ML022490401
| ML022490401 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/03/2002 |
| From: | Merschoff E NRC Region 4 |
| To: | Mayben W Nebraska Public Power District (NPPD) |
| References | |
| Download: ML022490401 (9) | |
Text
",.
C William R. Mayben, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, Nebraska 68601
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PRESENTATION TO THE NEBRASKA PUBLIC POWER DISTRICT BOARD OF DIRECTORS AUGUST 8, 2002
Dear Mr. Mayben:
This refers to the presentation by the NRC Executive Director for Operations and the Region IV Regional Administrator to the Nebraska Public Power District Board of Directors on August 8, 2002. The purpose of this meeting was to present the results of the supplemental inspections conducted at the Cooper Nuclear Station and the necessary actions required to improve performance at the plant. The NRC's presentation is enclosed.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available 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).
Sincerely, Ellis W. Merschof Regional Adm i irator Docket: 50-298 License: DPR-46
Enclosure:
NRC's Presentation to the NPPD Board of Directors UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8084 SEP - 3 2002
Nebraska Public Power District cc w/enclosure:
David L. Wilson, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Michael T. Coyle Site Vice President Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 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 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 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 Nebraska Public Power District 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 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, Iowa 50309 William R. Mayben, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, Nebraska 68601 U. S. Nuclear Regulatory Commission Presentation to Nebraska Public Power District Board of Directors August 8, 2002 CIO Dr. William D. Travers Executive Director for Operations Ellis W. Merschoff Regional Administrator
ACTION MATRIX Note 1: The regulatory actions for plants in the Multiple/Repetitive Degraded Cornerstone column are not mandatory agency actions. However, the regional office should consider each of these regulatory actions when significant new information regarding licensee performance becomes available.
Ali Assessment Inputs 110neorTwo White Inputs one Degraded 11 RepaIltive Degraded rail Unacceptable (Performance Indicators (in different Cornerstone (2 White 1 Cornerstone, Multiple 1ý Performance; Plants N Inputs or I Yellow Input) aded Cornerstones, Permitted to Operate (Pis) and Inspection cornerstones) In a I
De riple Yellow Inputs, Within this Bond, I GeTSatrnayte3glWchPiteerilfnpuls In M tuign Findings) Green; Strategic Performancis ormance or I Red Input 1 Unacceptable May!
Cornerstone ObjedWeq Area; Cornerstone 9
safety to objectives Fully Met Area; cornerstone 11 cornerstone Oblectfire I h L ingstanding Objectives Met with lim6twt 0
Moderate Degradation In issues or Signif Icant safety Performance Degradation in Safety Lperforman
Cooper Action Matrix Calendar Year 2000 Calendar Year 2001 Calendar Year 2002 Quarter 3 Quarter 4 Quarter 1 Quarter 2 Quarter 3 Quarter 4n Quarter 1 Quarter 2 Quarter 3t Cresoe 7/11/00 -
,10/1/00 -
1/1/01 -
4/1/01 -
7/1/01 -
1//01 -6//0
/30/02 9/30/02 -
12/31/02 Cornestone 9/30/00 12/31/00 3/31/01 6/30/01 9/30/00 12/31/01 3/31/02 63/2 93/2 1/10 Initiating Events.......
Dates in parenthesis are exit dates for the findings 1.) Compromise of the requalification biennial written examinations 2.) Failure of exercise critique process 3.) Ineffective corrective actions to prevent recurrence of a dose assessment performance weakrness 4.) Failure to perform timely offsite notifications following an Alert iý 5.) Failure to meet planning standard for timely augmentation of emergency response facilities 6.) Preliminary White associated with RCIC instrument line snubber fouling issue
Cooper TIP Process Problem Characterization Corrective Action Plan Implementation Plan Resource Loading Prioritization Scheduling Performance Monitoring Effectiveness Reviews Closure Process I
NPPD BOARD PRESENTATION BACKGROUND Good Morning. The NRC implements a Safety Oversight Process that is intended to be transparent to the public and other interested parties, and, one that is predictable to nuclear power plant owners. The heart of this safety oversight process are pre determined decision points for each category of nuclear power plant safety performance. These pre-determined decisions are reflected in what we call the "action matrix." The NRC classifies nuclear power plant safety performance into 5 categories, Category 1 is the best, Category 5 is the worst. Moving from Category 1 to Category 4 represents a reduction in the margin of safety. In Category 5, the margin of safety is unacceptably small, and the plant is not permitted to operate.
The entry conditions for this Action Matrix are performance deficiencies which are grouped by safety significance into four categories: Green (very low), White (low),
Yellow (moderate), and Red (high).
Now, if we take a look at Cooper Station's performance since July of 2000, we can clearly see the decline in safety performance. In the third quarter of 2000, all Green Performance, there were no significant regulatory Issues. In the fourth quarter, an Emergency Preparedness Drill weakness was noted, moving Cooper to Category 2. In the second quarter of 2001, the same EP problem recurred, indicating ineffective corrective actions, moving Cooper into Category 3. In the third quarter of 2001, two additional White Findings were assessed resulting from an actual plant event which was classified at the Alert Level. During this event, Cooper Station personnel failed to make timely offsite notifications and failed to man their emergency facilities within the time requirements.
These two additional Whites cause Cooper to remain in Category 3 for over a year, which results in the safety performance being further downgraded to Category 4.
In the fourth quarter of 2001, we see problems in a different cornerstone, mitigating systems. Of note, in the inspection conducted to close the White Emergency Preparedness findings in 2002, we found that adequate corrective action had still not been taken, and thus, the White findings remain open.
Once a plant's performance degrades to Column 4, we form a large team of very experienced inspectors to independently assess the plant. In the case of Cooper, we felt that the previous 10 years provided an extensive history of well founded independent assessments of the plant's performance that likely captured the full spectrum of problem types that exist at Cooper. We felt that the NRC's resources would be best spent on assessing the adequacy of Cooper's Corrective Action Plans rather than provide yet another listing of Cooper's unaddressed problems.
This was an innovative approach, designed to move Cooper forward toward a solution. I believe our team and your staff worked together exceptionally well to make this a thorough and effective assessment of your corrective action plan.
We focused our effort in three main areas of the TIP Process, Problem Characterization
- did the TIP capture all the problems; Corrective Action Plans - were they complete, thorough, and achievable; and the Implementation Plan - was it prioritized, resource loaded, and realistic.
Results Overall, we found that Cooper Station continued to be operated safely.
However, while good progress has been made in developing the Strategic Improvement Plan, Significant Deficiencies were noted in all three areas assessed, indicating the need for substantially more work, perhaps as much effort as has already been invested in the TIP.
Specifically, we found the Cooper Nuclear Station lacked a systematic process for developing the extent of condition reviews and the TIP Revision 1 Action Plans. Rather than a formal procedure driven repeatable process, we found an informal evolving process that lacked the requisite coordination between the problem characterization and the Corrective action portion of the effort. This is an important weakness in that ultimately the credibility of the process and the confidence that it need not be repeated when a new problem arises, rests with the formality, rigor, and repeatability of the process.
In the area of Problem Characterization, we noted that the bulk of the problems warranting attention had been appropriately captured by the process, with only one issue missed in its entirety, the management of spare and replacement parts.
In summary, your efforts to date have gotten you about half way to the end of the beginning - simply to develop the plan.
We saw a lack of rigor in the process - But progress made from a brute force approach Problem characterization generally effective with some important omissions Insufficient detail in steps for half of the action plans, and Very little work done on planning for implementation.