NLS2004089, Reply to a Notice of Violation NRC Letter No. EA-04-120

Reply to a Notice of Violation NRC Letter No. EA-04-120

ML042120239
Person / Time
Site:	Cooper
Issue date:	07/26/2004
From:	Edington R Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
EA-04-120, NLS2004089
Download: ML042120239 (6)

Text

Nebraska Public Power District Always there when you need us NLS2004089 July 26, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Reply to a Notice of Violation NRC Letter No. EA 120 Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46

Reference:

1. Letter to Randall K. Edington (Nebraska Public Power District) from Dwight D. Chamberlain (U.S. Nuclear Regulatory Commission) dated June 25, 2004, "NRC Supplemental Inspection Report 05000298/2004-01 1 and Notice of Violation" The purpose of this letter is to provide Nebraska Public Power District's (NPPD) reply to a Notice of Violation in accordance with 10 CFR 2.201. By letter dated June 25, 2004 (Reference 1), the Nuclear Regulatory Commission (NRC) cited NPPD for being in violation of NRC requirements.

The violation is concerned with the inadequate use of cycle written examinations to evaluate comprehension of training subjects presented during Licensed Operator Requalification training.

Reference I discusses the performance deficiency associated with this violation. This report concluded that failure to administer comprehensive cycle examinations on a regular, periodic basis that test on the topics covered in training, had a significant impact on the effectiveness of the Licensed Operator Requalification training.

NPPD recognizes the importance of its responsibilities in the licensed operator requalification process and accepts the violation. NPPD has taken prompt action to ensure compliance with 10 CFR 55.59 and to prevent recurrence of this violation.

Enclosure I of Reference I requested that NPPD's reply to the Notice of Violation be clearly marked as a "Reply to a Notice of Violation; EA-04-026." During a telephone conversation between Jerry Roberts (NPPD), et al, and Ryan Lantz (NRC), et al, on July 25, 2004, this was identified as a typographical error. The correct designation for the Notice of Violation is "EA-04-120."

COOPERNUC!ARSTATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax (402) 825-5211 www.nppd.com

NLS2004089 Page 2 of 2 Should you have any questions concerning this matter, please contact Mr. Paul Fleming at (402) 825-2774.

Si erely, andall K. Edington Vice President - Nuclear and Chief Nuclear Officer

/dwv Attachment cc: Regional Administrator w/ attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector wI attachment USNRC NPG Distribution w/ attachment Records w/ attachment 4

Attachment I NLS2004089 Page I of 3 REPLY TO A NOTICE OF VIOLATION: EA-04-120 COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During Nuclear Regulatory Commission (NRC) inspection activities conducted from April 5 through May 12, 2004, a violation of NRC requirements was identified. The particular violation and Nebraska Public Power District's (NPPD) reply are set forth below:

Restatement of the Violation Section I 0 CFR 55.59(c) provides, in part, that "The requalficationprogram must meet the requirements ofparagraphs(c)(J) through (7) of this section. In lieu ofparagraphs(c)(2), (3) and (4) of this section, the Commission ma)' approve a programdeveloped by using a systems approach to training." Section JO CFR 55.4 defines a systems approach to trainingas "a trainingprogram that includes thefollowing five elements... ' Element (4) is "Evaluation of trainee mastery of the objectives during training."

Through Generic Letter 87-07 and the licensee's notificationdatedAugust 13, 1987, the NRC approved the licensee's requalficationprogram, developed using a systems approachto training.

Cooper TrainingProgramProcedure201, "CNS Licensed/SRO CertifiedPersonnel Requalfication Program," Revision 25, Step 4.1. 1 requires that, "Cycle examinationsshall be used to evaluate comprehension of trainingsubjects presented duringLOR (licensed operator requalification)training.... ' Step 2.1.7 defines a cycle written examinationas, "A written exam to demonstrateproficiency on materialcovered during cycle(s) training." The licensee divided the biennial requalficationtrainingprogram into 12 trainingcycles, each of which was approximately 6 weeks in duration.

Contrarv to the above, during the biennialrequalficationprogram periodfrom February25, 2002 through January 11, 2004, the licensee's use of cycle written examinations was not adequateto evaluate comprehensionof trainingsubjectspresentedduring LOR training. During this biennialrequalficationprogramperiod, the licensee administereda total of three cycle written examinations. Two of the cycle examinationswere administeredfollowing two cycles of training. The third cycle examination was administeredfollowingsix cycles of training (a period of approximately 36 weeks) andfailedto test comprehension of several trainingsubjects, including,for example, changes to severe accident managementguidelines and modifications to the reactorvessel level control system.

This violation is associatedwith a White significance determinationprocessfinding that was previously issued in a NRC letter ofMarch 24, 2004.

j

Attachment I NLS2004089 Page 2 of 3 Admission or Denial of Violation NPPD accepts the violation.

Reason for Violation

Background

The operating examinations for the Licensed Operator Requalification program at Cooper Nuclear Station were administered November through December 2003. Failures during the biennial cycle included a thirty-six percent failure on the biennial written examination. Examiner Standard 601 E.3.a(1) specifies, in part, that for a requalification program to maintain satisfactory performance, seventy-five percent or greater of the participants must pass all portions of the biennial examinations.

During the examination cycle, licensed operators and Shift Technical Engineer personnel who failed any portion of the examination were removed from license and/or shift duties. Following the examination cycle some of the questions were regraded resulting in additional failures. The final overall failure rate was forty-six percent. Those licensed operators and Shift Technical Engineer personnel affected by this regrade, were also removed from license and/or shift duties.

Some of these personnel had previously returned to license and/or shift duties following their initial examination. This is the subject of a Green non-cited violation documented in Inspection Report 2004-011. Personnel affected by the failures were subjected to remedial training and retested prior to returning to shift watch-standing duties, or a determination was made by plant management that the license was no longer required.

Final significance determination for the high failure rate resulted in a White finding as stated in a NRC letter of March 24, 2004. The NRC, from April 5 through May 12, 2004, conducted a supplemental inspection. This inspection concluded that failure to administer comprehensive cycle examinations on a regular, periodic basis that test on the topics covered in training, had a significant impact on the effectiveness of the Licensed Operator Requalification training. The NRC determined this to be a violation of 10 CFR 55.59(c).

Cause for Violation NPPD performed a formal root cause evaluation for the condition that resulted in a White finding. This root cause evaluation encompasses the condition identified in the Notice of Violation. The root cause and corrective actions resulting from the evaluation are applicable to the violation. The evaluation determined the reason for the violation was several organizational and process breakdowns over the two-year cycle. The common tie with these breakdowns was ineffective fundamental management oversight of the training and examination processes.

Attachment I NLS2004089 Page 3 of 3 Corrective Steps Taken and Results Achieved The following corrective steps were taken to correct the conditions that caused the violation.

These actions have been completed.

1. The Operations Training organization was changed to align with the Entergy standard model that facilitates increased supervisory attention on the conduct of the training programs. This action will drive more management oversight of the processes and align CNS with the proven model utilized by the Entergy fleet.

2. NPPD validated that the membership and agenda of oversight committee meetings address the precursors that contributed to the high failure rate and knowledge weaknesses found during training. Membership of the committee was changed to include the Training Manager and establish a quorum. The agenda for the committee meetings was revised to include declining and marginal student performance and to review certain aspects of the Operations two-year plan. This action will facilitate training and line management alignment in controlling training programs.

3. NPPD incorporated the examination strategy into the two-year plan that prepares operators for the comprehensive examination and included this in the appropriate procedure. The two-year plan includes alternating quizzes and open/closed reference exams. The appropriate training procedure was revised to require a minimum of six cyclic written examinations per two-year program cycle and no licensed operator will exceed three cycles without a written examination.

Corrective Steps That Will Be Taken to Avoid Further Violations Corrective steps to prevent recurrence of the violation and to ensure compliance with 10 CFR 55.59 have been completed as noted above.

Date When Full Compliance Will Be Achieved NPPD believes it is in full compliance.

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© l Correspondence Number: NLS2004089 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None t

t I

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