IR 05000298/2005001
| ML050610232 | |
| Person / Time | |
|---|---|
| Site: | Cooper  (DPR-046) |
| Issue date: | 03/02/2005 |
| From: | Mallett B NRC Region 4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| References | |
| FOIA/PA-2006-0007 IR-05-001 | |
| Download: ML050610232 (9) | |
Text
March 2, 2005
SUBJECT:
ANNUAL ASSESSMENT LETTER - COOPER NUCLEAR STATION (REPORT 05000298/2005001)
Dear Mr. Edington:
On February 2, 2005, the NRC staff completed its end-of-cycle plant performance assessment of the Cooper Nuclear Station (CNS). The end-of-cycle review for CNS involved the participation of all technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results for the period January 1 through December 31, 2004. 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.
This performance review and enclosed inspection plan do not include physical protection information. A separate end-of-cycle performance review letter designated and marked as Exempt from Public Disclosure in Accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.
Overall, CNS operated in a manner that preserved public health and safety. Plant performance for the most recent quarter was within the Regulatory Response Column of the NRC's Action Matrix, based on one finding of low to moderate significance (White) in the Mitigating Systems Cornerstone, which involved a significant number of licensed operator requalification written examination failures.
While plant performance for the most recent quarter was within the Regulatory Response Column of the Action Matrix, at the beginning of the 2004 assessment cycle, CNS was in the Multiple/Repetitive Degraded Cornerstone column of the NRCs Action Matrix based on three White emergency preparedness findings existing for greater than four quarters. During the second quarter of 2004, the NRC closed these White findings based on correction of the underlying performance deficiencies. However, the NRC concluded that additional oversight was warranted while Nebraska Public Power District (NPPD) completed the actions specified in the Confirmatory Action Letter (CAL), which was issued on January 30, 2003. Accordingly, on May 3, 2004, the Executive Director for Operations approved a deviation from the Action Matrix to authorize the NRC to maintain the level of oversight of CNS consistent with the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix. This enhanced level of oversight included continued NRC assessment of the strategic improvement plan, continued
Nebraska Public Power District-2-assessment of the effectiveness of the CAL actions, and senior NRC management involvement in site visits and other assessment activities. The details of this decision were communicated to NPPD in a letter dated July 2, 2004.
Based on the enhanced level of oversight, the NRC concluded that NPPD had completed the commitments described in the CAL and that these actions were effective in addressing the specific performance issues. Therefore, as discussed in a public meeting held on January 25, 2005, and documented in our letter of January 28, 2005, all commitments documented in CAL 4-03-001, dated January 30, 2003, are closed. Also, since the commitments in the CAL have been satisfied, we have concluded that the enhanced level of oversight described in the Action Matrix deviation memorandum is no longer necessary. As a result, NRC oversight of CNS will be reduced to a level consistent with the Regulatory Response Column of the NRC Action Matrix based on the White finding in the Mitigating Systems Cornerstone, which was issued in March of 2004.
During the assessment period, two supplemental inspections were performed. On May 7, 2004, the NRC completed a supplemental inspection to assess the causes for and actions taken related to the PI for unplanned scrams per 7000 critical hours. This PI crossed the threshold from Green to White in the fourth quarter of 2003 and returned to Green in the first quarter of 2004. The NRC concluded that NPPD performed thorough evaluations for each of the three scrams, including a thorough root cause analysis, extent of cause, and extent of condition review to identify and implement corrective actions.
On May 12, 2004, the NRC conducted another supplemental inspection in response to a White finding involving a high number of failures on the licensed operator biennial requalification written examinations. The NRC determined that NPPDs root cause evaluation of the finding was adequate and corrective actions identified should correct the requalification program weaknesses. However, the inspection also concluded that NPPDs extent of condition and extent of cause evaluations were not completed at the time of the inspection and that other areas of the root cause lacked in-depth evaluation, including the adequacy of operator knowledge and the establishment of objective criteria to evaluate the effectiveness of the corrective actions. A followup inspection to verify the effectiveness of NPPDs additional corrective actions is in progress.
Additionally, on August 12, 2004, the NRC staff issued an inspection report with a preliminary Greater than Green finding. The finding involved the misalignment of the service water system that rendered one train of service water system inoperable for a period of 21 days. A regulatory conference was held September 27, 2004, at the NRC Region IV office. During this conference, NPPD indicated that the significance of this finding was very low. The final significance determination of this finding is pending. This finding does not represent a current safety concern because the valve lineup was restored to the normal configuration.
As updated in our Midcycle Performance Review letter, dated August 30, 2004, we advised you of our continuing concerns associated with two substantive crosscutting issues in the areas of human performance and problem identification and resolution. In the human performance area, we acknowledged the actions you had taken and noted some improvement in performance, but we also noted continuing problems. We indicated our intention to assess the effectiveness of your actions to improve the level of procedural compliance and to reinforce expectations and
Nebraska Public Power District-3-standards in the performance of work. In the problem identification and resolution area, we acknowledged your past actions to address this area and the new initiatives you were implementing to increase management ownership of the corrective action program and timeliness of corrective actions. However, we noted that a number of corrective action deficiencies, primarily involving equipment problems, had not been fully resolved.
Since the issuance of our August 30, 2004, letter, the NRC has recognized that NPPD has further improved its performance in the areas of human performance and the corrective action program at CNS. These improvements were discussed during a public meeting held on January 25, 2005. At this meeting, the NRC provided the basis for concluding that NPPD had satisfied the commitments that it made to the NRC, as documented in the CAL. At this meeting, we concluded that NPPD had taken the actions confirmed in the CAL in the areas of human performance, the corrective action program, and the four other performance areas addressed by the CAL. We also concluded that performance had improved in all six areas; therefore, there was sufficient basis for closing the CAL as a regulatory tool for enhanced oversight of the safety performance of CNS. Further, we noted that there were still a number of ongoing improvement initiative actions, particularly in the area of equipment reliability. At this meeting, NPPD summarized its ongoing and new initiatives to further improve performance in all of these areas.
Completion of the major actons remaining from your improvement plan will need to be verified through the baseline inspection program to confirm that improved performance will be sustained.
Notwithstanding these improvements and, as explained in detail below, we have concluded that the two substantive crosscutting issues will remain open. As discussed at the January 25, 2005, meeting, we plan to focus baseline inspections in the areas of equipment reliability, human performance, and corrective action program effectiveness.
During this assessment period, multiple findings were identified in the area of human performance. A number of these findings involved the common performance characteristic of procedural compliance, which primarily involved operations personnel. Six findings involved personnel failing to follow procedural guidance affecting the Initiating Events, Barrier Integrity, and Mitigating Systems Cornerstones. Another human performance area of concern involved problems resulting from programmatic or procedural inadequacies. For example, multiple deficiencies were identified concerning the operator training program that contributed to a significant number of licensed operator failures of a biennial requalification written examination.
As previously discussed, these deficiencies resulted in a White Finding. Additional examples involved ineffective evaluation and implementation of vendor data, resulting in inadequate preventive maintenance practices and use of inappropriate materials for intended applications.
These deficiencies resulted in findings involving premature failures of a station air compressor, reactor recirculation pump, reactor feed pump, and the reactor feed startup flow control valves.
These deficiencies also resulted in unplanned power reductions and increased plant risk due to reduced equipment availability and reliability.
In the area of problem identification and resolution, there were a number of findings involving failures to promptly identify and correct safety-related and important to safety-related equipment problems and failures, including instances in which corrective actions were not adequate to prevent recurrence. Additionally, in a few instances, NRC involvement was necessary to ensure that adverse conditions were appropriately identified and placed into the corrective action
Nebraska Public Power District-4-program, which indicates that the corrective action program was not consistently implemented throughout the CNS organization. Specifically, nine findings involved failures to promptly identify and correct adverse conditions affecting the Initiating Events and Mitigating Systems Cornerstones. Examples requiring NRC involvement included the failure to enter high pressure coolant injection procedural implementation violations and a fire watch procedural implementation violation into the corrective action program until prompted by the NRC.
Human performance deficiencies and inconsistent implementation of the corrective action program have also been identified as areas for improvement by NPPD self-assessments and NRC CAL inspections throughout the assessment period. The NRC recognizes that CNS has implemented actions to improve both human performance (e.g., human performance training, reenforcing standards and expectations, improved performance measure results, etc.) and the implementation of the corrective action program (e.g., improved root and apparent cause analyses, reduced threshold for entering problems into the corrective action system, improved performance measure results, etc.); however, until there is a reduction in the number and significance of findings associated with the previously identified areas of concern over the course of an assessment interval, the NRC will continue to focus baseline inspection efforts in these areas.
The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. 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 because of their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the midcycle review meeting.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made 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 the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Michael Hay at 817-860-8144 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/ by TPGwynn for Bruce S. Mallett Regional Administrator Docket: 50-298 License: DPR-46
Nebraska Public Power District-5-Enclosure:
Cooper Nuclear Station Inspection/Activity Plan cc w/enclosure:
Michael T. Boyce, Nuclear Asset Manager Nebraska Public Power District 1414 15th Street Columbus, NE 68601 John C. McClure, Vice President and General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 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, NE 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, IA 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339 Marlin Logan Presiding Commissioner Atchison County P.O. Box 280 Rock Port, MO 64482
Nebraska Public Power District-6-Dennis Martin, Sheriff Atchison County Sheriff's Office 511 West Clay Rock Port, MO 64482 Brent Lottman, Sheriff 1805 N Street Auburn, NE 68305 Randall Rohrs, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Dick Hainje, Regional Director FEMA Region VII Department of Homeland Security 2323 Grand Boulevard, Suite 900 Kansas City, MO 64108-2670 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, NE 68508 Al Berndt, Assistant Director Emergency Management Agency 1300 Military Road Lincoln, NE 68508 Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570
Nebraska Public Power District-7-Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (SDC)
Branch Chief, DRP/C (MCH2)
Senior Project Engineer, DRP/C (WCW)
Team Leader, DRP/TSS (RLN1)
RITS Coordinator (KEG)
RidsNrrDipmIipb V. Dricks, PAO (VLD)
W. Maier, RSLO (WAM)
C. Gordon (CJG)
DRS Branch Chiefs (LJS, MPS1, ATG, JAC)
S. Richards, Chief, NRR/DIPM/IIPB (SAR)
M. Case, Deputy Dir. for Inspection and Programs (MJC)
B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)
B. Wetzel, Acting Chief, ROPMS, OEDO (BAW)
H. Berkow, Director, LPD4, NRR/DLPM (HNB)
A. Howe, Chief, PDIV-1, NRR/DLPM (AGH1)
M. Honcharik, NRR Project Manager (MCH3)
SISP Review Completed: _wcw___ ADAMS: / Yes G No Initials: ____wcw_
/ Publicly Available G Non-Publicly Available G Sensitive
/ Non-Sensitive S:\\DRP\\DRPDIR\\EOC 04\\Assessment Letters\\CNS.wpd RIV:C:DRP/C D:DRS D:DRP DRA RA MCHay;df DDChamberlain ATHowell III TPGwynn BSMallett
/RA/
/RA/
/RA/
/RA/
TPGwynn for 2/23/05 2/25/05 2/27/05 2/28/05 2/28/05 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Cooper Inspection / Activity Plan 03/04/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 03/01/2005 08:33:38 Report 22
OB-INIT
- INITIAL EXAM Not Applicable 05/09/2005 05/14/2005 COOPER (06/05) - INITIAL EXAM X02288
Not Applicable 06/06/2005 06/17/2005 COOPER (06/05) - INITIAL EXAM X02288
1 ALARA2
- ALARA PLANNING AND CONTROLS Baseline Inspections 04/11/2005 04/15/2005 ALARA Planning and Controls IP 7112102
5 EB21/02
- SSD&PCI/50.59 Baseline Inspections 05/02/2005 05/06/2005 Safety System Design and Performance Capability IP 7111121
Baseline Inspections 05/16/2005 05/20/2005 Evaluation of Changes, Tests, or Experiments IP 7111102
Baseline Inspections 05/16/2005 05/20/2005 Safety System Design and Performance Capability IP 7111121
1 OB-EP2
- EMERG PREPAREDNESS PROGRAM INSPECTION Baseline Inspections 05/16/2005 05/20/2005 Alert and Notification System Testing IP 7111402
Baseline Inspections 05/16/2005 05/20/2005 Emergency Response Organization Augmentation Testing IP 7111403
Baseline Inspections 05/16/2005 05/20/2005 Emergency Action Level and Emergency Plan Changes IP 7111404
Baseline Inspections 05/16/2005 05/20/2005 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 7111405
Baseline Inspections 05/16/2005 05/20/2005 Performance Indicator Verification IP 71151
6 PEB-52
- CNS PIR INSPECTION Baseline Inspections 06/13/2005 06/17/2005 Identification and Resolution of Problems IP 71152B
Baseline Inspections 06/20/2005 06/24/2005 Identification and Resolution of Problems IP 71152B
4 RP TEAM
- RADIATION SAFETY TEAM INSPECTION Baseline Inspections 06/06/2005 06/10/2005 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103
Baseline Inspections 06/06/2005 06/10/2005 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112201
Baseline Inspections 06/06/2005 06/10/2005 Radioactive Material Processing and Transportation IP 7112202
Baseline Inspections 06/06/2005 06/10/2005 Radiological Environmental Monitoring Program IP 7112203
1 ALARA3
- ALARA PLANNING AND CONTROLS Baseline Inspections 08/22/2005 08/26/2005 ALARA Planning and Controls IP 7112102
3 OB-RQ
- REQUAL INSPECTION Baseline Inspections 11/14/2005 11/18/2005 Licensed Operator Requalification Program IP 7111111B
1 PEB
- MAINTENANCE RULE BIENNIAL Baseline Inspections 04/10/2006 04/14/2006 Maintenance Effectiveness IP 7111112B
3 EB02/17
- PERMANENT MODS/50.59 Baseline Inspections 04/24/2006 04/28/2006 Evaluation of Changes, Tests, or Experiments IP 7111102
Baseline Inspections 04/24/2006 04/28/2006 Permanent Plant Modifications IP 7111117B
1 PEB
- HX PERFORMANCE Baseline Inspections 06/26/2006 06/30/2006 Heat Sink Performance IP 7111107B
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Cooper Inspection / Activity Plan 03/04/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 03/01/2005 08:33:38 Report 22
EP1
- EMERG PREPAREDNESS EXERCISE Baseline Inspections 07/17/2006 07/21/2006 Exercise Evaluation IP 7111401
Baseline Inspections 07/17/2006 07/21/2006 Emergency Action Level and Emergency Plan Changes IP 7111404
Baseline Inspections 07/17/2006 07/21/2006 Performance Indicator Verification IP 71151
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.