IR 05000298/2013009
| ML13130A037 | |
| Person / Time | |
|---|---|
| Site: | Cooper  (DPR-046) |
| Issue date: | 05/09/2013 |
| From: | Kellar R L Division of Reactor Safety IV |
| To: | Limpias O A Nebraska Public Power District (NPPD) |
| References | |
| EA-13-075 IR-13-009 | |
| Preceding documents: |
|
| Download: ML13130A037 (36) | |
Text
May 9, 2013
SUBJECT:
COOPER NUCLEAR STATION STATION NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2013009 AND NOTICE OF VIOLATION
Dear Mr. Limpias:
On March 28, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Cooper Nuclear Station facility. The enclosed inspection report documents the inspection results, which the inspection team discussed on March 28, 2013, with you and your staff. This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and to regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and the overall performance related to identifying, evaluating, and resolving problems at Cooper Nuclear Station was adequate to support nuclear safety. The team noted that you and your staff have made improvements to corrective action programs, processes, and procedures since the previous biennial problem identification and resolution inspection in June 2011. The team observed that your staff generally identified problems and entered them into the corrective action program at a low threshold. In most cases, your staff effectively prioritized and evaluated problems commensurate with their safety significance, resulting in the identification of appropriate corrective actions. However, the team noted weaknesses in some of evaluation processes, s of the operability of degraded structures, systems, and components important to safety-basis documents, and the subsequent determinations of whether these degraded conditions required reports to the NRC. The attached Notice of Violation and inspection report discuss specific examples of these weaknesses. Your staff generally implemented corrective actions timely, commensurate with the safety significance of the problems they were designed to correct. Most corrective actions reviewed by the team adequately addressed the causes of identified problems. Your staff appropriately reviewed and applied lessons learned from industry operating experience. udits and self-assessments effectively identified problems and appropriate corrective actions, though the team noted one instance where a problem common to several audits was not evaluated in the aggregate. Finally, the team determined that maintains a healthy safety-conscious work environment where employees feel free to raise nuclear safety concerns without fear of retaliation. The team identified one finding of very low safety significance (Green) during this inspection. This finding involved a violation of NRC requirements. The violation was evaluated in accordance with the NRC Enforcement Policy; it did not meet the criteria to be treated as a non-cited violation. The current version of this Policy is available on the NRC website at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. This violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is cited in the Notice in accordance with Section 2.3.2.a of the Enforcement Policy because after the violation was previously identified as a non-cited violation, you failed to restore compliance within a reasonable time. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. Also based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. This violation is being treated as a non-cited violation If you contest either of these violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at South Texas Project. If you disagree with the cross-cutting aspect assigned to the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at Cooper Nuclear Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management 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/ Ray L. Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety Docket No.: 50-298 License No.: DPR-46 Enclosure: 1. Notice of Violation 2. Inspection Report 05000298/2013009 w/ Attachments cc w/ encl: Electronic Distribution
SUMMARY OF FINDINGS
IR 05000298/2013009; March 11-28, 2013; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems The team inspection was performed by one senior reactor inspector, two reactor inspectors, and one resident inspector. One violation of Green safety significance and one non-cited violation of Severity Level IV were identified during this inspection. The significance of most findings is indicated by a color (Green, White, Yellow, Red) using Inspection Manual Chapter 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's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006. Identification and Resolution of Problems The team reviewed approximately 220 condition reports, including associated work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation. The purpose of this review, focused on documentation of higher-significance issues, was to determine whether the licensee had properly identified, characterized, and entered these issues into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team concluded that the licensee maintained a corrective action program in which issues were generally identified at an appropriately low threshold. Issues entered into the corrective action program were appropriately evaluated and timely addressed, commensurate with their safety significance. Corrective actions were generally effective, addressing the causes and extents of condition of problems. The team determined that the licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the corrective action program. The licensee used industry operating experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments, as demonstrated by its self-identification of some needed improvements in corrective action program performance and of ineffective corrective actions. The licensee maintained a safety-conscious work environment in which personnel felt free to raise nuclear safety concerns without fear of retaliation. All individuals interviewed by the team were willing to raise these concerns by at least one of the several methods available.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The team identified a Green violation of 10 CFR Part 50, Appendix B, Criterion associated with the standby liquid control (SLC) system test tank were correctly translated into procedures. As a result, the licensee failed to maintain the tank empty as required to meet seismic design requirements. The violation is cited because the licensee failed to restore compliance in a reasonable time following documentation of the issue as a non-cited violation in NRC Inspection Report 05000298/2012002, issued May 10, 2012 (ML12131A674). The licensee entered these issues into its corrective action program for resolution as Condition Report CR-CNS-2013-01962, CR-CNS-2013-02027, and CR-CNS-2013-02328. The failure to maintain design control of the standby liquid control system was a performance deficiency. This performance deficiency was of more than minor safety significance because it was associated with the design control attribute of the mitigating systems cornerstone and it adversely affected cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to procedures to ensure the SLC test tank remained in a seismically qualified condition resulted in an inability to provide reasonable assurance of operability following a seismic event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very low safety significance (Green) because it was a design deficiency that did not result in the loss of functionality. This finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to adopt a requirement to demonstrate that a proposed action was safe in order to proceed rather than a requirement to demonstrate it was unsafe in order to disapprove the action (H.1(b)). (Section 4OA2.5.1)
Cornerstone: Miscellaneous
SL-IV. The team identified a Severity Level IV non-cited violation of 10 CFR 50.72, that the standby liquid control test tank could not meet Seismic Class I requirements unless empty, the team discovered that the tank was full. The licensee immediately drained the tank and implemented a compensatory action to maintain it empty. However, the licensee failed to recognize that because the compensatory measure was required to provide a reasonable assurance of operability, the as-found condition of the SLC systemwith the test tank fullrendered both trains of the system inoperable. Because this could the licensee was required to report the condition to the NRC within eight hours of discovery. After identification, the licensee entered this issue into its corrective action program and made a late report to the NRC, restoring compliance with the regulation. The failure to make a required report to the NRC within the required time was a performance deficiency. The team determined that traditional enforcement applied to this violation because the violation impeded the regulatory process. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory oversight function. Assessing the violation in accordance with Enforcement Policy, the team determined it to be of by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9). Because this was a traditional enforcement violation with no associated finding, no cross-cutting aspect is assigned to this violation. (Section 4OA2.5.2)
B. Licensee-Identified Violations
None
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
The team based the following conclusions on a sample of corrective action documents that were open during the assessment period, which ranged from June 25, 2011, to the end of the on-site portion of this inspection on March 28, 2013.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed approximately 220 condition reports (CRs), including associated root cause, apparent cause, and direct cause evaluations, from approximately 18,000 that had been initiated between June 25, 2011, and March 28, 2013. The condition reports selected for review focused on risk-significant issues. In performing its review, the team evaluated whether the licensee had properly identified, characterized, and entered issues into the corrective action program, and whether the licensee had appropriately evaluated and resolved the issues in accordance with the established programs, processes, and procedures. The team also reviewed these programs, processes, and procedures to determine if any issues existed that may impair their effectiveness. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the the scope of problems by reviewing selected logs, work orders, self-assessment results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed daily CRs, and attended the Condition Review Group meetings to assess the reporting threshold, prioritization efforts, and significance determination process, and to observe the interfaces with the operability assessment and work control processes when applicable. verification that the licensee considered the full extent of cause and extent of condition for problems, as well as a review of how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of problems similar to those the licensee had previously addressed. The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program. The team reviewed corrective action documents that addressed past NRC-identified violations to ensure that corrective actions addressed the issues described in the inspection reports. The team reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions remained appropriate and timely.
risk assessments to focus the sample selection and plant tours on risk-significant systems and components. The team focused a portion of its sample on the standby liquid control systems and the residual heat removal system, which the team selected for a five-year in-depth review. The samples reviewed by the team focused on but were not limited to these systems. The team conducted walk-downs of these systems to assess whether licensee personnel identified problems at a low threshold and entered them into the corrective action program.
b. Assessments 1. Effectiveness of Problem Identification During the 21-month inspection period, licensee staff generated approximately 18,000 condition reports.
CR generation rate of approximately 11,000 per year had been relatively constant over the previous four years. The team determined that most conditions that required generation of a CR by procedure 0.5, were appropriately entered into the corrective action program. The team noted three exceptions in which the licensee had not identified and evaluated adverse trends through the corrective action program as required by revision 19. These failures to identify the trends represented minor performance deficiencies that were not subject to enforcement action in accordance with the NRC Enforcement Policy: In the ten quality assurance audits reviewed by the team, the licensee had self-identified seven failures to implement industry recommendations or to incorporate vendor guidance into station procedures. The licensee had evaluated each of these instances individually, but did not identify and evaluate the potential adverse trend as required by The licensee documented -CNS-2013-02411.
In several condition reports, the licensee documented failures to completely evaluate design bases in operability evaluations. The licensee reviewed each of these instances individually, but did not identify and evaluate the potential adverse trend. This trend of inadequate documentation of operability evaluations is also referenced in the discussion of weaknesses in the in section 4OA2.1.b.2 below. The licensee docu-CNS-2013-02413.
The licensee identified cases where it did not incorporate appropriate vendor guidance into procedures. The licensee evaluated the implementation of vendor guidance for specific issues, but not for the incorporation of vendor guidance as a whole. This issue was also discussed in section 4OA2.1.b.1, above.
The team concluded that despite this performance deficiency, the licensee maintained a low threshold for the formal identification of problems and entry into the corrective action problem for evaluation. All personnel interviewed by the team understood the requirement and expressed a willingness to enter identified issues into the corrective action program at a very low threshold. 2. Assessment - Effectiveness of Prioritization and Evaluation of Issues The team concluded that once the licensee entered issues into its corrective action program, most issues were appropriately evaluated and prioritized. The licensee screened approximately 8,400 (46%) of the 18,000 CRs generated during the inspection period as adverse conditions and approximately 300 (2%) of the CRs as requiring root or apparent cause evaluations. The sample of CRs reviewed by the team was focused on these higher-tier issues. The team reviewed a number of condition reports that involved operability reviews to assess the quality, timeliness, and prioritization of operability assessments. In general, most immediate and prompt operability assessments reviewed were adequately completed, and the team noted improvements in these evaluations since the previous problem identification and resolution inspection in June 2011. However, the team noted weaknesses in some of . Particularly, the team noted weaknesses evaluations of the operability of degraded structures, systems, and components important to safety, as -basis documents, and the subsequent determinations of whether these degraded conditions required reports to the NRC. -CNS-2013-02413. These adverse trends in section 4OA2.1.b.1 above. Additionally, section 4OA5.5 below includes a specific example of an inadequate operability and reportability evaluation information. The team also noted aperform a required 10 CFR 50.59 applicability screen for a procedural change that could have affected the method for controlling a design function. Specifically, the licensee hung a caution tag that restricted the allowable modes of operation of backup safety-related battery chargers. Prior to identification by the team, the licensee had failed to evaluate whether this restriction, which had been in place for approximately five months, constituted a change per 10 CFR 50.59. This was a minor performance deficiency that is not subject to enforcement action in accordance with the NRC Enforcement Policy CR-CNS-2013-02022. Overall, the team determined that the licensee had an adequate process for screening and prioritizing issues that had been entered into the corrective action program, though some weaknesses were noted. The team made the following observations:
(CRG) screening process, the screening group discussed each CR of A, B, or C significance individually. However, D-significance CRs were only discussed when a CRG member took percent screen of these CRs. The team noted that prior to the end of this inspection, the licensee changed its process to perform an individual screen of all CRs, regardless of significance. Though the team had provided this observation to the licensee prior to the change being implemented, the licensee made the Although CRG and Corrective Action Review Board (CARB) members must be qualified through a formal training program, no continuing qualification requirements to maipre-screen group, which provides the initial screening and significance classification for CRs, lacks a formal qualification program.
The team observed several additional potential weaknesses in CARB process. While the team did not identify a specific adverse result from these potential weaknesses, it determined that the weaknesses could tion and evaluation of problems. The licensee documented thCR-CNS-2013-02414. o The licensee typically lacks documentation for the basis behind decisions made during CARB meetings, specifically regarding decisions on significance. o On March 26Per 0-EN-LI-the CARB is review and approval of root cause evaluations and selected apparent cause evaluations. However, the team noted that the CARB seemed to function more as a step in the editing and revision process for the cause evaluation rather than a management review and approval step. The team noted one instance where CARB approved a cause evaluation after a 40-minute discussion of weaknesses in the evaluation. o Changes to CARB-approved plans do not require further review. The team noted one instance in which the licensee changed a corrective action for a CARB-approved cause evaluationwhich included a statement that the but the change did not receive CARB review or approval (CR-CNS-2011-09071 CA 7). The licensee stated that this was acceptable per procedure. o By process, the CARB provides only a front-end review of significant corrective actions. CARB is required to review and approve the corrective action plan and effectiveness review plan for root causes, but CARB does not review corrective actions to prevent recurrencedesigned to correct the root causes of significant conditionsor effectiveness reviews once they are complete.
During the 2011 problem identification and resolution inspection, the inspection team had During this inspection period, the licensee continued to have weaknesses in the area of operability evaluations and in subsequent evaluations of whether identified conditions require reports to the NRC. The licensee has identified and generally addressed the lack of adequate documentation in operability evaluations. However, as noted above, opportunities remain for further improvementspecifically in the incorporation of design basis information into operability evaluations. Additionally, the 2011 problem identification and resolution inspection team noted a general e current inspection, the team noted improved. All evaluations reviewed appeared to be thorough enough to fully address and correct the identified problems. Overall, the team determined that the licensee for screening and prioritizing issues that had been entered into the corrective action program was adequate to support nuclear safety. assessment letter dated March 4, 2013 (ML13063A76), the licensee has an open substantive cross-cutting issue in the area of problem identification and resolution, associated with a theme in the thoroughness of problem evaluation. This substantive cross-cutting issue, open since March 5, 2012, further indicates problems. 3. Assessment Effectiveness of Corrective Actions Overall, the team concluded that the licensee implemented effective corrective actions for the problems identified and evaluated in the corrective action program. The team reviewed eleven corrective action effectiveness reviews for significant conditions adverse to quality and determined that the licensee had implemented effective corrective actions for the conditions.
With the exception of the standby liquid control test tank issue discussed in section 4OA2.5, the team noted that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection had been timely and effective. Overall, the team concluded that the licensee generally developed appropriate corrective actions to address identified problems. The licensee generally implemented these corrective actions in a timely manner, commensurate with their safety significance, and reviewed the effectiveness of the corrective actions appropriately. The team reviewed several corrective actions that the licensee had evaluated as having been less than fully effective. However, all these ineffective corrective actions had been self-identified by the licensee as part of its corrective action review process. The team determined that the licensee had improved the effectiveness of its corrective actions since the June 2011 problem identification and resolution inspection.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
for reviewing industry operating experience, including reviewing the governing procedure and self-assessments. The team reviewed a sample of industry operating experience communications to assess whether the licensee had appropriately evaluated the communications for relevance to the facility. The team also reviewed assigned actions to determine whether they were appropriate. The team reviewed a sample of root and apparent cause evaluations to ensure that the licensee had appropriately included industry operating experience.
b. Assessment Overall, the team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. Of the operating experience items reviewed by the team, the licensee had entered all applicable items into the corrective action program and had evaluated these items in accordance with station procedures. The team further determined that the licensee appropriately evaluated industry operating experience when performing root cause investigations and apparent cause evaluations. The licensee appropriately incorporated both internal and external operating experience into lessons-learned for training and pre-job briefs. In addition, the team reviewed twelve NRC bulletins, regulatory issue summaries, and information notices issued during the inspection period and found that in all cases, the licensee wrote a condition report and evaluated the applicability of the bulletin, regulatory issue summaries, or information notice to their facility. The team found the assessments were clearly documented and were appropriate for the circumstances.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample size of twenty-four licensee audits and self-assessments to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self-assessments and the role of the quality assurance department. The specific audit and self-assessment documents reviewed are listed in the Attachment. b. Assessment The team concluded that the licensee generally had an adequate audit and self-assessment process. Audits and self-assessments were performed using station procedures and were documented thoroughly. Performance elements and standards were appropriate for the programs and processes evaluated. Attention was given to assigning team members with the requisite skills and experience, including individuals from outside organizations, to perform effective audits and self-assessments. Audits were self-critical, thorough, and identified new findings, performance deficiencies, and other concerns in addition to evaluating known performance deficiencies across key functional areas. The licensee generated condition reports to document these findings, performance deficiencies, and other concerns. However, the team identified a missed opportunity to identify whether adverse performance trends existed across internal programs or processes in that CNS did not perform a collective review of audits and self-assessments. From their review, the team identified collective weaknesses in procedure adherence and adequate procedures. Specifically, the audits and self-assessments identified instances of missing torque values, untimely updates of controlled copies of documents, and failure to include vendor recommendations or industry guidance among others across programs and processes. The team notes that the licensee does have a corrective action to perform a common cause analysis of NRC identified findings. Overall, the team determined that the licensee had generally developed appropriate corrective actions to address findings from audits and self-assessments, though these were not always effectively implemented. For example, the team notes that over the past several years the licensee had performed and documented multiple audits and self-assessments that identified longstanding programmatic issues with the Quality Control Program. However, the licensee has developed an Improvement Plan for the Quality Control Program that would likely remedy these programmatic issues when fully implemented.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The team interviewed thirty-nine individuals in six focus groups. The purpose of these interviews was
- (1) to evaluate the willingness of licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, -conscious work environment (SCWE). The focus group participants were from Security, Radiation Protection, Chemistry, Engineering, Operations, and Maintenance. The individuals were selected blindly from these work groups, based partially on availability. To supplement these focus group discussions, the team interviewed the Employee Concerns Program (ECP) manager to assess her afety concerns. Finally, the team reviewed the -assessment of its safety-conscious work environment. b. Assessment 1. Willingness to Raise Nuclear Safety Issues All individuals interviewed indicated that they had no hesitation raising nuclear safety and other concerns. All felt that their management is receptive to nuclear safety concerns and is willing to address them promptly. All of the interviewees further stated that if they were not satisfied with the response from their immediate supervisor, they would feel free to escalate the concern. Most expressed positive experiences after raising issues to their supervisors or documenting issues in condition reports.
2. Employee Concerns Program All interviewees were aware of the Employee Concerns Program. Most explained that they had heard about the program through various means, such as posters, training, presentations, and discussion by supervisors or management at meetings. Most did not have any personal experience with the ECP because, as noted above, they felt free to raise safety concerns to their supervisors; they did not need to use the ECP in these cases. However, all interviewees stated that they would use the program if they felt it was necessary. None of the interviewed personnel had heard of any issues dealing with breaches of confidentiality by the ECP staff, though several noted that the location of the ECP office in a high-traffic area near management offices did not lend itself to confidential meetings. 3. Preventing or Mitigating Perceptions of Retaliation When asked if there have been any instances where individuals experienced retaliation or other negative reaction for raising issues, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation, harassment, intimidation or discrimination at the site. The team determined that licensee management was successfully implementing processes it had in place to mitigate such issues.
.5 Findings
1. Failure to maintain seismic qualification of standby liquid control
Introduction.
The team identified a Green violation of 10 CFR Part 50, Appendix B, requirements associated with the standby liquid control (SLC) system test tank were correctly translated into procedures. As a result, the licensee failed to maintain the tank empty as required to meet seismic design requirements. This violation did not meet the criteria to be treated as a non-cited violation because after it had been previously documented by the NRC, the licensee failed to restore compliance in a reasonable period of time.
Description.
On May 10, 2012, the NRC documented a non-cited violation for the into specifications, drawings, procedures, and instructions (NCV 05000298/2012002-04; see ML12131A674). The licensee generated calculation NEDC 12-015 as its prompt operability evaluation following identification of the 2012 violation. The licensee determined that NEDC 12-015 provided a reasonable assurance of SLC system operability while developing a design basis The licensee initiated calculation NEDC13-Liqufull seismic qualification of the SLC tanks and to establish the seismic design basis for these tanks.
On February 28, 2013, the licensee approved NEDC 13-010, revision 0, and engineering evaluation 13-revision 0. This calculation and evaluation concluded that the standby liquid control test tank met Seismic Class I design requirementsas required for safety-related systemsonly when empty; the tank did not meet these requirements when full. After approval of this calculation and engineering evaluation, the licensee closed the CRs related to NCV 2012002-04, documenting that all corrective actions were complete. On March 13, 2013, after reviewing the completed corrective actions for the 2012 NCV, including the new design basis information documented in NEDC 13-010, the team walked down the SLC system to verify corrective actions. During this walk-down, the team identified that the SLC test tank was full, causing the SLC system to be in a . observation, the licensee immediately drained the tank. The licensee implemented Standing Order 2013-006 to maintain the test tank drained and to declare the SLC system inoperable when the tank is filled for testing. The team determined that after adoption of the new design basis calculation, the licensee had failed to implement procedure changes or compensatory actions to ensure the test tank was empty. Instead, the licensee inappropriately relied on a previous, superseded calculation to justify operability. The licensee had thus failed to maintain seismic qualification of the SLC system. This failure did not result in an actual loss of system function. observations in condition reports CR-CNS-2013-01962, CR-CNS-2013-2027, and CR CNS-2013-02328.
Analysis.
The failure to maintain design control of the standby liquid control system was a performance deficiency. This performance deficiency was of more than minor safety significance because it was associated with the design control attribute of the mitigating systems cornerstone and it adversely affected cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, to implement procedures to ensure the SLC test tank remained in a seismically qualified condition resulted in an inability to provide reasonable assurance of operability following a seismic event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very low safety significance (Green) because the finding did not result in the loss of the system or its function. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very low safety significance (Green) because it was a design deficiency that did not result in the loss of functionality. Because licensee personnel improperly decided to use a superseded calculation to justify operability rather than reevaluating operability using current, more conservative design information, this finding had a cross-cutting aspect in the area of human performance associated with the decision-making component. The licensee failed to use conservative assumptions in decision making and to adopt a requirement to demonstrate that a proposed action was safe in order to proceed (H.1(b)).
Enforcement.
in part that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which the appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this requirement, from May 10, 2012 until March 13, 2013, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis for a component to which the appendix applied were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to assure that the design basis for the standby liquid control system test tank, a component to which 10 CFR 50 Appendix B applies, was translated into plant procedures to ensure that the standby liquid control system would be available following a design-basis seismic event.
Following identification of this violation by the team, the licensee documented the problem in its corrective action program, drained the standby liquid control test tank, and established a standing order to maintain the test tank drained and to declare system inoperable when the tank is filled for testing. In accordance with Section 2.3.2.a of the NRC Enforcement Policy, this finding is being cited because the licensee failed to restore compliance within a reasonable amount of time after the violation was initially identified in NRC Inspection Report 05000298/2012002. It therefore did not meet the criteria to be treated as a non-cited violation: VIO 05000298/2012009-01Maintain Seismic Qualification 2. Failure to make a required report
Introduction.
The team identified a Severity Level IV non-cited violation of 10 CFR make a required report to the NRC. Specifically, the licensee failed to report a condition that could have prevented fulfillment of a safety function.
Description.
On February 28, 2013, the licensee approved calculation NEDC13-010, - Liquid Control This calculation and evaluation concluded that the standby liquid control test tank met Seismic Class I design requirementsas required for safety-related systemsonly when empty; the tank did not meet these requirements when full. The team noted that the failure of the SLC test tank would result in the loss of functionality of both trains of SLC, a technical-specification-required system. On March 13, 2013, during a walk-down of the system, the team identified that the SLC test tank was full. After the team informed the control room of the condition, the licensee immediately drained the tank. The licensee initiated standing order 2013-006 to maintain the standby liquid control system test tank empty and to declare the system inoperable when the test tank is filled. The licensee credited this standing order as a compensatory measure to ensure operability of the SLC system and declared the system operable with this compensatory measure in place. However, the licensee failed to recognize that because the compensatory measure was required to provide a reasonable assurance of operability, the as-found condition of the SLC systemwith the test tank fullrendered both trains of the system inoperable. Because this could have to report the condition to the NRC within eight hours of discovery. On March 28, 2013, the licensee entered this issue into its corrective action program as condition report CR-CNS-2013-02410. Also on March 28, 2013, the licensee made Event Notification 48865 to the NRC Operations Center.
Analysis.
The failure to make a required report to the NRC within the required time was a performance deficiency. The team determined that traditional enforcement applied to this violation because the violation impeded the regulatory process. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory oversight function. Assessing the violation in accordance with Enforcement Policy, the team determined it to be of make a report required by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9). Because this was a traditional enforcement violation with no associated finding, no cross-cutting aspect is assigned to this violation.
Enforcement.
Title 10 CFR 50.72(b)(3)(v) requires in part that licensee report within eight hours of discovery any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to shutdown the reactor and maintain it in a safe shutdown condition. Contrary to this requirement, on March 13, 2013, the licensee failed to report within eight hours of discovery an event or condition that could have prevented the fulfillment of the safety function of a system needed to shut down the reactor and maintain it in a safe shutdown condition. Specifically, the standby liquid control test tank was discovered to be full, a condition in which functionality of the standby liquid control system could not be reasonably assured following a seismic event. The licensee failed to report this condition to the NRC within eight hours of discovery. Following discovery of the condition, the licensee immediately restored the system to a qualified condition. After acknowledging that the required report had not been made, the licensee entered the issue into its corrective action program on March 28, 2013, and made Event Notification 48865. This event notification, though late, restored compliance with applicable regulations. Because this violation resulted in no or relatively inappreciable potential safety consequences (SL-IV) and was entered into the corrective action program as Condition Report CR-CNS-2013-02410, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000298/2013009-02
4OA3 Event Follow-up
(Closed) 05000298/2012006-Prohibited Condition On November 7, 2012, the licensee discovered that a plug was missing from the top of Z sump vent connection, resulting in a breach of secondary containment integrity. Upon discovery, the control room and maintenance personnel were notified and the plug was reinstalled. The licensee later determined that the plug had been removed to obtain an air sample per procedure. However, the change in configuration had not been documented. The licensee determined that a procedural inadequacy was the root cause of this event. To prevent recurrence of this event, the licensee implemented a corrective action to revise the procedure and preventive maintenance work items associated with the Z sump. These revisions will add explicit requirements to replace the plug to reestablish secondary containment integrity upon completion of work activities. The team reviewed these planned revisions and determined that when implemented, they would likely correct the condition. No findings were identified. LER 05000298/2012006-00 is closed.
4OA6 Meetings
Exit Meeting Summary
On March 28, 2013, the team presented the inspection results to Mr. Oscar Limpias, Vice PresidentNuclear and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information that the team reviewed had been returned or destroyed.
ATTACHMENTS: 1. Supplemental Information 2. Information Request 3. Supplemental Information Request
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Kirkpatrick, Quality Control Program Coordinator
- G. Smith, Engineer, Nuclear Steam Supply System
- J. Ehlers, Engineering Supervisor, Electrical Systems/I&C
- J. Flaherty, Engineer, Licensing
- D. Cunningham, Instrument & Control Supervisor, Maintenance
- R. Estrada, Design Engineering Manager
- R. Penfield, Operations Manager
- A. Schroeder, Non-Licensed Nuclear Plant Operator
- L. Dewhirst, Corrective Action & Assessments Manager
- E. Montgomery, Engineer, Electrical Systems/I&C
NRC personnel
- J. Josey, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
- 05000298/2013009-01 VIO Failure to Maintain Seismic Qualification of Standby Liquid Control System (Section 4OA2.5)
- 05000298/2013009-02 NCV Failure to Notify the NRC within Eight Hours of a Nonemergency Event (Section 4OA2.5)
Closed
- 05000298/LER-2012-006-00 LER Missing Vent Plug Results in Technical Specification Prohibited Condition (Section 4OA3)
- 2 -
LIST OF DOCUMENTS REVIEWED
Condition Reports
(CRs)
- 3 -
Work Orders
- 4 -
Procedures
- Number Title Revision/Date 0.10 Operating Experience Program 30 0.12 Working Hour Limitations and Personnel Fatigue Management 29 0.4 Procedure Change Process 57 0.40 Work Control Program 85 0.4.IDOCS Requesting Procedure Change in IDOCS 4 0.5 Conduct of the Condition Report Process 70 0.5.CR Condition Report Initiation, Review, and Classification 19 0.5.EVAL Preparation of Condition Reports 24 0.5.NAIT Corrective Action Implementation and Nuclear Action Item Tracking 45 0.5.OPS Operations Review of Condition Reports/Operability Determination 39 0.5.ROOT-CAUSE Root Cause Analysis Procedure 15 0.5.TRND Corrective Action Program (CAP) Trending 14 0.5.OPS Operation Review of Condition Reports/Operability Determination 40 0.9 Tagout 79 0-Barrier Barrier Control Process 0 0-Barrier-Control Control Building 0 0-Barrier-Misc Miscellaneous Building 0 0-Barrier-Reactor Reactor Building 0 0-CNS-WM-105 Planning 4 0-EN-DC-205 Maintenance Rule Monitoring 3 0-EN-FAP-LI-003 Corrective Action Review Board (CARB) Process 8C1 0-EN-LI-102 Corrective Action Process
- 20C0 0-EN-LI-118 Root Cause Evaluation Process 18C0 0-EN-LI-119 Apparent Cause Evaluation (ACE) Process 16C0
- 5 -
- 0-EN-OE-100 Operating Experience Program 16C0 0-QA-01 CNS Quality Assurance Program 16 0-QA-02 Conduct of Internal Audits 9 0-QA-05 QA Audit Requirements, Frequencies, and Scheduling 11 0-QA-08 Quality Assurance Training Program 9 13.17.2 Thermal Performance Test Procedure for Residual Heat Removal Heat Exchangers June 28, 2012 2.0.11 Entering and Exit Technical Specification/TRM/ODAM LCO Condition(s) 36 2.0.12 Operator Challenges 9 2.0.3 Conduct of Operations 80 2.0.4 Relief Personnel and Shift Turnover 45 2.1.1 Startup Procedure 167 2.1.1.1 Plant Startup Review and Authorization 22 2.1.1.2 Technical Specification Pre-Startup Checks 35 2.2.24.2 250 VDC Electrical System (Div 2) 14 2.2.25.2 125 VDC Electrical System (Div 2) 21 2.2.74A Standby Liquid Control System Component Checklist 10 2.2.A.REC.DIV3 Reactor Equipment Cooling System Common Divisional Component Checklist 2
- 6.1HV.303 Division 1 Essential Control Building Ventilation Temperature Switch Change Out and Functional Test 14 6.2HV.303
- Division 2 Essential Control Building Ventilation Temperature Switch Change Out and Function Test 17 6.Log.601 Daily Surveillance Log
- Modes 1, 2, and 3 111 7.0.5 Post Maintenance Testing 44 7.2.42.2 RHR Heat Exchanger Maintenance January 7, 2009 7.3.31.6 Safety-Related 125V/250V Battery Cell Replacement (Off-Line) 4 7.3.5 EQ Terminal Box Examination and Maintenance 22
- EN-DC-345 Equipment Reliability Clock 0C0 Security Procedure 2.5 Personnel Access Control 43
- 6 -
- Audits Number Area Date 11-03 Procurement July 7, 2011 11-04 Maintenance October 28, 2011 11-05 Radiological Effluents and Environmental Monitoring Program and Chemistry November 9, 2011 11-06 Quality Assurance September 16, 2011 11-08 Training January 11, 2011 12-01 Engineering April 4, 2012 12-02 Corrective Action Program May 9, 2012 12-03 Radiological Controls July 30, 2012 12-04 Operations and Technical Specifications September 19, 2012 12-05 Document Control and Records November 6, 2012 12-06 Quality Control Re-Audit September 28, 2012 12-07 Emergency Plan January 31, 2013 S12-01 Nuclear Safety Culture May 1, 2012
- Other Number Title Revision/Date
- RHR Surveillance Performance History (01/01/2008
- 02/14/2013)
- RHR Corrective Maintenance Orders (02/02/2008
- 11/22/2012)
- RHR System Health Report January 2013
- OE RHRSWBP Performance:
- Administrative Compensatory Actions to address degraded RHRSWBP operation 0
- QC Program Improvement Plan March 26, 2013
- SW System Health Report January 2013
- System Engineer Desktop Guide:
- Section V
- System Trending 7
- T-8B1 Seal per Drawing
- CF-SP-34126-1 September 2, 1992
- 7 -
- Number Title Revision/Date
- RHR System Trend Plan
- RHR System Engineering Walkdown February 2013
- RHR System Engineering Walkdown January 2013
- CED 6032263 Gear Ratio Change for
- RHR-MO39A and B A COR002-23-02 OPS Residual Heat Removal System 27 NEDC 95-003 Determination of Allowable Operating Parameters for CNS MOV Program MOVs 27C4 NEDC09-102 Internal Flooding
- BLDG-F12 Performance Basis Criteria Document 1
- BLDG-F13 Performance Basis Criteria Document 3
- BLDG-F16 Performance Basis Criteria Document 3
- BLDG-F19 Performance Basis Criteria Document 3
- HPCI-F01 Performance Basis Criteria Document
- NEDC12-012 Turbine Generator Building Siding Blowout Pressure, other than EQ purposes 0 NEDC03-005 Turbine Generator Building Siding Blowout Pressure 4 NEDC11-135 Qualification of Doors R208, R209, and N104 0 NEDC13-010 CNS SLC Storage, Test, and Mix Tanks Seismic Qualification 0 Engineering Evaluation 13-009 Standby Liquid Control System/Reactor Equipment Cooling 0
- TCC 4920141 Jumper OMAS on DG1 for Automatic Operation 0
- SW-V-145 0 Burns and Roe Drawing 2036 Sheet 1 Flow Diagram Reactor Building Service Water System N99 TCC4917859 Temporary Repair on Service Water Booster Pump D
- TCC4742749 Install Gag on
- SW-V-145
- Burns and Roe 2031 Sheet 2 Flow Diagram Reactor Building
- 8 -
- Number Title Revision/Date CNS System Health Service Water January 2013
- EE-DC January 2013 Burns and Roe 2045 Sheet 2 Flow Diagram Standby Liquid Control System N21 NEDC10-060 DG2 Mechanical Overspeed Governor Assembly Stud Evaluation 1 CNS System Health Reactor Equipment Cooling January 2013
- LER 05000298/2012006 Missing Vent Plug Results in Technical Specification Prohibited Condition 0
- CNSLO-2012-0060 50.59 Program Implementation Focused Self Assessment March 12-23, 2012
- 2011 Fatigue Management Program Annual Effectiveness Review Summary 01/24/2012
- 2012 Fatigue Management Program Annual Effectiveness Review Summary 01/29/2013 NEDC 09-102 Internal Flooding- HELB, MELB, and Feedwater Line Break 0
- FAS 2013-003 Fatigue Assessment Summary 03/07/2013
- FAS 2013-001 Fatigue Assessment Summary 01/10/2013
- Nuclear Safety Culture Assessment December 2010
- Snapshot Assessment/Benchmark on: Effectiveness Review of Actions Taken to Resolve Issues Identified During the Nuclear Safety Culture Assessment Performed in December 2010 December 28, 2011
- Safety Conscience [sic] Work Environment: 2011 Survey Results Information Request Biennial Problem Identification and Resolution Inspection Cooper Nuclear Station January 17, 2013
- Inspection Report:
- 50-298/2013-009 On-site Inspection Dates: March 11-15 & 25-28, 2013
- This inspection will cover the period from June 25, 2011 through March 28, 2013.
- All requested information should be limited to this period or to the date of this request unless otherwise specified.
- To the extent possible, the requested information should be provided electronically in Adobe PDF (preferred) or Microsoft Office format.
- Any sensitive information should be provided
- Lists of documents should be provided in Microsoft Excel or a similar sortable format.
- Please of on-action requests, cause evaluations, and/or other similar documents, as applicable to Cooper Nuclear Station.
- Please provide the following information no later than February 22, 2013:
- 1. Document Lists Note:
- For these summary lists, please include the document/reference number, the document title, initiation date, current status, and long-text description of the issue. a. Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period b. Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period c. Summary lists of all corrective action documents which were upgraded or downgraded in priority/significance during the period (these may be limited to those downgraded from, or upgraded to, apparent-cause level or higher) d. Summary list of all corrective action documents initiated during the period that e. Summary lists of operator workarounds, operator burdens, temporary modifications, and control room deficiencies currently open, or that were evaluated or closed during the period f. Summary list of safety system deficiencies that required prompt operability determinations (or other engineering evaluations) to provide reasonable assurance of operability
- 2 - g. Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent) (sensitive information can be made available h. Summary list of all Apparent Cause Evaluations completed during the period i. Summary list of all Root Cause Evaluations planned or in progress but not complete at the end of the period, with planned completion or due date
- 2. Full Documents with Attachments a. Root Cause Evaluations completed during the period b. Quality Assurance audits performed during the period c. All audits/surveillances, performed during the period, of the Corrective Action Program, of individual corrective actions, and of cause evaluations d. Functional area self-assessments and non-NRC third-party assessments (i.e., peer assessments performed as part of routine or focused station self- and independent assessment activities; do not include INPO assessments) that were performed or completed during the period; include a list of those that are currently in progress e. Corrective action documents generated during the period associated with the following: i. NRC findings and/or violations issued to Cooper Nuclear Station ii. Licensee Event Reports issued by Cooper Nuclear Station f. Corrective action documents generated for the following, if they were determined to be applicable to Cooper Nuclear Station (for those that were evaluated but determined not to be applicable, provide a summary list): i. NRC Information Notices, Bulletins, and Generic Letters issued or evaluated during the period ii. Part 21 reports issued or evaluated during the period iii. Vendor safety information letters (or equivalent) issued or evaluated during the period iv. Other external events and/or Operating Experience evaluated for applicability during the period
- 3 - g. Corrective action documents generated for the following: i. Emergency planning drills and tabletop exercises performed during the period ii. Maintenance preventable functional failures which occurred or were evaluated during the period iii. Adverse trends in equipment, processes, procedures, or programs that were evaluated during the period iv. Action items generated or addressed by offsite review committees during the period
- 3. Logs and Reports a. Corrective action performance trending/tracking information generated during the period and broken down by functional organization (if this information is fully included in item 3.c, it need not be provided separately) b. Corrective action effectiveness review reports generated during the period c. Current system health reports, Management Review Meeting package, or similar metric/trending data d. Radiation protection event logs during the period e. Security event logs and security incidents during the period (sensitive information can be made avail f. Employee Concern Program (or equivalent) logs (sensitive information can be g. List of training deficiencies, requests for training improvements, and simulator deficiencies for the period
- Note:
- For items 3.d3.g, if there is no log or report maintained separate from the corrective action program, please provide a summary list of corrective action program items for the category described.
- 4. Procedures a. Corrective action program procedures, to include initiation and evaluation procedures, operability determination procedures, apparent and root cause evaluation/determination procedures, and any other procedures that implement the corrective action program at Cooper Nuclear Station
- 4 - b. Quality Assurance program procedures (specific audit procedures are not necessary) c. Employee Concerns Program (or equivalent) procedures d. Procedures which implement/maintain a Safety Conscious Work Environment
- 5. Other a. List of risk-significant components and systems, ranked by risk worth b. Organization charts for plant staff and long-term/permanent contractors c. For each week the team is on site, i. Planned work/maintenance schedule for the station ii. Schedule of management or corrective action review meetings (e.g. operations focus meetings, CR screening meetings, CARBs, MRMs, challenge meetings for cause evaluations, etc.) iii. Agendas for these meetings
- Note:
- The items listed in 5.c may be provided on a weekly or daily basis after the team arrives on site. d. Electronic copies of the FSAR, technical specifications, and technical specification bases, if available
- All requested documents should be provided electronically where possible.
- Regardless of whether they are uploaded to an internet-based copies on CD or DVD.
- One copy of the CD or DVD should be provided to the resident inspector at Cooper Nuclear Station; three additional copies should be sent to the team lead, to arrive no later than February 22, 2013:
- Eric A. Ruesch U.S. NRC Region
- IV 1600 East Lamar Blvd. Arlington,
- TX 76011-4511 -4-
- PAPERWORK REDUCTION ACT STATEMENT This request does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
- Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.
- Supplemental Information Request Biennial Problem Identification and Resolution Inspection Cooper Nuclear Station March 7, 2013
- Inspection Report:
- 50-298/2013-009 On-site Inspection Dates: March 11-15 & 25-28, 2013
- This request supplements the original information request.
- Where possible, the information should be available to the inspection team immediately following the entrance meeting.
- The meeting agendas requested in item 1 should be provided when developed.
- This inspection will cover the period from June 25, 2011 through March 28, 2013.
- All requested information should be limited to this period or to the date of this request unless otherwise specified.
- Please provide the following:
- 1. For each week the team is on site,
- Planned work/maintenance schedule for the station
- Schedule of management or corrective action review meetings (e.g. CRB, MRM, CAR screening meetings, etc.)
- Agendas for these meetings
- 2. As part of the inspection, the team will do a five-year in-depth review of issues and corrective actions related to the residual heat removal (RHR) system.
- The following documents are to support this review (electronic format preferred):
- Copies of upper and lower tier cause evaluations performed on the RHR system within the last 5 years, including root cause evaluations not already provided
- List of all surveillances run on the RHR system within the last five years, sortable by component and including acceptance criteria
- List of all corrective maintenance work orders performed on the RHR system within the last 5 years
- List of maintenance rule functional failure assessmentsregardless of the resultperformed on the RHR system within the last 5 years
- System training manual(s) for the RHR system
- Engineering forms/logs containing notes from the last two engineering walk-downs of the RHR system
- 3. documents support this review:
- List of all fatigue assessments performed during the inspection period separated by department
- List of all work hour rule waivers and violations during the inspection period separated by department
- Fatigue rule implementing procedures
- 2 -
- 4. Specific documents:
- Documentation of modifications and temporary modifications (include associated condition reports): o TCC4896041 Gag Open RHR A Inlet Valve
- SW-V-145 o TCC4920141 Jumper OMAS on DG1 for Automatic Operation o TCC4917859 Temporary Repair of Leak on SWBP D o TCC4908683 Service Water Discharge Pipe Repair o CED6028000
Procedures
o 2.2.65 o 6.LOG.601 o 10.5 o 10.8
- Condition reports: o
- CR-CNS-2012-09691 -2- PAPERWORK REDUCTION ACT STATEMENT This request does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
- Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.