IR 05000298/2003001

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Annual Assessment Letter - Cooper Nuclear Station (Report 50-298/03-01)
ML030650070
Person / Time
Site: Cooper Entergy icon.png
Issue date: 03/04/2003
From: Merschoff E
NRC Region 4
To: Warren C
Nebraska Public Power District (NPPD)
References
IR-03-001
Download: ML030650070 (9)


Text

rch 4, 2003

SUBJECT:

ANNUAL ASSESSMENT LETTER - COOPER NUCLEAR STATION (REPORT 50-298/03-01)

Dear Mr. Warren:

On February 6, 2003, the NRC staff completed its end-of-cycle plant performance assessment of Cooper Nuclear Station. The end-of-cycle review for Cooper Nuclear Station involved the participation of all technical divisions in evaluating performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2002. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

Overall, the Cooper Nuclear Station operated in a manner that preserved public health and safety. While Cooper Nuclear Station met all cornerstone objectives, plant performance was within the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix based on multiple White findings in the Emergency Preparedness Cornerstone for more than four quarters.

Cooper Nuclear Station began the assessment period in the Degraded Cornerstone Column of the Action Matrix. On April 1, 2002, Cooper Nuclear Station entered the Multiple/Repetitive Degraded Cornerstone Column due to a degraded Emergency Preparedness Cornerstone that existed for more than four quarters. The White findings that contributed to the repetitive degraded cornerstone were identified during the previous two assessment periods and were described in the annual assessment letters dated May 29, 2001, and March 4, 2002.

As a result of the degraded Emergency Preparedness Cornerstone, the NRC conducted a supplemental inspection in April 2002. The results of this inspection indicated that Nebraska Public Power District's (NPPD) root cause evaluation did not fully identify and assess all contributing causes that resulted in the breakdown of the Emergency Preparedness Program.

These two findings, which were assessed during the third quarter of calender year 2001, remained open during this assessment period.

Nebraska Public Power District -2-Upon entry into the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix, and with oversight by the NRC, NPPD developed a plan to improve performance at Cooper Nuclear Station. On June 10, 2002, NPPD submitted Revision 1 of The Strategic Improvement Plan to the NRC. On August 22, 2002, the NRC completed a supplemental inspection using Inspection Procedure 95003, Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input." The inspection found that a number of long-standing performance problems existed at Cooper Nuclear Station. Of greatest concern was the failure of Cooper Nuclear Station to correct recurring performance issues. For example, the improvement plan did not include actions to correct recurring equipment problems and was not comprehensive in addressing problems with the corrective action program. NPPD had been unsuccessful in previous efforts to improve performance with focused improvement plans. The inability to effectively correct problems resulted in recurring problems with the reliability of safety systems, personnel errors, implementation of the emergency plan, and the quality of engineering, training, and maintenance activities. On August 8, 2002, the NRC Executive Director for Operations and the Region IV Regional Administrator met with NPPD to discuss the performance at Cooper Nuclear Station.

Following completion of the NRC supplemental inspection, NPPD revised their improvement plan and submitted Revision 2 of the plan to the NRC on November 25, 2002. On January 30, 2003, NRC issued a Confirmatory Action Letter to NPPD. The purpose of the Confirmatory Action Letter was to confirm the commitments made by NPPD regarding completion of those actions in their improvement plan developed to address regulatory performance issues.

Licensee actions confirmed in the Confirmatory Action Letter addressed long-standing performance issues in the areas of emergency preparedness, human performance, material condition and equipment reliability, plant modification and configuration control, corrective action program, and engineering programs. The NRC will conduct periodic inspections to verify completion of these actions and the effectiveness of these actions in addressing the specific performance issues. Cooper Nuclear Station will remain in the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix until the satisfactory completion of the actions listed in this Confirmatory Action Letter and NPPD has demonstrated sustained improvements in plant performance.

An additional White finding in the Mitigating Systems Cornerstone was finalized during this period and assessed during the fourth quarter of the previous assessment period. This White finding involved a compromise of the 2000 Biennial Requalification Written Examinations. A supplemental inspection, conducted by the NRC, determined that NPPD performed a comprehensive root cause evaluation, determined the extent of condition, and developed appropriate corrective actions for this issue. This finding was closed during the third quarter of this assessment period.

In our annual assessment letter dated March 4, 2002, we advised you of substantive crosscutting issues in the areas of Problem Identification and Resolution and Human Performance. Numerous findings identified during this assessment period indicate that these areas continue to exhibit an adverse trend. Your improvement plan provides for specific actions to address these areas. These activities and any changes resulting from these activities will be reviewed during the scheduled quarterly inspections and as part of the baseline inspection program.

Nebraska Public Power District -3-In accordance with IMC 0305, Operating Reactor Assessment Program, your plant will be discussed at the upcoming Agency Action Review Meeting. We will notify you via separate correspondence if any agency actions change as an outcome of the meeting.

This letter advises you of our planned inspection effort resulting from the Cooper Nuclear Station end-of-cycle review. The enclosed inspection plan details the inspections scheduled through March 31, 2004. In addition to the baseline inspections, quarterly inspections to verify the actions taken with respect to the improvement plan and the Confirmatory Action Letter will be conducted as shown. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last six months of the inspection plan are tentative and may be revised at the midcycle review meeting.

As you are aware, since the terrorist attacks on September 11, 2001, the NRC has issued several Orders and threat advisories to enhance security capabilities and improve guard force readiness. We have conducted inspections to review your implementation of these requirements and have monitored your actions in response to changing threat conditions. For calendar year 2003, we plan to continue these inspections and conduct portions of the security baseline inspection program, as well as perform additional inspections to evaluate your compliance with new requirements that may be ordered. Based on our final determinations in this regard, we will notify you of any inspection plan changes.

In accordance with 10 CFR 2.790 of the NRCs 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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Kriss Kennedy at (817) 860-8144 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Ellis W. Merschoff Regional Administrator Docket: 50-298 License: DPR-46 Enclosure:

Cooper Nuclear Station Inspection/Activity Plan

Nebraska Public Power District -4-cc w/enclosure:

Michael T. Coyle Site Vice President Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 P. V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources 205 Jefferson Street Jefferson City, Missouri 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, Missouri 65101

Nebraska Public Power District -5-Vick L. Cooper, Chief Radiation Control Program, RCP Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, Kansas 66612-1366 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, Iowa 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, Nebraska 68601 Marlin Logan Presiding Commissioner Atchison County P.O. Box 280 Rock Port, Missouri 64482 Dennis Martin, Sheriff Atchison County Sheriff's Office 511 West Clay Rock Port, Missouri 64482 Loras Baumhover, Sheriff 1805 N Street Auburn, Nebraska 68305 Dick Hainje, Regional Director Federal Emergency Management Agency Region VII 2323 Grand Blvd., Suite 900 Kansas City, Missouri 64108-2670 Gary McNutt, Director, Radiation Control Program Section for Environmental Public Health P.O. Box 570 Jefferson City, Missouri 65102-0570

Nebraska Public Power District -6-Robert Leopold, State Liaison Officer Nebraska Health and Human Services Department of Regulation and Licensure Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Institute of Nuclear Power Operations (INPO)

700 Galleria Parkway SE Atlanta, Georgia 30339-5943

Nebraska Public Power District -7-Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (SCS)

Branch Chief, DRP/F (KMK)

Senior Project Engineer, DRP/F (TRF)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

Jim Isom, Pilot Plant Program (JAI)

RidsNrrDipmLipb V. L. Dricks, PAO (VLD)

W. A. Maier, RSLO (WAM)

C. J. Gordon (CJG)

DRS Branch Chiefs (TWP, ATG, CSM)

W. D. Travers, EDO (WDT)

C. A. Carpenter, Chief, NRR/DIPM/IIPB (CAC)

R. K. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)

R. W. Borchardt, Associate Dir. for Inspection and Programs (RWB1)

B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

S. Morris, Acting Chief, Regional Operations Staff, OEDO (SAM1)

H. Berkow, NRR Project Director (HNB)

R. Gramm, Chief, Section 1, NRR/DLPM (RAG)

M. Thadani, NRR Project Manager (LJB)

S:\DRP\DRPDIR\EOC 2003\Assessment Letters\CNS.wpd RIV:C:DRP/F C:DRS C:DRP RA KMKennedy;df;vlh DDChamberlain ATHowell EWMerschoff

/RA/ /RA/ /RA/ /RA/

2/27/03 2/28/03 2/28/03 3/4/03 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 Cooper 03/05/2003 07:35:26 Inspection / Activity Plan Report 22 03/02/2003 - 03/31/2004 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type ALARA 2 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 03/10/2003 03/14/2003 Baseline Inspections ACCESSPI - ACRSA 1 1 IP 7112101 Access Control to Radiologically Significant Areas 03/17/2003 03/21/2003 Baseline Inspections 1 IP 71151 Performance Indicator Verification 03/17/2003 03/21/2003 Baseline Inspections EMB - ISI 1 1 IP 7111108G Inservice Inspection Activities - BWR 04/07/2003 04/11/2003 Baseline Inspections EMB - SSD&PCI 5 1 IP 7111121 Safety System Design and Performance Capability 05/05/2003 05/09/2003 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 05/19/2003 05/23/2003 Baseline Inspections EMB - 50.59 1 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 05/05/2003 05/09/2003 Baseline Inspections OB-IN - INITIAL EXAM PREP 4 1 X02234 COOPER - INITIAL EXAM (04/03) 05/26/2003 05/30/2003 Not Applicable CNS CAL - CAL QUARTERLY INSPECTION 4 1 IP 71152 Identification and Resolution of Problems 06/02/2003 06/06/2003 Other Routine RP-TM - RAD SAFETY TEAM 5 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 06/09/2003 06/13/2003 Baseline Inspections 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 06/09/2003 06/13/2003 Baseline Inspections 1 IP 7112202 Radioactive Material Processing and Transportation 06/09/2003 06/13/2003 Baseline Inspections 1 IP 7112203 Radiological Environmental Monitoring Program 06/09/2003 06/13/2003 Baseline Inspections OB-IN - INITIAL EXAMS 4 1 X02234 COOPER - INITIAL EXAM (04/03) 06/16/2003 06/20/2003 Not Applicable ALARA3 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 07/07/2003 07/11/2003 Baseline Inspections PSB-EP1 - EP PROGRAM BASELINE INSPECTION 1 1 IP 7111402 Alert and Notification System Testing 07/14/2003 07/18/2003 Baseline Inspections 1 IP 7111403 Emergency Response Organization Augmentation Testing 07/14/2003 07/18/2003 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 07/14/2003 07/18/2003 Baseline Inspections 1 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 07/14/2003 07/18/2003 Baseline Inspections 1 IP 71151 Performance Indicator Verification 07/14/2003 07/18/2003 Baseline Inspections PSB-S1 - SECURITY INSPECTION PROGRAM 1 1 IP 7113002 Access Control (Search of Personnel, Packages, and Vehicles: Identification and Authorizati 08/04/2003 08/08/2003 Baseline Inspections 1 IP 7113003 Response to Contingency Events (Protective Strategy and Implementation of Protective Stra 08/04/2003 08/08/2003 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Cooper 03/05/2003 07:35:26 Inspection / Activity Plan Report 22 03/02/2003 - 03/31/2004 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type PSB-S1 - SECURITY INSPECTION PROGRAM 1 1 IP 71151 Performance Indicator Verification 08/04/2003 08/08/2003 Baseline Inspections CNS CAL - CAL QUARTERLY INSPECTION 4 1 IP 71152 Identification and Resolution of Problems 08/11/2003 08/15/2003 Other Routine OB-PIR - CNS PIR INSPECTION 2 1 IP 71152B Identification and Resolution of Problems 09/15/2003 09/19/2003 Baseline Inspections 1 IP 71152B Identification and Resolution of Problems 09/29/2003 10/03/2003 Baseline Inspections CNS CAL - CAL QUARTERLY INSPECTION 4 1 IP 71152 Identification and Resolution of Problems 11/03/2003 11/07/2003 Other Routine OB-RQ - REQUALIFICATION INSPECTION 2 1 IP 7111111B Licensed Operator Requalification 11/17/2003 11/21/2003 Baseline Inspections CNS CAL - CAL QUARTERLY INSPECTION 4 1 IP 71152 Identification and Resolution of Problems 02/23/2004 02/27/2004 Other Routine EMB - MAINTENANCE EFFECTIVENESS 1 1 IP 7111112B Maintenance Effectiveness 03/15/2004 03/19/2004 Baseline Inspections ACCESSPI - ACRSA/PIV 1 1 IP 7112101 Access Control to Radiologically Significant Areas 03/15/2004 03/19/2004 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.