ML020570352

02-07-02 Cooper/Nebraska Public Power District Meeting Summary

ML020570352
Person / Time
Site:	Cooper
Issue date:	02/26/2002
From:	Good G Plant Support Branch Region IV
To:	Denise Wilson Nebraska Public Power District (NPPD)
References
Download: ML020570352 (38)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV "611RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8064 February 26, 2002 David L. Wilson, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321

SUBJECT:

COOPER NUCLEAR STATION REGULATORY PERFORMANCE MEETING

Dear Mr. Wilson:

This refers to the public meeting between NRC and Nebraska Public Power District conducted in Auburn, Nebraska, on February 7, 2002. This meeting was held to discuss your root cause analysis, extent of condition evaluation, self assessments, and corrective actions associated with two White findings at the Cooper Nuclear Station. The findings involved a failure of the emergency response organization to recognize a simulated degraded core condition during an evaluated exercise and again during a later drill, which resulted in issuance of incorrect protective action recommendations for offsite populations.

We found the meeting to be informative in addressing our concerns. As was stated during the meeting, we will inform you by separate correspondence as to the extent of additional inspection which is currently being planned consistent with our Reactor Oversight Process to address these and other Emergency Preparedness Cornerstone issues.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be 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.qov/reading-rm/adams.html (the Public Reading Room).

Should you have any questions concerning this matter, we will be pleased to discuss them with you.

Si rely, Gail M. Good, Chief Plant Support Branch Division of Reactor Safety Docket: 50-298 License: DPR-46

Nebraska Public Power District

Enclosures:

1. Attendance List

2. Licensee Presentation cc:

G. R. Horn, Senior Vice President of Nuclear and Enterprise Effectiveness Nebraska Public Power District 1414 15th Street Columbus, Nebraska 68601 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 D. F. Kunsemiller, Risk and Regulatory Affairs Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech Manager - Nuclear MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Ron Stoddard Lincoln Electric System 1040 0 Street P.O. Box 80869 Lincoln, Nebraska 68501-0869 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305

Nebraska Public Power District Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources 205 Jefferson Street Jefferson City, Missouri 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, Missouri 65101 Vick L. Cooper, Chief Radiation Control Program, RCP Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, Kansas 66612-1366 Training, Exercises, & Evaluation Branch Chief FEMA Region VII 2323 Grand Blvd., Suite 900 Kansas City, Missouri 64108-2670

Nebraska Public Power District Electronic distribution from ADAMS by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Branch Chief, DRS/PSB (GMG)

EP Inspector, DRS/PSB (REL)

Senior Resident Inspector (MCH2)

Branch Chief, DRP/C (KM K)

Senior Project Engineer, DRP/C (vacant)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

Jim Isom, Pilot Plant Program (JAI)

State Liaison Officer (WAM)

DMB (IE35)

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

ENCLOSURE1 Cooper Nuclear Station Regulatory Performance Meeting Attendance February 7, 2002 Auburn, NE Kevin Billesbach, QA, NPPD Beth Borsch, Sr. Manager, Corporate Comm., NPPD Columbus Loras Baumhover, Sheriff, Nemaha Co.

Greg Casto, Emergency Preparedness Manager, CNS Tim Chard, Chemistry/RP Manager, NPPD Michael Coyle, Asst. VP, NMC/CNS Brent Curtis, REP Planner, NE EMA Ken Fike, Chemist, NPPD Jim Flaherty, Site Regulatory Liaison, CNS Ronald Fraass, Supervisor Env. Rad. & EP, NDHE Rick Gardner, Sr. Manager, QA, CNS Charles Garst, Watson Mo.

Jim Genweck, Director, Richardson Co. EMA Mark Gillan, Work Control Manager, NPPD Roger Goas, Director, Nemaha Co. EMA Gail Good, Chief, PSB, NRC Region IV Michael Hay, Resident Inspector, CNS, NRC Region IV Guy Horn, Sr. Vice President, NPPD Columbus Brad Houston, QA Manager, CNS Art Howell, Director, DRS, NRC Region IV Jim Hutton, Plant Manager, CNS, NPPD Don Jagger, Director, Atchison Co. 911 James Kelsay, EP Coordinator, CNS David Kunsemiller, Manager, Risk & Regulatory Affairs, NPPD Ryan Lantz, Sr. Emergency Preparedness Inspector, NRC Region IV Bill Leech, VP-Nuclear, Mid-American Energy Dave Meyers, Sr. Manager, Site Support, CNS Gail Rentschler, Atchison Co. 911 David Robinson, QA Manager, NPPD Ed Rotkvia, Health Physicist, NPPD Julia Schmitt, Program Manager, Nebraska HHS R&L Jon Schwarz, Rad. Programs Manager, NE EMA Steve Sherron, ALARA Engineer, NPPD Ronald Stoddard, Consultant, LES Jim Sumpter, Project Manager, Licensing, CNS Chris Sunderman, RP, NPPD

ENCLOSURE 2 Nebraska Public Power District Emergency Preparedness Regulatory Performance Meeting Cooper Nuclear Station February 7, 2002

Agenda

"* Introduction................... Dave Wilson

"* Timeline and EP Improvement Plan. Dave Meyers

"* Past Performance Issues .......... Jim Sumpter

• Self-Assessments ............... Greg Casto

• EP Improvements ................ Greg Casto

• Follow-Up Inspection Resolution.... Greg Casto

• Line Ownership of EP...0......... Jim Hutton

• Closing Remarks .................. Guy Horn February 7, 2002 Cooper Nuclear Station 2

Introduction David Wilson February 7, 2002 Cooper Nuclear Station 3

Timeline 2000 Aug Biennial exercise Nov Preliminary White finding issued August drill root cause issued Dec Final determination (1 st White finding) 2001 Apr Supplemental Inspection (1 st White finding)

EP Drill Jun Alert - Voltage transformer failure April drill root cause issued Emergency Preparedness Improvement Plan issued February 7, 2002 Cooper Nuclear Station 4

Timeline 2001 Jul Preliminary 2nd White finding issued Aug Final determination (2nd White finding)

USA external self assessment Sep White finding root cause issued Nov Supplemental Inspection (2nd White finding)

February 7, 2002 Cooper Nuclear Station 5

Emergency Preparedness Improvement Plan Development

"* Staff-identified improvement opportunities

"* Corrective actions from White findings

"* Corrective actions from June alert

"* Quality assurance audits and escalation letter

"* Root cause evaluations

"* External assessment February 7, 2002 Cooper Nuclear Station 6

EP Improvement Plan Structure

• Augmentation "* Management Ownership

• Activation "* Offsite Programs

"* Backshift

"* Procedure Issues

"* Administration

"* QA Responses

"* Assessment

"* Regulatory Issues

"* Corrective Action

• Training Program

"* Emergency Plan Review February 7, 2002 Cooper Nuclear Station 7

Past Performance Issues Two (2) NRC White inspection findings

- Weaknesses in two (2) drills

"* August 2000

"* April 2001 February 7, 2002 Cooper Nuclear Station 8

August 2000 Biennial Exercise

"* Critique process failed to identify drill issues

- First White finding

"* Failure to identify degraded core and make correct protective action recommendation (PAR) during exercise February 7, 2002 Cooper Nuclear Station 9

Root Cause Evaluations

• Root cause for critique failure (RCR 2000-0912)

- Lack of performance standard for evaluating dose assessment performance

• Root cause for failure to identify degraded core and make correct PAR determination (RCR 2000-0909)

- Procedure inconsistencies and lack of procedural guidance for wind shift February 7, 2002 Cooper Nuclear Station 10

Extent of Condition

"* Failure to identify degraded core

- No review conducted

"* Critique failure

- Reviewed other risk-significant drill evaluation areas for performance standards

- Determined two risk-significant areas also lacked performance standards for drill evaluations

"* Notifications

"* PARS February 7, 2002 Cooper Nuclear Station 11

Corrective Actions - Critique Failure

"* Instituted use of performance standards in drill evaluations for areas lacking those standards

"* Enhanced evaluator training February 7, 2002 Cooper Nuclear Station 12

Corrective Actions - Failure to Identify Degraded Core

"* Resolved procedure inconsistencies

"* Developed guidance to address wind shifts

"* Conducted training to review drill issues and corrective actions February 7, 2002 Cooper Nuclear Station 13

Status

• Corrective actions completed for both root cause evaluations

• Critique process effective per subsequent drills

• Inadequate critique issue closed in Inspection Report 01-04.

February 7, 2002 Cooper Nuclear Station 14

April 2001 Drill

"* Failure to identify degraded core and make correct PAR recommendation

"* Critique identified drill performance issues February 7, 2002 Cooper Nuclear Station 15

Root Cause Evaluation

• Root cause for failure to identify degraded core and make correct PAR determination (RCR 2001-0331)

Teamwork needs improvement

• Communications e Procedure usage e Command and control February 7, 2002 Cooper Nuclear Station 16

Extent of Condition

"* Reviewed other similar positions in other emergency response facilities for teamwork issues

"* No other cases found February 7, 2002 Cooper Nuclear Station 17

Corrective Actions

"* Developed objective criteria for teamwork to be used for evaluating drill performance in each emergency response facility

"* Conducted immediate training for key emergency response organization members on procedure adherence and degraded core assessment

"* Provided additional training on core damage assessment for key emergency response organization members February 7, 2002 Cooper Nuclear Station 18

Second White Finding

• Corrective actions to prevent recurrence of dose assessment weaknesses experienced in August 2000 exercise were not fully effective February 7, 2002 Cooper Nuclear Station 19

Root Cause Evaluation (SCR 2001-0624)

• Previous root cause evaluations narrowly focused

- Addressed degraded core

- Did not address failure to make correct PAR determination

- No common causes identified

"* Re-performed previous root cause evaluations

"* Focused on failure to make correct PAR determination

"* Results

- Identified common causes

- Identified additional causes February 7, 2002 Cooper Nuclear Station 20

Root Causes

"* Failure to recognize significance of EP performance issues

"*Inadequate guidance in corrective action process concerning significance of EP performance issues

"* Inadequate dose assessment and command and control training

• Inadequate drill scenario validation February 7, 2002 Cooper Nuclear Station 21

Extent of Condition

"* Found three other performance areas with potential similar weaknesses

- Physical Protection

- Radiation Safety

- NRC Performance Indicators

"* Events in these areas appropriately classified in corrective action program February 7, 2002 Cooper Nuclear Station 22

Corrective Actions

"* Revised corrective action program procedures

"*Provided additional training

- Importance of risk-significant areas in corrective action program

- Core damage assessment

- Command and control

"* Improved drill scenario control

"*Corrective actions completed February 7, 2002 Cooper Nuclear Station 23

Self-Assessments 2001 Aug Emergency response facility appraisal Utilities Service Alliance assessment External peer review Sep Emergency plan/regulatory review Oct EP program commitment review 2002 Jan EP management program assessment February 7, 2002 Cooper Nuclear Station 24

Self Assessment Findings Improvements recommended in:

"* Emergency response facilities

"* Emergency plan implementing procedures

"* Staff augmentation

"* Corrective action program backlog

"* Training February 7, 2002 Cooper Nuclear Station 25

Significant Accomplishments-2001

"* Established and managed a broad based improvement plan

"* Demonstrated high level of plant management commitment and on-site support

"* Installed additional backup power to emergency response facilities

• Incorporated 2 years of critique data into corrective action program

"* Developed work-off plan for corrective action backlog

"* Improved drill and exercise manual

"* Improved/tested staff augmentation process February 7, 2002 Cooper Nuclear Station 26

Planned Improvements-2002

"* Procedures/Training

- Upgrade Emergency Plan implementing procedures and training to best industry practices

"* Drills

- Nine scheduled

- Includes player briefs/performance training drills

"* Scenario development software

- Improved program for simulator scenario development, critique trending, major Emergency Plan element tracking

• Emergency response organization (ERO) improvements

- Additional management assignments to ERO February 7, 2002 Cooper Nuclear Station 27

Performance Measurement

"* Revised key performance indicators

- ERO performance

- Staff augmentation

- ERO staffing

"* Corrective action program performance

- Site-wide

- Departmental February 7, 2002 Cooper Nuclear Station 28

Performance Assessment

"* Completion of Improvement Plan milestones

"* Drill critiques

"* Monthly review of Performance Indicators

"* Continued self-assessments

"* QA audits and surveillances February 7, 2002 Cooper Nuclear Station 29

Follow-Up Inspection Resolution

"* Dose assessment team performance

- Additional training for dose assessment team complete

"*EP corrective action program implementation

- 2000/2001 drill performance issues entered into corrective action program

- Recently completed QA surveillance February 7, 2002 Cooper Nuclear Station 30

Follow-Up Inspection Resolution

"* Historical research of condition reports

- Historical search relative to extent of condition documented in SCR 2001-0624

"* Self-assessments

- Root cause evaluations and self-assessments have bounded the issues identified in White findings February 7, 2002 Cooper Nuclear Station 31

Line Ownership

"* Organizational commitment is an imperative

"* Top ten site wide focus areas includes EP performance improvement

"* Additional management personnel assigned key roles February 7, 2002 Cooper Nuclear Station 32

Closing Remarks Guy Horn February 7, 2002 Cooper Nuclear Station 33