ML19345B061

Responds to NRC 800924 Ltr Re Violations Noted in IE Insp Rept 50-298/80-13.Corrective Actions:Quizzes Graded Promptly to Assure Proper Monitoring of Requalification Program.Qa Training Will Be Incorporated Into Station Training Program

ML19345B061
Person / Time
Site:	Cooper
Issue date:	10/16/1980
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19345B059	List: ML19345B061
References
LQA8000434, NUDOCS 8011260051
Download: ML19345B061 (4)

Text

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CoopE A NUCLEAR STATION Nebraska Public Power District

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LQ A8000434 October 16, 1980 Mr. Karl V. Seyfrit, Director U.S. Nuclear Regulatory Co= mission Of fice of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to IE Inspection Report No. 50-298/80-13

Dear Mr. Seyfrit:

This letter is written in response to IE Inspection Report No. 50-298/80-13.

Statement of Violation 10 CFR 55, Appendix A, Requalification program Requirements, requires that the requalification program include pre-planned lectures on a regular and continuing basis throughout the license period in those areas where annual operator and senior operator written examinations indicate that scope and depth of coverage is needed. This is amplified in Cooper Nuclear Station's requalification program approved by NRR on August 18, 1976 which states, "With the exception of special activity periods, such as refueling outages, the lecture series will be spread reasonably evenly throughout each ye.r."

10 CFR 55, Appendix A, Requalification Program Requirements, also re-quires the requalification program include written examinations which determine licensed operator's and senior operator's knowledge of sub-jects covered in the requalification program and provide a basis for evaluating their knowledge of abnormal and emergency procedures. The licensee's approved requalification program, states, " Written examin-ations shall be given covering material presented in the requalification program lecture series."

Contrary to the above:

1. The licensee had not initiated a requalification program lecture series tor the 1980 training cycle beginning in February 1980.

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'Mr. Karl V' . Seyfrit October 16, 1980 Page 2.

2. Requalification Qui: 103. 22, administered in November 1979, had not been: graded to determine the knowledge that licensed operators and I senior operators had in the subjects covered'in the requalification program lecture series.

This is an' infraction (289/80-13-01).

Discussion of Violation i We take issue with,th'e first part of this infraction in chat we were, at the time of the inspection, making a reasonable effort toward imple-menting our:requalification program. The 1980 training cycle started in i February ~1980. During this month the 1980 requalification exam was administered. 'The 1980 refueling and maintenance outage extended from March 1,: 1980 through about June 6,1980. During the outage and the -

months of June, July, and August, which are heavy vacation periods, the requalification lecture. series was not initiated. During July we also

were forced to shutdown per IE Bulletin 80-17.

The decision not'to start the requalification training was based on, (1) '

the February 1980 requalification exam score- average was 89% and no individual section score was below 70%;-(2) that time is not available dering refueling outage; and (3) many people were on vacation, had the training been scheduled during June, July, and August.

The first part of our.requalification program for all station personnel 4,

.in the areas of-Security, Radiation Protection, Hands-on' Fire Training I

and Fire Chief Training commenced on September 2,1980. This progsam ,

was completed on October 2, 1980 and the remainder of the licensed oper-

_ ator requalification program, which had not been formally scheduled at 4

the time of the inspection, was formally scheduled and commenced on r October 7, 1980.

We believe this' program was reasonably-spread throughout the year con-sidering the extenuating circumstances which eristed. This was ex-plained to the inspectors at the exit interview. We feel were were ar.d are now in full compliance.

We 'recogni e that. the second part of the infraction violated the intent of our ~ training requalification program and corrective action is ad-dressed below. _

~

Corrective Steps Taken and Results Achieved

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'The requalificat1on qui: was graded. All scores ware satisfactory.

- ,. . = - . . . ., - .- , ,

Mr. Karl V. Seyfrit October 16, 1980 Page 3.

Corrective Steps to Avoid Further Noncompliance The responsible personnel have been informed that quiz:es must be graded pro;ptly to assure proper monitoring of the requalification program.

Date When Full Compliance Will Be Achieved We are currently in f*t11 compliance.

Notice of Deviation Based on the results of an NRC inspection conducted on September 8-11, 1980, it appears that certain of your activities were not conducted in full conformance with your commitment to the Commission as indicated below:

The licensee's approved operator requalification program states that "A planned lecture series shall be presented covering, as a mini =um, those areas where annual examinations indicate the need for additional training in the following subjects:

"1. Theory and principles of operation.

"10. Station QA program as related to station operations."

In deviation from the above, the annual examination administered in February - April,1980, did not address the subject of " Station QA program as related to Station operations" (298/80-13-04).

Discussion of Deviation The topic " Station QA program as related to station operations" was added to the nine existing requalification topics at the time of our program revision in 1976. This was at the insistence of the NRC and was intended to ensure that operations personnel kept current concerning QA practices and procedures. Since that time, operators as well as certain other station personnel have been included in a QA requalification program. We did not consider and still do not consider that the above stated requirement specifically meant that a test question must cover that area. We also discussed this matter with an Operator Licensing Branch member during his last visit at this site. He concurred with our inte rpretation. QA policies and procedures are covered'in general under the Administrative Procedures section of the exam. Bost Administrative Procedures relate to or support the 18 Criteria of 10 CFR 50, Appendix B.

Mr. Karl V. Seyfrit October 16, 1980 Page 4.

Corrective Action Taken The requalification program guide was revised October 1,1980 in re-sponse to the March 28,1980_ letter from H. R. Denton concerning oper-ator training. The reviaed program omits the specific reference to Q.A.

training; this training vill be given as part of the Station QA Training which is :iven to most station employees.

We also feel we were and are now in full compliance.

If you have any questions concerning this response, please contact me.

Sincerely, h4 .'

'S .. Pilant Director of Licensing and Quality Assurance JMP:PJB:cg l

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