NLS2013041, 30-Day Response Regarding Substantive Cross-Cutting Issues Cooper Nuclear Station

30-Day Response Regarding Substantive Cross-Cutting Issues Cooper Nuclear Station

ML13105A135
Person / Time
Site:	Cooper
Issue date:	04/01/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2013041, IR-12-801
Download: ML13105A135 (3)

Text

N Nebraska Public Power District Always there when you need us NLS2013041 April 1, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001

Subject:

30-Day Response Regarding Substantive Cross-Cutting Issues Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter from the U.S. Nuclear Regulatory Commission to Oscar A. Limpias, Nebraska Public Power District, dated March 4, 2013, "Annual Assessment Letter for Cooper Nuclear Station (Report 05000298/2012801)"

Dear Sir or Madam:

As requested in the above reference letter, the purpose of this letter is for Nebraska Public Power District (NPPD) to provide the Nuclear Regulatory Commission (NRC) with NPPD's 30-day written response.

In the reference letter, the NRC determined that the performance of Cooper Nuclear Station (CNS) in the most recent assessment period was in the Licensee Response Column of the NRC's Reactor Oversight Process Action Matrix. However, a Substantive Cross-Cutting Issue (SCCI) was identified in the P. 1(c) area associated with the corrective action component related to the thoroughness of problem evaluations such that resolutions address causes and extent of condition. An SCCI was also identified in the H.l(b) area associated with the decision-making component related to conservative assumptions.

Additionally, an SCCI was identified in the H.2(c) area associated with the resources component related to design, procedures, and labeling.

As such, the NRC requested a 30-day written response detailing planned corrective actions for each of the open SCCIs. In addition, the written response was to include a schedule outlining when CNS would be ready for inspection of the corrective actions for each of the open SCCIs.

In an effort to improve performance at CNS, NPPD has created and is implementing an improvement plan that addresses five key areas. The areas identified in the plan include Organizational Effectiveness and the Corrective Action Program (CAP). This plan will address several of the performance areas identified in the SCCIs with a specific focus on CAP implementation and execution.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com k IL'?

NLS2013041 Page 2 of 2 Additionally, NPPD has determined that a root cause evaluation is required to identify corrective actions needed to address each of the SCCIs. Actions identified as a result of this root cause evaluation will be added to the current improvement plan, as necessary, and tracked in CAP. Within 30 days following completion of the root cause evaluation, NPPD will submit details regarding additional corrective actions to address the open SCCIs and also a schedule outlining readiness for inspection of the corrective actions to the NRC.

This letter contains a new regulatory commitment which is identified in the Attachment.

Should you have any questions or require additional information, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

Sincere l ,

Os ar . Limpias Vice President - Nuclear and Chief Nuclear Officer

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Attachment:

List of Regulatory Commitments cc: Regional Administrator, w/attachment USNRC Region IV Cooper Project Manager, w/attachment USNRC NRR Project Directorate IV-1 Senior Resident Inspector, w/attachment USNRC - CNS NPG Distribution, w/attachment CNS Records, w/attachment

NLS2013041 Attachment Page 1 of 1 LIST OF REGULATORY COMMITMENTS Correspondence Number: NLS2013041 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED COMMITMENT / (Check One) COMPLETION COMMITMENT NO. ONE- DATE TIME CONTINUING (If Required)

ACTION COMPLIANCE NPPD will submit details regarding X Within 30 days additional corrective actions to following address the open SCCIs and a completion of the schedule outlining readiness for associated root inspection of the corrective actions to the NRC. cause analysis.

NLS2013041-01