IR 05000298/2014301

Er 050002982014301; 07/28/2014 to 08/20/2014; Cooper Nuclear Station; Initial Operator Licensing Examination Report

ML14240A053
Person / Time
Site:	Cooper
Issue date:	08/28/2014
From:	Vincent Gaddy Division of Reactor Safety IV
To:	Limpias O Nebraska Public Power District (NPPD)
References
ER-2014-301
Download: ML14240A053 (20)

Text

ust 28, 2014

SUBJECT:

COOPER NUCLEAR STATION - NRC EXAMINATION REPORT 5000298/2014301

Dear Mr. Limpias:

On August 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Cooper Nuclear Station. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on July 31, 2014, with you and other members of your staff. A telephonic exit meeting was conducted on August 20, 2014, with Mr. M. Maness, Initial Training Supervisor, who was provided the NRC licensing decisions.

The examination included the evaluation of five applicants for reactor operator licenses, one applicant for instant senior reactor operator license, and three applicants for upgrade senior reactor operator licenses. The license examiners determined that two of the applicants satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued. There were four post examination comments submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post examination comment resolution.

No findings were identified during this examination. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Vincent G. Gaddy, Chief Operations Branch Division of Reactor Safety Docket: 50-298 License: DPR-46 Enclosures:

1. NRC Examination Report 05000298/2014301, w/Attachment 2. NRC Review of CNS Written Post-Examination Comments 3. Form ES-501 Simulator Fidelity Report Electronic Distribution for Cooper Nuclear Station

ML14240A053 SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: KClayton Yes No Non-Publicly Available Sensitive NRC-002 OFFICE SOE:OB OE:OB SRI:PSB2 SOE:OB SOE:OB C:PBC C:OB NAME KClayton/dch MBloodgood JDrake SGarchow KClayton DAllen VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 8/25/14 8/27/14 8/25/14 8/26/14 8/27/14 8/27/14 8/28/14

Letter to Oscar from Vincent G. Gaddy, dated August 28, 2014 SUBJECT: COOPER NUCLEAR STATION - NRC EXAMINATION REPORT 5000298/2014301 Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Michael.Hay@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Christopher.Henderson@nrc.gov)

Branch Chief, DRP/C (Don.Allen@nrc.gov)

Senior Project Engineer (Ray.Azua@nrc.gov)

Project Engineer (Paul.Nizov@nrc.gov)

Project Engineer (Michael.Langelier@nrc.gov)

CNS Administrative Assistant (Amy.Elam@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Joseph.Sebrosky@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-298 License: DPR-46 Report: 05000298/2014301 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, Nebraska Dates: July 28 to August 20, 2014 Inspectors: K. Clayton, Chief Examiner S. Garchow, Senior Operations Engineer J. Drake, Senior Reactor Inspector M. Bloodgood, Operations Engineer M. Kennard, Operations Engineer (U/I)

Approved By: Vincent G. Gaddy, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY

ER 05000298/2014301; 07/28/2014 to 08/20/2014; Cooper Nuclear Station; Initial Operator

Licensing Examination Report.

NRC examiners evaluated the competency of five applicants for reactor operator licenses, one applicant for instant senior reactor operator license, and three applicants for upgrade senior reactor operator licenses at Cooper Nuclear Station.

The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on August 4, 2014. NRC examiners administered the operating tests the week of July 28, 2014.

The examiners determined that two of the applicants satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued.

NRC-Identified and Self-Revealing Findings

None.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA5 Other Activities (Initial Operator License Examination)

.1 License Applications

a. Scope

NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.

b. Findings

No findings were identified.

.2 Examination Development

a. Scope

NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.

b. Findings

No findings were identified.

The operating test and written examination submitted by the licensee were within the range of acceptability expected for a proposed examination. However, the operating test required substantial work by the examination team during validation to fix such items as critical tasks on scenarios, Job Performance Measure (JPM) critical steps, and appropriate events for the scenarios. One of the scenarios had too many events for one board station (the Balance-of-Plant Operator position) and there were several events that were not safety-significant and, therefore, were removed from the operating test. Furthermore, the critical task list the station uses for both initial examinations and requalification examinations does not meet the NRC standards in NUREG-1021 for proper bounding conditions. For example, one critical task in the proposed draft operating test submittal was Spray the drywell when torus pressure reaches ten psig.

This critical task example and most in this document do not have a parameter bounding the action. This allows the task to be accomplished at any time once ten psig is reached in the drywell and it should be done before any design bases are exceeded or equipment is damaged, as defined in NUREG-1021. A critical task for this action that meets the standard would be to spray the drywell when torus pressure reaches 10 psig and before the pressure suppression pressure is exceeded on the PSP-L graph of the emergency operating procedures. The licensee already has areas for improvement that include improved critical task development and scenario performance weaknesses on critical tasks, with Condition Report CR-CNS-2014-04683 written to address these issues.

During the draft examination and post-examination comment resolution reviews, the NRC examiners had to request additional resources to review examination materials that were not provided as part of the reference material submittal as required by 3 of ES-201 of NUREG-1021. This attachment provides specific guidance on the references required for this submittal and should be a standard submittal each time the licensee submits initial exam materials for review. The licensee wrote Condition Report CR-CNS-2014-04965 to address this issue.

The licensee satisfactorily completed comment resolution of all draft materials prior to examination administration.

During exam validation week, the licensed operator and examiners had challenges while trying to validate a JPM submitted by the licensee to align the Standby Liquid Control (SLC) tanks to the Reactor Core Isolation Cooling (RCIC) pump via a fire hose during emergency conditions using Emergency Procedure 5.8.8, Alternate Boron Injection and Preparation, Revision 14. This JPM could be required to be done in the dark (because of loss of power conditions in the plant and SLC pumps not available) by a single operator (usually a non-licensed operator) and requires routing a fire hose down several levels between electrical conduits. The electrical conduit appeared to interfere with the path that would be used to lower the hose down to the RCIC suction piping. Additionally, the connection at the RCIC pump required an elbow removal from the RCIC suction line connection so that the connection could be made with the fire hose. A smaller drain line was in direct interference with the elbow on the larger RCIC line and would not allow rotation of the elbow to screw it off the pipe without bending the two pipes apart. The procedure did not provide adequate guidance on how to get the elbow off (bending the larger pipe away from the smaller pipe) with this interference issue. The licensed operator and the examiners concluded that the JPM could not be performed with the procedure and equipment configuration in its current state so the JPM was removed from the exam. Subsequent to this action, the licensee responded by sending a senior licensed operator (SRO) with considerable experience to demonstrate that this task could be completed with the current procedure and equipment configuration. Although the NRC requested to watch the JPM, he proceeded on his own (with another individual who appeared to help with the fire hose routing). This SRO later reported to the chief examiner that the task was accomplished with no issues. The examiners went back into the plant to review the pipe interference issue and it was clear that the pipe had been slightly bent to allow removal of the elbow.

The chief examiner turned this issue over to the resident inspector staff for follow-up and the licensee wrote Condition Report CR-CNS-2014-03921 to address the issue and then closed the condition report.

.3 Operator Knowledge and Performance

a. Scope

On August 4, 2014, the licensee proctored the administration of the written examinations to all nine applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post examination comments to the NRC on August 11, 2014.

The NRC examination team administered the various portions of the operating tests to all nine applicants on the week of July 28, 2014.

b. Findings

No findings were identified.

Two of the applicants passed the written examination and all nine applicants passed all parts of the operating test. The final written examinations, the operating test, and post-examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in Enclosure 2. The licensee requested and received approval by the NRC during the initial facility contact discussions to withhold the written examinations from the public document room for two years after the administration date.

The examination team noted the following generic weaknesses during the operating tests:

1) Two of three crews demonstrated a weakness in the ability to diagnose a plugged instrument air dryer, which led to a reactor trip and completely uncovered the fuel during scenario 2.

2) Three out of four senior reactor operator applicants failed to identify entry into Procedure 2.4CHEM, which was required for high conductivity. The required actions in this procedure were more limiting than the TRM requirements, which was the only resource that these three applicants used.

3) There were many examples during JPM and scenario administration where applicants failed to follow procedures. If the applicants had not been able to back out their mistakes and complete the tasks successfully, there would have been several failures on the operating tests due to JPM failures.

4) There were several examples of command and control issues during the scenarios by the senior reactor operator applicants. One example includes handing off abnormal procedures to the board operators without any direction or feedback for actions completed until they were done.

5) Several operators used the wrong section of EOP 5.8.2 to try to get Reactor Water Clean Up in Reactor Pressure Vessel depressurization mode during simulator JPM e.

6) During scenarios, the applicant crews need to be timelier when making plant announcements for plant staff in the field during high radiation and/or high temperature conditions during emergencies to protect the staff in the plant.

7) During scenarios and some JPMs, the crews did not always use Alarm Response Procedures.

The licensee is performing a root cause analysis for the written examination failures and generic operating test weaknesses to address all weaknesses and it will be documented in Condition Report CR-CNS-2014-04931.

Additionally, the licensee submitted four post-examination comments (Q66, Q74, Q83, and Q87) that required review and disposition by the chief examiner. The regional branch chief for operator licensing assigned a panel of examiners that were not part of the examination team effort at Cooper Nuclear Station to review the four question challenges and provide a response back to him and the chief examiner. They reviewed the four questions and accepted one of the four proposed changes to the written examination (Q87-accept two correct answers as requested). The panel denied two of the proposed changes in which the licensee requested deletion of Q74 and Q83 and recommended the deletion of question 66 because of no correct answer. The two question key modifications did not change the outcome of the pass/fail grades on the written examination and consequently seven out of nine applicants failed the written examination. More details are included in Enclosure 2 of this report and the entire licensees post examination comments and analysis can be found in ADAMS using Accession Number ML14234A352.

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.

b. Findings

No findings were identified.

The simulator was not set up for data capture for the scenarios as required by NUREG-1021 and as specified in the corporate notification letter. After the first scenario run on Tuesday, July 29, the simulator was placed in freeze for follow-up questions and the chief examiner asked the licensee if all the data was saved on the simulator for the first run of Scenario 2. They informed him that this was not done. The simulator engineering staff was able to capture this data prior to reset and then set up the simulator to capture 27 parameters (some of which were redundant) for the exam activities. The chief examiner communicated that all safety-related parameters are required to be captured in order for the examiners to be able to determine how the simulator responded to applicant actions and the timing of those actions for grading purposes. Although it did not impact the grading for this exam, it could have challenged the NRC to complete the grading process and, therefore, was discussed with the station. They agreed to correct the issue and entered it into their corrective action program as Condition Report CR-CNS-2014-04695.

There were two simulator fidelity issues observed during the examination administration week. These are documented in Enclosure 3 of this report per NUREG-1021 requirements. The licensee entered these items into their corrective action program as Conditions Reports CR-CNS-2014-04750 and CR-CNS-2014-04753.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

No findings were identified.

The licensee continues to struggle with examination security issues. The licensee received a Green Non-Cited Violation (NCV) for exam security issues on the previous initial examination. On this examination there were multiple near-miss cases involving things like sequestration, use of passwords with electronic exam materials between contractor and licensee, resetting exam security between JPMs (erasing procedures and removing keys from switches), and restriction of personnel activities once they are on the security agreement. These issues are captured in Condition Reports CR-CNS-2014-02998, CR-CNS-2014-03036, and CR-CNS-2014-04966. On June 4, 2014, the licensee reported a hacking event on a contractors home computer who wrote parts of this examination. The licensee reported it to the NRC chief examiner on the same day. The NRC program office was consulted and a subsequent list of questions was provided to the licensee and the contractor by the NRC staff to assess the potential examination security issues. Additionally, the contractor hired a computer forensics company to inspect the computer that was hacked. The computer forensics company determined that 1) the exam files were not compromised, 2) the hacker was only on the computer for a few minutes, and 3) the hacker retrieved financial information for bank fraud then got off of the computer. The computer forensics company also verified during this review that all examination files on the contractors computer were password protected and the password did not reside anywhere on the computer.

Because of this detailed forensics review and acceptable answers to the questions from the NRC staff, the NRC determined that the examination could continue without any changes to its content. The licensee entered this item into their corrective action program as Condition Report CR-CNS-2014-03036.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. O. Limpias, Vice President-Nuclear and Chief Nuclear Officer, and other members of the staff on July 31, 2014. A telephonic exit meeting was conducted on August 20, 2014, between Mr. K. Clayton, Chief Examiner, and Mr. M. Maness, Initial Training Supervisor, communicating the results of the examination.

The licensee submitted proprietary information during the post-examination reviews and these materials have been destroyed or returned to the staff at Cooper Nuclear Station.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

O. Limpias, Vice President-Nuclear and Chief Nuclear Officer

D. Van Der Kamp, Licensing Manager

J. Austin, Training Manager

J. Flaherty, Senior Staff Licensing Engineer, Licensing

J. Olberding, Licensing Specialist

J. Florence, Simulator Supervisor

M. Maness, Initial Training Supervisor

E. Jackson, Exam Developer

NRC Personnel

J. Josey, Senior Resident Inspector

C. Henderson, Resident Inspector