NLS2002018, Clarification Related to NRC Inspection Report 50-298/0112
| ML020440423 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/25/2002 |
| From: | Denise Wilson Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4 |
| References | |
| IR-01-012, NLS2002018 | |
| Download: ML020440423 (11) | |
Text
Nebraska Public Power District Nebraska's Energy Leader NLS2002018 January 25, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Clarification Related to NRC Inspection Report 50-298/0112 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1) Letter to David L. Wilson (NPPD) from Arthur T. Howell III (USNRC) dated January 2, 2002, "NRC Inspection Report 50-298/0112; Preliminary White Finding (Cooper Nuclear Station)"
- 2) Letter to the U.S. Nuclear Regulatory Commission from David L. Wilson (NPPD) dated January 11, 2002, "Request for Regulatory Conference" By letter (Reference 1), the Nuclear Regulatory Commission (NRC) cited an apparent violation and provided the Nebraska Public Power District (NPPD) an opportunity to discuss its position regarding this issue during a Regulatory Conference. This conference is scheduled for February 1, 2002. By letter (Reference 2), NPPD responded agreeing to a Regulatory Conference and committing to provide additional information prior to the conference as requested, to facilitate discussions between the NRC and NPPD. The attached information is submitted to clarify and provide additional information.
If you have any questions please contact Mr. David Kunsemiller, Risk and Regulatory Affairs Manager at (402) 825-5236.
Sincerely,
.* David LWilton Vice Presidert of Nuclear Energy
/dwv cc: Regional Administrator USNRC - Region IV/0 Senior Project Manager USNRC - NRR Project Directorate IV-1 Cooper Nuclear Station P.O. Box 98/ Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 http://www.nppd.com
NLS2002018 Page 2 of 2 Senior Resident Inspector USNRC NPG Distribution Records
NLS2002018 Attachment 1 Clarification and Time Line
NLS2002018 Aitachment 1 Page 1 of 3 The following information is provided prior to the February 1, 2002 Regulatory Conference to facilitate discussions between the NRC and the District.
- 1) To clarify the sequences of events and NPPD's actions in response to discovery of this issue, a time line is attached.
- 2) Page 4 in the Report Details section of Inspection Report 50-298/0112 states, "The licensee's 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."
Response
NPPD's original report, issued September 5, 2001, (provided during the inspection) states in its conclusion that, "...the examination should be considered compromised" and "...the impact of the validation process on the examination results was negligible." This conclusion of compromise was not based on the form/similarity of the exam questions, but instead was based upon the equitable administration of the validation process (i.e., the individual operators would possibly gain advantage through exposure to certain reference materials via the validation of the exam). This response was supported by an additional report that focused on statistical evaluations of the results, and was completed on November 8, 2001. That report stated, "Overall, the statistics do not support any consistent advantage gained by the validation process." The November 8, 2001 document was silent on whether a compromise had occurred or not.
- 3) Page 4 in the Report Details section of Inspection Report 50-298/0112 states, "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."
Response
NPPD's November 8, 2001 analysis provided to the NRC was the basis for the NRC's conclusion in its January 2, 2002 inspection report. The NPPD report analyzed the consequences of a worst case scenario. The report also showed that if regrading on this "worst case" basis were performed, it would result in some operators failing the examination.
However, after studying the inspection report and re-evaluating the questions based on regulatory guidance, NPPD has now concluded that the "worst case" results are not valid and do not accurately reflect actual performance on the examination. In addition, the NPPD report attached to the NRC Inspection Report 50-298/0112 concluded that there were some questions in which compromise could not be statistically eliminated. The NRC inspection report also noted question sets in which the results "supported a conclusion that the examination was not administered in an equitable and consistent manner." NPPD has duplicated what NPPD believes to be the process used by the NRC for regrading the affected examinations by removing all of the NRC and CNS challenged questions. The results of
NLS200201 8 Page 2 of 3 NPPD's regrades show that no additional operator failures would occur. Therefore, using the NRC's approach, NPPD concludes that there is no impact resulting from the validation methods used for the 2000 biennial licensed operator requalification written exam. In addition, removal of all of the above-mentioned questions would result in no more than five questions removed from anyone 35 question exam. NPPD is providing additional supporting information attached to this submittal.
- 4) With regard to the flowchart block #14 of Appendix I (Inspection Manual 0609), NPPD believes there is a clear distinction between the definition of compromise as stated in 10CFR55.49 and guidance regarding how to address occurrence of a compromise in Inspection Manual 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP).
The operator requalification SDP defines compromise as a loss of control of the exam material such that the exam validity is affected. NPPD's analysis demonstrates that the exam was valid and therefore in the context of the SDP. NPPD concludes that the actions taken and documented by NPPD in August 2000 were appropriate.
NLS2002018 Page 3 of 3 Timeline 2/17/00 to 6/1/00 Exams Developed 6/13/00 to 7/25/00 Annual written exams validated and administered 8/10/00 Problem Identification Report (PIR) 4-10812 written to identify possible preconditioning of operators 8/11/00 Peer Evaluation performed and concluded no compromise existed 9/18/00 to 10/29/00 Annual operating exams administered 12/5/00 PIR 4-10812 closed based on exams being valid 7/10/01 Notification 10096558 written, possible incorrect conclusion to PIR 4-10812 7/13/01 Industry Expert evaluation begins 7/14/01 1Vt CNS evaluation begins 7/24/01 Industry Expert evaluation concluded potential compromise existed 7/26/01 1" CNS position paper concluded unintended potential compromise existed 1 st CNS evaluation concluded exam was compromised but valid 9/5/01 10/15/01 NRC Licensed Operator Requal Program Inspection begins (IP 71111.11) 10/18/01 2 "dCNS position paper issued (request by NRC) concluded possible inequitable administration, validity not affected. Scores consistent with past performance.
11/08/01 Second detailed CNS evaluation (request by NRC) concluded statistics do not support consistent advantage gained by the validation process.
12/3/011 NRC telephonic exit 1/2/02 NRC IR 50-298/0112 issued 1/4/02 Significant Condition Report (SCR) 2001-1495 initiated to determine why a potential compromise was not identified during the evaluation of PIR 4-10812 in August 2000.
NLS2002018 Aftachment 2 Attachment 2 Examination Regrade
NLS2002018 Attachment 2 Page 1 of3 Re-grade results for 5 NRC identified question sets and 4 CNS identified question sets NRC report 50-298/0112 identified 5 question sets that based on crew performance supports the conclusion that the examination was not administered in an equitable and consistent manner and thereby compromised. These question sets were 10,15,S31, S32, and R35. It further concluded that if the examinations were regraded with the removal of questions that showed evidence of compromise, at least two individuals would have failed and that these individuals were returned to shift duties without re-training and re-evaluation.
A re-grade of the 2000 Licensed Requalification written exam was performed removing the questions that showed evidence of compromise (10, 15, S31, S32, R35). This regrade revealed that the only licensed operators with post regrade scores less than 80% were the individuals who failed the original exam. These individuals were properly re-trained and re-examined prior to resuming shift duties.
The questions that showed evidence of compromise (10, 15, S3 1, S32, R35) were only removed from exams if the corresponding question used for validation was similar to the one on the exam.
The following is a breakdown of question removal Test 1 Remove S31, S32, R35 Test 2 Remove 10, S31, R35 Test 3 Remove (S29 see note below)
Test 4 Remove 10, 15, S31, R35, (S29 see note below)
Test 5 Remove S31, S32 Note:
Question set SR029 was also included in this re-grade since one of the operations training instructors noted he was asked to assist in the validation of this question for 2 crews by explaining TRM chemistry requirements. The crews that took test 3 and 4 both averaged 100%
on this question. The remaining crews averaged 40% on this question. As a result, an assumption was made that the crews that took test 3 and 4 were the crews that received the TRM training, so this question was eliminated.
Attached is a table that shows the post question removal re-grade scores.
NLS2002018 Page 2 of 3 NAME NRC NRC AND CNS NOTES QUESTIONS QUESTIONS REMOVED REMOVED Test I SCORE GRADE SCORE GRADE SRO 30/33 90.9 30/33 90.9 SRO 28/33 84.8 28/33 84.8 SRO 30/33 90.9 30/33 90.9 RO 30/34 88.2 30/34 88.2 RO 28/34 82.3 28/34 82.3 Test 2 SRO 27/33 81.8 27/33 81.8 SRO 29/33 87.8 29/33 87.8 SRO 29/33 87.8 29/33 87.8 SRO 30/33 90.9 30/33 90.9 SRO 30/33 90.9 30/33 90.9 SRO 27/33 81.8 27/33 81.8 SRO 31/33 93.9 31/33 93.9 RO 31/33 93.9 31/33 93.9 RO 28/33 84.8 28/33 84.8 RO 29/33 87.8 29/33 87.8 Test 3 SRO 30/35 85.7 29/34 85.3 SRO 30/35 85.7 29/34 85.3 RO 27/35 77.1 27/35 77.1 Failed Original RO 28/35 80.0 28/35 80.0 RO 29/35 82.8 29/35 82.8
NLS2002018 Page 3 of 3 Test 4 SRO 29/32 90.6 28/31 90.3 SRO 29/32 90.6 28/31 90.3 SRO 27/32 84.4 26/31 83.9 RO 27/32 84.4 27/32 84.4 RO 22/32 68.7 22/32 68.7 Failed Original Test 5 SRO 24/33 72.7 24/33 72.7 Failed Original SRO 27/33 81.8 27/33 81.8 SRO 28/33 84.8 28/33 84.8 SRO 29/33 87.8 29/33 87.8 RO 32/35 91.4 32/35 91.4 RO 29/35 82.9 29/35 82.9
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS Correspondence Number: NLS2002018 The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal represent intended or planned actions by the District. They are described for information only and are not regulatory commitments.
Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None.
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