ML042440585
| ML042440585 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/30/2004 |
| From: | Mallett B NRC Region 4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| References | |
| Download: ML042440585 (9) | |
Text
August 30, 2004 Randall K. Edington, Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
SUBJECT:
MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - COOPER NUCLEAR STATION (CNS)
Dear Mr. Edington:
On August 5, 2004, the NRC staff completed its midcycle plant performance assessment of CNS. The midcycle review for CNS involved the participation of all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of your performance, including the performance indicators (PIs) for the most recent quarter and the inspection results over the previous 12 months. 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.
This performance review and inspection plan does not include physical protection information.
A separate letter designated and marked as Exempt from Public Disclosure in Accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.
Plant performance for the most recent quarter could be assessed as within the Regulatory Response column of the NRCs Action Matrix if you do not factor in our assessment of your actions to improve performance that led you to initiate a strategic improvement plan with actions confirmed in our January 30, 2003, Confirmatory Action Letter (CAL). This is based on a White finding issued in March 2004 for a high failure rate on the licensed operator biennial requalification written examinations. As discussed in the following paragraphs, we have assessed that our oversight of your performance should be equal to that eliciting NRC response consistent with the Multiple/Repetitive Degraded Cornerstone column of the NRCs Action Matrix.
At the beginning of the 2004 assessment cycle, CNS was in the Multiple/Repetitive Degraded Cornerstone column of the NRCs Action Matrix because there were three White emergency preparedness findings that had existed for more than four quarters. During the second quarter of 2004, the NRC closed these White findings on the basis of the correction of the underlying performance deficiencies. However, NRC concluded that additional NRC oversight was warranted while Nebraska Public Power District (NPPD) completes the actions specified in the CAL. Accordingly, on May 3, 2004, the Executive Director for Operations approved a deviation from the Action Matrix to authorize the NRC to maintain the level of oversight of CNS consistent
Nebraska Public Power District with the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix. This enhanced level of oversight includes continued NRC assessment of the strategic improvement plan, continued assessment of the effectiveness of the CAL actions and senior NRC management involvement in site visits and other assessment activities. This increased oversight will continue until NPPD has demonstrated, and the NRC has verified, that the improvement plan actions addressed by the CAL have resulted in sustained improvement in plant performance. The details of this decision were communicated to NPPD in a letter dated July 2, 2004.
On May 7, 2004, the NRC completed a supplemental inspection to assess the causes for and actions taken related to the PI for unplanned scrams per 7000 critical hours. This PI crossed the threshold from Green to White in the fourth quarter of 2003 and returned to Green in first quarter of 2004. The NRC concluded that CNS performed thorough evaluations for each of the three scrams, including a thorough root cause analysis, extent of cause, and extent of condition review to identify and implement corrective actions in response to these scrams.
On May 12, 2004, the NRC completed another supplemental inspection conducted in response to the White finding for the high failure rate on the licensed operator biennial requalification written examinations. The NRC determined that NPPDs root cause analyses of the finding was appropriately evaluated and understood. The corrective actions identified as a result of the NPPD evaluations addressed the root and contributing causes and should correct the requalification program weaknesses provided the corrective actions are consistently implemented. However, the inspection also concluded that NPPDs extent of condition and extent of cause evaluations of the high failure rate were not completed at the time of the inspection and that other areas of the root cause lacked in-depth evaluation, including the adequacy of operator knowledge and the establishment of objective criteria to evaluate effectiveness of the corrective actions. A followup inspection will be conducted in the fourth quarter of 2004 to verify the effectiveness of NPPDs additional corrective actions.
In the first two quarters of 2004, the NRC completed two quarterly inspections of the implementation, including effectiveness, of the CAL actions. These inspections were performed to assess your progress in addressing regulatory performance issues in the areas of emergency preparedness, human performance, material condition/equipment reliability, plant modifications/configuration control, corrective action programs, and engineering programs. The second inspection completed in 2004 confirmed that you have taken the actions confirmed by the CAL. These inspections were also conducted to confirm whether these actions have resulted in sustained improved performance within the six CAL focus areas. On the basis of these and other inspections, the NRC determined that the actions taken within the emergency preparedness area have resulted in sustained improved performance.
In other CAL focus areas, our inspections identified a number of positive actions that have been implemented, but that sustained improved performance has not been achieved as of the end of our midcycle review period. Specifically, in the area of material condition and equipment reliability, actions completed to date have provided the necessary processes for improvement.
Numerous equipment improvements have been recently completed; however, there are a number of long-standing or repetitive problems that have not been fully resolved. In the area of plant modifications and configuration control, progress in operability determination screening and lessons learned training has provided the potential for enhancing the ability to prioritize and
Nebraska Public Power District perform operability determinations by emphasizing knowledged based tools. In the area of engineering programs, actions taken to date have resulted in several positive performance trends.
The remaining two CAL focus areas are also addressed by two substantive crosscutting issues in problem identification and resolution, as well as human performance. In our annual assessment letter dated March 3, 2004, we provided you an assessment of these substantive crosscutting issues. Performance in these areas continues to be of concern based on the inspection findings identified during the past 12 months.
In the area of problem identification and resolution, our March 3, 2004, annual assessment letter noted that your staff adequately identified issues and that you have implemented a number of actions with the goal of improving the implementation effectiveness of your corrective action, self-assessment, and operating experience review programs. We also noted, however, that there were a number of Green findings involving instances of inadequate corrective actions. Common themes associated with these findings included: inadequate extent of condition reviews, inappropriate symptom-based problem solving, inadequate treatment of plant-specific and industry operating experience, and failures to implement planned corrective actions. Since that time, you have implemented a number of other initiatives to increase management ownership of the corrective action program and improve the timeliness of correction actions. We have observed that the implementation of these improvements has resulted in more timely program reviews of operating experience and more timely closure of significant condition reports. However, a number of plant problems, particularly those involving systems and components, have not been fully resolved. Accordingly, we plan to continue to focus our baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in overall improved corrective action effectiveness.
In the human performance area, our annual assessment letter recognized that your staff had implemented actions to improve human performance and that some improvement had been observed. Notwithstanding these improvements, we indicated that there were instances in which plant staff members failed to follow procedures. Since the beginning of the year, your staff has continued to implement ongoing initiatives, as well as undertake additional actions. In recent months, however, there have been a number of component manipulation errors, one of which is potentially significant. As a result, we will continue to focus baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in improved performance, particularly in the areas of procedural compliance and the reinforcement of expectations and standards in the performance of work.
On August 12, 2004, the NRC staff issued an inspection report with a preliminary Greater Than Green finding. The finding involved the misalignment of the service water system that rendered one train of service water system inoperable for a period of 21 days. A regulatory conference is scheduled for September 27, 2004, at the NRC Region IV office to allow you to provide additional information regarding the significance of this issue. This finding does not present a current safety concern because the valve lineup was restored to the normal configuration.
Nebraska Public Power District On August 18, 2004, a meeting was held between NRC and NPPD. At that meeting you provided the results of your self-assessment of the effectiveness of the actions that NPPD has taken in response to the CAL. You also discussed the actions you have taken or planned in response to this self-assessment. We will consider the information provided at this meeting as part of our ongoing and future oversight activities.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. In addition to the supplemental inspection discussed previously, the NRC will conduct inspections associated with the CAL. Also, the plan contains an inspection using Temporary Instruction (TI) 2515/159, Review of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment. This TI is in response to the Davis-Besse Reactor Vessel Head Degradation Lessons-Learned Task Force and is being performed at a sampling of nuclear power plants across the country.
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 because of their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the end-of-cycle 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 made 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 the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Kriss M. 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 Dockets: 50-298 Licenses: DPR-46
Enclosure:
Cooper Nuclear Station Inspection/Activity Plan
Nebraska Public Power District cc:
Clay C. Warren, Vice President of Strategic Programs Nebraska Public Power District 1414 15th Street Columbus, NE 68601 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing 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 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 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339
Nebraska Public Power District 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 (KEG)
Jennifer Dixon-Herrity, OEDO RIV Coordinator (JLD)
RidsNrrDipmLipb V. Dricks, PAO (VLD)
W. Maier, RSLO (WAM)
C. Gordon (CJG)
DRS Branch Chiefs (LJS, MPS1, ATG, JAC)
L. Reyes, EDO (LAR1)
S. Richards, Chief, NRR/DIPM/IIPB (SAR)
R. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)
C. Carpenter, Deputy Dir. for Inspection and Programs (CAC)
B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)
T. Bergman, Chief, ROPMS, OEDO (TAB)
H. Berkow, Director, LPD4, NRR/DLPM (HNB)
R. A. Gramm, Chief, PDIV-1A, NRR/DLPM (RAG)
M. Honcharik, NRR Project Manager (MCH3)
ADAMS: WYes G No Initials: __wcw___
W Publicly Available G Non-Publicly Available G Sensitive W Non-Sensitive S:\DRP\DRPDIR\MIDCYCLE2004\CNS.wpd RIV:SPR:DRP\C C:DRP\C D:DRS D:DRP DRA WCWalker;mjs;dlf KMKennedy DDChamberlain ATHowell TPGwynn
/RA/ WCWalker for VLOrdaz for /RA/ /RA/
8/18/04 8/18/04 8/25/04 8/27/04 8/27/04 RA BSMallett
/RA/
8/27/04 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Page 1 of 2 Cooper 08/27/2004 07:56:14 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type CAL COA - CAL CLOSEOUT ASSESSMENT 4 1 IP 95003 Inspection For Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple 05/10/2004 09/04/2004 Supplemental Program TI-SW - TI-2515/159 - REVIEW OF GL 89-13 2 1 IP 2515/159 Review of Generic Letter 89-13: Service Water System Problems Affecting Safety-Related Eq 09/07/2004 09/16/2004 Safety Issues PEB-07B - HX & HEAT SINK PERFORMANCE TESTING 1 1 IP 7111107B Heat Sink Performance 09/13/2004 09/17/2004 Baseline Inspections ACCESS - ACRSA & PIV 1 1 IP 7112102 ALARA Planning and Controls 09/13/2004 09/17/2004 Baseline Inspections OB-EP EX - EP EXERCISE 3 1 IP 7111401 Exercise Evaluation 09/20/2004 09/24/2004 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 09/20/2004 09/24/2004 Baseline Inspections 1 IP 71151 Performance Indicator Verification 09/20/2004 09/24/2004 Baseline Inspections OB-INIT - INITIAL EXAM 4 1 X02288 COOPER (06/05) - INITIAL EXAM 05/09/2005 05/14/2005 Not Applicable 1 X02288 COOPER (06/05) - INITIAL EXAM 06/06/2005 06/17/2005 Not Applicable OB-RQ - REQUAL INSP 1 1 IP 7111111B Licensed Operator Requalification Program 11/01/2004 11/05/2004 Baseline Inspections ALARA - ALARA PLANNING AND CONTROLS 1 1 IP 7112101 Access Control to Radiologically Significant Areas 11/29/2004 12/03/2004 Baseline Inspections EB08G - ISI 1 1 IP 7111108G Inservice Inspection Activities - BWR 01/24/2005 01/28/2005 Baseline Inspections ACRSA - ACCESS CONTROLS TO RAD SIGNIFICANT AREAS 1 1 IP 7112101 Access Control to Radiologically Significant Areas 01/24/2005 01/28/2005 Baseline Inspections ALARA2 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 04/11/2005 04/15/2005 Baseline Inspections EB21/02 - SSD&PCI/50.59 5 1 IP 7111121 Safety System Design and Performance Capability 05/02/2005 05/06/2005 Baseline Inspections 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 05/16/2005 05/20/2005 Baseline Inspections OB-EP2 - EMERG PREPAREDNESS PROGRAM INSPECTION 1 1 IP 7111402 Alert and Notification System Testing 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7111403 Emergency Response Organization Augmentation Testing 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 05/16/2005 05/20/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 05/16/2005 05/20/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Cooper 08/27/2004 07:56:14 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type RP TEAM - RADIATION SAFETY TEAM INSPECTION 4 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 06/06/2005 06/10/2005 Baseline Inspections 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 06/06/2005 06/10/2005 Baseline Inspections 1 IP 7112202 Radioactive Material Processing and Transportation 06/06/2005 06/10/2005 Baseline Inspections 1 IP 7112203 Radiological Environmental Monitoring Program 06/06/2005 06/10/2005 Baseline Inspections PEB-PIR - PIR INSPECTION 3 1 IP 71152B Identification and Resolution of Problems 06/13/2005 06/17/2005 Baseline Inspections 1 IP 71152B Identification and Resolution of Problems 06/20/2005 06/24/2005 Baseline Inspections ALARA3 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 08/22/2005 08/26/2005 Baseline Inspections OB-RQ - REQUAL INSPECTION 2 1 IP 7111111B Licensed Operator Requalification Program 11/14/2005 11/18/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.