IR 05000298/2006001

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Annual Assessment Letter - Cooper Nuclear Station (NRC Inspection Report 05000298-06-001)
ML060610293
Person / Time
Site: Cooper Entergy icon.png
Issue date: 03/02/2006
From: Howell A
NRC/RGN-IV/DRP
To: Edington R
Nebraska Public Power District (NPPD)
References
IR-06-001
Download: ML060610293 (9)


Text

rch 2, 2006

SUBJECT:

ANNUAL ASSESSMENT LETTER - COOPER NUCLEAR STATION (NRC INSPECTION REPORT 05000298/2006001)

Dear Mr. Edington:

On February 7, 2006, the NRC staff completed its performance review of Cooper Nuclear Station (CNS). Our technical staff reviewed performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2005. 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.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as "Official Use Only - Security-Related Information" will include the physical protection review and resultant inspection plan.

Overall, CNS operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Licensee Response column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green). Although plant performance was within the Licensee Response column, the significance of a finding resulting from our special inspection of a service water strainer clogging event that occurred on October 20, 2005, is still under review as part of the Significance Determination Process which, when finalized, may change our assessment of your plants safety performance.

While plant performance for the most recent quarter is within the Licensee Response column of the Action Matrix, CNS was in the Regulatory Response Column of the NRCs Action Matrix at the beginning of this assessment period. This was based on one finding of low to moderate significance (White) in the Mitigating Systems Cornerstone. This finding involved a significant number of licensed operator requalification written examination failures. A supplemental inspection conducted by the NRC determined that your root cause, extent of condition and cause, and associated corrective actions were appropriately performed to address the deficiencies noted in the CNS operator requalification program. As a result, this finding was closed in NRC Inspection Report 05000298/2004015, dated March 16, 2005.

Nebraska Public Power District -2-In our midcycle assessment letter dated August 30, 2005, we advised you that the substantive crosscutting issue in the area of human performance would remain open based on the number of findings identified across several cornerstones and the impacts that this performance deficiency had on plant operations. We indicated that focused NRC oversight of this area through baseline inspections would continue until CNSs actions were effective in improving the level of procedural adherence. Based on our review of inspection results for the period from January 1 through December 31, 2005, the NRC has concluded that this substantive crosscutting issue can be closed. These inspection results are documented in the 2005 baseline inspection reports. Although the NRC continued to identify inspection findings in the area of human performance, we noted improvement in the level of procedural adherence at CNS and that you adequately addressed the basis for opening this substantive crosscutting issue. Additionally, CNS began developing a performance improvement plan in the latter part of the assessment period to further improve performance in this area.

In our midcycle assessment letter dated August 30, 2005, we advised you that the substantive crosscutting issue in the area of problem identification and resolution would remain open based on the NRCs continuing identification of inspection findings related to inadequate corrective actions resulting in repetitive problems which impacted plant operation. We indicated that focused NRC oversight of this area through baseline inspections would continue until CNSs actions were effective in preventing repetitive or similarly recurring problems that significantly impact plant performance.

Based on our review of inspection results for the period from January 1 through December 31, 2005, the NRC has concluded that this substantive crosscutting issue will remain open. A recurring theme, which also has been documented in previous NRC assessments, involves inadequate corrective actions resulting in repetitive problems which impact plant operation.

During this assessment period, there were nine Green findings involving problem identification and resolution, eight of which involved the causal factor of corrective action. Findings in the Barrier Integrity, Initiating Events, Mitigating Systems, and Occupational Radiation Safety cornerstones related to this crosscutting area were identified. Examples included the failure to take adequate corrective actions to prevent recurrence of the failure of safety-related motor-operated valve motor starters, the failure to properly address the root cause of operating the reactor in excess of licensed thermal power, the failure to correct repeated occurrences of placing the high pressure coolant injection auxiliary oil pump switch in pull-to-lock following a reactor scram, and the failure to promptly correct degraded conditions affecting a service water booster pump.

There has been a substantive crosscutting issue in this area for several assessment periods and improving problem identification and resolution at CNS was the subject of an NRC Confirmatory Action Letter and a CNS Performance Improvement Plan. Despite the extensive focus in this area, consequential plant issues continue to occur at CNS. To address problems in this area, your staff began developing an additional performance improvement plan in the latter part of the assessment period; however, the implementation effectiveness has not yet been assessed.

Nebraska Public Power District -3-Because there has been a substantive crosscutting issue in the area of problem identification and resolution for more than two consecutive assessment letters, you are requested to provide a written response within 30-days of the date of this letter describing your assessment of performance and your plans to improve performance in this area. Following our review of your response, we will schedule a public meeting with you to discuss this issue. Focused NRC oversight of this area through baseline inspections will continue until our inspections indicate that your actions have been effective preventing repetitive or similarly recurring problems that significantly impact plant performance.

The enclosed inspection plan details the inspection, except those related to physical protection, scheduled through September 30, 2007. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to 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.

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 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/

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

Cooper Nuclear Station Inspection/Activity Plan cc w/enclosure:

Atchison County Sheriff's Office Marlin Logan 511 West Clay Presiding Commissioner Rock Port, MO 64482 Atchison County Courthouse P.O. Box 280 Rock Port, MO 64482 Brent Lottman, Sheriff Dennis Martin, Sheriff Nemaha County

Nebraska Public Power District -4-1805 N Street Julia Schmitt, Manager Auburn, NE 68305 Radiation Control Program Nebraska Health & Human Services Randall Rohrs, Chairman Dept. of Regulation & Licensing Nemaha County Board of Commissioners Division of Public Health Assurance 73260 629 Avenue 301 Centennial Mall, South Johnson, NE 68378 P.O. Box 95007 Lincoln, NE 68509-5007 Bob Hutton, Commissioner, District 1 Nemaha County Board of Commissioners H. Floyd Gilzow 72546 644 Avenue Deputy Director for Policy Nemaha, NE 68414 Missouri Department of Natural Resources P. O. Box 176 Monty Lovelace, Commissioner, District 2 Jefferson City, MO 65102-0176 Nemaha County Board of Commissioners 73360 641 Avenue Ronald Reynolds, Director Auburn, NE 68305 Missouri State Emergency Management Agency Dick Hainje, Regional Director P.O. Box 116 FEMA Region VII Jefferson City, MO 65102-0116 Department of Homeland Security 9221 Ward Parkway, Suite 300 Chief, Radiation and Asbestos Kansas City, MO 64114-3372 Control Section Kansas Department of Health Robert Leopold, Administrator and Environment Nebraska Health and Human Services Bureau of Air and Radiation Division of Public Health Assurance 1000 SW Jackson, Suite 310 Department of Regulation and Licensure Topeka, KS 66612-1366 301 Centennial Mall, South P.O. Box 95007 Daniel K. McGhee Lincoln, NE 68508 Bureau of Radiological Health Iowa Department of Public Health Al Berndt, Assistant Director Lucas State Office Building, 5th Floor Nebraska Emergency Management Agency 321 East 12th Street 1300 Military Road Des Moines, IA 50319 Lincoln, NE 68508 John F. McCann, Director, Licensing Scott Clardy, Director Entergy Nuclear Northeast Section for Environmental Public Health Entergy Nuclear Operations, Inc.

P.O. Box 570 440 Hamilton Avenue Jefferson City, MO 65102-0570 White Plains, NY 10601-1813 Michael J. Linder, Director Keith G. Henke, Planner Nebraska Department of Division of Community and Public Health Environmental Quality Office of Emergency Coordination P.O. Box 98922 930 Wildwood, P.O. Box 570 Lincoln, NE 68509-8922 Jefferson City, MO 65102

Nebraska Public Power District -5-Chief, Radiological Emergency 301 Centennial Mall, South Preparedness Section P.O. Box 95007 Kansas City Field Office Lincoln, NE 68509-5007 Chemical and Nuclear Preparedness and Protection Division Director, Missouri State Emergency Department of Homeland Security Management Agency 9221 Ward Parkway, Suite 300 P.O. Box 116 Kansas City, MO 64114-3372 Jefferson City, MO 65102-0116 Jon Schwarz Chief, Radiation and Asbestos Nebraska Emergency Management Agency Control Section 1300 Military Road Kansas Department of Health Lincoln, NE 68508-1090 and Environment Bureau of Air and Radiation Gene Mace 1000 SW Jackson, Suite 310 Nuclear Asset Manager Topeka, KS 66612-1366 Nebraska Public Power District P.O. Box 98 Daniel K. McGhee Brownville, NE 68321 Bureau of Radiological Health Iowa Department of Public Health John C. McClure, Vice President Lucas State Office Building, 5th Floor and General Counsel 321 East 12th Street Nebraska Public Power District Des Moines, IA 50319 P.O. Box 499 Columbus, NE 68602-0499 William J. Fehrman, President and Chief Executive Officer P. V. Fleming, Licensing Manager Nebraska Public Power District Nebraska Public Power District 1414 15th Street P.O. Box 98 Columbus, NE 68601 Brownville, NE 68321 Jerry C. Roberts, Director of Michael J. Linder, Director Nuclear Safety Assurance Nebraska Department of Nebraska Public Power District Environmental Quality P.O. Box 98 P.O. Box 98922 Brownville, NE 68321 Lincoln, NE 68509-8922 John F. McCann, Director, Licensing Chairman Entergy Nuclear Northeast Nemaha County Board of Commissioners Entergy Nuclear Operations, Inc.

Nemaha County Courthouse 440 Hamilton Avenue 1824 N Street White Plains, NY 10601-1813 Auburn, NE 68305 Keith G. Henke, Planner Julia Schmitt, Manager Division of Community and Public Health Radiation Control Program Office of Emergency Coordination Nebraska Health & Human Services 930 Wildwood, P.O. Box 570 Dept. of Regulation & Licensing Jefferson City, MO 65102 Division of Public Health Assurance

Nebraska Public Power District -6-Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

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

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (SCS)

Branch Chief, DRP/C (KMK)

Project Engineer, DRP/C (WCW)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

V. Dricks, PAO (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (JAC, ATG, LJS, MPS1)

S. Richards, Deputy Director, DIRS, NRR (SAR)

C. Holden, Deputy Director, DORL, NRR (CFH)

T. Bergman, Chief, TRPS, OEDO (TAB)

C. Haney, Director, DORL, NRR (CXH)

D. Terao, Chief, LPLG, DORL, NRR (DXT)

B. Benney, NRR Project Manager (BJB)

RidsNrrDirslpab SUNSI Review Completed: _kmk__ ADAMS: : Yes G No Initials: _kmk___

Publicly Available G Non-Publicly Available G Sensitive : Non-Sensitive S:\DRP\DRPDIR\EOC 05\Assessment Letters\CNS.wpd RIV:C:DRP\C D:DRS D:DRP RA KMKennedy;mjs DDChamberlain ATHowell III BSMallett

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

2/24/06 2/24/06 2/27/06 2/28/06 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 Cooper 03/01/2006 08:31:08 Inspection / Activity Plan Report 22 03/01/2006 - 09/30/2007 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type EB1-2/17 - PERMANENT MODS/50.59 3 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 04/17/2006 04/21/2006 Baseline Inspections 1 IP 7111117B Permanent Plant Modifications 04/17/2006 04/21/2006 Baseline Inspections EXAM - INITIAL EXAMINATION 5 1 X02344 COOPER - INITIAL EXAM (11/06) 09/11/2006 09/15/2006 Not Applicable 1 X02344 COOPER - INITIAL EXAM (11/06) 10/02/2006 10/13/2006 Not Applicable 1 X02344 COOPER - INITIAL EXAM (11/06) 10/16/2006 10/20/2006 Not Applicable BRQ SIM - BIENNIAL RQ SIM ONLY 1 1 IP 7111111B Licensed Operator Requalification Program 05/01/2006 05/05/2006 Baseline Inspections EB2-12B - MAINTENANCE RULE BIENNIAL 1 1 IP 7111112B Maintenance Effectiveness 05/08/2006 05/12/2006 Baseline Inspections REQUAL - REQUALIFICATION 2 1 IP 7111111B Licensed Operator Requalification Program 06/12/2006 06/16/2006 Baseline Inspections EB2-07B - HX PERFORMANCE 1 1 IP 7111107B Heat Sink Performance 06/26/2006 06/30/2006 Baseline Inspections EP1 - EMERG PREPAREDNESS EXERCISE 3 1 IP 7111401 Exercise Evaluation 07/17/2006 07/21/2006 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 07/17/2006 07/21/2006 Baseline Inspections 1 IP 71151 Performance Indicator Verification 07/17/2006 07/21/2006 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1 IP 7112101 Access Control to Radiologically Significant Areas 10/16/2006 10/20/2006 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 10/16/2006 10/20/2006 Baseline Inspections 1 IP 71151 Performance Indicator Verification 10/16/2006 10/20/2006 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1 IP 7112101 Access Control to Radiologically Significant Areas 10/30/2006 11/03/2006 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 10/30/2006 11/03/2006 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1 IP 7112101 Access Control to Radiologically Significant Areas 03/19/2007 03/23/2007 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 03/19/2007 03/23/2007 Baseline Inspections 1 IP 71151 Performance Indicator Verification 03/19/2007 03/23/2007 Baseline Inspections EB2-05T - TRIENNIAL-FP 5 1 IP 7111105T Fire Protection [Triennial] 05/21/2007 05/25/2007 Baseline Inspections 1 IP 7111105T Fire Protection [Triennial] 06/11/2007 06/15/2007 Baseline Inspections RP TEAM - RADIATION SAFETY TEAM 5 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 05/14/2007 05/18/2007 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 03/01/2006 08:31:08 Inspection / Activity Plan Report 22 03/01/2006 - 09/30/2007 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type RP TEAM - RADIATION SAFETY TEAM 5 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 05/14/2007 05/18/2007 Baseline Inspections 1 IP 7112202 Radioactive Material Processing and Transportation 05/14/2007 05/18/2007 Baseline Inspections 1 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 05/14/2007 05/18/2007 Baseline Inspections EP2 - EP PROGRAM 1 1 IP 7111402 Alert and Notification System Testing 07/23/2007 07/27/2007 Baseline Inspections 1 IP 7111403 Emergency Response Organization Augmentation Testing 07/23/2007 07/27/2007 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 07/23/2007 07/27/2007 Baseline Inspections 1 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 07/23/2007 07/27/2007 Baseline Inspections 1 IP 71151 Performance Indicator Verification 07/23/2007 07/27/2007 Baseline Inspections EB2-52B - PIR TEAM INSPECTION 5 1 IP 71152B Identification and Resolution of Problems 07/16/2007 07/20/2007 Baseline Inspections 1 IP 71152B Identification and Resolution of Problems 07/30/2007 08/03/2007 Baseline Inspections EB1-21 - CDB 7 1 IP 7111121 Component Design Bases Inspection 08/27/2007 08/31/2007 Baseline Inspections 1 IP 7111121 Component Design Bases Inspection 09/10/2007 09/21/2007 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1 IP 7112101 Access Control to Radiologically Significant Areas 09/10/2007 09/14/2007 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 09/10/2007 09/14/2007 Baseline Inspections 1 IP 71151 Performance Indicator Verification 09/10/2007 09/14/2007 Baseline Inspections This report does not include INPO and OUTAGE activities.

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