ML12243A437
| ML12243A437 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/04/2012 |
| From: | Vincent Gaddy NRC/RGN-IV/DRP/RPB-C |
| To: | O'Grady B Nebraska Public Power District (NPPD) |
| Gaddy V | |
| References | |
| IR-12-006 | |
| Download: ML12243A437 (6) | |
See also: IR 05000298/2012006
Text
September 4, 2012
Mr. Brian J. OGrady, Vice President-Nuclear
and Chief Nuclear Officer
Nebraska Public Power
Cooper Nuclear Station
72676 648A Avenue
Brownville, NE 68321
SUBJECT:
MID-CYCLE ASSESSMENT LETTER FOR COOPER NUCLEAR STATION
(REPORT 05000298/2012006)
Dear Mr. OGrady:
On August 15, 2012, the NRC completed its mid-cycle performance review of Cooper Nuclear
Station. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to
inspection results and enforcement actions from July 1, 2011, through June 30, 2012. This
letter informs you of the NRCs assessment of your facility during this period and its plans for
future inspections at your facility. The security inspection plan will be sent via separate
correspondence.
The NRC determined the performance at Cooper Nuclear Station during the most recent quarter
was within the Licensee Response Column of the NRC=s Reactor Oversight Process (ROP)
Action Matrix because all inspection findings had very low (i.e., green) safety significance, and
all PIs indicated that your performance was within the nominal, expected range (i.e., green).
Therefore, the NRC plans to conduct ROP baseline inspections at your facility.
The NRC identifies substantive cross-cutting issues to communicate a concern with the
licensees performance in a cross-cutting area and to encourage the licensee to take
appropriate action before more significant performance issues emerge. In our assessment
letter dated March 5, 2012, (ML120650243), the NRC opened a substantive cross-cutting issue
in the problem identification and resolution area associated with the corrective action
component related to the thoroughness of problem evaluations such that the resolutions
address causes and extent of condition P.1(c). Your staff determined that the primary cause
was a result of inadequate or inconsistent management oversight, and secondary causes were
1) control errors as a result of inadequate management oversight and follow-up on issues, and
2) organizational interface breakdowns as a result of inadequate organization-to-organization
performance in addressing issues.
During this assessment period, we noted there has not been sustainable improvement in this
area, as evidenced by the identification of 8 findings with this cross-cutting theme P1(c). As a
result, this substantive cross-cutting issue P.1(c) will remain open until your staff demonstrates
sustainable performance improvements as evidenced by effective implementation of an
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4511
B. OGrady
- 2 -
appropriate corrective action plan that results in no safety significant inspection finding and a
notable reduction in the overall number of inspection findings with the same common theme.
Because this is the second consecutive assessment letter documenting a substantive cross-
cutting issue with the same cross-cutting aspect, the NRC requests that you provide us a written
response that details your corrective actions to address this cross-cutting theme including
schedule, milestones, and performance monitoring metrics. The NRC will continue to monitor
your staffs effort and progress in addressing this theme and will inspect your response to this
theme after you notify us, in writing, of your readiness for inspection.
The NRC also identified a cross-cutting theme in the resources component of the human
performance area, in that the NRC identified four findings associated with procedures that were
not complete, accurate and up-to-date H.2(c). The NRC determined that a substantive cross-
cutting issue does not exist because the NRC does not have a concern with your staffs scope
of effort and progress in addressing the cross-cutting theme. Specifically, while there were four
inspection findings with this theme, we determined that this represented a recent performance
trend. Also, once you identified this theme, you placed it into your corrective action program
and are presently developing plans to address this theme. The NRC will continue to monitor
your staffs efforts and progress in addressing this theme until the theme criterion is no longer
met.
The NRC also identified a cross-cutting theme in the work practices component of the human
performance area, in that the NRC identified four findings associated with the failure to ensure
appropriate supervisory oversight of work activities to support nuclear safety H.4(c).
The NRC determined that a substantive cross-cutting issue does not exist because the NRC
does not have a concern with your staffs scope of effort and progress in addressing the
cross-cutting theme. Specifically, while there were four inspection findings with this theme, we
determined that this represented a recent performance trend. Also, once you identified this
theme, you placed it into your corrective action program and are presently developing plans to
address this theme. The NRC will continue to monitor your staffs efforts and progress in
addressing the theme until the theme criterion is no longer met.
In the current assessment period, the NRC again identified a cross-cutting theme in the
decision-making component of the human performance area, in that the NRC identified eight
findings associated with issues related to the use of conservative decision-making H.1(b).
The NRC determined that a substantive cross-cutting issue exists because the NRC has a
concern with your staffs scope of effort and progress in addressing this cross-cutting theme.
Specifically, this theme repeats a theme that was identified in the 2009 mid-cycle and
end-of-cycle assessment letters, declared a substantive cross-cutting issue in the 2010
end-of-cycle letter, reviewed in the 2011 mid-cycle letter, and closed in the 2011 end-of-cycle
letter. This theme again became apparent in the fourth quarter of the current assessment
period. On July 25, 2012, your staff initiated CR-CNS-2012-04267 to acknowledge this repeat
theme and is presently in the early stages of identifying corrective actions to again mitigate the
theme.
In recent years, you have implemented several corrective actions that were `intended to mitigate
this theme. Some have been successful, in the short-term, in mitigating the theme; however,
none has been sustainable in substantially mitigating this cross-cutting theme even though a
reasonable duration of time has passed for your corrective actions to show sustained progress.
The NRC will close this substantive cross-cutting issue when you demonstrate sustainable
performance improvement as evidenced by effective implementation of an appropriate
corrective action plan that results in no safety significant inspection findings and a notable
B. OGrady
- 3 -
reduction in the overall number of inspection findings with the same common theme. The NRC
plans to perform focused baseline inspections of this theme after you notify us in writing of your
readiness for inspection.
The enclosed inspection plan lists the inspections scheduled through December 31, 2013.
Routine inspections performed by resident inspectors are not included in the inspection plan.
In addition to the baseline inspections, consistent with the Agencys actions related to
Fukushima, the NRC will perform TI-187, Inspection of Near-Term Task Force
Recommendation 2.3 Flooding Walkdowns, and TI-188, Inspection of Near-Term Task Force
Recommendation 2.3 Seismic Walkdowns. The inspections listed during the last nine months
of the inspection plan are tentative and may be revised at the end-of-cycle performance review.
The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and
personnel availability issues. The NRC will contact you as soon as possible to discuss changes
to the inspection plan should circumstances warrant any changes. This inspection plan does
not include security-related inspections, which will be sent via separate, non-publicly available
correspondence.
In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Please contact me at 817-200-1144 with any questions you may have regarding this matter.
Sincerely,
/RA/
Vincent Gaddy, Chief
Reactor Projects Branch C
Division of Reactor Projects
Docket No:
50-298
License No:
Enclosure: Cooper Nuclear Station Inspection / Activity Plan
cc w/Enclosure: Electronic Distribution
B. OGrady
- 4 -
Electronic Distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
Acting DRP Deputy Director (Allen.Howe@nrc.gov)
Acting DRS Director (Thomas.Blount@nrc.gov)
Acting DRS Deputy Director (Patrick.Louden@nrc.gov)
Senior Resident Inspector (Jeff.Josey@nrc.gov)
Resident Inspector (Christopher.Henderson@nrc.gov)
CNS Administrative Assistant (Amy.Elam@nrc.gov)
Branch Chief / C (Vincent.Gaddy@nrc.gov)
Senior Project Engineer (Bob.Hagar@nrc.gov)
Project Engineer (Rayomond.Kumana@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Regional State Liaison Officer (Bill.Maier@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov)
Branch Chief, DRS/EB2 (Geoff.Miller@nrc.gov)
Branch Chief, DRS/PSB1 (Michael.Hay@nrc.gov)
Acting Branch Chief, DRS/PSB2 (James.Drake@nrc.gov)
Branch Chief, DRS/OB (Mark.Haire@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
Director, DIRS, NRR (Ho.Nieh@nrc.gov)
Deputy Director, DIRS NRR (John.Lubinski@nrc.gov)
Director, DORL, NRR (Michele.Evans@nrc.gov)
Deputy Director, DORL, NRR (Louis.Lund@nrc.gov)
Chief, PLB IV, DORL, NRR (Michael.Markey@nrc.gov)
NRR Project Manager (Lynnea.Wilkins@nrc.gov)
RIV/ETA: OEDO (Silas.Kennedy@nrc.gov)
RA Administrative Assistant (Lisa.Quayle@nrc.gov)
DRA Administrative Assistant (Anita.Tannenbaum@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
TSB Technical Assistant (Loretta.Williams@nrc.gov)
RidsNrrDirslpabResource@nrc.gov
ROPreports@nrc.gov
R:\\_Reactors\\Midcycle 2012\\CNS.docx
ADAMS: No Yes
SUNSI Review Complete
Reviewer Initials:VGG
Publicly Available
Non-Sensitive
Non-publicly Available
Sensitive
C:DRP/A
D:DRS
D:DRP
C:DRP/A
VGaddy
TBlount
KKennedy
VGaddy
/RA/
/RA/
/RA/
/RA/
8/20/12
8/20/12
8/28/12
8/29/12
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Page 1 of 2
08/29/2012
14:01:14
Report 22
Unit
Number
Planned Dates
Start End
Inspection Activity
Title
No. of Staff
on Site
Cooper
Inspection / Activity Plan
09/01/2012 - 12/31/2013
EXAM
- INITIAL OPERATOR EXAM
3
1
INITIAL EXAM - COOPER (08/2012)
X02489
09/17/2012
09/21/2012
1
INITIAL EXAM - COOPER (08/2012)
X02489
10/29/2012
11/02/2012
2515/182
- DEGRADATION UNDERGROUND PIPING (PHASE 1)
3
1
IP
Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping
2515/182
03/01/2012
06/30/2013
2515/187
- NTTF FLOODING WALKDOWNS
2
1
IP
Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns
2515/187
07/01/2012
12/31/2012
2515/188
- NTTF SEISMIC WALKDOWNS
2
1
IP
Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns
2515/188
07/06/2012
12/31/2012
PSP2-08
- INSERVICE INSPECTION
1
1
IP
Inservice Inspection Activities - BWR
7111108G
10/22/2012
11/02/2012
EB2-03
- POST-APPROVAL LICENSE RENEWAL (PHASE 1)
2
1
IP
Post-Approval Site Inspection for License Renewal
71003
10/29/2012
11/02/2012
RS13
- RADIATION SAFETY
2
1
IP
Radiological Hazard Assessment and Exposure Controls
11/05/2012
11/09/2012
1
IP
In-Plant Airborne Radioactivity Control and Mitigation
11/05/2012
11/09/2012
1
IP
Occupational Exposure Control Effectiveness
71151-OR01
11/05/2012
11/09/2012
1
IP
RETS/ODCM Radiological Effluent
71151-PR01
11/05/2012
11/09/2012
2515/188
- NTTF SEISMIC WALKDOWNS
2
1
IP
Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns
2515/188
01/01/2013
12/31/2013
2515/187
- NTTF FLOODING WALKDOWNS
2
1
IP
Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns
2515/187
07/01/2013
12/31/2013
EB1-17T
- 50.59 & PERM PLANT MOD
2
1
IP
Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
7111117T
02/25/2013
03/08/2013
1
IP
change/test/evaluations
7111117T-chng/tst
02/25/2013
03/08/2013
1
IP
evaluations
7111117T-evals
02/25/2013
03/08/2013
1
IP
permanent mods
7111117T-permmods
02/25/2013
03/08/2013
PI&R 52B
- BIENNIAL PI&R
4
1
IP
Problem Identification and Resolution
03/11/2013
03/29/2013
PSB2-RP
- RADIATION SAFETY
4
1
IP
Radiation Monitoring Instrumentation
04/29/2013
05/03/2013
1
IP
Radioactive Gaseous and Liquid Effluent Treatment
04/29/2013
05/03/2013
1
IP
Radiological Environmental Monitoring Program
04/29/2013
05/03/2013
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2
08/29/2012
14:01:14
Report 22
Unit
Number
Planned Dates
Start End
Inspection Activity
Title
No. of Staff
on Site
Cooper
Inspection / Activity Plan
09/01/2012 - 12/31/2013
PSB2-RP
- RADIATION SAFETY
4
1
IP
Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation
04/29/2013
05/03/2013
EP1
- BIENNIAL PROGRAM INSPECTION
1
1
IP
Alert and Notification System Testing
7111402
06/24/2013
06/28/2013
1
IP
Emergency Preparedness Organization Staffing and Augmentation System
7111403
06/24/2013
06/28/2013
1
IP
Correction of Emergency Preparedness Weaknesses and Deficiencies
7111405
06/24/2013
06/28/2013
EB2-05T
- TRIENNIAL FIRE PROTECTION INSPECTION
4
1
IP
Fire Protection [Triennial]
7111105T
08/12/2013
08/16/2013
1
IP
Fire Protection [Triennial]
7111105T
08/26/2013
08/30/2013
PSB2-RP
- RADIATION PROTECTION
2
1
IP
Radiological Hazard Assessment and Exposure Controls
08/05/2013
08/09/2013
1
IP
Occupational ALARA Planning and Controls
08/05/2013
08/09/2013
1
IP
Occupational Exposure Control Effectiveness
71151-OR01
08/05/2013
08/09/2013
1
IP
RETS/ODCM Radiological Effluent
71151-PR01
08/05/2013
08/09/2013
EB2-03
- POST-APPROVAL LICENSE RENEWAL
5
1
IP
Post-Approval Site Inspection for License Renewal
71003
10/07/2013
10/11/2013
1
IP
Post-Approval Site Inspection for License Renewal
71003
10/21/2013
10/25/2013
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.