ML21217A118

Notification of Inspection (NRC Inspection Report 05000298/2021004) and Request for Information

ML21217A118
Person / Time
Site:	Cooper
Issue date:	08/05/2021
From:	Thomas Farina Division of Reactor Safety IV
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2021004
Download: ML21217A118 (8)

See also: IR 05000298/2021004

Text

August 05, 2021

Mr. John Dent, Jr., Vice President

and Chief Nuclear Officer

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

P.O. Box 98

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF INSPECTION (NRC

INSPECTION REPORT 05000298/2021004) AND REQUEST FOR

INFORMATION

Dear Mr. Dent:

During the week of October 4, 2021, three inspectors from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline biennial requalification

inspection at Cooper Nuclear Station, using NRC Inspection Procedure 71111.11B, Licensed

Operator Requalification Program.

Experience has shown that this inspection is a resource intensive inspection both for the NRC

inspectors and your staff. To minimize the impact to your onsite resources and to ensure a

productive inspection, we have enclosed a request for documents needed for this inspection.

These documents have been divided into three groups:

• The first group (Section A of the enclosure) identifies information to be provided prior to

the inspection to ensure that the inspectors are adequately prepared.

• The second group (Section B of the enclosure) identifies the information the inspectors

will need upon arrival at the site.

• The third group (Section C of this enclosure) identifies the items which are necessary to

close out the inspection and are usually sent a few weeks after the inspectors have left

the site.

It is important that all these documents are up to date and complete to minimize the number of

additional documents requested during the preparation and/or the onsite portions of the

inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Mr. Jim Florence of your training

organization. Our inspection dates are subject to change based on your updated schedule of

examination activities. If there are any questions about this inspection or the material

requested, please contact me, Thomas Farina, at (817) 200-1117 (thomas.farina@nrc.gov).

J. Dent 2

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control

number 3150-0018. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

Thomas Farina, Senior Operations Engineer

Operations Branch

Division of Reactor Safety

Docket No. 50-298

License No. DPR-46

Enclosure:

Initial Request for Information

Biennial Requalification Inspection

Initial Request for Information

Biennial Requalification Inspection

Cooper Nuclear Station

Inspection Report: 05000298/2021004

Inspection Dates: October 4-8, 2021

Inspection Procedure: IP 71111.11B, Licensed Operator Requalification

Program

Lead Inspector: Thomas Farina, Senior Operations Engineer

A. The following information is requested to support inspection preparation activities.

These items are listed by section as they appear in the inspection module (i.e. 03.04a,

03.04b, etc.). Requested materials should uploaded to the NRC BOX server, via a link

provided by the lead inspector, no later than September 24, 2021. Alternately, it may

be sent in an electronic format on CD/DVD to the Region IV office.

• CD/DVD to: US Nuclear Regulatory Commission, Region IV

ATTN: Thomas Farina

1600 E. Lamar Blvd

Arlington, TX 76011

General Requests:

• List of licensed operators (SRO & RO) by crew (operating & staff)

• Training and Operations Department organization charts (with qualified LOR

evaluators identified)

• Procedures that identify process for revising and maintaining LO continuing training

program up to date

• List of outstanding LOR program changes

• List of plant events and industry operating experience incorporated into LOR

program since last BRQ

• Audits and/or self-assessment reports addressing the licensed operator

requalification training program

• Last 2 years of Simulator Review Committee (or equivalent) meeting minutes

• Last 2 years of Curriculum Review Committee (or equivalent) meeting minutes

• A summary report of all condition reports related to operator actions/errors in the

control room

Enclosure

• Any revised requalification training that was based on licensed operator performance

issues

03.04a: Biennial Requalification Written Examinations

• The current and approved biennial written examination schedule

• The current requalification cycle written examination results for both SRO & RO that

have already been administered up to the week prior to the inspectors arrival onsite.

• All written examinations that have been approved for administration up to and

including the week before the inspectors are onsite. This will need to have adequate

password protection or double envelope protection if mailed via regular mail per

NUREG-1021.

• The current requalification cycle examination methodology (sample plan)

03.04b: Annual Requalification Operating Tests

• The schedule for the operating tests (JPMs & scenarios) to be given the week of

October 4, 2021.

• The operating tests (JPMs & scenarios) (password protected and provide separately

via telephone at later date) to be given the week of October 4, 2021.

• Current requalification cycle operating tests (SRO & RO) and results up to the week

prior to the inspection inspectors arrival onsite

• All 2020 NRC required annual operating tests

• Current requalification cycle operating test methodology (sample plan)

• All portions of the UFSAR that identify operator response times for time critical

operator actions

03.04c: Administration of an Annual Requalification Operating Test

• All procedures used to administer the annual operating test

• All procedures used to assess operator performance

• All procedures that describe conduct of simulator training

• All procedures used to test, operate, and maintain the simulator

03.04d: Requalification Examination Security

• Submit any tracking tools that you use to prevent excessive overlap on the written

examinations and meet the intent of sampling all required topics on a periodic basis.

• Submit any tracking tools that you use to prevent excessive overlap on the operating

tests and meet the intent of sampling all required malfunctions (including major

events, instrument/component malfunctions, TS calls, etc.) on a periodic basis.

2

• All procedures that describe examination security, including procedures used to

develop the examinations that include guidelines on overlap between examinations

in current exam cycle tests and prior year examinations

• List of all condition reports since the last biennial requalification inspection related to

examination security and overlap

03.04e: Remedial Training and Re-Examinations

• List of remedial training conducted or planned since last requalification exam

(includes training provided to operators to enable passing requalification exam and

training provided to correct generic or individual weaknesses observed during

previous requalification exam cycle)

• Remediation plans (lesson plans, reference materials, and attendance

documentation)

03.04f: Operator License Conditions

• All procedures and program documentation for maintaining active operator licenses,

tracking training attendance, and ensuring medical fitness of licensed operators

• All procedures and associated documentation that supports reactivation of any

SRO/RO license (operating or staff crew) since the last biennial inspection

03.04g: Control Room Simulator

• An index of the most recent operability test packages required by ANSI 3.5 2009

Appendix B, including performance and approval dates, and results.

• A list of simulator baseline data sources (ANSI 3.5 2009 5.1.1) for the transient

performance tests required by ANSI 3.5 2009 Appendix B.3.2.1.

• All simulator management and configuration procedures if not already provided

• Simulator discrepancy report summary list for all open discrepancy reports and

summary list for those items closed since October 1, 2019.

• Primary parameters tested to verify core physics parameters (such as moderator

temperature coefficient, integral rod worth)). The applicable reference graphs from

the plant physics data book (electronic or other means as available) should also be

included as well as the test procedures used and the acceptance criteria with results.

• All simulator modification packages that are on hold, delayed, or not completed in the

last 2 years

• A list of simulator modification packages completed in the last two-year window

3

• An index of Post-Event Simulator Testing conducted since October 1, 2019.

• Current Simulator Differences List / Lesson plan used in training.

The following information is requested to support the onsite inspection activities.

Requested materials should be available to the inspectors, either electronically or

hardcopy, upon site arrival on October 4, 2021.

03.03: Requalification Exam Results / 03.04a and 03.04b: Biennial Requalification Written

Exam and Annual Requalification Operating Tests Quality

• All operating tests (JPMs & scenarios) to be given in all subsequent weeks after

onsite week, if available

• All results up to the day the inspectors leave the site

03.04f: Conformance with Operator License Conditions

• Access to licensed operators records (operating and staff crews)

• Access to licensed operators training attendance records

• Access to licensed operators medical records

03.04g: Control Room Simulator Performance

• Simulator discrepancies from October 1, 2019. This should include all open and

closed simulator discrepancy reports, including the documentation/justification for

closure.

• Acceptance test documentation, including hardware and software model revisions at

the time of acceptance (as available)

• Documentation that validates current models, including the thermal-hydraulics and

neutronics models, to the actual plant

• All current model deficiencies, including FSAR vs design differences in the simulator

(any documentation on this)

• Summary list of modifications from October 1, 2019.

• Plant modifications (both hardware and software) completed on the simulator by due

date from October 1, 2019.

• Simulator differences lesson plan used in training (current to October 4, 2021.

• The complete book of all simulator annual performance test packages (usually in a

single book but may be electronic or in single test packages), complete with all

transient tests, steady state tests, and malfunction tests. This should also include

the test procedures for each test, the acceptance criteria, and results.

4

• For each transient test, the reference chart should be included or an equivalent

subject matter expert review versus the simulator results with a write-up for any

differences beyond the ANSI standard requirements.

• All test packages used to verify core physics parameters (such as moderator

temperature coefficient and integral rod worth). The applicable reference graphs

from the plant physics data book (electronic or other means as available) should also

be included as well as the test procedures used and the acceptance criteria with

results.

• All simulator tests, configuration management, and related documents available in

the room for inspectors to review. This includes training needs analysis packages,

Simulator Review Committee meeting minutes, etc.

• Current copy of ANSI 3.5 standard you are committed to for simulator testing

B. Cooper Nuclear Station is required to send the final results summary (see Table 1

below) and any remaining exams and operating tests that have not been reviewed to

the regional office lead inspector for this inspection for final review and comparison

against the Significance Determination Tools to communicate the exit results for the

inspection.

TABLE 1: EXAMINATION RESULTS

1. Total number of licensed operators.

2. Number of licensed operators administered a requalification

examination required by 10 CFR 55.59(a).

3. Number of individual licensed operators who failed any portion of a

requalification examination (written, JPM, or individual simulator

scenario failures).

4. Divide line 3 by line 2 to obtain the individual requalification

examination failure rate. Line 3/Line 2.  %

5. Number of crews administered simulator scenarios as part of a

requalification examination required by 10 CFR 55.59(a).

6. Number of crews who performed unsatisfactorily on the

simulator scenarios.

7. Divide line 6 by line 5 to obtain the crew simulator scenario

failure rate. Line 6/Line 5.  %

5

ML21217A118

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: TJF Yes No Publicly Available Sensitive NRC-002

OFFICE SOE:DRS/OB

NAME TFarina

SIGNATURE tjf

DATE 8/3/2021