IR 05000298/2004007

IR 05000298-04-007; 02/10-14/2004; Cooper Nuclear Station; Special Inspection to Verify Provisions of the NRC Confirmatory Action Letter and the Licensee'S Strategic Improvement Plan (TIP)

ML042220048
Person / Time
Site:	Cooper
Issue date:	08/06/2004
From:	Howell A NRC/RGN-IV/DRP
To:	Edington R Nebraska Public Power District (NPPD)
References
IR-04-007
Download: ML042220048 (25)

Text

ust 6, 2004

SUBJECT:

COOPER NUCLEAR STATION - QUARTERLY CONFIRMATORY ACTION LETTER INSPECTION REPORT 05000298/2004007

Dear Mr. Edington:

On May 14, 2004, the NRC completed an inspection at your Cooper Nuclear Station. The enclosed inspection report documents the inspection findings, which were discussed on June 23, 2004, with you and other members of your staff during a telephone exit meeting.

This inspection examined activities related to the NRC Confirmatory Action Letter, dated January 30, 2003, and the Strategic Improvement Plan, Revision 2. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection no findings of significance were identified.

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 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).

Sincerely,

/RA/

Arthur T. Howell III, Director Division of Reactor Projects Docket: 50-298 License: DPR-46

Enclosure:

NRC Inspection Report 05000298/2004007

Nebraska Public Power District -2-

REGION IV==

Docket.: 50-298 License: DPR-46 Report No.: 05000298/2004007 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: P.O. Box 98 Brownville, Nebraska Dates: October 6-10, 2003, with additional in-office review through May 19, 2004 May 10-14, 2004, Telephonic exit June 23, 2004 Team Leader: W. Walker, Senior Project Engineer, Project Branch C, Division of Reactor Projects (DRP)

Inspectors: D. Dumbacher, Project Engineer, Project Branch D, DRP C. Osterholtz, Senior Resident Inspector, Project Branch C, DRP C. Paulk, Senior Reactor Inspector, Engineering Branch, DRS T. McConnell, Reactor Inspector, Plant Engineering Branch, DRS Approved By: Arthur T. Howell IIl, Director Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000298/2004007; 02/10-14/2004; Cooper Nuclear Station; special inspection to verify provisions of the NRC Confirmatory Action Letter and the licensees Strategic Improvement Plan (TIP).

The inspection was conducted by four Region-based inspectors and one resident inspector.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

This inspection was the sixth of a series of inspections performed by the NRC to assess Nebraska Public Power Districts progress with respect to the implementation of their improvement plan and to verify the effectiveness of actions taken in response to the provisions outlined in the NRC Confirmatory Action Letter, dated January 30, 2003. The inspection primarily focused on the areas specified in the Confirmatory Action Letter which include: (1)emergency preparedness; (2) human performance; (3) material condition and equipment reliability; (4) plant modifications and configuration control; (5) corrective action program, utilization of industry operating experience, and self-assessments; and (6) engineering programs. In addition, the inspection reviewed baseline inspection reports, licensee performance measures, and the licensee staffs utilization of performance indicators and assessed the progress in the above areas.

In the area of emergency preparedness, the licensees performance indicators, NRC performance indicators, and baseline inspection results indicated a satisfactory level of performance. Also in the area of engineering programs, improvements are in place and an improving trend has been noted in licensee performance indicators and no significant findings have been identified during NRC baseline inspections. In the area of human performance, baseline inspection findings continue to be identified in which personnel errors have contributed to plant performance issues. TIP action steps implemented and ongoing have provided some improvement as evidenced by two of four licensee performance indicators performing satisfactorily and the other two requiring further improvement but trending in a positive direction.

In the three remaining Confirmatory Action Letter areas, the team concluded, by reviewing licensee performance indicators, NRC performance indicators, licensee self-assessments, and NRC baseline inspection results, that a number of positive actions have been implemented but they have not yet resulted in sustained improved performance. Specifically, in the area of material condition and equipment reliability, actions completed to date have provided the necessary processes for improvement, and numerous equipment improvements have been recently completed. However, a number of the licensees performance indicators did not meet their performance goals. In the area of plant modifications and configuration control, progress in operability determination screening and lesson learned training was noted and provides potential for enhancing the licensees ability to prioritize and perform operability determinations by emphasizing knowledged based tools. This conclusion was reinforced through interviews with operations and engineering personnel. Lastly, in the area of corrective action, a new take action now philosophy has also been implemented to increase manager ownership of corrective action performance indicators, through presentations of performance indicator status to senior management on a regular basis. The early trending information or the effectiveness of the take action now philosophy has shown a marked improvement in timely corrective actions.

REPORT DETAILS

The following documents are available to the public in the NRC Agency-wide Document Access and Management System (ADAMS) using the appropriate accession number. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

The licensees Strategic Improvement Plan (TIP), Revision 1; dated June 10, 2002; ADAMS Accession Number ML023010136 TIP, Revision 2; dated November 25, 2002; ADAMS Accession Number ML030340146 The Nuclear Regulatory Commission Confirmatory Action Letter (CAL) dated January 30, 2003; ADAMS Accession Number ML030310263 TIP consists of a series of individual steps, each with an assigned scheduled completion date.

As each step is completed, the licensee staff creates a closure package containing all associated documents, drawings, procedures, etc., that support the closure of that step. An independent reviewer checklist is completed for each step to ensure package completeness and is included in the closure package. The team reviewed the completed closure packages for the steps indicated in this report.

To assess the licensees progress in implementing the improvement plan, the team reviewed documents and interviewed personnel responsible for the completed action plan steps to verify that the steps were completed on schedule as defined in the CAL and that the actions taken met the intent of the action plan step. In addition, the team assessed the effectiveness of the improvement plan by reviewing the results of NRC baseline inspections, NRC performance indicators, and licensee performance measures and indicators.

1. CAL Item 1 - Emergency Preparedness

a. Scope

The licensee had previously completed all emergency preparedness action plan steps addressed in the CAL. The NRCs review of these steps is documented in NRC Inspection Report 05000298/2003009. However, the team performed a review of licensee performance indicators and NRC baseline inspection results to determine effectiveness of TIP actions associated with emergency preparedness.

b. Implementation of Action Plan Steps All actions had been previously completed and reviewed by the NRC.

c. Performance Assessment The team reviewed the following licensee performance indicators (these performance indicators are similar to the NRC performance indicators in the Emergency Preparedness Cornerstone):

Indicator Performance Trend Alert and Notification Green - Excellent Performance Stable System Reliability (number of successful siren tests in previous 4 quarters divided by total number of siren tests in previous 4 quarters)

Emergency Preparedness White - Meets Goal Stable Emergency Response Organization (ERO) Staffing (tracks ERO staffing vacancies to assure adequate personnel to manage the responsibilities of the ERO)

ERO Drill Participation Green - Excellent Performance Stable (measures percentage of key ERO members who have participated recently in proficiency enhancing drills, exercises, training opportunities, or in an actual event)

ERO Performance White - Meets Goal Stable (number of successful emergency opportunities divided by total opportunities in previous 12 months)

The team determined that TIP emergency preparedness performance indicators were meeting licensee goals.

The team also reviewed NRC performance indicators and baseline inspection results and determined there were no significant findings.

d. Conclusions

The team reviewed the licensees performance indicators, NRC performance indicators, and baseline inspection results for emergency preparedness and concluded that the licensee staff continues to demonstrate an acceptable level of performance.

2. CAL Item 2 - Human Performance

a. Scope

The team reviewed the following completed TIP, Revision 2, action plan steps associated with CAL Item 2, Human Performance:

Action Plan Title Step 5.1.4.1 Human Performance 5c, 6, 7, 8, 20b The team reviewed the closure packages and supporting documentation and conducted interviews with various licensee personnel knowledgeable of the specific steps. The team also reviewed the baseline inspection reports and licensee performance measures and performed a review of site performance indicators to evaluate the effectiveness of TIP actions associated with human performance.

b. Implementation of Action Plan Steps The licensee staff completed the CAL-related improvement plan steps as scheduled, and the actions taken met the intent of the associated steps.

c. Performance Assessment The team performed a review of four licensee performance indicators associated with human performance:

Indicator Performance Trend Human Performance Yellow - Action Required Stable Event Free Days Configuration Control White - Meets Goal Stable Events Human Performance Yellow - Action Required Positive Error Rate OSHA Recordable Injury White - Meets Goal Stable Rate Two of the four indicators demonstrated performance with further action required (Yellow). Two indicators demonstrated acceptable performance (White). All the indicators demonstrated stable or positive trends.

The team determined that TIP action steps implemented and ongoing have provided some overall improvement in human performance as evidenced by two of four licensee performance indicators performing satisfactorily and an improving trend noted in human performance data over the last 6 months. Specific actions that have had a positive impact included: increased use of management observations in the field, maintenance department implementation of job-site specific reviews of human performance tools, a monthly Management Performance Review Meeting which focuses site upper management on progress in improving site-wide human performance and site-wide training using a recently developed human performance simulator.

Despite these improvements, baseline inspection findings continue to be identified.

The team reviewed baseline NRC inspection reports from March to June 2004 and determined that the following examples of failure to follow procedures by operators resulted in errors:

• A failure to follow station procedures resulted in an incorrect breaker being opened causing an inadvertent actuation of the primary containment isolation system in March 2004.

• A failure to follow station procedures for equipment control of diesel fuel oil storage tank cross tie valves resulted in both emergency diesel generators being declared inoperable in March 2004 Procedural noncompliance has been previously identified as one of the common themes within this area. In addition, two yellow indicators (Human Performance Error Rate and Human Performance Event Free Days), although demonstrating a stable or improving trend, indicate a need for further effort in this area. The licensee has implemented additional actions to improve human performance. These activities include: an initiative implemented site wide in March 2004 to address concerns with procedure use and adherence expectations; a site level Good Catch recognition tool; a more consistent method of communicating error information; and requirements to provide supervisors more time in the field.

d. Conclusions

The team reviewed the baseline inspection findings, licensee performance measures, NRC performance indicators, and licensee self-assessments to determine whether the licensees actions have been effective in improving human performance. The team concluded that some improvements have been observed as reflected in two of the licensee performance indicators. However, a number of human performance errors continue to occur. These errors have resulted in improper operation of safety-related equipment and incorrect system configuration involving risk significant accident mitigation systems, resulting in inoperability of safety-related equipment. The licensee has continued to implement additional actions to improve human performance, including the start of a second cycle of site-wide training using the human performance mock-up trainer and ongoing emphasis on quality management observations to improve human performance.

3. CAL Item 3 - Material Condition and Equipment Reliability

a. Scope

The team reviewed the following completed TIP , Revision 2, action plan steps associated with CAL Item 3, Material Condition and Equipment Reliability:

Action Plan Title Steps 5.3.1.2.a Service Water 5d 5.3.1.2.c Offsite Power/Switchyard Reliability 18, 19, 21 5.3.1.2.d Feedwater Controls Improvement 2, 3 5.3.1.2.e Water Sulfates 5, 7, 8, 17, 19 5.3.1.2.f Heating, Ventilation, and Air Conditioning 1b, 1c, 1d, 2b, 2c, 2d, 8, 5c, 6 5.3.1.2.g Primary Containment Vacuum Breakers 3 5.3.1.2.h Control Room Recorder Obsolescence 2c1, 3b1, 6 5.3.1.2.i Air Systems 8b, 8d 5.3.1.2.j Kaman Radiation Monitors 2, 2c 5.3.1.2.k Optimum Water Chemistry 6 5.3.1.1 Equipment Reliability Improvement Plan 1c, 2, 3f, 4b, 5d, 8 The team reviewed the licensees closure packages and supporting documentation. In addition, interviews with knowledgeable licensee personnel and equipment walkdowns were conducted. The team reviewed NRC baseline inspection reports and 19 licensee site performance indicators that are used to assess the effectiveness of TIP actions associated with material condition and equipment availability.

b. Implementation of Action Plan Steps The licensee completed the CAL-related improvement plan steps as scheduled. The actions taken satisfied the intent of the associated steps.

c. Performance Assessment The team reviewed the following 19 licensee performance indicators to aid in the assessment of the performance in the area of material condition and equipment reliability.

Indicator Performance Trend Components in Green - Excellent Stable Accelerated Testing Control Room Deficiencies Green - Excellent Stable Forced Loss Rate Red - Unsatisfactory Positive (18-Month)

Long-Term White- Meets Goal Positive Clearance Orders Maintenance Rework Yellow - Action Required Stable On-Line Corrective Green - Excellent Positive Maintenance Backlog On-Line Plant Leaks Green - Excellent Stable Overdue Preventive Green - Excellent Stable Maintenance Non-Technical Program White - Meets Goal Positive Health Risk Significant Yellow - Action Required Stable Functional Failures Safety System Functional Failures White - Meets Goal Stable Safety System Unavailability:

Emergency A/C Green - Excellent Negative Power HPCI White - Meets Goal Stable RCIC White - Meets Goal Stable RHR White - Meets Goal Stable System Health Yellow - Action Required Stable Unplanned Entries Red - Unsatisfactory Negative into LCOs Chemistry Performance Red - Unsatisfactory Positive The team observed that there has been improvement in the licensee performance indicators tracking long-term clearance orders, overdue preventive maintenance, corrective maintenance backlog, and nontechnical program health. In addition, recent performance improvements have been noted in water sulfate chemistry, optimum water chemistry, reactor building ventilation, and control room recorders. The team observed that 6 of the 19 licensee performance indicators were either unsatisfactory or have action required. Two indicators have a negative trend, Emergency A/C Power and Unplanned Entries into LCOs. Unplanned LCO entries trended from white to red. The major contributors to this change were equipment failures associated with Kaman Radiation Monitors, Fire Doors, Air Operated Valves and Motor Operated Valves associated with Primary and Secondary Containment. Notification 10312078 was written and contained a recommendation to evaluate the effectiveness of programs initiated to address unplanned LCO entries.

The 19 performance indicators and 11 action plans having deliverables this inspection show evidence of improving equipment reliability. However, during interviews the licensee acknowledged that in the area of equipment reliability their focus needs to be broader than the CAL related TIP items. The other action plan areas will require continued monitoring and completion of remaining improvement deliverables to lend confidence that the licensee can focus on other priorities. In addition the licensee has initiated a new integrated process designed to prioritize and schedule maintenance.

This process emphasizes feedback to reveal issues and to serve as a trend mechanism.

The team determined that the licensees ability to identify latent equipment and material condition problems prior to functional failures actually occurring needs continued effort.

Functional failures continue to occur on a too frequent basis as evidenced by the licensees Risk Significant Functional failure performance indicator which remained in the action required (Yellow) category this inspection quarter.

The following risk significant failures have recently occurred contributing to the unsatisfactory PI:

• Repeated clogging of the emergency diesel generator fuel oil strainer in March 2004;

• Tripping of the A turbine equipment cooling pump in February 2004.

d. Conclusions

The team determined that the licensee completed the CAL-related TIP items as scheduled. During interviews the licensee acknowledged that in the area of equipment reliability their focus needs to be broader than the CAL related TIP items. As such the licensee has initiated a new integrated process designed to prioritize and schedule maintenance. This process emphasizes feedback to reveal issues and to serve as a trend mechanism.

A review of the most recent baseline inspection results revealed additional inspection findings involving emergency diesel generator reliability. The team concluded that the licensee was tracking the system health and risk significant functional failure performance indicators. Actions were being implemented to improve performance in these areas; however, the failure rate does not meet licensee expectations as noted by the yellow performance indicator.

4. CAL Item 4 - To Resolve Long-Standing Problems With Plant Modifications and

Configuration Control

a. Scope

The team reviewed the following completed TIP action plan steps associated with CAL Item 4, Resolve Long-Standing Problems with Plant Modifications and Configuration Control:

Action Plan Title Steps 5.2.1.2 Operability Determinations 7, 10 5.3.3.3 Unauthorized Modifications 5, 7 The team reviewed the closure packages and supporting documentation and conducted interviews with various licensee personnel knowledgeable of the specific steps. The team also reviewed baseline inspection reports and licensee performance measures and performed a review of six licensee performance indicators used to track effectiveness of the TIP actions associated with the CAP, utilization of industry operating experience, and self-assessment.

b. Implementation of Action Plan Steps The licensee staff completed the CAL-related improvement plan steps as scheduled, and the actions taken met the intent of the associated step.

c. Performance Assessment The team reviewed the following six Plant Modifications and Configuration Control Performance Indicators:

Indicator Performance Trend Modification Green - Excellent Positive Closeout Backlog Operator Challenges Green - Excellent Positive Operator Workarounds Green - Excellent Positive Temporary Modifications Green - Excellent Positive Drawings and Vendor Green - Excellent Negative Change Backlog Drawing Change White - Meets Goal Stable Notice (DCN) On-time Completion Five of the six performance indicators were in the Green band, four of which indicated a positive trend and the other (Drawings and Vendor Change Backlog) a negative trend.

The team noted that the DCN on-time completion performance indicator still indicated White, but that the previously noted negative trend in this indicator had stabilized.

The team considered that the new program for increasing the effectiveness of operability determinations (ODs) provided a potential enhancement for increasing the licensees ability to prioritize and perform ODs by emphasizing knowledge based tools.

The teams assessment was reinforced through interviews with operations and engineering personnel. The team also concluded that efforts to resolve problems with unauthorized modifications had improved. Based on corrective actions initiated, for example, the licensee performed 33 Engineering Evaluations in 2003 to identify the need to incorporate DCNs to eliminate unauthorized configurations. The team also noted that, as of May 2004, 23 additional DCNs had been generated and the remaining 10 had been scheduled for the January 2005 refueling outage, indicating progress was made and is ongoing.

d. Conclusions

The team determined that the licensee completed the CAL-related TIP items as scheduled. The licensees performance indicators were all satisfactory and 4 of 6 were trending in the positive direction. The team noted that the new program for increasing effectiveness of operability determinations was recently initiated and included provisions for increasing the licensees ability to prioritize and perform operability determinations. The team also concluded that efforts to resolve problems with unauthorized modifications had imporved.

5. CAL Item 5 - To Resolve Long-Standing Problems With The Corrective Action

Program (CAP)

a. Scope

The team reviewed the following TIP action plan steps associated with CAL Item 5, Corrective Action Program, Utilization of Industry Operating Experience, and Self-Assessments:

Action Plan Title Steps 5.2.7.1 Improve Use of CAP (Corrective 1a, 1j, 5a Action Program) to Effectively Resolve Station Problems The team reviewed the closure packages and supporting documentation and conducted interviews with various licensee personnel knowledgeable of the specific steps. The team also reviewed baseline inspection reports and licensee performance measures and performed a review of five licensee performance indicators used to track effectiveness of the TIP actions associated with the CAP, utilization of industry operating experience, and self-assessment.

b. Implementation of Action Plan Steps The licensee staff completed the CAL-related improvement plan steps as scheduled, and actions taken met the intent of the associated step.

c. Performance Assessment The team performed a review of the five site performance indicators used to track effectiveness of the TIP actions associated with the CAP, utilization of industry operating experience, and self-assessments. Specifically, the team reviewed the following indicators:

Indicator Performance Trend Corrective Action Green - Excellent Stable Program Performance Index Timeliness of Cooper Nuclear Green - Excellent Positive Station Response to Industry Issues Significant Condition Report Green - Excellent Negative On-Time Completion Corrective Action Program Red - Unsatisfactory Negative Self-Identification On Schedule Completion Green - Excellent Stable of QA Findings The team noted that the performance indicator for CAP self-identification had declined from Yellow to Red with a negative trend. The licensee indicated that this was primarily due to findings as a result of an increased number of quality assurance audits that were recently performed. The licensee initiated Notification 10313582 to assess the negative trend and to evaluate areas for improvement in corrective action self-identification. The licensees assessment was still in progress at the end of the inspection. Of the other PIs, Timeliness of CNS Response to Industry Issues was Green with a positive trend, On Schedule Completion of Quality Assurance Findings was Green and stable, and Significant Condition Report On Time completion was Green with a negative trend.

The team determined that efforts were ongoing to reinforce a take action now philosophy, creating a methodology for increasing line manager ownership of corrective action performance indicators, and establishing an equipment trending program for incorporating corrective action program work items. The team reviewed the licensees program to enhance line manager ownership of performance indicators through presentations of performance indicator status to senior management on a regular basis and considered it a good initiative. The licensee also demonstrated that early trending information on the effectiveness of on-the-spot corrective action through the take action now philosophy was reducing the corrective action backlog and ensuring high priority notifications were addressed in a timely manner.

d. Conclusions

The team determined that the licensee completed the CAL-related TIP items as scheduled. The team reviewed the performance indicators and determined that 4 of 5 indicators were meeting licensee goals. The CAP self-identification performance indicator was unsatisfactory. The licensee was in the process of evaluating corrective actions to improve performance in this area. Also recent actions to improve line manager ownership of the corrective action program have resulted in a reduction of the corrective action backlog and the effectiveness of the on the spot corrective action through the take action now philosophy has resulted in more timely correction of plant problems.

6. CAL Item 6 - Engineering Programs

a. Scope

The team reviewed the following completed TIP, Revision 2, action plan step associated with CAL Item 6 Engineering Programs:

Action Plan Title Step 5.3.2.1 Engineering Programs 40 The team reviewed the closure package and supporting documentation and conducted interviews with various licensee personnel knowledgeable of the specific step. The team also reviewed baseline inspection reports and licensee performance measures and performed a review of three licensee site performance indicators that are used to assess the effectiveness of TIP actions associated with engineering programs.

The team reviewed the actions taken by the licensee to address the qualification of electrical equipment required to operate in harsh environments to mitigate the accident that caused the harsh environment. The effort consisted of the review of 24 environmental qualification data packages; the procedural guidance for documenting and demonstrating qualification; 9 qualification test reports; and Engineering Evaluation EE 03-086, "Assessment of CNS Compliance with 10CFR50.49," dated June 27, 2003. The inspectors also reviewed the corrective actions taken in response to Notice of Violations05000298/2000007-05, "Failure to Maintain Environmental Qualifications of Safety-Related Equipment," and 05000298/2000010-03, "Failure to Take Prompt Corrective Actions," as stated in Cooper Nuclear Station Letters NLS2001104 and NLS2000109, respectively.

b. Implementation of Action Plan Steps The licensees staff completed the CAL-related improvement plan step as scheduled, and action taken met the intent of the associated step.

The team noted that work had been performed during the development of the qualification data packages by contractors. The contractor did not have a quality assurance program that met the requirements of Appendix B to 10 CFR Part 50.

Therefore, the work was performed under the Cooper Nuclear Station quality assurance program. All of the work performed by the contractor was reviewed and approved by licensee personnel.

The team also noted that some of the calculations used to support the qualification data packages had not received approval at the time of the inspection. The team found that those calculations did not adversely affect the qualification of installed equipment at Cooper Nuclear Station. Those calculations were part of qualification data packages that were being revised to make the packages consistent in form and content. As such, the calculations, as part of the revision process, were to receive the required reviews and approvals.

The team reviewed four audits performed between June 2000 and February 2004 and four quality assurance surveillances performed between July 2001 and June 2003.

The three audits performed between June 2000 and May 2002 that included environmental qualification issues were corrective action program audits and addressed only that aspect of Appendix B.

Each of the surveillances and the February 2004 audit addressed various criteria of Appendix B, including design control, procedural adequacy and implementation, and corrective actions. In Quality Assurance Surveillance Report S302-0203, performed in October 2002, the licensee's reviewer identified that contractors were not performing calculations in accordance with approved procedures. The licensee issued a stop work order and licensee personnel performed independent review and approval of the contractors' work in accordance with approved Cooper Nuclear Station procedures.

c. Performance Assessment The team reviewed the following performance indicators:

Indicator Performance Trend Overdue Preventive White - Meets Goal Stable Maintenance Cooper Nuclear Station White - Meets Goal Stable Program Health Engineering Inventory White - Meets Goal Positive The team noted that all of the performance indicators were meeting licensee goals and have remained stable or continued to improve from the last quarterly inspection. In addition, all the performance indicators were trending in the positive direction. Also, the teams review of baseline inspections indicated no adverse trends in this area.

d. Conclusions

The team determined that the licensee completed the CAL-related TIP items as scheduled. The team reviewed the licensee performance indicators for engineering programs and determined all of the indicators were meeting licensee goals.

The team also found that, in the area of environmental qualification of electric equipment, appropriate oversight of quality activities had been applied through audits and surveillances. This oversight assured that contractor supplied work products were accurate and in compliance with Cooper Nuclear Station procedures and regulatory requirements.

4AO6 Exit Meeting On October 9, 2003, the team presented their findings regarding the environmental qualification portion of the inspection, to Mr. R. Eddington and members of his staff.

The management representatives acknowledged the inspection results.

On June 23, 2004, a telephonic exit meeting was held to present the results of the CAL inspection to Mr. Minahan and other members of the licensee staff. The licensee staff acknowledged the inspection results.

While some materials examined during the inspection should be considered proprietary, no proprietary information is included in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Boyce, Corrective Action and Assessments

D. Buman, Manager, Design Engineering

J. Christensen, Co-Director of Nuclear Safety Assurance

D. Cook, Manager, Strategic Improvement Plan

R. Edington, Vice President - Nuclear Energy and Chief Nuclear Officer

R. Estrada, Performance Assessment Department Manager

P. Flemming, Licensing Manager

T. Hottavy, Manager of Equipment Reliability Department

G. Kline, Director of Engineering

D. Knox, Manager, Maintenance

D. Meyers, General Manager Site Support

S. Minahan, General Manager Plant Operations

D. Montgomery, Human Performance Coordinator

T. Pospisil, Engineer, Environmental Qualification

J. Sumpter, Senior Engineer, Licensing

M. Unruh, Program Engineer, Environmental Qualification

B. Toling, Manager, Root Cause Analysis

W. Victor, Senior Licensing Engineer

A. Williams, Manager, Engineering Programs

NRC

S. Alexander, Senior Engineer, Office of Nuclear Reactor Regulation

S. Cochrum, Resident Inspector, Cooper Nuclear Station

S. Schwind, Senior Resident Inspector, Cooper Nuclear Station

LIST OF ITEMS

CLOSED

05000298/2000007-05 NOV Failure to Maintain Environmental Qualifications of Safety-Related Equipment

05000298/2000010-03 NOV Failure to Take Prompt Corrective Actions Attachment