ML040430044
| ML040430044 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/11/2004 |
| From: | Chamberlain D Division of Reactor Safety IV |
| To: | Edington R Nebraska Public Power District (NPPD) |
| References | |
| EA-04-026 IR-04-009 | |
| Download: ML040430044 (14) | |
See also: IR 05000298/2004009
Text
February 11, 2004
Randall K. Edington, Vice
President-Nuclear and CNO
Nebraska Public Power District
P.O. Box 98
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION - NRC INSPECTION
REPORT 05000298/2004-009 BIENNIAL LICENSED OPERATOR
REQUALIFICATION INSPECTION - PRELIMINARY WHITE FINDING
Dear Mr. Edington:
On November 20, 2003, the U. S. Nuclear Regulatory Commission (NRC) completed a biennial
licensed operator requalification inspection at your Cooper Nuclear Station. The enclosed
report documents the inspection findings, which were discussed on February 5, 2004, with
Jerry C. Roberts and other members of your staff.
This report discusses a finding that appears to have low to moderate safety significance
(White). As described in Section 1R11 of this 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). Examiner 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. The finding was assessed using NRC Manual Chapter 0609, Appendix I,
Operator Requalification Human Performance Significance Determination Process (SDP), and
was preliminarily determined to be a White finding. The basis for arriving at this preliminary
determination is described in the enclosed inspection report.
We acknowledge that the personnel affected by the failures, who have returned to shift watch
standing positions, were subjected to remedial training and retested prior to returning to those
duties.
Nebraska Public Power District -2-
Before we make a final decision on this matter, we are providing you an opportunity to
(1) present to the NRC your perspectives on the facts and assumptions used by the NRC to
arrive at the finding and its significance, at a Regulatory Conference or, (2) submit your position
on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held
within 30 days of the date of this letter and we encourage you to submit supporting
documentation 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. If you decide to submit only a written response, such submittal should be sent to
the NRC within 30 days of the receipt of this letter.
Please contact Anthony T. Gody, Chief, Operations Branch, at (817) 860-8159 within
10 business 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 you will
be advised by separate correspondence of the results of our deliberations on this matter.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its
enclosure, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the NRCs document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your
response should not include any personal privacy, proprietary, or safeguards information so
that it can be made available to the Public without redaction.
Sincerely,
/RA/
Dwight D. Chamberlain, Director
Division of Reactor Safety
Docket: 50-298
License: DPR-46
Enclosures:
NRC Inspection Report 05000298/2004-009
cc w/enclosure:
Clay C. Warren, Vice President-Nuclear
Nebraska Public Power District
P.O. Box 98
Brownville, NE 68321
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, NE 68602-0499
Nebraska Public Power District -3-
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
205 Jefferson Street
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 (NBH)
Dan Merzke, Pilot Plant Program (DXM2)
RidsNrrDipmLipb
Debby Jackson, OEDO RIV Coordinator (DAJ1)
CNS Site Secretary (SLN)
OEMAIL
Gary Sanborn
ADAMS: : Yes * No Initials: _GWJ_____
- Publicly Available * Non-Publicly Available * Sensitive * Non-Sensitive
SOE:OB OE:OB ACES C:OB C:IEHB C:PBC D:DRS
GWJohnston/lmb MHaire GSanborn ATGody DTrimble KMKennedy DDChamberlain
/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ WCW for /RA/
2/10/04 2/10/04 2/11/04 2/10/04 2/11/04 2/10/04 2/11/04
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.: 50-298/04-09
Licensee: Nebraska Public Power District
Facility: Cooper Nuclear Station
Location: P.O. Box 98
Brownville, Nebraska
Dates: November 17, 2003, through February 5, 2004
Inspectors: G. Johnston, Senior Operations Engineer
M. Haire, Operations Engineer
Approved By: A. Gody, Chief, Operations Branch
Division of Reactor Safety
-2-
SUMMARY OF FINDINGS
IR 05000298/2004-009; on 10/15-12/03/2001; Cooper Nuclear Station, Licensed Operator
Requalification Report.
The inspection was conducted by two regional operations engineers. The inspection identified
one finding whose significance was preliminarily evaluated as White. The significance of most
findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual
Chapter 0609, Significance Determination Process. The NRC's program for overseeing the
safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- TBD. The licensee 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). 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.
Immediate corrective actions implemented by the licensee included remedial training
and retesting prior to returning operators to shift.
The finding was more than minor because it was associated with the reactor safety
cornerstone attributes concerning the licensee requalification program. High operator
failure rates in the biennial requalification program may be indicative of programmatic
issues with the operator license requalification program. The finding was preliminarily
determined to be of low to moderate significance (White) because the licensee failed to
meet the criteria for maintaining satisfactory performance. (Section 1R11)
Report Details
1. REACTOR SAFETY
1R11 Licensed Operator Requalification (71111.11B)
.1 Biennial Inspection
a. Inspection Scope
The inspectors (1) evaluated examination security measures and procedures for
compliance with 10 CFR 55.49, Integrity of Examinations and Tests; (2) evaluated the
licensees sample plan for the written examinations for compliance with 10 CFR 55.59,
Requalification, and NUREG-1021, Operator Licensing Examination Standards for
Power Reactors, Revision 8, Supplement 1, as referenced in the facility requalification
program procedures; and (3) evaluated maintenance of license conditions for
compliance with 10 CFR 55.53, Conditions of Licenses, by review of facility records
(medical and administrative), procedures, and tracking systems for licensed operator
training, qualification, and watch standing. In addition, the inspectors reviewed remedial
training for examination failures for compliance with facility procedures and
responsiveness to address areas failed.
Furthermore, the inspectors (1) interviewed eight personnel (four operators, two
instructors/evaluators, and two training supervisors) regarding the policies and practices
for administering examinations, and (2) observed the administration of two dynamic
simulator scenarios to one requalification crew by facility evaluators. Job performance
measures were observed for conformance to facility administration practices.
The inspectors also reviewed the remediation process for individuals, who had written
examination failures. The results of the examinations were assessed to determine the
licensees appraisal of operator performance and the feedback of performance analysis
to the requalification training program.
The inspectors interviewed members of the training department, training department
managers, and four members of an operating crew to assess the responsiveness of the
licensed operator requalification program. Inspectors also observed the examination
security maintenance for the operating tests during the examination week.
Additionally, the inspectors assessed the Cooper Nuclear Station plant-referenced
simulator for compliance with 10 CFR 55.46, Simulation Facilities, using Baseline
Inspection Procedure IP-71111.11 (Section 03.11). The inspectors assessed the
adequacy of the facility licensees simulation facility (simulator) for use in operator
licensing examinations. The inspectors did not assess the ability of the simulation
facility to implement experience requirements as prescribed in 10 CFR 55.46 because
the licensee does not use the simulator for reactivity manipulations.
-2-
The inspectors reviewed a sample of simulator performance test records (i.e., transient
tests, surveillance tests, malfunction tests, and scenario-based-tests), simulator work
request records, and processes for ensuring simulator fidelity commensurate with
10 CFR 55.46. The inspectors also interviewed personnel involved in the licensees
simulator configuration control program as part of this review.
b. Findings
Introduction. 10 CFR 55.59 (a)(1) requires each licensee to successfully complete a
requalification program developed by the facility licensee that has been approved by the
Commission. Further, 10 CFR 55.59 (c) states, in part, that the . . . facility licensee
shall have a requalification program reviewed and approved by the Commission. . . .
NUREG-1021, Examination Standard 601, Section 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.
One potential example of a self-revealing finding of low to moderate significance (White)
associated with the licensees licensed operator requalification program.
Description. The licensee failed to demonstrate satisfactory licensed operator
requalification program performance as described in NUREG-1021, Revision 8,
Supplement 1, Examination Standard 601, Section E.3.a(1). 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.
Analysis. The issue was screened using NRC Manual Chapter 0612, Appendix B, and
was found to be a performance deficiency because the licensee failed to demonstrate
satisfactory licensed operator requalification program performance as described in
NUREG-1021, Revision 8, Supplement 1. The finding was more than minor because it
was associated with the reactor safety cornerstone attributes concerning the licensee
requalification program. High operator failure rates in the biennial requalification
program may be indicative of programmatic issues with the operator license
requalification program.
NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance
Significance Determination Process (SDP), (Appendix I) was used to assess the
significance of the finding. Since operator performance during implementation of the
biennial requalification cycle included a 36 percent failure rate on the biennial written
examination, the flow chart was utilized along with a description of a satisfactory
requalification program as described in NUREG-1021, Revision 8, Supplement 1, to
determine the preliminary color of the finding. Appendix I requires that each aspect of a
performance deficiency be evaluated and integrated into an overall assessment of
biennial requalification program performance. This concept is described in the
Introduction, Simulator Operational Matrix, and The SDP Flow Chart, sections of
Appendix I. Of note is the paragraph contained in The SDP Flow Chart section of
Appendix I, which states, Finally, the SDP looks at the overall requalification program
by asking if less than 75% of the operators passed all portions of the exam
-3-
(NUREG-1021, Rev. 8, ES 601), and if more than 20% of the operator licensing records
have operationally risk important deficiencies. Accordingly, to conclude that the
abovementioned performance deficiency statement was appropriate, two aspects of
operator requalification program performance were evaluated using Appendix I:
(Aspect 1) high failure rates on the biennial written examination and (Aspect 2) overall
requalification program performance.
Aspect 1 was limited to the high failure rate on the written examination. Block 2 of
Appendix I asks if the issue was related to incorrect or inappropriate grading of the
written examination or operating test by the licensee. The inspectors found that the
examinations were graded properly. Block 4 of Appendix I asks if the issue was related
to written examination quality, security, or operator performance in taking the
examination. The inspectors found that examination quality was acceptable and that
examination security was maintained. However, 36 percent of the operators failed the
written examination. Therefore, for Aspect 1, Block 4 was answered, yes. Block 13 of
Appendix I asks if the issue was related to the quality (accuracy, clarity,
appropriateness, discrimination, etc.) of the written examination. The inspectors review
of the prepared examinations indicated that the material was prepared in an acceptable
manner and thoroughly covered the biennial requalification cycle curricula. A substantial
portion of the written examinations broadly covered expected operator knowledge.
Further, many of the questions in the examinations were new and covered more topical
areas. Therefore, Block 13 was answered no. Block 14 of Appendix I asks if the
integrity of the written examination had been compromised. As discussed, examination
security was maintained. Furthermore, the inspectors determined that licensee
corrective actions from a previous examination integrity issue were effective. Therefore,
Block 14 was answered no. Block 15 of Appendix I asks if more than 20 percent of the
operators who took the written examination in this training cycle failed. During a review
of operator performance on the biennial written examination, the inspectors determined
that 36 percent of the operators failed the written examination. If Aspect 1 were
evaluated as a stand alone finding, Block 15 would be answered yes. Recognizing
that Block 15 of Appendix I defines the lower boundary for acceptable performance, the
preliminary conclusion of significance was not made until all aspects of the licensees
operator license requalification program performance were evaluated.
As required by Appendix I, Aspect 2 was focused on the overall acceptability of the
licensees requalification program performance. A high failure rate may indicate a
programmatic weakness not narrowly isolated to issues associated with examination
grading, the written examination, the individual operating test, simulator fidelity, scenario
quality, scenario integrity, or crew performance. Therefore, Blocks 2, 4, 5, 6, 20, 21,
and 22 of Appendix I were answered no. In accordance with Block 23 of Appendix I,
since greater than 25 percent of operators failed at least one part of the biennial
requalification examinations, the inspectors concluded that the answer to this question
was yes. Therefore, the performance deficiency was preliminarily determined to be of
low to moderate significance (White). The licensee entered this issue into their
corrective action program as Notification 10284648. The issue was subsequently
classified by the licensee as a significant condition report (SCR 2003-1966).
Enforcement. No violation of NRC requirements associated with this finding have been
identified at this time.
-4-
4OA6 Meetings, including Exit
The inspectors conducted a final telephonic exit meeting to discuss the preliminary
findings and other minor observations with Mr. Jerry C. Roberts and other members of
the licensees staff, on February 5, 2004.
Licensee management did not identify as proprietary any materials examined during the
inspection.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the
licensee and are violations of NRC requirements, which meet the criteria of Section VI of
the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited
violation.
- 10 CFR Part 55.49 requires that licensees not engage in any activities that
compromises the integrity of any examination. Further, Procedure OTP 810,
Operations Department Examination Security, Revision 8, required that any
examination material under development be controlled under the custody of
personnel covered by a security agreement. Contrary to this requirement, the
licensee failed to maintain custody of examination scenario batch files on a
diskette, which was inadvertently left in a simulator instructor console for a
period of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Subsequent review of the material, and the fact that the
material was found in the position last in custody of licensee examination
development personnel, indicated that actual effects on the integrity of the
examination was very unlikely. This finding was discovered on October 16,
2003, and was documented in the licensees corrective action program as
Notification 10276342. This finding was only of very low safety significance,
ATTACHMENT
KEY POINTS OF CONTACT
Licensee
M. Schaible, Operations Training Programs Supervisor
D. Van Der Kamp, Regulatory Affairs
H. McDaniel, Nuclear Instructor 1
P. Fleming, Risk and Regulatory Affairs Manager
L. Edwards, Training Manager
NRC
S. Schwind, Senior Resident Inspector
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
OTP 805, Licensed Operator Annual/Biennial Exam Development, Revision 6
OTP 809, Operator Requalification Examination Administration, Revision 8
OTP 810, Operations Department Examination Security, Revision 8
Examination Materials
2003 Operating Examination Summary
2003 Written Examination Master Sample Plan
2003 Week 1 through 5 Written Outlines
2003 Exam Scenario History
2003 Exam JPM History
2003 Training Scenario Matrix
2003 PRA Data Input
2003 Operating Experience Input
2003 Week 1 LOR Written Exam
2003 Week 2 LOR Written Exam
2003 Week 1 LOR Written Exam Analysis, Licensed Operators Only
2003 LOR Week 1 Written Exam Test Item Analysis
2003 Week 2 LOR Scenario SKL052-52-07 Revision 7
2003 Week 2 LOR Scenario SKL052-52-26 Revision 4
JPM SKL034-30-35
JPM SKL034-10-91
JPM SKL034-10-17
JPM SKL034-11-04
JPM SKL034-21-57
JPM SKL034-21-54
-2-
Self Assessment Corrective Action
Quality Assurance Audit Report 02-01, "Training Programs, February 28, 2002
SA02039 Training Self Assessment Report, September 30 - October 7, 2002
Notification 10232221
Notification 10276342
Training Feedback
Attachment 4, Course Feedback Form for Course/Cycle 02-16
Attachment 4, Course Feedback Form for Course/Cycle 02-12
Attachment 4, Course Feedback Form for Course GEN003-04-01
Attachment 4, Course Feedback Form for Course OTH015-03-02
Simulator Materials
Cooper Simulator Self-Assessment: October 14 -15, 2003
NAIT Feedback Form: RCR 2003-1826 Action 1 regarding lapsed simulator testing
Simulator Discrepancies List by Due Date
SWP 03-0061 regarding discrepancy from Malfunction test ED11C
SWP 03-0062 regarding discrepancy from Malfunction test ED11D
SWP 03-0063 regarding discrepancy from Malfunction test ED11F
CNS SIMULATOR TEST Transient 4 performed 3/23/03
CNS SIMULATOR TEST Stability/Accuracy Test performed 3/21/03
2003 Annual Simulator Performance Report
Management Overview - 2003 Annual Simulator Performance Test Report
Real-Time Trend Plots from RRMG Trip: Tape 86-002
NPPD Simulator Desk Guide 4.1: Simulator Performance Testing
Lesson Plan SKL012-06-01 BET 1851: OPS Simulator Introduction
NAIT Feedback Form: DD 10249452 regarding CNS Simulator Response to 5/26/03 Turbine
Post Event Review: Main Turbine High Vibration Shutdown 5/26/03 (Event 03-07)
Post Event Review: Plant Shutdown for Refueling Outage 20 11/3/00 (Event 01-09)
Post Event Review: Plant Shutdown due to FW Heater LCV Failure 2/20/03 (Event 03-02)
-3-
Post Event Review: Plant Shutdown to Repair Moisture Separator C Reheat Valve 4/20/03
(Event 03-04)
Post Event Review: Manual Scram after Fire on 345KV Wooden Cross-Arm 10/28/03
(Event 03-10)
Appendix E: Simulator System Design Assumptions and Simplifications