ML040631087
| ML040631087 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/03/2004 |
| From: | Mallett B NRC Region 4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| References | |
| IR-04-001 | |
| Download: ML040631087 (10) | |
See also: IR 05000298/2004001
Text
March 3, 2004
Randall K. Edington, Vice
President-Nuclear and CNO
Nebraska Public Power District
P.O. Box 98
Brownville, NE 68321
SUBJECT:
ANNUAL ASSESSMENT LETTER - COOPER NUCLEAR STATION
(NRC REPORT 05000298/2004001)
Dear Mr. Edington:
On January 28, 2004, the NRC staff completed its end-of-cycle plant performance assessment
of the Cooper Nuclear Station. The end-of-cycle review for the Cooper Nuclear Station involved
the participation of all technical divisions in evaluating performance indicators for the most
recent quarter and inspection results for the period from January 1 through December 31, 2003.
The purpose of this letter is to inform you of our assessment of your safety performance during
this period and our plans for future inspections at your facility so that you will have an
opportunity to prepare for these inspections and to inform us of any planned inspections that
may conflict with your plant activities.
Overall, the Cooper Nuclear Station operated in a manner that preserved public health and
safety. While the Cooper Nuclear Station met all cornerstone objectives, plant performance
remained within the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix as
discussed further below. The Cooper Nuclear Station entered the Multiple/Repetitive Degraded
Cornerstone Column of the NRCs Action Matrix on April 1, 2002. The White findings that
contributed to the initial placement in the Repetitive Degraded Cornerstone were identified
during the 2000 and 2001 assessment periods and were described in the annual assessment
letters dated May 29, 2001, and March 4, 2002.
Upon entry into the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix, and
with oversight by the NRC, you developed a plan to improve performance at the Cooper
Nuclear Station. On June 10, 2002, you submitted Revision 1 of The Strategic Improvement
Plan to the NRC. On August 22, 2002, we completed a supplemental inspection using
Inspection Procedure 95003, Inspection for Repetitive Degraded Cornerstones, Multiple
Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input." Following completion of
the NRC supplemental inspection, you revised the improvement plan and submitted Revision 2
of the plan to the NRC on November 25, 2002. On January 30, 2003, we issued a Confirmatory
Action Letter to Nebraska Public Power District (NPPD). The purpose of the Confirmatory
Action Letter was to confirm the commitments made by NPPD regarding completion of those
actions in the improvement plan developed to address regulatory performance issues. Your
actions confirmed in the Confirmatory Action Letter addressed long-standing performance
issues in the areas of emergency preparedness, human performance, material condition and
Nebraska Public Power District
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equipment reliability, plant modification and configuration control, corrective action program,
and engineering programs. In addition to baseline inspections, the NRC conducted periodic
inspections to verify completion of these actions and the effectiveness of these actions in
addressing the specific performance issues. Four of these inspections were completed in
2003. On the basis of inspection activities conducted in 2003, we have concluded that you
have corrected the specific performance deficiencies associated with the White inspection
findings in the Emergency Preparedness Cornerstone and that performance has improved in
this cornerstone. This has been demonstrated during the performance of a graded emergency
preparedness exercise and confirmed during NRC baseline inspection and quarterly
Confirmatory Action Letter inspections. In addition, the NPPD completed a comprehensive
assessment of the Cooper Nuclear Station emergency preparedness program in accordance
with the Strategic Improvement Plan and committed to in the Confirmatory Action Letter. This
assessment, which was also reviewed by the NRC staff, found that performance had improved
in this area.
With respect to the other five regulatory issues discussed in the Confirmatory Action Letter,
NPPD is scheduled to complete the applicable improvement plan actions by March 31, 2004.
Based on the results of inspections of your progress in completing the actions of the
Confirmatory Action Letter, the NRC has found that NPPD is completing the actions on
schedule. We have assessed that you have made some progress in addressing performance
issues in these five areas, but actions taken in several areas have not yet resulted in sustained
improved performance. These areas include human performance, corrective action program,
material condition, and equipment reliability. Following NPPDs completion of the actions of the
Confirmatory Action Letter, the NRC will conduct a comprehensive assessment of the
effectiveness of these actions in addressing the performance issues. Accordingly, Cooper
Nuclear Station will remain in the Multiple/Repetitive Degraded Cornerstone Column of the
Action Matrix until the satisfactory completion of the actions listed in this Confirmatory Action
Letter and you have demonstrated sustained improvements in plant performance.
During the most recent quarter of the inspection cycle, the NRC staff identified that the Cooper
Nuclear Station crossed the threshold from Green to White for the Unplanned Scrams per
7000 Critical Hours performance indicator. Therefore, we plan to conduct a supplemental
inspection in accordance with NRC Inspection Procedure 95001, Inspection for One or Two
White Inputs in a Strategic Performance Area, to review the actions taken in response to this
White performance indicator. The purpose of this supplemental inspection will be to provide
assurance that the root and contributing causes for the White performance indicator are
understood, to provide assurance that the extent of condition and extent of cause are identified,
and to provide assurance that the corrective actions are sufficient to address the root and
contributing causes and prevent their recurrence.
In addition, NRC Inspection Report 05000298/2004009, dated February 11, 2004, documented
a preliminary White finding associated with your failure to demonstrate satisfactory licensed
operator requalification program performance as described in NUREG-1021, "Operator
Licensing Examination Standards for Power Reactors," Revision 8, Supplement 1, Examination
Standard 601, Section E.3.a(1). Examination Standard 601 E.3.a(1) specifies, in part, that, for
a requalification program to maintain satisfactory performance, 75 percent or greater of the
participants must pass all portions of the biennial examinations. Failures during the biennial
Nebraska Public Power District
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cycle included a 36 percent failure rate on the biennial written examination. The NRC will
review your response to this preliminary White finding before making a final significance
determination.
In our annual assessment letters dated March 4, 2002, and March 4, 2003, we advised you of a
substantive crosscutting issue in the area of Human Performance. In the area of Human
Performance, our inspections confirmed that Strategic Improvement Plan action steps
implemented during the third Quarter of 2003 have provided for some improvement in human
performance as evidenced by an improving trend in your Human Performance Error Rate
performance indicator. Specific actions that have had a positive impact included: (1) increased
use of management observations in the field; (2) maintenance department implementation of
job-site specific reviews of human performance tools; and (3) a monthly Management
Performance Review Meeting which focuses site upper management on progress in improving
site-wide human performance. We note that you are in the process of implementing additional
actions to improve human performance. These activities include: (1) a human performance
mock-up trainer in which site-wide staff training was initiated in November 2003; (2) a paired
observation program to establish common standards and alignment on the observation and
oversight of field work; (3) formal performance management skills training; (4) meetings for
first-line supervisors focusing on human performance improvements; and (5) development of
departmental human performance improvement plans. Despite these improvements, we
identified multiple instances (at the Green finding level) throughout the assessment cycle in the
Initiating Events, Mitigating Systems, Barrier Integrity, and Occupational Radiation Safety
Cornerstones where the contributor to the performance problems was human performance.
Examples include a number of instances of operators and workers failing to follow procedures.
In one example that occurred early in the assessment cycle, plant operators failed to reduce
power to less than 25 percent within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of a partial loss of feedwater heating.
Also, in our annual assessment letters dated March 4, 2002, and March 4, 2003, we advised
you of a substantive crosscutting issue in the area of Problem Identification and Resolution. In
that area, our inspections have generally indicated that your staff adequately identified issues.
We also noted that you have implemented a number of Strategic Improvement Plan actions
with the goal of improving the implementation effectiveness of your corrective action,
self-assessment, and operating experience review programs. Despite these improvements, we
identified multiple instances of inadequate corrective actions (at the Green finding level)
throughout the assessment period in the Initiating Events, Mitigating Systems, and Barrier
Integrity Cornerstones. Examples include two preventable fires and a repetitive problem with
the clogging of an emergency diesel generator fuel oil transfer system filter. Causal factors
associated with these and other corrective action findings primarily involved failures to identify
the extent of condition, symptom-based problem solving, inadequate treatment of plant-specific
and industry operating experience, and failures to adequately implement identified corrective
actions. These are the very types of problems that your improvement initiatives are intended to
address. Your ongoing actions to address these substantive crosscutting issues have been
discussed during several public meetings, including a meeting conducted on March 1, 2004.
The NRC will continue to review the implementation of these improvement activities and any
changes resulting from these activities. The reviews will be performed during the scheduled
quarterly inspections of the actions described in the Confirmatory Action Letter and as part of
the baseline inspection program.
Nebraska Public Power District
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In accordance with IMC 0305, Operating Reactor Assessment Program, your plant will be
discussed at the upcoming Agency Action Review Meeting. We will notify you via separate
correspondence if any agency actions change as an outcome of the meeting.
As you are aware, the NRC has issued several Orders and threat advisories to enhance
security capabilities and improve guard force readiness since the terrorist attacks on
September 11, 2001. We have conducted inspections to review your implementation of these
requirements and have monitored your actions in response to changing threat conditions. For
calendar year 2004, we plan to continue inspections of Order implementation combined with
newly developed portions of the security baseline inspection program. This letter advises you
of our planned inspection effort resulting from the Cooper Nuclear Stations end-of-cycle review.
The enclosed inspection plan details the inspections scheduled through September 30, 2005.
In addition to the baseline inspections, quarterly inspections to verify the actions taken with
respect to the improvement plan and the Confirmatory Action Letter will be conducted as
shown. The inspection plan is provided to minimize the resource impact on your staff and to
allow for scheduling conflicts and personnel availability to be resolved in advance of inspector
arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous
nature. The inspections in the last 12 months of the inspection plan are tentative and may be
revised at the midcycle review meeting.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosure 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.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change this inspection plan, we will contact you to
discuss the change as soon as possible. Please contact Mr. Kriss Kennedy at 817/860-8144
with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Bruce S. Mallett
Regional Administrator
Docket: 50-298
License: DPR-46
Enclosure:
Cooper Nuclear Station Inspection/Activity Plan
Nebraska Public Power District
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cc w/enclosure:
Clay C. Warren, Vice President-Nuclear
Nebraska Public Power District
P.O. Box 98
Brownville, NE 68321
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, NE 68602-0499
P. V. Fleming, Licensing and
Regulatory Affairs Manager
Nebraska Public Power District
P.O. Box 98
Brownville, NE 68321
Michael J. Linder, Director
Nebraska Department of
Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
Chairman
Nemaha County Board of Commissioners
Nemaha County Courthouse
1824 N Street
Auburn, NE 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, NE 68509-5007
Ronald A. Kucera, Deputy Director
for Public Policy
Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65101
Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, MO 65102-0116
Nebraska Public Power District
-6-
Chief, Radiation and Asbestos
Control Section
Kansas Department of Health
and Environment
Bureau of Air and Radiation
1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
Daniel K. McGhee
Bureau of Radiological Health
Iowa Department of Public Health
401 SW 7th Street, Suite D
Des Moines, IA 50309
William J. Fehrman, President
and Chief Executive Officer
Nebraska Public Power District
1414 15th Street
Columbus, NE 68601
Marlin Logan
Presiding Commissioner
Atchison County
P.O. Box 280
Rock Port, MO 64482
Dennis Martin, Sheriff
Atchison County Sheriff's Office
511 West Clay
Rock Port, MO 64482
Brent Lottman, Sheriff
1805 N Street
Auburn, NE 68305
Dick Moody, Chairman
Nemaha County Board of Commissioners
Nemaha County Courthouse
1824 N Street
Auburn, NE 68305
Dick Hainje, Regional Director
Federal Emergency Management Agency
Region VII
2323 Grand Blvd., Suite 900
Kansas City, MO 64108-2670
Nebraska Public Power District
-7-
Robert Leopold, State Liaison Officer
Nebraska Health and Human Services
Department of Regulation and
Licensure Assurance
301 Centennial Mall, South
P.O. Box 95007
Lincoln, NE 68509-5007
Al Berndt, Assistant Director
Emergency Management Agency
1300 Military Road
Lincoln, NE 68508
Scott Clardy, Director
Section for Environmental Public Health
P.O. Box 570
Jefferson City, MO 65102-0570
Institute of Nuclear Power Operations (INPO)
700 Galleria Parkway SE, Suite 100
Atlanta, GA 30339
Nebraska Public Power District
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Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (SCS)
Branch Chief, DRP/C (KMK)
Senior Project Engineer, DRP/C (WCW)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
Dan Merzke, Pilot Plant Program (DXM2)
RidsNrrDipmLipb
V. Dricks, PAO (VLD)
W. A. Maier, RSLO (WAM)
C. J. Gordon (CJG)
DRS Branch Chiefs (LJS, TWP, ATG, CSM)
W. D. Travers, EDO (WDT)
S. J. Collins, DEDO (SJC1)
S. A. Richards, Chief, NRR/DIPM/IIPB (SAR)
R. K. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)
J. W. Craig, Associate Dir. for Inspection and Programs (JWC1)
B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)
T. A. Bergman, Chief, Regional Operations Staff, OEDO (TAB)
H. N. Berkow, NRR Project Director (HNB)
R. A. Gramm, Chief, Section 1, NRR/DLPM (RAG)
M. Honcharik, NRR Project Manager (MCH3)
ADAMS: Yes
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/RA/
/RA/
/RA/
/RA/
2/19/04
2/26/04
3/2/04
3/2/04
3/3/04
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
Cooper
Inspection / Activity Plan
03/01/2004 - 10/01/2005
Inspection
Type
Inspection Activity
Planned Dates
Start End
No. of Staff
on Site
Title
Unit
Number
Page 1 of 2
03/01/2004
15:32:50
Report 22
1
PEB-12B
- MAINTENANCE EFFECTIVENESS
Baseline Inspections
03/15/2004
03/19/2004
Maintenance Effectiveness
IP 7111112B
1
5
PEB-05T
- TRIENNIAL FIRE PROTECTION
Baseline Inspections
04/05/2004
04/09/2004
Fire Protection
IP 7111105T
1
Baseline Inspections
04/19/2004
04/23/2004
Fire Protection
IP 7111105T
1
4
- CAL QUARTERLY INSPECTION
Other Routine
03/22/2004
03/26/2004
Identification and Resolution of Problems
1
2
EB-17
- PERM. PLANT MODIFICATIONS
Baseline Inspections
03/29/2004
04/02/2004
Permanent Plant Modifications
IP 7111117B
1
2
PSB-S1
- AA-AC-FFD-PI
Baseline Inspections
04/05/2004
04/09/2004
Access Authorization
1
Baseline Inspections
04/05/2004
04/09/2004
Access Control
1
Baseline Inspections
04/05/2004
04/09/2004
Fitness For Duty Program
1
Baseline Inspections
04/05/2004
04/09/2004
Performance Indicator Verification
1
4
- CAL QUARTERLY INSPECTION
Other Routine
06/21/2004
06/26/2004
Identification and Resolution of Problems
1
1
PEB-07B
- HX & HEAT SINK PERFORMANCE TESTING
Baseline Inspections
07/19/2004
07/23/2004
Heat Sink Performance
IP 7111107B
1
1
ALARA1
- ALARA PLANNING AND CONTROLS
Baseline Inspections
09/13/2004
09/17/2004
ALARA Planning and Controls
1
3
OB-EP2
- EP EXERCISE
Baseline Inspections
09/20/2004
09/24/2004
Exercise Evaluation
1
Baseline Inspections
09/20/2004
09/24/2004
Emergency Action Level and Emergency Plan Changes
1
Baseline Inspections
09/20/2004
09/24/2004
Performance Indicator Verification
1
4
OB-INIT
- INITIAL EXAM
Not Applicable
05/09/2005
05/14/2005
COOPER (06/05) - INITIAL EXAM
X02288
1
Not Applicable
06/06/2005
06/17/2005
COOPER (06/05) - INITIAL EXAM
X02288
1
1
ACCESSPI
- ACRSA/PIV
Baseline Inspections
10/25/2004
10/29/2004
Access Control to Radiologically Significant Areas
1
1
EB08G
- ISI
Baseline Inspections
01/24/2005
01/28/2005
Inservice Inspection Activities - BWR
IP 7111108G
1
1
ACRSA
- ACCESS CONTROLS TO RAD SIGNIFICANT AREAS
Baseline Inspections
01/24/2005
01/28/2005
Access Control to Radiologically Significant Areas
1
1
ALARA2
- ALARA PLANNING AND CONTROLS
Baseline Inspections
04/11/2005
04/15/2005
ALARA Planning and Controls
1
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Cooper
Inspection / Activity Plan
03/01/2004 - 10/01/2005
Inspection
Type
Inspection Activity
Planned Dates
Start End
No. of Staff
on Site
Title
Unit
Number
Page 2 of 2
03/01/2004
15:32:50
Report 22
6
EB21/02
- SSD&PCI/50.59
Baseline Inspections
05/02/2005
05/06/2005
Safety System Design and Performance Capability
1
Baseline Inspections
05/09/2005
05/13/2005
Safety System Design and Performance Capability
1
Baseline Inspections
05/16/2005
05/20/2005
Evaluation of Changes, Tests, or Experiments
1
Baseline Inspections
05/16/2005
05/20/2005
Safety System Design and Performance Capability
1
1
OB-EP2
- EMERG PREPAREDNESS PROGRAM INSPECTION
Baseline Inspections
05/16/2005
05/20/2005
Alert and Notification System Testing
1
Baseline Inspections
05/16/2005
05/20/2005
Emergency Response Organization Augmentation Testing
1
Baseline Inspections
05/16/2005
05/20/2005
Emergency Action Level and Emergency Plan Changes
1
Baseline Inspections
05/16/2005
05/20/2005
Correction of Emergency Preparedness Weaknesses and Deficiencies
1
Baseline Inspections
05/16/2005
05/20/2005
Performance Indicator Verification
1
4
RP TEAM
- RADIATION SAFETY TEAM INSPECTION
Baseline Inspections
06/06/2005
06/10/2005
Radiation Monitoring Instrumentation and Protective Equipment
1
Baseline Inspections
06/06/2005
06/10/2005
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
1
Baseline Inspections
06/06/2005
06/10/2005
Radioactive Material Processing and Transportation
1
Baseline Inspections
06/06/2005
06/10/2005
Radiological Environmental Monitoring Program
1
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.