ML111230653

IR 05000298-11-002 and Notice of Violation, on 01/01/11 - 03/24/11, Cooper

ML111230653
Person / Time
Site:	Cooper
Issue date:	05/03/2011
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	O'Grady B Nebraska Public Power District (NPPD)
References
EA-2011-090 IR-11-002
Download: ML111230653 (48)

See also: IR 05000298/2011002

Text

`

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

May 3, 2011

EA-2011-090

Brian J. OGrady, Vice President-Nuclear

and Chief Nuclear Officer

Nebraska Public Power - Cooper

Nuclear Station

72676 648A Avenue

Brownville, NE 68321

Subject: COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT

NUMBER 05000298/2011002 AND NOTICE OF VIOLATION

Dear Mr. OGrady:

On March 24, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Cooper Nuclear Station. The enclosed integrated inspection report documents the

inspection findings, which were discussed on March 29, 2011, with you and other members of

your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, the NRC has identified an issue that was evaluated

under the risk significance determination process as having very low safety significance

(Green). The NRC has also determined that a violation is associated with this issue.

This violation was evaluated in accordance with the NRC Enforcement Policy. The current

Enforcement Policy is included on the NRC's Web site at

(http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding it are described in detail in the subject inspection report. The violation involved the

failure to appropriately assess and manage the risk associated with planned maintenance

activities. The violation is being cited in the Notice because the licensee failed to restore

compliance with NRC requirements within a reasonable time after violations were identified in

Inspection Reports 05000298/2009005, 2010002, and 2010005. This is consistent with the

NRC Enforcement Policy; Section 2.3.2, which states, in part, that a cited violation will be

EA-2011-090

Nebraska Public Power District -2-

considered if the licensee fails to restore compliance within a reasonable time after a violation is

identified.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

Based on the results of this inspection, the NRC has also determined that one additional

Severity Level IV violation of NRC requirements occurred, and three additional issues that were

evaluated under the risk significance determination process as having very low safety

significance (Green). The NRC has determined that violations are associated with these issues.

Additionally, one licensee-identified violation, which was determined to be of very low safety

significance, is listed in this report. However, because of the very low safety significance and

because they were entered into your corrective action program, the NRC is treating these

findings as a noncited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the violation or the significance of the noncited violations, you should provide a

response within 30 days of the date of this inspection report, with the basis for your denial, to

the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,

Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the

NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect

assigned to any finding in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your disagreement, to the Regional Administrator,

Region IV, and the NRC Resident Inspector at the facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosures, and your response, if you choose to provide one, will be made available

electronically for public inspection in the NRC Public Document Room or from the NRC's

document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-

rm/adams.html. To the extent possible, your response should not include any personal privacy

or proprietary, information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Vince Gaddy, Chief

Project Branch C

Division of Reactor Projects

EA-2011-090

Nebraska Public Power District -3-

Docket: 50-298

License: DRP-46

Enclosure 1 - Notice of Violation

Enclosure 2 - NRC Inspection Report 05000298/2011002

Attachment: Supplemental Information

cc w/Enclosure:

Distribution via ListServ

EA-2011-090

Nebraska Public Power District -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Tom.Blount@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Michael.Chambers@nrc.gov)

Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)

CNS Administrative Assistant (Amy.Elam@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Lynnea.Wilkins@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (James.Trapp@nrc.gov)

Senior Enforcement Specialist (Ray.Kellar@nrc.gov)

OEMail Resource

ROPreports

RIV OEDO/ETA (Stephanie Bush-Goodard)

DRS/TSB STA (Dale.Powers@nrc.gov)

R:\_Reactors\_CNS\2011\CNS2011002-RP-JJ-vgg.docx

ADAMS: No Yes SUNSI Review Complete Reviewer Initials: VGG

Publicly Available Non-Sensitive

Non-publicly Available Sensitive

SRI:DRP/ RI:DRP/ C:DRS/EB1 C:DRS/EB2 C:DRS/OB

JJosey MLChambers TRFarnholtz NFOKeefe MSHaire

/RA/E-VGG /RA/E VGG /RA/ /RA/ /RA/

4/27/11 4/27/11 4/14/111 4/15/11 4/13/11

C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB SEO:ORA/OE C:DRP/

MPShannon GEWerner MCHay RKellar VGGaddy

/RA/ /RA/ /RA/HFreeman /RA/ /RA/

4/18/11 4/15/11 4/18/11 4/18/11 5/3/11

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

NOTICE OF VIOLATION

Nebraska Public Power District Docket No. 50-298

Cooper Nuclear Station License No. DPR-46

EA-2010-090

During an NRC inspection conducted January 1 through March 24, 2011, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

Title 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants, requires, in part, that before performing

maintenance activities the licensee shall assess and manage the increase in risk that

may result from the proposed maintenance activities.

Contrary to the above, from November 26, 2008 through February 17, 2011 work control

and operations personnel failed to adequately access and manage the increase in risk

associated with maintenance activities. Specifically, qualitative assessments of

maintenance activities in or near the electrical switchyard and offsite power components

were not included in the on-line risk assessment.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Cooper Nuclear Station is hereby required to

submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional

Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the

subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-2011-090"

and should include for each violation: (1) the reason for the violation, or, if contested, the basis

for disputing the violation or severity level, (2) the corrective steps that have been taken and the

results achieved, (3) the corrective steps that will be taken, and (4) the date when full

compliance will be achieved. Your response may reference or include previous docketed

correspondence, if the correspondence adequately addresses the required response. If an

adequate reply is not received within the time specified in this Notice, an order or a Demand for

Information may be issued as to why the license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

-1- Enclosure 1

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

Dated this 3rd day of May, 2011

-2- Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000298

License: DRP-46

Report: 05000298/2011002

Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: 72676 648A Ave

Brownville, NE 68321

Dates: January 1 through March 24, 2011

Inspectors: M. Chambers, Resident Inspector

T. Farina, Operations Engineer

J. Josey, Senior Resident Inspector

C. Steely, Operations Engineer

G. George, Reactor Inspector

Approved By: Vince Gaddy, Chief, Project Branch C

Division of Reactor Projects

-3- Enclosure 1

SUMMARY OF FINDINGS

IR 05000298/2011002; 01/01/2011 - 03/24/2011; Cooper Nuclear Station, Integrated Resident

and Regional Report; Licensed Operator Requalification Program, Maintenance Risk

Assessments and Emergent Work Control, Refueling and Other Outage Activities, Identification

and Resolution of Problems, and Event Follow-up.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspections by region-based inspectors. One Green cited violation, three Green

noncited violations, and one Severity Level IV violation were identified. The significance of most

findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual

Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined

using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings

for which the significance determination process does not apply may be Green or be assigned a

severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Initiating Events

• Green. The inspectors identified a cited violation of 10 CFR 50.65(a)(4),

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants, for the failure of work control and operations personnel to adequately

assess and manage the increase in risk associated with maintenance activities.

Specifically, on February 17, 2011, work control and operations personnel failed

to adequately assess and manage the increase in risk associated with

maintenance activities involving the use of heavy equipment in or near the

electrical switchyard and offsite power components. Due to the licensees failure

to restore compliance from the previous NCV 050000298/2008005-02 and other

subsequent violations within a reasonable time after the violations were

identified, this violation is being cited in a Notice of Violation consistent with

Section 2.3.2 of the NRC Enforcement Policy. This finding was entered into the

licensees corrective action program as condition reports CR-CNS-2010-09146,

CR-CNS-2008-08645 and CR-CNS-2009-03714.

The performance deficiency associated with this finding involved the licensees

failure to adequately assess and manage the risk of planned maintenance

activities. This finding is greater than minor because it affected the protection

against external factors attribute of the Initiating Events Cornerstone, and directly

affected the cornerstone objective to limit the likelihood of those events that

upset plant stability and challenge critical safety functions during shutdown as

well as power operations. The inspectors determined that Manual Chapter 0609,

Appendix K, Maintenance Risk Assessment and Risk Management Significance

Determination Process, could not be used due to the licensees inability to

quantify the increase in risk associated with the heavy equipment activity in the

-1- Enclosure 2

switchyard. The inspectors therefore used Manual Chapter 0609, Appendix M,

Significance Determination Process Using Qualitative Criteria. The inspectors

performed a bounding qualitative evaluation using the best available information

and determined that the finding was of very low safety significance because

another qualified source of offsite power (the emergency transformer) was

unaffected by this performance deficiency and provided sufficient remaining

defense in depth in the event of a loss of offsite power. This finding has a

crosscutting aspect in the area of problem identification and resolution

associated with the corrective action program component because the licensee

did not take appropriate corrective actions to address safety issues and adverse

trends in a timely manner, commensurate with their safety significance and

complexity P.1(d)(Section 1R13).

Cornerstone: Mitigating Systems

• Green. The inspectors identified a noncited violation of

10 CFR Part 55.59 (a)(2)(ii), Requalification, for the failure of the licensee to

ensure that three senior operator license holders were evaluated during the

annual operating test to the appropriate level of their license. This issue was

entered into the licensees corrective action program as Condition

Report CR-CNS-2010-09350.

The failure of the licensee to properly evaluate the three senior operators to the

level of their license in the annual operating test was a performance deficiency.

The performance deficiency is more than minor, and therefore a finding, because

it adversely impacted the human performance attribute of the Mitigating Systems

Cornerstone objective of ensuring the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

Additionally, if left uncorrected, the performance deficiency could have become

more significant in that allowing licensed operators to return to the control room

without valid demonstration of appropriate knowledge on the biennial

examinations could be a precursor to a significant event if undetected

performance deficiencies develop. Using Manual Chapter 0609, Significance

Determination Process, Phase 1 worksheets, and Appendix M, Significance

Determination Process Using Qualitative Criteria, the finding was determined to

have very low safety significance (Green) because, although the finding resulted

in three senior operator license holders standing watch in the senior operator

position without being properly evaluated during the annual operating test, there

were no actual safety consequences. This finding has a crosscutting aspect in

the area of human performance associated with the decision making component

because the licensee failed to use conservative assumptions in decision making

and adopt a requirement to demonstrate that the proposed action is safe in order

to proceed rather than a requirement to demonstrate that it is unsafe in order to

disapprove the action H.1(b) (Section 1R11).

• Green. The inspectors identified a noncited violation of 10 CFR 50 Appendix B,

Criterion V, Instructions, Procedures and Drawings, regarding the licensees

-2- Enclosure 2

failure to follow the requirements of Administrative Procedure 0.5.CR, Condition

Report Initiation, Review and Classification. to enter conditions adverse to

quality into the corrective action program. Specifically, between January 12,

2011, and February 24, 2011, the inspectors identified multiple instances where

licensee personnel were aware of conditions adverse to quality, but failed to

appropriately enter them into the corrective action program until being prompted

by the inspectors. The licensee entered this issue in their corrective action

program as CR-CNS-2011-1239.

The performance deficiency associated with this finding involved the licensees

failure to initiate condition reports as required by Administrative Procedure

0.5.CR, Condition Report Initiation, Review and Classification. The

performance deficiency was more than minor because it affected the equipment

performance attribute of the Mitigating Systems Cornerstone, and directly

affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Although the examples mentioned above may be minor

violations, the inspectors used Section 2.10.F of the NRC Enforcement Manual to

determine that the performance deficiency was more than minor and is therefore

a finding because the NRC has indication that the minor violation had occurred

repeatedly. Using the Manual Chapter 0609, Attachment 4, Phase 1 - Initial

Screening and Characterization of Findings, the inspectors determined that the

finding has very low safety significance because all of the items in the

Table 4a Mitigating Systems Cornerstone checklist were answered in the

negative. The finding has a crosscutting aspect in the area of problem

identification and resolution associated with the corrective action program

component, in that the licensee takes appropriate corrective actions to address

safety issues and adverse trends in a timely manner. Specifically, the licensee

failed to take appropriate corrective actions to address previously identified

examples of employees not initiating condition reports in response to conditions

adverse to quality P.1(d) (Section 4AO2).

Cornerstone: Barrier Integrity

• Green. The inspectors identified a noncited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated

with the licensees failure to adequately implement Procedure 0.45, Foreign

Material Exclusion Program, Revision 33. Specifically, between

November 24, 2010, and March 24, 2011 multiple occasions were identified

where licensee personnel failed to implement appropriate foreign material

exclusion controls in areas designated as Zone 1 areas around safety related

equipment (e.g., failure to appropriately log material into and out of the zone, or

appropriately lanyard material in the zone) as required by station procedure.

This issue was entered into the licensee's corrective action program as Condition

Reports CR-CNS-2010-9173, CR-CNS-2010-9678, CR-CNS-2011-2775 and CR-

CNS-2011-3214.

-3- Enclosure 2

The failure of station personnel to follow Procedure 0.45, Foreign Material

Exclusion Program, when working in Zone 1 foreign material exclusion areas

around safety related equipment/areas, was a performance deficiency. The

performance deficiency was more than minor because it affected the human

performance attribute of the Barrier Integrity Cornerstone, and directly affected

the cornerstone objective of providing reasonable assurance that physical

barriers protect the public from radionuclide releases caused by accidents or

events, and is therefore a finding. Furthermore, station personnels continued

failure to implement appropriate foreign material exclusion controls could result in

the introduction of foreign material into critical areas, such as the spent fuel pool

or the reactor cavity, which in turn could result in degradation and adverse

impacts on materials and systems associated with these areas. Using Inspection

Manual Chapter 0609, Significance Determination Process, Phase 1

Worksheets (at power issues), and Manual Chapter 0609, Appendix G,

Shutdown Operations Significance Determination Process, Phase 1 guidance

(shutdown issues), this finding was determined to have a very low safety

significance because; the finding was only associated with the fuel barrier (at

power), and did not result in an increase in the likelihood of a loss of reactor

coolant system inventory, degrade the ability to add reactor coolant system

inventory, or degrade the ability to recover decay heat removal (shutdown). This

finding had a crosscutting aspect in the area of human performance associated

with the work practices component, in that the licensee failed to define and

effectively communicate expectations regarding procedural compliance and

personnel follow procedures H.4(b) (Section 1R20).

Cornerstone: Miscellaneous

• Severity Level IV. The inspectors identified a Severity Level IV noncited violation

of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear

Power Reactors, for the licensees failure to notify the NRC Operations Center

within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following discovery of an event meeting the reportability criteria as

specified. Specifically, on January 18, 2011, while the B train of residual heat

removal was inoperable for scheduled maintenance the A train experienced a

fault which rendered it inoperable for its low pressure coolant injection function.

As a result, both trains of residual heat removal were incapable of performing

their system specified safety function of residual heat removal. The licensees

evaluation of this condition determined that it was not a reportable event because

both core spray pumps were operable and the D residual heat removal pump

was available therefore the overall function of decay heat removal was

maintained. The inspectors questioned this rational, because the apparent intent

of the reporting criteria as described in NUREG 1022, Event Reporting

Guidelines 50.72 and 50.73, Revision 2, section 3.2.7, was to cover an event or

condition where structures, components, or trains of a safety system could have

failed to perform their intended safety function as described in the plant safety

analysis. Consultation with the Office of Nuclear Reactor Regulation determined

that this was the intent of the criteria. As such, the inspectors determined that

the licensee had failed to make a non-emergency 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report as required by 10

-4- Enclosure 2

CFR 50.72(b)(3)(v). The licensee submitted the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report on January 21,

2011 and entered this issue into the corrective action program as Condition

Report CR-CNS-2011-0618.

The failure to make an applicable non-emergency 8-hour event notification report

within the required time frame was determined to be a performance deficiency.

The inspectors reviewed this issue in accordance with NRC Inspection Manual

Chapter 0612 and the NRC Enforcement Manual. Through this review, the

inspectors determined that traditional enforcement was applicable to this issue

because the NRC's regulatory ability was affected. Specifically, the NRC relies

on the licensees to identify and report conditions or events meeting the criteria

specified in regulations in order to perform its regulatory function; and when this

is not done, the regulatory function is impacted. The inspectors determined that

this finding was not suitable for evaluation using the significance determination

process, and as such, was evaluated in accordance with the NRC Enforcement

Policy. The finding was reviewed by NRC management and because the

violation was determined to be of very low safety significance, was not repetitive

or willful, and was entered into the corrective action program, this violation is

being treated as a Severity Level IV noncited violation consistent with the NRC

Enforcement Policy. This finding had a crosscutting aspect in the area of human

performance associated with the decision making component, in that, the

licensee failed to use conservative assumptions in their decision making H.1(b)

(Section 4OA3).

B. Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have

been reviewed by the inspectors. Corrective actions taken or planned by the licensee

have been entered into the licensees corrective action program. These violations and

corrective action tracking numbers (condition report numbers) are listed in

Section 4OA7.

-5- Enclosure 2

REPORT DETAILS

Summary of Plant Status

Cooper Nuclear Station began the inspection period at full power on January 1, 2011. On

March 7, 2011, the plant began power coast down, and on March 13, 2011, the plant was

shutdown for Refueling Outage 26.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

Readiness to Cope with External Flooding

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with

the design basis probable maximum flood. The evaluation included a review to check

for deviations from the descriptions provided in the Updated Final Safety Analysis Report

for features intended to mitigate the potential for flooding from external factors. As part

of this evaluation, the inspectors checked for obstructions that could prevent draining,

checked that the roofs did not contain obvious loose items that could clog drains in the

event of heavy precipitation, and determined that barriers required to mitigate the flood

were in place and operable. Additionally, the inspectors performed an inspection of the

protected area to identify any modification to the site that would inhibit site drainage

during a probable maximum precipitation event or allow water ingress past a barrier.

The inspectors also reviewed the abnormal operating procedure for mitigating the design

basis flood to ensure it could be implemented as written. Specific documents reviewed

during this inspection are listed in the attachment.

The inspectors reviewed Cooper Nuclear Stations external flood protection strategy to

resolve unresolved item URI 05000298/2010005-06, Failure to Update Flood Protection

for Safety Related Buildings. The inspectors verified that flood protection strategy would

adequately protect to the flood levels stated in the Updated Final Safety Analysis Report.

Since the inspectors verified the adequacy of the external flood protection strategy to

design basis flood levels, URI 05000298/2010005-06 is closed.

These activities constitute completion of one external flooding sample as defined in

Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

-6- Enclosure 2

1R04 Equipment Alignments (71111.04)

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

• High pressure coolant injection system

• Fuel pool cooling decontamination flush/alternate decay heat removal

• Supplemental diesel generator

The inspectors selected these systems based on their risk significance relative to the

reactor safety cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, Updated Final Safety Analysis Report, technical specification

requirements, administrative technical specifications, outstanding work orders, condition

reports, and the impact of ongoing work activities on redundant trains of equipment in

order to identify conditions that could have rendered the systems incapable of

performing their intended functions. The inspectors also inspected accessible portions

of the systems to verify system components and support equipment were aligned

correctly and operable. The inspectors examined the material condition of the

components and observed operating parameters of equipment to verify that there were

no obvious deficiencies. The inspectors also verified that the licensee had properly

identified and resolved equipment alignment problems that could cause initiating events

or impact the capability of mitigating systems or barriers and entered them into the

corrective action program with the appropriate significance characterization. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as

defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

-7- Enclosure 2

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• January 12, 2011, Residual heat removal 1A heat exchanger room during

residual heat removal valve RHR-101 freeze seal, Zone 2A

• January 25, 2011, Torus Area, Zone 1F

• February 16, 2011, Control rod drive repair area, reactor building 958 feet

elevation, Zone 4C

• February 24, 2011, Alternate decay heat removal hot work permit area, reactor

building 958 feet elevation, Zone 4C

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire-protection inspection samples

as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

-8- Enclosure 2

1R11 Licensed Operator Requalification Program (71111.11)

.1 Quarterly Review

a. Inspection Scope

On February 9, 2011, the inspectors observed a crew of licensed operators in the plants

simulator to verify that operator performance was adequate, evaluators were identifying

and documenting crew performance problems and training was being conducted in

accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crews ability to identify and implement appropriate technical specification

actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to preestablished

operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Biennial Review

The licensed operator requalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators were

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators were

administered an operating test and a comprehensive written examination.

-9- Enclosure 2

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification

program, the inspectors conducted personnel interviews, reviewed both the operating

tests and written examinations, and observed ongoing operating test activities.

The inspectors interviewed six licensee personnel, consisting of two reactor operators,

two senior operators, one simulator supervisor and one operations training supervisor to

determine their understanding of the policies and practices for administering

requalification examinations. The inspectors also reviewed operator performance on the

written exams and operating tests. These reviews included observations of portions of

the operating tests by the inspectors. The operating tests observed included two job

performance measures and two scenarios that were used in the current biennial

requalification cycle. These observations allowed the inspectors to assess the licensee's

effectiveness in conducting the operating test to ensure operator mastery of the training

program content. The inspectors also reviewed medical records of six licensed

operators for conformance to license conditions and the licensees system for tracking

qualifications and records of license reactivation for one operator.

The results of these examinations were reviewed to determine the effectiveness of the

licensees appraisal of operator performance and to determine if feedback of

performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed minutes of

training review group meetings to assess the responsiveness of the licensed operator

requalification program to incorporate the lessons learned from both plant and industry

events. Examination results were also assessed to determine if they were consistent

with the guidance contained in NUREG 1021, "Operator Licensing Examination

Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual

Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance

Determination Process."

In addition to the above, the inspectors reviewed examination security measures,

simulator fidelity and existing logs of simulator deficiencies.

The inspectors completed one inspection sample of the biennial licensed operator

requalification program.

b. Findings

Introduction. The inspectors identified a Green noncited violation of

10 CFR Part 55.59 (a)(2)(ii), Requalification, for the failure of the licensee to ensure

that all senior operator license holders were evaluated during the annual operating test.

Three of the twenty-nine senior operator license holders were not evaluated during the

annual operating test due to the licensees interpretation of Frequently Asked Questions

Inspection Procedure .3 on the Operator Licensing section of the NRC website. This

failure resulted in three senior operator license holders standing watch without being

properly evaluated during the annual operating test, but did not lead to any actual safety

consequences.

- 10 - Enclosure 2

Description. On November 30, 2010, while performing a biennial requalification

inspection in accordance with Inspection Procedure 71111.11, Licensed Operator

Requalification Program, the inspectors discovered that during calendar year 2009,

three senior operators were not properly evaluated during the annual operator test. This

resulted in this group of senior operators standing watch without properly completing the

annual operating test. The licensee had determined at the beginning of 2009, per their

interpretation of Frequently Asked Questions Inspection Procedure .3 on the Operator

Licensing feedback section of the NRC website, that senior operators could be properly

evaluated while in the reactor operator position without rotating to the level of their

license during scenario evaluations. The inspectors informed the licensee that

Frequently Asked Questions Inspection Procedure .3 was intended to allow licensees to

evaluate senior operator license holders in the shift manager position without rotating

them in another scenario back to the control room supervisor position. This would still

allow evaluation of the senior operator in command and control functions and

emergency procedure usage. The three senior operators were evaluated at the

appropriate senior operator position during the 2010 annual operating examination. All

three individuals successfully passed their annual operating examination.

Analysis. The failure of the licensee to properly evaluate the three senior operators to

the level of their license in the annual operating test was a performance deficiency. The

performance deficiency is more than minor, and therefore a finding, because it adversely

impacted the human performance attribute of the Mitigating Systems Cornerstone

objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. Additionally, if left uncorrected,

the performance deficiency could have become more significant in that allowing licensed

operators to return to the control room without valid demonstration of appropriate

knowledge on the biennial examinations could be a precursor to a significant event if

undetected performance deficiencies develop. Using Manual Chapter 0609,

Significance Determination Process, Phase 1 worksheets, and Appendix M,

Significance Determination Process Using Qualitative Criteria, the finding was

determined to have very low safety significance (Green) because, although the finding

resulted in three senior operator license holders standing watch in the senior operator

position without being properly evaluated during the annual operating test, there were no

actual safety consequences. This finding has a crosscutting aspect in the area of

human performance associated with the decision making component because the

licensee failed to use conservative assumptions in decision making and adopt a

requirement to demonstrate that the proposed action is safe in order to proceed rather

than a requirement to demonstrate that it is unsafe in order to disapprove the

action H.1(b).

Enforcement. 10 CFR 55.59, Requalification, requires, in part, that facility licensees

shall pass a comprehensive requalification written exam and operating test to include a

sample of items from 55.45. Among this sample is the ability to demonstrate the

knowledge of the emergency plan for the facility and the ability by the senior operator to

decide whether the plan should be executed and the duties under the plan assigned.

Contrary to the above, during the calendar year of 2009 the licensee engaged in an

- 11 - Enclosure 2

activity that compromised the ability to evaluate three senior operators according to

10 CFR 55.59 (a)(2)(ii). Specifically, three senior operators were not evaluated in the

senior operator position during scenarios and instead were evaluated in the reactor

operator position for which they normally stand. This resulted in three senior operators

standing watch in the senior operator position without properly being evaluated in the

annual operating test. The inspectors determined that there were no actual safety

consequences due to the three senior operators standing watch without being properly

evaluated. Because this finding is of very low safety significance and has been entered

into the licensees corrective action program as CR-CNS-2010-09350, this violation is

being treated as a noncited violation consistent with Section 2.3.2 of the NRC

Enforcement Policy: NCV 05000298/2011002-01, Failure to Properly Evaluate License

Holders during Annual Operating Test

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

• March 8, 2011, Review of maintenance rule 10 CFR 50.65(a)(1) status systems

• March 8, 2011, Review of maintenance rule 10 CFR 50.65(a)(3) assessment;

Cooper Nuclear Station missed 24 month assessment

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

- 12 - Enclosure 2

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of two quarterly maintenance effectiveness

samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and

safety-related equipment listed below to verify that the appropriate risk assessments

were performed prior to removing equipment for work:

• January 26, 2011, Work in the switchyard with heavy equipment

• February 17, 2011, Work in the switchyard with heavy equipment during high

pressure coolant injection system maintenance Yellow risk window

• March 3, 2011, Review of actions to correct noncited violation 05000298/2010005-02, Failure to Assess and Manage Risk for Electrical

Switchyard Impacting Maintenance

• March 3, 2011, Steam exclusion boundary door maintenance activities

• March 8, 2011, Work in the switchyard with a crane in proximity of the main

generator 345kV output line and other first quarter work in the switchyard

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

- 13 - Enclosure 2

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five maintenance risk assessments inspection

samples as defined in Inspection Procedure 71111.13-05.

b. Findings

Introduction. The inspectors identified a Green cited violation of 10 CFR 50.65(a)(4),

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants, for the failure of work control and operations personnel to adequately assess

and manage the increase in risk associated with maintenance activities. Specifically, on

February 17, 2011, work control and operations personnel failed to adequately assess

and manage the increase in risk associated with maintenance activities involving the use

heavy equipment in or near the electrical switchyard and offsite power components.

Description. During plant status activities on February 17, 2011, inspectors noticed

heavy equipment work in the switchyard. The work involved a 100 ton crane, a small

crane, service trucks, oil tankers, semi tractors and a vacuum trailer. The inspectors

questioned whether these maintenance activities, that could increase the likelihood of

initiating events, were considered in the stations on-line risk assessment. The

inspectors determined that the risk assessment was inadequate in that it had not

assessed all initiating events and the activity was not included in the overall on-line plant

risk.

The inspectors were aware that the plant was in a planned elevated (Yellow) risk window

due to ongoing maintenance of the high pressure coolant injection pump. The

inspectors were also aware that past switchyard work had been performed with

inadequate risk assessments indicating a deficiency in the licensees ability to blend

qualitative and quantitative risk assessments. The inspectors contacted the control

room staff to obtain a copy of the risk assessment for this work and discuss the work

being performed during the Yellow risk window. The inspectors reviewed work

order 4786633 and noted that the risk assessment only evaluated a loss of offsite power

and no other initiating events were considered. The switchyard risk assessment

concluded the work was medium risk and did not evaluate that risk against the Yellow

probabilistic risk assessment risk window in progress for the high pressure coolant

injection pump work during the switchyard work. The control room stopped work in the

switchyard yard until the condition could be resolved and initiated CR-CNS-2011-01439.

The inspectors reviewed the requirements of Administrative Procedure 0.49, Schedule

Risk Assessment, Revision 24 and noted no requirement to review the list of initiating

events for any significant potential of work to increase risk to the many possible initiating

events other than a loss of offsite power.

- 14 - Enclosure 2

The inspectors had noted several previous failures to perform a qualitative risk

assessments in accordance with 10 CFR 50.65(a)(4) for work in the switchyard and

transformer yard. Three weeks earlier the inspectors noted heavy equipment work in the

switchyard. A review of work orders 4740890, 4806573 and 4809054 found that the

licensee had not identified any risk associated with this work. The station was in a

normal Green risk window and when inspectors walked down the activities they found no

risk mitigation actions were being taken for the work. The control room initiated

CR-CNS-2011-00749 for this improper risk characterization of non-routine switchyard

activities.

On December 7, 2010, while the plant was in a Yellow risk configuration due to

maintenance activities on emergency diesel generator number two, the inspectors

observed transmission personnel using a crane in the electrical switchyard. The

inspectors determined that the work was being performed without an assessment that

considered the increase in risk due to potential initiating events, and the licensee had not

assessed the work to be performed coincident with the emergency diesel generator

Yellow probabilistic assessment risk window. This violation of 10 CFR 50.65(a)(4) was

documented in Inspection Report 05000298/2010005 as noncited violation,

NCV 05000298/2010005-02, Failure to Assess and Manage Risk for Electrical

Switchyard Impacting Maintenance. In response, the licensee issued Revision 0 of the

resulting apparent cause evaluation, CR-CNS-2010-09146, on January 5, 2011. This

revision stated, that an increase in risk did not actually occur and the work activities

would not have challenged CNS with a loss of offsite power initiating event. As a result,

no actions to restore compliance were implemented. Following inspectors Revision 0

comments, Revision 1 of the CR-CNS-2010-09146 apparent cause evaluation was

issued January 10, 2011, that has corrective actions to revise the station risk

management procedures to perform qualitative risk assessments of non-routine

switchyard work that considers the increase in risk to all reasonable initiating events.

The evaluation also identified that two similar noncited violations in 2008 and 2009 for

failure to adequately assess risk for work near the transformer yard only addressed

implementation of additional mitigation actions They did not address the lack of

qualitative risk assessments. The 2008 violation is documented as

NCV 05000298/2008005-02, "Failure to Assess and Manage the Risk of Heavy

Equipment Operations. On November 26, 2008, inspectors noticed heavy equipment

operating within a few feet of the 161 kV transmission line tower to the startup

transformer. The licensee was operating an excavator, a backhoe, a bulldozer and a

dump truck in the area. As part of this activity, the bulldozer had created a large pile of

concrete blocks, the base of which was only a few feet from the transmission tower. The

inspectors were aware that the plant was already in a planned Yellow risk window due to

ongoing maintenance activities that made diesel generator two unavailable. The

inspectors challenged the heavy equipment operators, who were unaware of the

importance of the transmission tower and had not received any specific instructions

regarding standoff distances or other specific precautions. The inspectors contacted the

control room staff, who were unaware of the ongoing heavy equipment operations in the

vicinity of the transmission tower. The control room subsequently stopped work on the

heavy haul road until diesel generator two had been returned to service.

- 15 - Enclosure 2

This violation was repeated in 2009 and documented as NCV 05000298/2009002-01,

"Repeat Failure to Assess and Manage the Risk of Heavy Equipment Operations. On

January 29, 2009, the licensee was in a Yellow risk configuration due to ongoing repairs

to diesel generator one. Inspectors questioned control room staff to determine if any

heavy equipment operations were anticipated in the vicinity of the transmission line

towers in the protected area during the elevated risk condition. The control room staff

expressed that no such operations were anticipated. Later that shift, the inspectors

noted a water drilling truck operating in the vicinity of the transmission towers. In

maneuvering the drilling truck to unload its contents, the driver pulled the truck to within

one foot of an unprotected leg of the 345 kV transmission tower that provides the first

support for the transmission lines coming from the unit main power transformers. The

inspectors alerted station personnel, who redirected the truck activity to an alternate

route away from the towers. The inspectors promptly informed the control room staff to

allow them to properly assess and manage the risk of the ongoing truck activity in the

vicinity of the transmission towers.

In response to these two issues the licensee implemented corrective actions to identify

equipment in need of protection and posted appropriate signage. No actions were

established to assess the increase in risk associated with maintenance activities.

Analysis. The performance deficiency associated with this finding involved the

licensees failure to assess and manage the risk of planned maintenance activities. This

finding is greater than minor because it affected the protection against external factors

attribute of the Initiating Events Cornerstone, and directly affected the cornerstone

objective to limit the likelihood of those events that upset plant stability and challenge

critical safety functions during shutdown as well as power operations. The inspectors

determined that Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and

Risk Management Significance Determination Process, could not be used due to the

licensees inability to quantify the increase in risk associated with the heavy equipment

activity in the switchyard. The inspectors therefore used Manual Chapter 0609,

Appendix M, Significance Determination Process Using Qualitative Criteria. The

inspectors performed a bounding qualitative evaluation and determined that the finding

was of very low safety significance because another qualified source of offsite power

(the emergency transformer) was unaffected by this performance deficiency and

provided sufficient remaining defense in depth in the event of a loss of offsite power.

This finding has a crosscutting aspect in the area of problem identification and resolution

associated with the corrective action program component because the licensee did not

take appropriate corrective actions to address safety issues and adverse trends in a

timely manner, commensurate with their safety significance and complexity P.1(d).

Enforcement. Title 10 CFR 50.65(a)(4), states in part, that before performing

maintenance activities, the licensee shall assess and manage the increase in risk that

may result from the proposed maintenance activities. Contrary to the above, from

November 26, 2008 through February 17, 2011 work control and operations personnel

failed to adequately assess and manage the increase in risk associated with

maintenance activities. Specifically, qualitative assessments of maintenance activities in

- 16 - Enclosure 2

or near the electrical switchyard and offsite power components were not included in the

on-line risk assessment. This finding was of very low safety significance and was

entered into the licensees corrective action program as condition

reports CR-CNS-2011-01439. Because the licensee failed to restore compliance with

NRC requirements within a reasonable time after November 26, 2008, this violation is

being treated as a cited violation, consistent with the NRC Enforcement Policy,

Section 2.3.2, which states, in part, that a cited violation will be considered if the licensee

fails to restore compliance within a reasonable time after a violation is identified:

VIO 05000298/2011002-02, "Failure to Assess and Manage Risk for Maintenance That

Could Impact Initiating Events."

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

• January 1, 2011, Control room steam exclusion door

• January 13, 2011, Residual heat removal valve RHR-101 failed post work test

• January 21, 2011, Diesel generator two lube oil heater leak operability review

• February 23, 2011, Residual heat removal service water pipe wall thinning

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that technical specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the technical specifications and Updated

Final Safety Analysis Report to the licensee personnels evaluations to determine

whether the components or systems were operable. Where compensatory measures

were required to maintain operability, the inspectors determined whether the measures

in place would function as intended and were properly controlled. The inspectors

determined, where appropriate, compliance with bounding limitations associated with the

evaluations. Additionally, the inspectors also reviewed a sampling of corrective action

documents to verify that the licensee was identifying and correcting any deficiencies

associated with operability evaluations. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of four operability evaluations inspection

sample(s) as defined in Inspection Procedure 71111.15-04

b. Findings

No findings were identified.

- 17 - Enclosure 2

1R18 Plant Modifications (71111.18)

.1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, The

inspectors reviewed the following temporary modification:

• February 21, 2011, Northwest torus hatch plug temporary removal

These activities constitute completion of one sample for temporary plant modifications as

defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed key parameters associated with energy needs, materials,

replacement components, timing, heat removal, control signals, equipment protection

from hazards, operations, flow paths, pressure boundary, ventilation boundary,

structural, process medium properties, licensing basis, and failure modes for the

permanent modification identified as supplemental diesel generator installation.

The inspectors verified that modification preparation, staging, and implementation did

not impair emergency/abnormal operating procedure actions, key safety functions, or

operator response to loss of key safety functions; postmodification testing will maintain

the plant in a safe configuration during testing by verifying that unintended system

interactions will not occur; systems, structures and components performance

characteristics still meet the design basis; the modification design assumptions were

appropriate; the modification test acceptance criteria will be met; and licensee personnel

identified and implemented appropriate corrective actions associated with permanent

plant modifications. Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of one sample for permanent plant modifications

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

- 18 - Enclosure 2

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

• January 13, 2011, Residual heat removal valve RHR-101 freeze seal postwork

test

• January 18, 2011, Residual heat removal system test including RHR-MO-25B

and RHR-MO-39B tests

• February 15, 2011, Core spray B event recorder repair

• March 8, 2011, Standby liquid control postwork test

• March 9, 2011, Fuel pool cooling system restoration following chemical

decontamination

• March 10, 2011, Fuel pool cooling bypass valve FPC-29 replaced with non-

throttle valve

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the Updated

Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and

various NRC generic communications to ensure that the test results adequately ensured

that the equipment met the licensing basis and design requirements. In addition, the

inspectors reviewed corrective action documents associated with postmaintenance tests

to determine whether the licensee was identifying problems and entering them in the

corrective action program and that the problems were being corrected commensurate

with their importance to safety. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of six postmaintenance testing inspection samples

as defined in Inspection Procedure 71111.19-05.

- 19 - Enclosure 2

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the RE-26

refueling outage, which commenced on March 13, 2011, to confirm that licensee

personnel had appropriately considered risk, industry experience, and previous site-

specific problems in developing and implementing a plan that assured maintenance of

defense-in-depth. During the refueling outage, the inspectors observed portions of the

shutdown and cooldown processes and monitored licensee controls over the outage

activities listed below.

• Configuration management, including maintenance of defense-in-depth, is

commensurate with the outage safety plan for key safety functions and

compliance with the applicable technical specifications when taking equipment

out of service.

• Clearance activities, including confirmation that tags were properly hung and

equipment appropriately configured to safely support the work or testing.

• Installation and configuration of reactor coolant pressure, level, and temperature

instruments to provide accurate indication, accounting for instrument error.

• Status and configuration of electrical systems to ensure that technical

specifications and outage safety-plan requirements were met, and controls over

switchyard activities.

• Monitoring of decay heat removal processes, systems, and components.

• Verification that outage work was not impacting the ability of the operators to

operate the spent fuel pool cooling system.

• Reactor water inventory controls, including flow paths, configurations, and

alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Maintenance of secondary containment as required by the technical

specifications.

• Refueling activities, including fuel handling and sipping to detect fuel assembly

leakage.

- 20 - Enclosure 2

• Licensee identification and resolution of problems related to refueling outage

activities.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one refueling outage and other outage

inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the

licensees failure to adequately implement Procedure 0.45, Foreign Material Exclusion

Program, Revision 33.

Description. On November 24, 2010, while performing reviews of the licensees

activities associated with the dry cask storage campaign, the inspectors noted that

condition reports CR-CNS-2010-6645, CR-CNS-2010-7355, and CR-CNS-2010-8940

detailed instances where foreign material had been found in a Zone 1 foreign material

exclusion area (areas which required the highest level of foreign material exclusion

controls), specifically the spent fuel pool. When the inspectors reviewed the applicable

sections of Station procedure 0.45 specific actions and documentation requirements

were noted for a loss of area integrity. Specifically, Attachment 10, Loss of Integrity

Actions and Notification Recovery Plan, was to be completed and attached to the

condition report. The inspectors noted that for the instances being reviewed these

attachments were not with the condition reports. The inspectors pointed this out to the

licensee who subsequently determined that the procedural requirements had not been

followed. This issue was entered into the licensees corrective action program as

condition report CR-CNS-2010-9173.

On December 30, 2010, while conducting a routine tour of the spent fuel floor the

inspectors noted work in the area of a dry fuel canister, which had been designated as a

zone 1 foreign material exclusion area, was not in accordance with station procedures.

Specifically, individuals working in the area were not appropriately implementing the

requirements of Procedure 0.45 because they were wearing jewelry in the area, and had

material in their pockets. The inspectors informed the licensee of this issue and it was

entered into the stations corrective action program as condition report CR-CNS-2010-

9678.

Based on these observations, and a concern with the implementation of the stations

foreign material exclusion program, the inspectors performed increased monitoring of

this program, including observations during the beginning of refueling outage RE-26.

Through increased observations in and around other Zone 1 foreign material exclusion

areas the inspectors noted eleven additional instances where licensee personnel failed

to appropriately implement procedural requirements associated with Zone 1 foreign

material exclusion controls. One of these instances, as stated below, actually resulted in

the loss of control of items that were inadvertently introduced into the reactor vessel.

- 21 - Enclosure 2

• March 19, 2011, during refueling activities, two ten foot pole sections, that were not

lanyarded as required by procedure, were dropped from the refuel platform onto the

reactor core. These items were immediately retrieved.

The inspectors concluded that not all of these examples of the licensees failure to follow

procedure 0.45, Foreign Material Exclusion Program, directly resulted in the

introduction of foreign material into a critical system. They were, however, indicative of a

programmatic issue associated with the licensees proper implementation of the foreign

material exclusion control program that if left uncorrected could become a more

significant issue.

Analysis. The failure of station personnel to follow Procedure 0.45, Foreign Material

Exclusion Program, when working in Zone 1 foreign material exclusion areas around

safety related equipment/areas, was a performance deficiency. The performance

deficiency was more than minor because it affected the human performance attribute of

the Barrier Integrity Cornerstone, and directly affected the cornerstone objective of

providing reasonable assurance that physical barriers protect the public from

radionuclide releases caused by accidents or events, and is therefore a finding.

Furthermore, station personnels continued failure to implement appropriate foreign

material exclusion controls could result in the introduction of foreign material into critical

areas, such as the spent fuel pool or the reactor cavity, which in turn could result in

degradation and adverse impacts on materials and systems associated with these

areas. Using Inspection Manual Chapter 0609, Significance Determination Process,

Phase 1 Worksheets (at power issues), and Manual Chapter 0609, Appendix G,

Shutdown Operations Significance Determination Process, Phase 1 guidance

(shutdown issues), this finding was determined to have a very low safety significance

because; the finding was only associated with the fuel barrier (at power), and did not

result in an increase in the likelihood of a loss of reactor coolant system inventory,

degrade the ability to add reactor coolant system inventory, or degrade the ability to

recover decay heat removal (shutdown). This finding had a crosscutting aspect in the

area of human performance associated with the work practices component, in that the

licensee failed to define and effectively communicate expectations regarding procedural

compliance and personnel follow procedures H.4(b).

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion

V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting

quality shall be prescribed by documented instructions, procedures or drawings, of a

type appropriate to the circumstances and shall be accomplished in accordance with

these instructions, procedures, or drawings. Contrary to the above, between November

24, 2010, and March 24, 2011, multiple occasions were identified where licensee

personnel failed to implement appropriate foreign material exclusion controls in areas

designated as Zone 1 foreign material exclusion areas as required by station Procedure

0.45. Because this finding is of very low safety significance and has been entered into

the licensees corrective action program as Condition Reports CR-CNS-2010-9173, CR-

CNS-2010-9678, CR-CNS-2011-2775 and CR-CNS-2011-3214, this violation is being

treated as a noncited violation, consistent with Section 2.3.2 of the NRC Enforcement

- 22 - Enclosure 2

Policy: NCV 05000298/2011002-03, Failure to Adequately Implement Foreign Material

Exclusion Controls.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, procedure

requirements, and technical specifications to ensure that the surveillance activities listed

below demonstrated that the systems, structures, and/or components tested were

capable of performing their intended safety functions. The inspectors either witnessed

or reviewed test data to verify that the significant surveillance test attributes were

adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

- 23 - Enclosure 2

• February 9, 2011, Diesel generator one monthly operability testing

• February 20, 2011, Reactor equipment cooling motor operated valve inservice

test

• February 28, 2011, Secondary containment isolation valve inservice test

• March 7, 2011, Diesel generator one operability test

• March 8, 2011, Standby liquid control pump inservice test

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five (2 routine, 2 inservice tests, and 1

containment isolation valve) surveillance testing inspection samples as defined in

Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on

February 9, 2011, which required emergency plan implementation by a licensee

operations crew. This evolution was planned to be evaluated and included in

performance indicator data regarding drill and exercise performance. The inspectors

observed event classification and notification activities performed by the crew. The

inspectors also attended the postevolution critique for the scenario. The focus of the

inspectors activities was to note any weaknesses and deficiencies in the crews

performance and ensure that the licensee evaluators noted the same issues and entered

them into the corrective action program. As part of the inspection, the inspectors

reviewed the scenario package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.06-05.

b. Findings

No findings were identified.

- 24 - Enclosure 2

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the second

quarter 2010 performance indicators for any obvious inconsistencies prior to its public

release in accordance with Inspection Manual Chapter 0608, Performance Indicator

Program.

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical

hours performance indicator for the period from the first quarter 2010 through the fourth

quarter 2010. To determine the accuracy of the performance indicator data reported

during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, issue

reports, event reports, and NRC integrated inspection reports for the period of

January 2010 through December 2010 to validate the accuracy of the submittals. The

inspectors also reviewed the licensees issue report database to determine if any

problems had been identified with the performance indicator data collected or

transmitted for this indicator and none were identified. Specific documents reviewed are

described in the attachment to this report.

These activities constitute completion of one unplanned scrams per 7000 critical hours

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

- 25 - Enclosure 2

.3 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000

critical hours performance indicator for the period from the first quarter 2010 through the

fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, issue

reports, maintenance rule records, event reports, and NRC integrated inspection reports

for the period of January 2010 through December 2010, to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the performance indicator data

collected or transmitted for this indicator and none were identified. Specific documents

reviewed are described in the attachment to this report.

These activities constitute completion of one unplanned transients per 7000 critical

hours sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical

Protection

4OA2 Identification and Resolution of Problems (71152)

.1 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

Introduction. The inspectors identified a Green noncited violation of 10 CFR 50

Appendix B, Criterion V, Instructions, Procedures and Drawings, regarding the

licensees failure to follow the requirements of Administrative Procedure 0.5, Conduct of

the Condition Reporting Process, and Administrative Procedure 0.5.CR, Condition

- 26 - Enclosure 2

Report Initiation, Review and Classification. Specifically, there are multiple examples

where licensee personnel failed to initiate condition reports or failed to initiate condition

reports in a timely manner, per the requirements of 0.5CR, Condition Report Initiation,

Review, And Classification, when problems are identified.

Description. During problem identification and resolution inspections and plant status

inspection activities performed in January and February of 2011 the inspectors

determined that condition reports had not been initiated to document newly-discovered

conditions adverse to quality.

The inspectors noted that Administrative Procedure 0.5, Conduct of the Condition

Report Process, Revision 67, provides overall direction on the conduct of the corrective

action program at Cooper Nuclear Station. Paragraph 7.1.3 provides the following

standard for condition report initiation: Employees and contractors are encouraged to

write condition reports for a broad range of problems. Problems reported must include,

but are not limited to, Adverse Conditions. The procedure goes on to define adverse

conditions as an event, defect, characteristic, state, or activity that prohibits or detracts

from safe, efficient nuclear plant operation or storage of spent nuclear fuel. Adverse

conditions include non-conformances, conditions adverse to quality, and plant reliability

concerns. Administrative Procedure 0.5.CR, Condition Report Initiation, Review and

Classification, provides additional instructions that, If a problem is identified, then a CR

should be initiated no later than the end of the current shift. The inspectors and the

licensees investigation by CR-CNS-2011-01239 have noted condition report initiation

examples affecting several departments including: Design Engineering, Engineering

Support, System Engineering, Columbus General Office (Records & Telecom),

Licensing, Maintenance, Operations, Strategic Initiatives/Projects, Training, Planning

Scheduling & Outages, Quality Assurance, Radiation Protection, and Security.

During baseline inspection activities the inspectors identified multiple adverse conditions

that did not have condition reports initiated until prompted by the inspectors. The

inspectors determined that the following examples met the licensees definition of an

adverse condition, and the condition reports should have been initiated by the end of

shift.

CR-CNS-2011-00544 was initiated January 20, 2011, for condition reports not generated

in accordance with Procedure 0.5CR requirements when issues were identified during

the inspectors January 12, 2011 post maintenance inspection of freeze seal work in the

residual heat removal heat exchanger room. These issues included adequacy of

restraints used on nitrogen dewars secured adjacent to the control rod drive

accumulators, the transient combustible conditions in the residual heat removal heat

exchanger room, overflow of liquid nitrogen on a safety related spring can, and

inspectors indentifying and stopping an escorted visitor from entering the residual heat

removal heat exchanger room without his escort. Followup review of the visitor issue

found that a licensee quality assurance inspector had noted and stopped the behavior of

allowing visitor craft from entering the residual heat removal heat exchanger room

without their escort the previous shift but had not yet issued a condition report on their

finding when the inspectors noted the same behavior. Six additional condition reports

- 27 - Enclosure 2

were subsequently originated associated with these issues to ensure effective corrective

actions were taken to prevent the risk of additional occurrences.

CR-CNS-2011-0110 was initiated February 7, 2011 following resident inspector

questions on licensee actions in response to an industry cyber security threat

operational experience. The inspector found that the licensee was aware of and had

taken measures to prevent the threat at Cooper Nuclear Station but had not documented

their review or actions in accordance with Procedure 0.5CR requirements.

CR-CNS-2011-01741 was initiated February 24, 2011, on follow up field observations of

the inspectors and licensee personnel for several programmatic and potential fire

protection issues in response to an inspectors February 16, 2011, field observations and

questions on hot work in the reactor building on the alternate decay heat removal

project. The inspectors had previously informed licensee personal that the original

condition report CR-CNS-2011-01413 failed to follow procedure 0.5CR requirements to,

have sufficient detail to provide a clear understanding of the condition.

CR-CNS-2011-01326 was initiated February 14, 2011, following several discussions

between the inspectors and the licensee following the December 27, 2010 inspection of

licensee work on the traversing in-core probe machine. During maintenance of this

equipment the licensee craft and engineering determined that a limit switch circuit board

had an unauthorized modification installed. The licensee initiated the proper

modification to document this condition that had existed since original installation.

However, until this was identified by the inspectors the licensee staff failed to understand

the procedure 0.5CR requirements to document nonconforming conditions to allow an

extent of condition review of the other two affected in-core machines to validate the

installed circuit configuration is adequate. In response, the licensee revised the previous

investigation by CR-CNS-2010-08310 to include this additional extent of condition review

action.

The inspectors reviewed the licensees evaluation of each condition and determined that

none of these conditions resulted in the inoperability of safety-related equipment.

The inspectors noted that similar violations had been documented in inspection reports05000298/2008005-04, Failure to Follow Procedure for Initiating Condition Reports,

and 05000298/2010002-01, Repeat Failure to Follow Procedure for Initiating Condition

Reports. The licensee initiated CR-CNS-2011-01239 on February 10, 2011, to

investigate failures to initiate condition reports in a timely manner. This investigation

reviewed approximately 39 condition reports on this issue from the years 2009, 2010

and 2011. The inspectors reviewed the corrective actions taken for noncited violations

2008005-04 and 2010002-01, and agreed with the licensees CR-CNS-2011-01239

investigation results that determined that there are weaknesses in the reinforcement of

the corrective action program expectations for condition report initiation. Past corrective

actions were taken to reinforce expectations but no actions were taken to make the

expectation reinforcements on a periodic basis. To address this concern the licensee is

implementing a corrective action to, Develop and implement a CAP [corrective action

program] Preventive Maintenance, type of process to provide periodic reinforcement

and monitoring of expectations for CR [condition report] initiation (to include standards

- 28 - Enclosure 2

for when a CR is needed as well as time limitation), CAP implementation, and CAP

quality. Ensure the process is institutionalized for sustainability.

The inspectors have determined that overall the licensees corrective action program is

effective. However, it does have a programmatic weakness associated with failures to

initiating condition reports. This programmatic weakness indicates that the failure is

more widespread than simple occasional human error. This programmatic weakness is

correctable by the licensees corrective action to institutionalize periodic reinforcement

and monitoring of condition report initiation. This is important to assure that conditions

adverse to quality do not go uncorrected and result in safety related equipment

degradation to occur unnoticed by licensee personnel.

Analysis. The performance deficiency associated with this finding involved the

licensees failure to initiate condition reports as required by Administrative Procedure

0.5.CR, Condition Report Initiation, Review and Classification. The performance

deficiency affected the equipment performance attribute of the Mitigating Systems

Cornerstone, and directly affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Although the examples mentioned above may be minor

violations, the inspectors used Section 2.10.F of the NRC Enforcement Manual to

determine that the performance deficiency was more than minor and is therefore a

finding because the NRC has indication that the minor violation had occurred repeatedly.

Using the Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, the inspectors determined that the finding has very low

safety significance because all of the items in the Table 4a mitigating systems

cornerstone checklist were answered in the negative. The finding has a crosscutting

aspect in the area of problem identification and resolution associated with the corrective

action program component, in that the licensee takes appropriate corrective actions to

address safety issues and adverse trends in a timely manner. Specifically, the licensee

failed to take appropriate corrective actions to address previously identified examples of

employees not initiating condition reports in response to conditions adverse to

quality P.1(d).

Enforcement. 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and

Drawings requires, in part, that activities affecting quality shall be accomplished in

accordance with procedures of a type appropriate to the circumstances. Administrative

Procedure 0.5CR, Conduct of the Condition Reporting Process, Revision 67, requires

that employees must initiate condition reports for adverse conditions no later than the

end of shift. Contrary to this requirement, from January 12, 2011 to February 24, 2011,

inspectors discovered multiple adverse conditions where the licensee had not initiated

condition reports as required by procedure. Because the finding is of very low safety

significance and has been entered into the licensees corrective action program as

CR-CNS-2011-01239, this violation is being treated as a noncited violation consistent

with Section 2.3.2 of the Enforcement Policy: NCV 05000298/2011002-04, "Repeat

Failure to Follow Procedure for Initiating Condition Reports.

- 29 - Enclosure 2

.2 In-depth Review of Operator Workarounds

a. Inspection Scope

The inspectors performed a review of control room deficiencies to ensure that the

licensee is identifying operator workaround problems at an appropriate threshold and

entering them in the corrective action program, and has proposed or implemented

appropriate corrective actions.

These activities constitute completion of one in-depth review of operator workarounds

sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings of significance were identified.

4OA3 Event Follow-up (71153)

.1 Unplanned entry into Limiting Condition for Operation 3.0.3 due to loss of both trains of

residual heat removal low pressure coolant injection function

a. Inspection Scope

On January 18, 2011, the inspectors responded to the control room when the licensee

determined that both trains of residual heat removal were inoperable with respect to the

low pressure coolant injection function, which resulted in the unplanned entry into

Technical Specification Limiting Condition for Operation 3.0.3. Subsequently, the

licensee was able to restore the B train of residual heat removal to an operable

condition and exit Technical Specification Limiting Condition for Operation 3.0.3.

Inspectors toured the control room during the event to verify stable plant conditions,

monitored the licensees actions to restore the B train of residual heat removal,

reviewed station logs, discussed the event with the operations and maintenance staff

and reviewed NUREG-1022, Event Reporting Guidelines, Revision 2, to ensure

licensee compliance.

b. Findings

Introduction. The inspectors identified a Severity Level IV noncited violation

of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power

Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

following discovery of an event meeting the reportability criteria as specified.

Description. On January 18, 2011, at 2:30 p.m. the licensee made the B train of residual

heat removal inoperable for scheduled maintenance. Subsequently, at 4:30 p.m. while

performing a panel walk down, an operator noted that the open position indicating light

for the A reactor recirculation pump discharge valve, RR-MOV-53A, was blown. Further

investigation by maintenance team determined that the control power circuit for the valve

was deenergized.

- 30 - Enclosure 2

Valve RR-MOV-53A must close at a specified reactor pressure to allow the A train of

residual heat removal to inject to the core during a loss of coolant accident involving

reactor recirculation loop A. The deenergized control power circuit rendered the A train

of residual heat removal inoperable for low pressure coolant injection. As such, at

5:31 p.m. operators declared the A train of residual heat removal inoperable. As a

result, both trains of residual heat removal were inoperable, and incapable of performing

their system specified safety function of residual heat removal. Operators entered

Technical Specification Limiting Condition for Operation 3.0.3, and commenced

preparations for a plant shut down.

Subsequent troubleshooting found a failed light socket that had caused the fuses to

open. The fuses were replaced and the circuit tested satisfactorily. At 7:15 p.m.

residual heat removal Loop "A" low pressure coolant injection was declared operable

and Technical Specification Limiting Condition for Operation 3.0.3 was exited.

The licensee evaluated this event for immediate reportability against the criteria

specified in 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear

Power Reactors, NUREG 1022, Event Reporting Guidelines 50.72 and 50.73,

Revision 2, and station procedures 2.0.5, Reporting to NRC Operations Center,

Revision 38, and 2.0.11.1, Safety Function Determination Program, Revision 4.

Specifically, the licensee considered 10 CFR 50.72(b)(2)(i), "The initiation of any nuclear

plant shutdown required by the plant's Technical Specifications,"

and 10 CFR 50.72(b)(3)(v), any event or condition that could have prevented the

fulfillment of the safety function of structures or systems that are needed to; A) Shut

down the reactor and maintain it in a safe shutdown condition; B) Remove residual heat;

C) Control the release of radioactive material, or D) Mitigate the consequences of an

accident, as the applicable reportability criteria.

Through their review the licensee determined that the overall decay heat removal safety

function was maintained if three low pressure emergency core cooling system/spray

pumps remained operable/available. The licensee determined that both core spray

pumps A and B were operable and residual heat removal pump D was available (the

pump had an available injection path) at the time of this event. Therefore the licensees

determination was that this event was not reportable under 10 CFR 50.72(b)(3)(v)

because the overall safety function of residual heat removal had been maintained. The

licensee also determined that this event was not reportable under 10 CFR 50.72(b)(2)(i)

since negative reactivity had not been added to the core.

On January 19, 2011, the inspectors reviewed licensees reportability evaluations. The

inspectors questioned the rational used for evaluating reportability

under 10 CFR 50.72(b)(3)(v). Inspectors noted that the apparent intent of this reporting

criteria as described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73,

Revision 2, Section 3.2.7, was to cover an event or condition where structures,

components, or trains of a safety system could have failed to perform their intended

safety function as described in the plant safety analysis. Consultation with the Office of

Nuclear Reactor Regulation determined that this was the intent of the criteria. While the

- 31 - Enclosure 2

licensee was correct that the overall decay heat removal function was maintained this

did not meet the intent of the safety system functional failure reportability to report the

failure of the residual heat removal system to perform all designed safety functions. As

such, the inspectors determined that the licensee had failed to make a nonemergency

8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report as required by 10 CFR 50.72(b)(3)(v).

The inspectors informed the licensee of their concern, and the licensee entered this

issue into their corrective action program as Condition Report CR-CNS-2011-0618.

Subsequently, the licensee made a late notification to the Operations Center on

January 21, 2011.

Analysis. The failure to make an applicable non-emergency 8-hour event notification

report within the required time frame was determined to be a performance deficiency.

The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined

that traditional enforcement was applicable to this issue because the NRC's regulatory

ability was affected. Specifically, the NRC relies on licensees to identify and report

conditions or events meeting the criteria specified in regulations in order to perform its

regulatory function; and when this is not done, the regulatory function is impacted. The

inspectors determined that this finding was not suitable for evaluation using the

significance determination process, and as such, was evaluated in accordance with the

NRC Enforcement Policy. The finding was reviewed by NRC management and because

the violation was determined to be of very low safety significance, was not repetitive or

willful, and was entered into the corrective action program, this violation is being treated

as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy.

This finding had a crosscutting aspect in the area of human performance associated with

the decision making component, in that, the licensee failed to use conservative

assumptions in their decision making H.1(b).

Enforcement. Title 10 CFR 50.72, Immediate Notification Requirements for Operating

Nuclear Power Reactors, requires, in part, that the licensee shall notify the NRC

Operations Center within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of a non-emergency event described in

paragraph (b)(3)(v). Paragraph (b)(3)(v) of 10 CFR 50.72 requires, in part, that

licensees report any event or condition that could have prevented the fulfillment of the

safety function of structures or systems that are needed to:

• Shut down the reactor and maintain it in a safe shutdown condition

• Remove residual heat

• Control the release of radioactive material

• Mitigate the consequences of an accident

Contrary to the above, on January 18, 2011, the licensee failed to notify the NRC

Operations Center within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the discovery of an event or condition that could

have prevented the fulfillment of the safety function. This finding was determined to be

applicable to traditional enforcement because the failure to report conditions or events

meeting the criteria specified in regulations affects the NRCs regulatory ability. The

finding was evaluated in accordance with the NRC's Enforcement Policy. The finding

- 32 - Enclosure 2

was reviewed by NRC management and because the violation was of very low safety

significance, was not repetitive or willful, and was entered into the corrective action

program, this violation is being treated as a Severity Level IV noncited violation,

consistent with the NRC Enforcement Policy: NCV 05000298/2011002-05, Failure to

Notify the NRC within Eight Hours of a Nonemergency Event.

.2 (Closed) LER 050002982010003, Low Voltage on Emergency Transformer Causes

Loss of Safety Function

On August 24, 2010, a low voltage condition occurred on the offsite power supply to the

emergency station service transformer during planned maintenance on the station

startup service transformer. Subsequently, emergency station service transformer

secondary voltage dropped below the level where essential 4160 volt alternating current

buses will automatically load onto the emergency station service transformer. Control

room operators declared the emergency station service transformer inoperable and

entered the Technical Specification limiting condition for operation condition for two

offsite circuits inoperable. After two minutes, emergency station service transformer

secondary voltage was restored to the proper level and the control room operators

returned the emergency station service transformer to operable status. The cause of

this event was the licensees review of a revised switching order, associated with

planned maintenance on the station startup service transformer, was inadequate.

Specifically, the low voltage condition had occurred due to a change in the component

switching order, and that the station had failed to recognize this change and its potential

to cause the low voltage condition, during their review of the switching order. The

licensee event report was reviewed by the inspectors. Inspectors determined that a

violation had occurred and this issue was documented as NCV 05000298/2010005-03.

This licensee event report is closed.

4OA6 Meetings

Exit Meeting Summary

On December 2, 2010, the inspectors discussed the results of the licensed operator

requalification program inspection with Mr. Art Zaremba, Director of Nuclear Safety, and other

members of the licensee's staff. The lead inspector obtained the final biennial examination

results and telephonically exited with Mr. Art Zaremba, Director of Nuclear Safety, on

January 11, 2011. The licensee representatives acknowledged the finding presented. The

inspectors asked the licensee whether any materials examined during the inspection should be

considered proprietary. No proprietary information was identified.

On March 29, 2011, the resident inspectors presented the inspection results to B. OGrady, and

other members of the licensee staff. The licensee acknowledged the issues presented. The

inspector asked the licensee whether any materials examined during the inspection should be

considered proprietary. No proprietary information was identified.

- 33 - Enclosure 2

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and

is a violation of NRC requirements which meet the criteria of Section 2.3.2 of the NRC

Enforcement Policy for being dispositioned as noncited violations.

• 10 CFR 50.65(a)(3) states, in part, that performance and condition monitoring activities

and associated goals and preventive maintenance activities shall be evaluated at least

every refueling cycle provided the interval between evaluations does not exceed

24 months. Contrary to the above, as of August 31, 2010, the licensee had not

completed the (a)(3) assessment in the 24 months since the last assessment period

ended August 2008. When a licensee self assessment determined on February 3, 2011

that they had failed to perform the assessment, Condition Report CR 2011-01003 was

initiated to track completed the assessment and revise the controlling procedure to

prevent recurrence of this condition. The inspectors determined that this issue was of

very low safety significance and no degraded performance or condition of associated

structure, system, and components functions within the scope of the maintenance rule,

resulted from the performance deficiency.

- 34 - Enclosure 2

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Austin, Manager, System Engineering

T. Barker, Manager, Quality Assurance

M. Bakker, Cognizant Switchyard Engineer

J. Bebb, Manager, Security

N. Beger, Work Control Supervisor

J. Dedic, Shift Manager

L. Dewhirst, Manager, Corrective Action and Assessments

J. Flaherty, Licensing Engineer

B. Gilbert, Operations Training Supervisor

D. Goodman, Assistant Operations Manager

T. Hottovy, Manager, Engineering Support

M. Joe, Operations Training Supervisor

J. Long, Shift Manager

S. Nelson, Engineer, Risk Management Supervisor

S. Norris, Work Control Manager

R. Penfield, Operations Manager

D. Sealock, Training Manager

K. Sutton, Manager, Nuclear Engineering Department

D. VanDerKamp, Licensing Manager

D. Werner, Operations Training Superintendent

D. Willis, Plant Manager

A. Zaremba, Director of Nuclear Safety Assurance

NRC Personnel

J. Josey, Senior Resident Inspector

M. Chambers, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Failure to Assess and Manage Risk for Maintenance That

05000298-2011002-02 VIO

Could Impact Initiating Events (Section 1R13)

Opened and Closed

Failure to Properly Evaluate All Senior Operator License

05000298-2011002-01 NCV

Holders during Annual Operating Test (Section 1R11)

Failure to Adequately Implement Foreign Material Exclusion

05000298-2011002-03 NCV

Controls. (Section 1R20)

Repeat Failure to Follow Procedure for Initiating Condition

05000298-2011002-04 NCV

Reports (Section 4OA2)

A-1 Attachment

Failure to Notify the NRC within Eight Hours of a

05000298-2011002-05 NCV

Nonemergency Event (Section 4OA3)

Closed

Failure to Update Flood Protection for Safety Related

05000298-2010005-06 URI

Buildings (Section 1R01)

Low Voltage on Emergency Transformer Causes Loss of

05000298-2010-003-00 LER

Safety Function (Section 4OA3)

LIST OF DOCUMENTS REVIEWED

Section 1RO1: Adverse Weather Protection

CALCULATIONS

NUMBER TITLE REVISION

NEDC 10-063 Probable Maximum Flood Hydraulic Evaluation 0

NEDC 10-073 Evaluation of External Flood Barriers 0

PROCEDURES

NUMBER TITLE REVISION

2.5.1.6 Operations Procedure, Radwaste Low Conductivity Liquid 41

Waste Sample Tank Fluid Transfer

2.5.2.3 Operations Procedure, Radwaste High Conductivity Liquid 50

Waste Floor Drain Sample Tank Fluid Transfer

5.1FLOOD Engineering Procedure, Emergency Procedure: Flood 9

7.0.11 Maintenance Procedure, Flood Control Barriers 10

7.0.11 Maintenance Procedure, Flood Control Barriers 11

CONDITION REPORT

CR-CNS-2010-02050 CR-CNS-2010-02869 CR-CNS-2010-04281 CR-CNS-2010-04394

CR-CNS-2010-04509 CR-CNS-2010-04628 CR-CNS-2010-04679 CR-CNS-2010-04718

CR-CNS-2010-04913 CR-CNS-2010-05149 CR-CNS-2010-05608 CR-CNS-2010-05613

CR-CNS-2010-08961 CR-CNS-2010-4620 CR-CNS-2011-0062 CR-CNS-2011-01688

CR-CNS-2011-01689 CR-CNS-2011-01690

A-2 Attachment

Section 1RO5: Fire Protection

MISCELLANEOUS DOCUMENTS

NUMBER TITLE

11-0016 Transient Combustible Evaluation Permit, Attachment 4

11-0016 Transient Combustible Evaluation Permit, Attachment 4

11-0023 Transient Combustible Evaluation Permit, Attachment 4

11-0026 Transient Combustible Evaluation Permit, Attachment 4

CONDITION REPORT

CR-CNS-2011-01413 CR-CNS-2011-01737 CR-CNS-2011-01741

WORK ORDER 4790368

Section 1RO6: Flood Protection Measures

CALCULATIONS

NUMBER TITLE DATE

NEDC 91-24 Maximum Flooding in the NE Quad (HELB) June 12,

1991

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

2038 Flow Diagram Reactor Bldg Floor & Roof Drain Systems SH1 N53

2182 Reactor Bldg Floor Drains WO2520 DWG N03

2709-23 FDR-2 Radioactive Floor Drains Reactor Bldg N01

2709-31 FDR-2 Radioactive Floor Drains Reactor Bldg N01

2709-41 FDR-2 Radioactive Floor Drains Reactor Bldg N01

2709-50 FDR-2 Radioactive Floor Drains Reactor Bldg N01

CONDITION REPORT

CR-CNS-2008-06903

A-3 Attachment

Section 1R11: Licensed Operator Requalification Program

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

2009/2010 Sample Plan

Simulator Stability/Accuracy Test December 7,

2009

Simulator Transient 1,5 and 8 November

2009

2009-002 LER December

30, 2009

2009-003 LER January 4,

2010

4.1 Sim. Desk Guide, Simulator Performance Testing 6

INT0231001 Ops Shutdown Risk Management 19

SDR-666 Simulator Deficiency Report June 20,

2007

SKL012-06-01 OPS Simulator Introduction 151

SKL034-10-94 In-plant JPM 2

SKL0374-22-01 Simulator JPM 1

SKL051-51-179 Scenario Guide 1

SKL052-52-83 Scenario (ATWS) 3

SKL052-52-87 Scenario (LOCA) 4

SKL054-01-31 Loss of Start Up Transformer, Loss of Shutdown Cooling, 4

Earthquake, sap/bet #35826

SWR-10771302 Simulator Work Package

PROCEDURES

NUMBER TITLE REVISION

OTP803 Development of Operations Training JPMs 4

OTP804 Requalification Scenario Exercise Guide Development 19

OTP805 Licensed Operator Requalification Biennial Written Exam 12

OTP806 Conduct of Simulator Training and Evaluation 16

A-4 Attachment

PROCEDURES

NUMBER TITLE REVISION

OTP808 Open Reference Examination Test Item Development 1

OTP809 Operator Requalification Examination Administration 16

OTP810 Operations Department Examination Security 11

OTP812 Conduct of Operator Oral Boards 12

OTP813 Annual Operating Requal. Exam Development and Admin 2

CONDITION REPORT

CR-CNS-2010-07850 CR-CNS-2010-09350

Section 1R12: Maintenance Effectiveness

CONDITION REPORT

CR-CNS-2010-05587 CR-CNS-2010-05779 CR-CNS-2011-1003

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

PROCEDURE

NUMBER TITLE REVISION

0-CNS-52 Administrative Procedure, Control of Switchyard and 22

Transformer Yard Activities at CNS

0.49 Administrative Procedure, Schedule Risk Assessment 24

CONDITION REPORT

CR-CNS-2008-08645 CR-CNS-2009-01465 CR-CNS-2009-03714 CR-CNS-2010-09146

CR-CNS-2011-00749 CR-CNS-2011-01369 CR-CNS-2011-01439

WORK ORDER 4716328 4740703 4740890 4784034 4786633

4806573 4809054 4815917

A-5 Attachment

Section 1R15: Operability Evaluations

PROCEDURES

NUMBER TITLE REVISION

0.16 Administrative Procedure, Control of Doors 42

CONDITION REPORT

CR-CNS-2010-00311 CR-CNS-2011-00438 CR-CNS-2011-0684 CR-CNS-2011-1619

CR-CNS-2011-1691

Section 1R18: Plant Modifications

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE

CED 6029940 Supplemental Diesel Generator May 25, 2010

EE-01-026 Northwest torus hatch plug temporary removal

Section 1R19: Postmaintenance Testing

PROCEDURES

NUMBER TITLE REVISION

6.2RHR.201 Surveillance Procedure, RHR Power Operated Valve 22

Operability Test (IST)(Div 2), performed 1/18/11 5:28 p.m.

6.2RHR.201 Surveillance Procedure, RHR Power Operated Valve 22

Operability Test (IST)(Div 2), performed 1/19/11 2:30 a.m.

CONDITION REPORT

CR-CNS-2011-00311 CR-CNS-2011-2241

WORK ORDER 4664218 4665167 4706519 4731168 4753298

4767972 4790368

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION

6.1DG.101 Surveillance Procedure, Diesel Generator 31 Day 67

A-6 Attachment

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION

Operability Test (IST)(Div 1)

WORK ORDER 4754071

Section 1EP6: Drill Evaluation

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

SKL054-01-31 Loss of Start Up Transformer, Loss of Shutdown Cooling, 4

Earthquake, sap/bet #35826

CONDITION REPORT

CR-CNS-2011-01200

Section 4OA2: Identification and Resolution of Problems

MISCELLANEOUS DOCUMENTS

TITLE DATE

Control Room Deficiency Tags March 6,

2011

Open Operator Challenges March 1,

2011

PROCEDURE

NUMBER TITLE REVISION

2.0.12 Conduct of Operations Procedure, Operator Challenges 9

CONDITION REPORT

CR-CNS-2011-0219

Section 4OA3: Event Follow-Up

CONDITION REPORT

CR-CNS-2011-00461 CR-CNS-2011-00618

A-7 Attachment