IR 05000298/2010001

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Annual Assessment Letter - Cooper Nuclear Station (NRC Inspection Report 05000298/2010001)
ML100621381
Person / Time
Site: Cooper Entergy icon.png
Issue date: 03/03/2010
From: Chamberlain D
NRC/RGN-IV/DRP
To: Minahan S
Nebraska Public Power District (NPPD)
References
IR 20100001
Download: ML100621381 (1)


Text

March 3, 2010

SUBJECT:

ANNUAL ASSESSMENT LETTER-COOPER NUCLEAR STATION

(NRC INSPECTION REPORT 05000298/2010001)

Dear Mr. Minahan:

On February 18, 2010, the NRC staff completed its performance review of Cooper Nuclear Station. Our technical staff reviewed performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2009. 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 security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.

Overall, Cooper Nuclear Station 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 NRC=s 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).

Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility.

While plant performance for the most recent quarter is within the Licensee Response column of the Action Matrix, there was a safety significant performance indicator affecting the first two quarters of the assessment cycle. Performance for the first two quarters of the assessment period was within the Regulatory Response column of the NRCs Action Matrix based on a White performance indicator for Mitigating Systems Performance Index - Emergency AC Power (MSPI-EAC). The performance indicator crossed the Green-White threshold in the fourth quarter of 2008 as a result of a failure of the Division I emergency diesel generator from a fault in the fuel oil transfer system on October 31, 2008. Consistent with the guidance in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the NRC conducted a supplemental inspection using Inspection Procedure 95001, Supplemental Inspection for One UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125

Nebraska Public Power

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or Two Inputs in a Strategic Performance Area, on June 30, 2009. The supplemental inspection determined that you performed a thorough evaluation in which specific problems were identified, an adequate root cause evaluation was performed, and corrective actions were taken to prevent recurrence. Based on the staffs verification of your corrective actions, Cooper Nuclear Station returned to the Licensee Response column of the NRCs Action Matrix for the third quarter of the assessment period.

In both the 2008 end-of-cycle and 2009 mid-cycle assessment letters, the NRC identified a crosscutting theme associated with the work practices component of the human performance area related to the use of human error prevention techniques H.4(a). Prior to issuance of the 2008 end-of-cycle letter, you recognized this theme and implemented corrective actions to mitigate this theme. Some of your corrective actions included biweekly tailgate meetings with employees on human performance fundamentals, increasing required supervisory oversight of high risk activities, implementation of a dynamic learning flow-loop simulator for all personnel to practice error prevention techniques and creation of a human performance review board to periodically review the status your program. Additionally you had also proposed other corrective actions that were in progress at the end of the assessment period. Since you recognized this theme and developed corrective actions, a crosscutting issue was not identified since a reasonable duration of time had not passed for the staff to determine the effectiveness of your corrective actions.

While preparing for the 2009 mid-cycle assessment, the staff again evaluated your scope of efforts and progress in addressing the crosscutting theme involving the use of human error prevention techniques H.4(a). The staff determined that you continued to appropriately recognize this theme and that your corrective actions appeared to be appropriate to mitigate the theme. The staff also recognized that your corrective actions had not been fully implemented and no crosscutting issue was identified.

Seven findings with the crosscutting aspect related to the use of human error prevention techniques have occurred during this assessment period, five of these occurred following full implementation of your corrective actions. Based on these findings with the repeated common theme, the NRC staff has identified a substantive crosscutting issue in the human performance area associated with work practices related to the use of human error prevention techniques at Cooper Nuclear Station H.4(a). These findings occurred in initiating events, barrier integrity and occupational radiation safety cornerstones. Examples included errors which lead to the loss of spent fuel pool cooling, errors which resulted in the tripping of a recirculation pump that left the core pressurized and without forced flow, and the use of an incorrect o-ring in the digital electro-hydraulic fluid system that required taking the turbine off-line and a manual scram from power. The NRC will clear this substantive crosscutting issue when you demonstrate sustainable performance improvements as evidenced by effective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common theme.

In our 2009 mid-cycle assessment letter, dated September 1, 2009, the NRC staff identified a crosscutting theme associated with the decision making component of the human performance area involving the use of conservative decision making H.1(b). At the time, the NRC did not identify a substantive crosscutting issue because you appropriately recognized this theme and

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implemented a range of corrective actions to address it.

During this 12-month assessment period, the staff identified four green findings with documented crosscutting aspects in the area of human performance associated with the same theme involving the use of conservative decision making H.1(b). However, each of the findings occurred in the first half of the current assessment period. Since no additional findings with this theme have occurred since the full implementation of your corrective actions, it appears your corrective actions have been effective in mitigating this theme. As such, we have determined that a substantive crosscutting issue with this theme does not exist at this time.

The enclosed inspection plan details the inspection, less those related to physical protection scheduled through June 30, 2011. 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 nine months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC=s ARules 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 Vincent Gaddy, Chief, Division of Reactor Projects, at (817) 860-8144 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Dwight D. Chamberlain, Director Division of Reactor Projects

Docket: 50-298 License: DPR-46

Enclosure:

Cooper Nuclear Station Inspection/ Activity Plan

Nebraska Public Power

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Gene Mace Nuclear Asset Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

John C. McClure, Vice President and General Counsel Nebraska Public Power District 1414 15th Street P.O. Box 499 Columbus, NE 68601

David Van Der Kamp 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

Randy Rohrs, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street, Suite 201 Auburn, NE 68305

Julia Schmitt, Manager Nebraska Department of Health and Human Services Division of Public Health Nebraska State Office Building, 3rd Fl Lincoln, NE 68509-5026

Deputy Director for Policy Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176

Nebraska Public Power

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Director, Missouri 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

Melanie Rasmussen, State Liaison Officer/

Radiation Control Program Director Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319

John F. McCann, Director, Licensing Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1813

Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination P.O. Box 570 Jefferson City, MO 65102

Art Zaremba Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

Ronald D. Asche, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601

Nebraska Public Power

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Chief, Technological Hazards Branch FEMA, Region VII 9221 Ward Parkway Suite 300 Kansas City, MO 64114-3372

Assistant Director Nebraska Emergency Management Agency 1300 Military Road Lincoln, NE 68508

Administrator Section for Disease Control & Environmental Epidemiology PO Box 570 Jefferson City, MO 65102-0570

Director Nemaha County Emergency Management 601 J Street Auburn, NE 68305

Chief, Radiological Emergency Preparedness Section FEMA, Region VII 9221 Ward Parkway Suite 300 Kansas City, MO 64114-3372

Commissioner Nemaha County Board of Commissioners District 1 72546 644 Avenue Nemaha, NE 68414

Administrator Nebraska Health & Human Services Division of Public Health 301 Centennial Mall South PO Box 95026 Lincoln, NE 68509-5026

Director Nebraska Department of Environmental Quality PO Box 98922 Lincoln, NE 68509-8922

Nebraska Public Power

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Presiding Commissioner Atchison County Courthouse P.O. Box 280 Rock Port, MO 64482

Sheriff Nemaha County 1805 N Street Auburn, NE 68305

Commissioner Nemaha County Board of Commissioners District 2 73360 641 Avenue Auburn, NE 68305

Sheriff Atchison County Sheriff's Office 511 West Clay Rock Port, MO 64482

Branch Chief, Radiological Emergency Preparedness Section Kansas City Field Office Chemical Nuclear Preparedness & Protection Div.

Department of Homeland Security 9221 Ward Parkway Suite 300 Kansas City, MO 64114-3372

Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building 5th Fl 321 East 12th Street Des Moines, IA 50319

Division Director, Radiation Event Medical Mgmt Missouri Dept of Health & Senior Services PO Box 570 Jefferson City, MO 65102

Director Missouri State Emergency Management Agency PO Box 116 Jefferson City, MO 65102-0116

Nebraska Public Power

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Chairman Nemaha County Board of Commissioiners 73260 629 Avenue Johnson, NE 68378

Radiological Programs Manager Radiological Emergency Preparedness Division Nebraska Emergency Management Agency 1300 Military Road Lincoln, NE 68508-1090

Chief, Radiation & Asbestos Control Section Missouri State Emergency Management Agency PO Box 116 Jefferson City, MO 65102-0116

Nebraska Public Power

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Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.goV)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

Senior Resident Inspector (Nick.Taylor@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Regional State Liaison Officer (Bill.Maier@nrc.gov)

RA Administrative Assistant (Lucy.Owen@nrc.gov)

DRA Administrative Assistant (Anita.Tannenbaum@nrc.gov)

Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov)

Branch Chief, DRS/EB2 (Neil.OKeefe@nrc.gov)

Branch Chief, DRS/PSB1 (Michael.Shannon@nrc.gov)

Branch Chief, DRS/PSB2 (Greg.Werner@nrc.gov)

Branch Chief, DRS/OB (Mark.Haire@nrc.gov)

OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)

Director, DIRS, NRR (Frederick.Brown@nrc.gov)

Director, DORL, NRR (Joseph.Giitter@nrc.gov)

Deputy Director, DORL, NRR (Robert.Nelson@nrc.gov)

Chief, PLB IV, DORL, NRR (Michael.Markley@nrc.gov)

NRR Project Manager (Fred.Lyon@nrc.gov)

RidsNrrDirslpab Resource@nrc.gov ROPreports.Resource@nrc.gov Congressional Affairs Officer (Jenny.Weil@nrc.gov)

mortensengk@INPO.org

File located: R:\\_Reactors\\EOC2009\\CNS.doc SUNSI Rev Compl.

Yes No ADAMS
Yes No Reviewer Initials VGG Publicly Avail
Yes No Sensitive Yes : No Sens. Type Initials VGG C:DRP/C D:DRS D:DRP

VGaddy RJCaniano DDChamberlain

/RA/

/RA/

/RA/

2/25/10 2/26/10 3/1/10

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Inspection / Activity Plan Page 1 of 1 02/18/2010 10:36:00 Report 22 04/01/2010 - 06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Cooper EP-1

- BIENNIAL EP EXERCISE INSPECTION

1 IP Exercise Evaluation 7111401 07/19/2010 07/23/2010

IP Emergency Action Level and Emergency Plan Changes 7111404 07/19/2010 07/23/2010

IP Drill/Exercise Performance 71151-EP01 07/19/2010 07/23/2010

IP ERO Drill Participation 71151-EP02 07/19/2010 07/23/2010

IP Alert & Notification System 71151-EP03 07/19/2010 07/23/2010 EB1-21

- COMPONENT DESIGN BASIS INSPECTION

1 IP Component Design Bases Inspection 7111121 07/19/2010 07/23/2010

IP Component Design Bases Inspection 7111121 08/02/2010 08/13/2010 RS45

- RADIATION SAFETY

1 IP Occupational Dose Assessment 71124.04 08/16/2010 08/20/2010

IP Radiation Monitoring Instrumentation 71124.05 08/16/2010 08/20/2010

IP Occupational Exposure Control Effectiveness 71151-OR01 08/16/2010 08/20/2010

IP RETS/ODCM Radiological Effluent 71151-PR01 08/16/2010 08/20/2010 EB2-05T

- TRIENNIAL FIRE PROTECTION

1 IP Fire Protection [Triennial]

7111105T 10/18/2010 10/22/2010

IP Fire Protection [Triennial]

7111105T 11/01/2010 11/05/2010 BRQ

- OPERATOR REQUAL INSPECTION

1 IP Licensed Operator Requalification Program 7111111B 12/06/2010 12/10/2010 PSB2-08G

- INSERVICE INSPECTION

1 IP Inservice Inspection Activities - BWR 7111108G 03/07/2011 04/10/2011 RP678

- RADIATION SAFETY TEAM

1 IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 05/09/2011 05/13/2011

IP Public Radiation Safety 71124.07 05/09/2011 05/13/2011

IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 05/09/2011 05/13/2011 EP1

- BIENNIAL EP PROGRAM INSPECTION

1 IP Radiological Environmental Monitoring Program 7111402 06/20/2011 06/24/2011

IP Emergency Response Organization Augmentation Testing 7111403 06/20/2011 06/24/2011

IP Emergency Action Level and Emergency Plan Changes 7111404 06/20/2011 06/24/2011

IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 06/20/2011 06/24/2011

IP Drill/Exercise Performance 71151-EP01 06/20/2011 06/24/2011

IP ERO Drill Participation 71151-EP02 06/20/2011 06/24/2011

IP Alert & Notification System 71151-EP03 06/20/2011 06/24/2011 TSB-52B

- BIENNIAL PI&R

1 IP Identification and Resolution of Problems 71152B 06/06/2011 06/24/2011 This report does not include INPO and OUTAGE activities.

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