security breach - NO
- No advance knowledge of actual questions.
- Analysis of results indicates consistency with past operator performance.
"* Block # 14 decision should be NO
- Leads to No Finding via Block # 15 21 Cooper Nuclear Station I
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I II SDP Decision Block # 17 Were appropriate measures taken immediately? - YES
- Evaluation concluded that exam was valid.
- Exam confirmed by PEER review to be valid.
- Upon reassessment no additional failures.
- Evaluation confirms that operators returned to shift were qualified.
- No compensatory measures were necessary
- "Green finding" 22 Cooper Nuclear Station February 1, 2002
SDP Review Conclusions
- SDP process demonstrates that finding has no or very low safety significance.
Cooper Nuclear Station 23 February 1, 2002
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II Root Cause/Extent of Condition John Christensen
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Root Cause Analysis
"* Two root causes completed
"* Summary of root causes
- Weak procedural guidance.
- Focus primarily on duplicate questions.
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IIII Extent of Condition Review Extent of condition review determined that issues related to this violation were limited to 00-20 written exam only.
- No other previous requalification exams were conducted using same development and validation processes.
- No other exam processes affected by this issue.
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I Corrective Actions John Christensen
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I!I Corrective Actions Corrective Actions were prompt Completed detailed analysis of impact on exam.
Revised CNS exam development and administration processes to provide specific guidance for conducting exam validation.
Revised CNS procedures to provide more control of examination material for non-regulatory exams.
Completed benchmark of other utilities for question duplication on successive exams for non-regulatory exams.
- New process in use during current requal written examination.
All corrective actions to prevent recurrence are complete.
28 Cooper Nuclear Station February 1, 2002
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III Closing Summary Dave Wilson