ML20198D722
| ML20198D722 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/24/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20198D520 | List: |
| References | |
| CNSS860300, NUDOCS 8605230349 | |
| Download: ML20198D722 (3) | |
Text
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GENERAL OFFICE Nebraska Public Power District
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CNSS860300 April 24,1986 g - 51986 b,-
J p.
Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
NPPD Response to Inspection Repart 50-298/86-06
Dear Mr. Gagliardo:
This letter is written in response to your letter dated March 7, 1986, transmitting Inspection Report 50-298/86-06.
Therein you indicated that one of our activities was in violation of NRC requirements.
Following is a statement of the violation and our response in accordance with 10CFR2.201.
Statement of Violation Failure to Follow the Requalification Training Plan 10 CFR Part 50.4(1-1), states, in part, "Notwithstanding the provisions of 50.59, the licensee shall not, except as specifically authorized by the Commission, make a change in an approved operator requalification program by which the scope, time allotted for the program for frequency in conducting different j
parts of the program is decreased." The licensee's approved requalification training program requires that individuals who score less than 80% correct on a section of the annual requalification examination, attend lectures pertinent to that section and that written examinations covering the lecture material presented be given.
Contrary to the above, two individuals who had scored less than 80% on specific sections of the 1984 requalification examination were not given written examinations as required by the approved requalification training plan after lectures, which they were required to attend because of low scores on the annual requalification examination.
' 5605230349 860519 lPDR ADOCK 05000298 G
PDR 760(62. 'th
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Mr. J. E. G:glinrdo April 24,1986 Page 2 This is a Severity Level IV violation (Supplement I.D) j (50-298/8606-02),
i Reason for Alleged Violation i
This alleged violation was discussed at length during the course of the Inspection.
The problem was clearly due to a difference in interpretation of our approved Operator and Senior Operator Requalification Program description.
In Section III,
" EVALUATION", paragraph B, the requirement is stated as j
follows:
" Written examinations shall be given covering material presented in the requalification program lecture series."
)
We do not believe that this statement should be interpreted to l
mean that a written examination is to be administered after each lecture. Hence, the reason for this alleged violation is due to a l
difference in interpretation of requirements specified in the CNS i
program. However, we do recognise that as a matter of j
standard practice, written examinations (quisses) administered after a series of lectures is an expected evaluation method of training program effectiveness.
In these instances cited, this 4
was not done.
l Corrective Steps Taken and Results Achieved i
l While we do not believe that our Licensed Operator Training Program requirements were violated, we do recognize that in these cases cited, the normal sequence of exam administration was not followed. To date, increased emphasis has been taken to insure that written examinations (quizzes) are administered consistent with standard practice.
Corrective Steps Taken to Avoid Further Violation It is our intent to continue administering quizzes covering i
]
lecture material presented subsequent to the lecture series l
conducted. However, recognizing that the approved program as j
written lends itself to misinterpretation, the District intends to l
3 revise the existing Program description to more clearly delineate j
requirements.
l Date When Full Compliance Will Be Achieved CNS is in full compliance with our stated Program requirements.
i R6 submittal of the Program description to clarify requirements i
shall be completed no later than 60 days after receipt of I
{
accreditation of these programs.
This action is expected to be j
completed prior to December,1986.
l j
t i
i
Mr. J. E. Grgli:rds 3
April 24,1986 Page 3 Should you have any questions regarding this response, please contact me.
Sincerely, tu J. M. Pilant Technical Staff Manager Nuclear Power Group JMP:DLR:JVS:dmr24/4(Y1) 3 e
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