IR 05000298/1988024

Ack Receipt of 881208 & 890210 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/88-24. Understands That Util Now Agrees That Violation Did Occur & Will Provide Addl Details to Prevent Recurrence

ML20245F539
Person / Time
Site:	Cooper
Issue date:	04/24/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8905020416
Download: ML20245F539 (2)

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APR 2 41989 )

In Reply Refer To:

Docket: 50-298/88-24 l Nebraska Public Power Distrilet ATTN: George A. Trevors- j Division Manager - Nuclear Support P.O. Box 499 Columbus, NE- 68602-0499 Gentlemen:

Thank you for your letters of Dece:nber 8,1988, and February 10, 1989. in  !

response to our letter and the attached Notice of Violation dated November 8, 1988. As a result of our review and telephone conversations on April 12 and 14, 1989, we understand that you now agree that the violation did occur and that you will provide additional details regarding your actions to prevent recurrence of the violatio We have no further questions regarding-your response to the open items (298/8212-01; 298/8412-03) and will review the implementation of your corrective action

'during a future inspectio Please provide the supplemental information within 30 days of the date of this lette

Sincerely,

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Original Signed By l L.). Callan L. J. Callan, Director  ;

Division of Reactor Projects cc:-

' Cooper Nuclear Station ATTN: Guy Horn, Division Manager of Nuclear Operations P.O. Box 98 Brownville, Nebraska' 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bcc w/ enclosures: (see next page)

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d U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Subject: NPPD Response to NRC Open Item (298/8212-01; 298/8412-03): Failure to Develop and Implement Training Plan for Offsite Personnel Cooper Nuclear Station Docket No. 50-298, DPR-46 Reference (1) Letter from Callan to G. A. Trevors dated November 8, 1988, transmitting Inspection Report 88-24 Centlement This letter is written in response to Reference (1) in which you requested that the District describe the actions taken, or being planned, to resolve the issue of training for corporate technical support personnel as discussed in paragraph 2.4.4 of the subject repor Following is a discussion of the open item s,d our respons (open) Open Item (298/8212-01; 298/8412-03): Failure to Develop and Implement i Training Plan for Offsite Personnel -

This open item identified the lack of a comprehensive training plan for corporate technical support personne ]

This program deficiency was identified on April 28, 1982, and it was identified ,

as Open Item isd/u2-0 The licensee formed a task force to resolve this '

and other training issue This task force developed a training program for general office (Corporate) personnel, which was approved on April 5,  !

1983, In 1984, this area was again reviewed by the NRC and it was found that "a formal written technical and nontechnical training program and j

requalification program which includes defined goals, objectives, schedules, j lesson plans, methods of evaluating the effectiveness of the training, and j methods for record retention had not been developed at the time of the

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inspection." This was again identified as an open itte (298/8412-03). During its meeting on January 14, 1988, the SRAB reviewed this issue and recommended that action be taken to resolve this issue. During this inspection the NRC inspector found that this issue was still open. The NRC is concerned that *

this item has been open for at least 6 years and has asked the licensee to respond to this report with a description of the actions to be taken to resolve this issu $~'h ~0 0 gg2-){

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NLS8900075 February 10, 1989

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Response In March and April 1988 initial meetings were held between training and corporate engineering personnel to identify the steps required to establish a formal training program for appropriate Nuclear Engineering Department (NED)- personnel to be developed using systematic -

approach-to-training method As a result, matrices of available training courses were prepared to assist line management in defining their training need Pending the development of this formal program, which was to be described in a Training Program Description, in May 1988 a revision to the NED Training Task Book 1 was issue This NED Training Task Book had been used in the past to outline and describe an indoctrination and training program for newly hired engineers in NE This revised book was used as an interim training course until the formal training program could be finalize This training program methodology continues to be utilized in NED and is effectiv Training records are maintained by the respective NED supervisors. Portions of this manual will be incorporated into the formal training progra On September 23, 1988 and again on October 6, 1988 representatives of the Corporate Training Department, the Nuclear Training Department, and the Nuclear Engineering Department met to start draf ting a Training Program Description (TPD), for the subject training program, in accordance with Nuclear Training Department procedure It is anticipated that this TPD will complete final review and be approved by March 1, 198 Upon TPD approval this training program will be formally administered under Nuclear Training Department procedures and will have defined goals, objectives, lesson plans, effectiveness evaluations and record retention requirement Please call me if you have any questions regarding this respons

Sincerely,

. . Trevors Division Manager Nuclear Support

/jw cc: U.S. Nuclear Regulatory Commission Regional Office, Region IV Arlington, TX

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Resident Inspector Office  ;

Cooper Nuclear Station '

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NLS8800554 December 8, 1988 '

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U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Subject: NPPD Response to NRC Inspection Report No. 50-298/88-24; Cooper Nuclear Station Docket No. 50-298, DPR-46 Reference: 1) Letter from L. J. Callan to C. A. Trevors dated November 8, 1988, transmitting Inspection Report 88-24 l Gentlemen:

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This letter is written in response to your letter dated November 8, 1988, Reference Therein you indicated that one of our activities was in violation of NRC requirement Following is the statement of the violation and our response in accordance with 10CFR2.201: i Statement of Violation Failure to Adequate 1v Review Procedure Changes The Cooper Nuclear Station Technical Specification (TS) 6.2.1.B.4.a, requires in part, that the safety evaluations for changes to procedures shall be reported to and reviewed by the safety review and audit board to verify that such actions did not constitute an unreviewed safety _

questio ,

Contrary to the above, the safety evaluation for changes to normal, abnormal, maintenance, and emergency operating procedures, which were reviewed by the station operations review committee in accordance with  !

TS 6.3.1, 6.3.2, 6.3.3, and 6.3.4, were not being routinely provided to the safety review and audit board for their required review in meetings No. 115 through 130, dated January 1987 through September 198 This is a Severity Level IV violatio (Supplement I) (298/8824-02)

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NLS8800554 =

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Reason for Violation if Admitted The District is of the opinion that a violation of CNS Technical Specification 6.2.1.B.4.a did not occur and requests a reconsideration of the violatio The District contends that safety evaluations for certain changes to procedures were submitted to and reviewed by the Safety Review and Audit Board (SRAB) in accorJance with Technical Specification requirement CNS Procedure 0.4, " Preparations, Review, and Approval of Procedures,"

currently requires that every procedure change receive a Safety Evaluation Applicability revie The intent of this review is to screen all procedure changes to ensure that the ones which 1) could result in an unrevieved safety question or, 2) require a change to Technical Specifications, are identified and then subjected to a detailed safety evaluatio A key feature of the applicability review is that should any uncertainty exist regarding the potential for either an unreviewed safety question, or Technical Specification change, a detailed safety evaluation is also performe Sections V.B.6 and V.C.5 of CNS Procedure 0.4 provide that "Should the Safety Evaluation applicability review indicate that a Safety Evaluation is required, ;

than the package shall be forwarded to the Engineering Manage The Engineering Manager ensures that a detailed Safety Evaluation is performed in accordance with CNS Engineering Procedure 3.3, " Station Safety ;

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Evaluations." Precedure 3.3,Section V.A.6, then requires that the submittal be sent to the SRAB for their revie The District's position is that the Safety Evaluation applicability review required by CNS Procedure 0.4 is a review to determine if a safety evaluation is require It is recognized that the guidance provided in NRC Inspection and Enforcement Manual, Part 9800, dated January 1, 1984, allows a simpler screening process to be imposed for proposed changes (i.e., Is the Safety Analysis Report (SAR) affected?). However, as described above, the intent )

of CNS Procedure 0.4 is to provide a more comprehensive review of proposed procedure change In reality, the applicability review, however, is clearly not a detailed safety evaluation as specified by the CNS Tech Specs and need not be reviewed by the SRA The District is concerned that the violation, as written, implies that the i NPPD Safety Review and Audit Board must review all procedure changes to comply with Technical Specification 6.2.1.B. To require the review of all procedures is both in3onsistent with the written requirements of the Technical Specification and Edd-intent. The Standard Review Plan, Section 13.4 and the Second Proposed Revision 3 to Regulatory Guide 1.33, Appendix A, as well as the CNS Technical Specifications, are clear that the Independent Review and Audit Group (NPPD SRAB) is not responsible for reviewing all procedures, oniv those requiring detailed Safety Evaluations for the change To require SRAB to conduct these reviews is not required nor meaningfu This time-consuming effort and the resulting review would unnecessarily divert and dilute the safety responsibilities of those involve On the j other hand, we realize that the existing procedural requirements need to be clarified to address the purpose of, and difference between, a preliminary and detailed safety evaluatio This clarification will be implemented by March 198 l

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Based on the above, the District respectively requests your reconsideration of the violatio It should be noted during your reconsideration that we have proceeded to ensure that SRAB receives copies of all procedure change safety evaluations, both preliminary and detailed, to alleviate all NRC concerns in this are The District's response to Open Item (298/8212-01; 298/8412-03), Failure to Develop and Implement Training Plan for Offsite Personnel will be the /

s'ubject of separate correspondenc If you have any questions regarding this response, please contact m

Sincerely, IfA O&

G. A. Trevors

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Division Manager Nuclear Support

/rg cc: U Nuclear Regulatory Commission Regional Office - Region IV Resident Inspector Cooper Nuclear Station

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