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Biennial Problem Identification and Resolution Inspection Report 05000298/2019011
	ML19225D247
Person / Time
Site:	Cooper
Issue date:	08/14/2019
From:	Ray Kellar; Division of Reactor Safety IV
To:	Dent J; Nebraska Public Power District (NPPD)
References
	IR 2019011
	Download: ML19225D247 (12)
	v • d • e

August 14, 2019

SUBJECT:

COOPER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2019011

Dear Mr. Dent:

On July 11, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Cooper Unit 1 and discussed the results of this inspection with Mr. Joe Sullivan, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any finding or violation of more than minor significance.

J. Dent, Jr.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Ray L. Kellar, P.E., Team Leader Inspection Programs & Assessment Team Division of Reactor Safety

Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number:

05000298

License Number:

DPR-46

Report Number:

05000298/2019011

Enterprise Identifier: I-2019-011-0001

Licensee:

Nebraska Public Power District

Facility:

Cooper Nuclear Station

Location:

Brownville, NE

Inspection Dates:

June 24, 2019 to July 11, 2019

Inspectors:

H. Freeman, Senior Reactor Inspector

D. Holman, Senior Physical Security Inspector

C. Peabody, Senior Resident Inspector

M. Stafford, Resident Inspector

Approved By:

Ray L. Kellar, P.E., Team Leader

Inspection Programs & Assessment Team

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

Main article: IP 71152

The team performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

(1) The team reviewed the stations corrective action program and implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action program. The sample included reviews of over 200 condition reports and associated records in addition to in-depth 5-year reviews of condition reports associated with the automatic depressurization system and the station service water system.

The team evaluated the stations use of industry and NRC operating experience and the effectiveness of the stations audits and self-assessments program. The team reviewed the process used to receive, distribute, and evaluate operating experience by reviewing five examples that had been received during the assessment period. The team reviewed nine self-assessments (benchmark, simple, formal departmental) and seven audits.

The team evaluated the stations safety-conscious work environment. The team interviewed 27 station personnel in five focus group interviews. These groups included personnel from operations, maintenance, radiological protection, engineering, and quality assurance. The team observed interactions between employees during the condition report screening meetings and during the Performance Improvement Review Group meetings. The team interviewed the employee concerns coordinator and reviewed the results of the sites latest safety culture surveys and investigations related to safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of Problem Identification, Prioritization and Evaluation, and Corrective Actions adequately supported nuclear safety.

The team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. During the 2-year assessment period, the licensee had initiated almost 16,000 condition reports which averages to over 650 per month.

The team found that the licensee was adequately prioritizing and evaluating problems. Of the condition reports initiated during the assessment period, roughly 3,600 were classified as conditions adverse to quality while the rest were non-adverse. The licensee initiated 3 root cause evaluations and 52 adverse condition assessments. The team did not identify any examples of conditions adverse to quality that had been miss-classified as non-adverse.

The team found that the licensee was developing and implementing corrective actions. The corrective actions appear to be effective and implemented on time frame commensurate with significance. And the corrective actions to prevent recurrence associated with root cause evaluations appear to be appropriate and the effectiveness reviews appeared to be reasonable measurable.

Assessment 71152B Use of Operating Experience, Self-Assessments and Audits

Based upon a review of the operating experience program and selected examples, the team determined the licensee's process for evaluating industry operating experience for relevance to the facility was effective. While the team noted that there had been a couple of examples documented in the corrective action program where operating experience had not been adequately reviewed (including non-cited violation 2018004-01), the team determined that these did not represent current performance and that the corrective actions implemented to address the causes were appropriate.

Based upon a review of selected samples of self-assessments and audits, the team determined that the issues identified were more than trivial and were being addressed appropriately by the responsible organizations. The team concluded that this was indicative of an effective and self-critical learning organization.

Assessment 71152B Safety-Conscious Work Environment

Based on inspection interviews and insights obtained from safety culture and other relevant assessments, the team found that the licensee had established and maintained a safety-conscious work environment where individuals felt free to raise concerns without fear of retaliation. Employees indicated that they had numerous avenues for raising safety concerns including writing condition reports, discussions with their management, using the chain-of-command (open door policy), the employee concerns program and the NRC. Several individuals indicated that licensee management had become much more responsive in addressing and correcting lower level (non-reactor or security safety) equipment issues promptly and that this had increased their confidence that future concerns would be addressed appropriately. All individuals indicated that they felt free to elevate concerns to higher levels without fear of retaliation but they had never had an occurrence where they thought an issue existed when it was necessary to use another path to raise their concerns.

Through reviews of the employee concerns program documents, the latest site safety culture survey results, and summary listings of anonymously submitted concerns, the team did not identify any impediments to the free flow of information. The employee concerns program is the point of contact for all anonymously submitted concerns. The team did not identify any concerns that were submitted to the employee concerns program of a technical nature that were not addressed (as appropriate) by the corrective action program.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On July 11, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Joe Sullivan, General Manager of Plant Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Cooper - 2019011
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \| 26 \|
2019 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 11(0) 12(0) 13(0) Security 405(0) 410(0) 411(0) 412(0) 413(0) Operator Exams Emergency Planning Other

IR 05000298/2019011