ML13130A037

IR 05000298-13-009; March 11-28, 2013; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems and Notice of Violation

ML13130A037
Person / Time
Site:	Cooper
Issue date:	05/09/2013
From:	Ray Kellar Division of Reactor Safety IV
To:	Limpias O Nebraska Public Power District (NPPD)
References
EA-13-075 IR-13-009
Download: ML13130A037 (36)

See also: IR 05000298/2013009

Text

U N IT E D S TA TE S

N U C LE AR R E GU LA TOR Y C OM MI S S I ON

R E G IO N I V

1600 EAST LAMAR BLVD

AR L I NG TO N , TE X AS 7 60 1 1 - 4511

May 9, 2013

EA-13-075

Oscar A. Limpias, Vice President Nuclear and

Chief Nuclear Officer

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION STATION - NRC PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000298/2013009 AND NOTICE

OF VIOLATION

Dear Mr. Limpias:

On March 28, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem

Identification and Resolution biennial inspection at your Cooper Nuclear Station facility. The

enclosed inspection report documents the inspection results, which the inspection team

discussed on March 28, 2013, with you and your staff.

This inspection was an examination of activities conducted under your license as they relate to

problem identification and resolution and to compliance with the Commissions rules and

regulations and the conditions of your license. Within these areas, the inspection involved

examination of selected procedures and representative records, observations of activities, and

interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the

corrective action program and the overall performance related to identifying, evaluating, and

resolving problems at Cooper Nuclear Station was adequate to support nuclear safety. The

team noted that you and your staff have made improvements to the stations corrective action

programs, processes, and procedures since the NRCs previous biennial problem identification

and resolution inspection in June 2011.

The team observed that your staff generally identified problems and entered them into the

corrective action program at a low threshold. In most cases, your staff effectively prioritized and

evaluated problems commensurate with their safety significance, resulting in the identification of

appropriate corrective actions. However, the team noted weaknesses in some of the stations

evaluation processes, particularly in your staffs evaluations of the operability of degraded

structures, systems, and components important to safety, as described by the stations design-

basis documents, and the subsequent determinations of whether these degraded conditions

required reports to the NRC. The attached Notice of Violation and inspection report discuss

specific examples of these weaknesses.

O. Limpias -2-

Your staff generally implemented corrective actions timely, commensurate with the safety

significance of the problems they were designed to correct. Most corrective actions reviewed by

the team adequately addressed the causes of identified problems. Your staff appropriately

reviewed and applied lessons learned from industry operating experience. The stations audits

and self-assessments effectively identified problems and appropriate corrective actions, though

the team noted one instance where a problem common to several audits was not evaluated in

the aggregate. Finally, the team determined that your stations management maintains a

healthy safety-conscious work environment where employees feel free to raise nuclear safety

concerns without fear of retaliation.

The team identified one finding of very low safety significance (Green) during this inspection.

This finding involved a violation of NRC requirements. The violation was evaluated in

accordance with the NRC Enforcement Policy; it did not meet the criteria to be treated as a non-

cited violation. The current version of this Policy is available on the NRCs website at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. This 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 is cited in the Notice in accordance with

Section 2.3.2.a of the Enforcement Policy because after the violation was previously identified

as a non-cited violation, you failed to restore compliance within a reasonable time.

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 NRCs

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

necessary to ensure compliance with regulatory requirements.

Also based on the results of this inspection, the NRC has determined that a Severity Level IV

violation of NRC requirements occurred. This violation is being treated as a non-cited violation

(NCV), consistent with section 2.3.2.a of the NRCs Enforcement Policy.

If you contest either of these violations, you should provide a response within 30 days of the

date of this inspection report, with the basis for your denial, to the Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the

Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at

South Texas Project.

If you disagree with the cross-cutting aspect assigned to the finding, 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

Cooper Nuclear Station.

O. Limpias -3-

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

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief

Technical Support Branch

Division of Reactor Safety

Docket No.: 50-298

License No.: DPR-46

Enclosure:

1. Notice of Violation

2. Inspection Report 05000298/2013009

w/ Attachments

cc w/ encl: Electronic Distribution

O. Limpias -4-

DISTRIBUTION:

Regional Administrator (Art.Howell@nrc.gov)

Acting Deputy Regional Administrator (Robert.Lewis@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Michael.Scott@nrc.gov)

DRS Director (Tom.Blount@nrc.gov)

Acting DRS Deputy Director (Jeff.Clark@nrc.gov)

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

Resident Inspector (Chris.Henderson@nrc.gov)

Branch Chief, DRP/C (David.Proulx@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 (Ray.Kellar@nrc.gov)

Senior Reactor Inspector, DRS/TSB (Eric.Ruesch@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Doug.Huyck@nrc.gov)

S:\DRS\REPORTS\Reports Drafts\CNS 2013009 RP EAR DRAFT.docx ML13130A037

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials EAR

Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials EAR

DRP/PBC DRS/EB2 DRS/EB1 C:DRP/PBC ORA/ACES DRS/TSB C:DRS/TSB

CHenderson CSpeer JBraisted DProulx RBrowder EARuesch RLKellar

via e-mail via e-mail via e-mail RCH/for /RA/ Via e-mail /RA/

5/6/13 5/2/13 5/6/13 5/9/13 5/9/13 5/9/13 5/9/13

OFFICIAL RECORD COPY

NOTICE OF VIOLATION

Nebraska Public Power District Docket No: 50-298

Cooper Nuclear Station License No: DPR-46

EA-13-075

During an NRC Inspection conducted from March 11 through 28, 2013, a violation of NRC

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

listed below:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that

measures shall be established to assure that applicable regulatory requirements and the

design basis, as defined in 10 CFR 50.2 and as specified in the license application, for

those structures, systems, and components to which the appendix applies, are correctly

translated into specifications, drawings, procedures, and instructions.

Contrary to above, from May 10, 2012 through March 13, 2013, the licensee failed to

establish measures to assure that applicable regulatory requirements and design basis,

as defined in 10 CFR 50.2 and as specified in the license application, for components to

which 10 CFR 50 Appendix B applies, were correctly translated into specifications,

drawings, procedures, and instructions. Specifically, the licensee failed to assure that

the applicable design basis requirements associated with the standby liquid control

system test tank were correctly translated into plant procedures to ensure that the

standby liquid control system would be available following design basis seismic event.

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

Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District 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 (ATTN: Mr. Ray L. Kellar, P.E., Chief, Technical Support Branch,

Division of Reactor Safety, and a copy to the NRC Resident Inspector at Cooper Nuclear

Station 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 Notice of Violation EA 13-075," and should

include: (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 to avoid further violations, 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.

-1- Enclosure 1

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 website at www.nrc.gov/reading-rm/pdr.html or 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 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 basis 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).

Dated this 9th day of May, 2013.

-2-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-298

License: DPR-46

Report: 05000298/2013009

Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: 72676 648A Avenue

Brownville, Nebraska 68321

Dates: March 11-28, 2013

Team Leader: E. Ruesch, Senior Reactor Inspector

Inspectors: J. Braisted, Ph.D., Reactor Inspector

C. Henderson, Resident Inspector

C. Speer, Reactor Inspector

Approved By: R.L. Kellar, P.E., Chief

Technical Support Branch

Division of Reactor Safety

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000298/2013009; March 11-28, 2013; Cooper Nuclear Station, Biennial Baseline

Inspection of the Identification and Resolution of Problems

The team inspection was performed by one senior reactor inspector, two reactor inspectors, and

one resident inspector. One violation of Green safety significance and one non-cited violation of

Severity Level IV were identified during this inspection. The significance of most findings is

indicated by a color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,

Significance Determination Process. 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.

Identification and Resolution of Problems

The team reviewed approximately 220 condition reports, including associated work orders,

engineering evaluations, root and apparent cause evaluations, and other supporting

documentation. The purpose of this review, focused on documentation of higher-significance

issues, was to determine whether the licensee had properly identified, characterized, and

entered these issues into the corrective action program for evaluation and resolution. The team

reviewed a sample of system health reports, self-assessments, trending reports and metrics,

and various other documents related to the corrective action program. The team concluded that

the licensee maintained a corrective action program in which issues were generally identified at

an appropriately low threshold. Issues entered into the corrective action program were

appropriately evaluated and timely addressed, commensurate with their safety significance.

Corrective actions were generally effective, addressing the causes and extents of condition of

problems.

The team determined that the licensee appropriately evaluated industry operating experience

for relevance to the facility and entered applicable items in the corrective action program. The

licensee used industry operating experience when performing root cause and apparent cause

evaluations. The licensee performed effective quality assurance audits and self-assessments,

as demonstrated by its self-identification of some needed improvements in corrective action

program performance and of ineffective corrective actions.

The licensee maintained a safety-conscious work environment in which personnel felt free to

raise nuclear safety concerns without fear of retaliation. All individuals interviewed by the team

were willing to raise these concerns by at least one of the several methods available.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The team identified a Green violation of 10 CFR Part 50, Appendix B, Criterion

III, Design Control, for the licensees failure to assure that design basis requirements

-2-

associated with the standby liquid control (SLC) system test tank were correctly

translated into procedures. As a result, the licensee failed to maintain the tank empty as

required to meet seismic design requirements. The violation is cited because the

licensee failed to restore compliance in a reasonable time following documentation of the

issue as a non-cited violation in NRC Inspection Report 05000298/2012002, issued

May 10, 2012 (ML12131A674). The licensee entered these issues into its corrective

action program for resolution as Condition Report CR-CNS-2013-01962,

CR-CNS-2013-02027, and CR-CNS-2013-02328.

The failure to maintain design control of the standby liquid control system was a

performance deficiency. This performance deficiency was of more than minor safety

significance because it was associated with the design control attribute of the mitigating

systems cornerstone and it adversely affected cornerstone objective to ensure the

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

prevent undesirable consequences. Specifically, the licensees failure to implement

procedures to ensure the SLC test tank remained in a seismically qualified condition

resulted in an inability to provide reasonable assurance of operability following a seismic

event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team

determined that the finding was of very low safety significance (Green) because it was a

design deficiency that did not result in the loss of functionality.

This finding had a cross-cutting aspect in the area of human performance associated

with the decision-making component because the licensee failed to adopt a requirement

to demonstrate that a proposed action was safe in order to proceed rather than a

requirement to demonstrate it was unsafe in order to disapprove the action (H.1(b)).

(Section 4OA2.5.1)

Cornerstone: Miscellaneous

SL-IV. The team identified a Severity Level IV non-cited violation of 10 CFR 50.72,

Immediate Notification Requirements for Operating Nuclear Power Reactors, for the

licensees failure to make a required report to the NRC. After the licensee determined

that the standby liquid control test tank could not meet Seismic Class I requirements

unless empty, the team discovered that the tank was full. The licensee immediately

drained the tank and implemented a compensatory action to maintain it empty.

However, the licensee failed to recognize that because the compensatory measure was

required to provide a reasonable assurance of operability, the as-found condition of the

SLC systemwith the test tank fullrendered both trains of the system inoperable.

Because this could have prevented the fulfillment of the SLC systems safety function,

the licensee was required to report the condition to the NRC within eight hours of

discovery. After identification, the licensee entered this issue into its corrective action

program and made a late report to the NRC, restoring compliance with the regulation.

The failure to make a required report to the NRC within the required time was a

performance deficiency. The team determined that traditional enforcement applied to

this violation because the violation impeded the regulatory process. Specifically, the

NRC relies on the licensee to identify and report conditions or events meeting the criteria

specified in regulations in order to perform its regulatory oversight function. Assessing

the violation in accordance with Enforcement Policy, the team determined it to be of

-3-

Severity Level IV because it involved the licensees failure to make a report required

by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9). Because this was a traditional

enforcement violation with no associated finding, no cross-cutting aspect is assigned to

this violation. (Section 4OA2.5.2)

B. Licensee-Identified Violations

None

-4-

REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The team based the following conclusions on a sample of corrective action documents

that were open during the assessment period, which ranged from June 25, 2011, to the

end of the on-site portion of this inspection on March 28, 2013.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 220 condition reports (CRs), including associated root

cause, apparent cause, and direct cause evaluations, from approximately 18,000 that

had been initiated between June 25, 2011, and March 28, 2013. The condition reports

selected for review focused on risk-significant issues. In performing its review, the team

evaluated whether the licensee had properly identified, characterized, and entered

issues into the corrective action program, and whether the licensee had appropriately

evaluated and resolved the issues in accordance with the established programs,

processes, and procedures. The team also reviewed these programs, processes, and

procedures to determine if any issues existed that may impair their effectiveness.

The team reviewed a sample of system health reports, operability determinations,

self-assessments, trending reports and metrics, and various other documents related to

the corrective action program. The team evaluated the licensees efforts in establishing

the scope of problems by reviewing selected logs, work orders, self-assessment results,

audits, system health reports, action plans, and results from surveillance tests and

preventive maintenance tasks. The team reviewed daily CRs, and attended the

licensees Condition Review Group meetings to assess the reporting threshold,

prioritization efforts, and significance determination process, and to observe the

interfaces with the operability assessment and work control processes when applicable.

The teams review included verification that the licensee considered the full extent of

cause and extent of condition for problems, as well as a review of how the licensee

assessed generic implications and previous occurrences. The team assessed the

timeliness and effectiveness of corrective actions, completed or planned, and looked for

additional examples of problems similar to those the licensee had previously addressed.

The team conducted interviews with plant personnel to identify other processes that may

exist where problems may be identified and addressed outside the corrective action

program.

The team reviewed corrective action documents that addressed past NRC-identified

violations to ensure that corrective actions addressed the issues described in the

inspection reports. The team reviewed a sample of corrective actions closed to other

corrective action documents to ensure that corrective actions remained appropriate and

timely.

-5-

The team considered risk insights from both the NRCs and Cooper Nuclear Stations

risk assessments to focus the sample selection and plant tours on risk-significant

systems and components. The team focused a portion of its sample on the standby

liquid control systems and the residual heat removal system, which the team selected for

a five-year in-depth review. The samples reviewed by the team focused on but were not

limited to these systems. The team conducted walk-downs of these systems to assess

whether licensee personnel identified problems at a low threshold and entered them into

the corrective action program.

b. Assessments

1. Effectiveness of Problem Identification

During the 21-month inspection period, licensee staff generated approximately

18,000 condition reports. The licensees CR generation rate of approximately 11,000

per year had been relatively constant over the previous four years. The team

determined that most conditions that required generation of a CR by procedure 0.5,

Conduct of the Condition Report Process, and its implementing procedures were

appropriately entered into the corrective action program.

The team noted three exceptions in which the licensee had not identified and

evaluated adverse trends through the corrective action program as required by

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

revision 19. These failures to identify the trends represented minor performance

deficiencies that were not subject to enforcement action in accordance with the NRC

Enforcement Policy:

In the ten quality assurance audits reviewed by the team, the licensee had self-

identified seven failures to implement industry recommendations or to

incorporate vendor guidance into station procedures. The licensee had

evaluated each of these instances individually, but did not identify and evaluate

the potential adverse trend as required by procedure 0.5.CR, Condition Report

Initiation, Review, and Classification, revision 19. The licensee documented

the teams observation in CR-CNS-2013-02411.

In several condition reports, the licensee documented failures to completely

evaluate design bases in operability evaluations. The licensee reviewed each

of these instances individually, but did not identify and evaluate the potential

adverse trend. This trend of inadequate documentation of operability

evaluations is also referenced in the discussion of weaknesses in the

licensees evaluation processes in section 4OA2.1.b.2 below. The licensee

documented the teams observations in CR-CNS-2013-02413.

The licensee identified cases where it did not incorporate appropriate vendor

guidance into procedures. The licensee evaluated the implementation of

vendor guidance for specific issues, but not for the incorporation of vendor

guidance as a whole. This issue was also discussed in section 4OA2.1.b.1,

above.

-6-

The team concluded that despite this performance deficiency, the licensee

maintained a low threshold for the formal identification of problems and entry into the

corrective action problem for evaluation. All personnel interviewed by the team

understood the requirement and expressed a willingness to enter identified issues

into the corrective action program at a very low threshold.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

The team concluded that once the licensee entered issues into its corrective action

program, most issues were appropriately evaluated and prioritized. The licensee

screened approximately 8,400 (46%) of the 18,000 CRs generated during the

inspection period as adverse conditions and approximately 300 (2%) of the CRs as

requiring root or apparent cause evaluations. The sample of CRs reviewed by the

team was focused on these higher-tier issues. The team reviewed a number of

condition reports that involved operability reviews to assess the quality, timeliness,

and prioritization of operability assessments. In general, most immediate and prompt

operability assessments reviewed were adequately completed, and the team noted

improvements in these evaluations since the previous problem identification and

resolution inspection in June 2011.

However, the team noted weaknesses in some of the stations evaluation processes.

Particularly, the team noted weaknesses in the licensees evaluations of the

operability of degraded structures, systems, and components important to safety, as

described by the stations design-basis documents, and the subsequent

determinations of whether these degraded conditions required reports to the NRC.

The licensee documented the teams observations in CR-CNS-2013-02413. These

observations are also referenced in a discussion of the licensees failure to identify

adverse trends in section 4OA2.1.b.1 above. Additionally, section 4OA5.5 below

includes a specific example of an inadequate operability and reportability evaluation

and an associated discussion of the licensees failure to apply updated design

information.

The team also noted an example of the licensees failure to perform a

required 10 CFR 50.59 applicability screen for a procedural change that could have

affected the method for controlling a design function. Specifically, the licensee hung

a caution tag that restricted the allowable modes of operation of backup safety-

related battery chargers. Prior to identification by the team, the licensee had failed to

evaluate whether this restriction, which had been in place for approximately five

months, constituted a change per 10 CFR 50.59. This was a minor performance

deficiency that is not subject to enforcement action in accordance with the NRC

Enforcement Policy. The licensee documented the teams observation in

CR-CNS-2013-02022.

Overall, the team determined that the licensee had an adequate process for

screening and prioritizing issues that had been entered into the corrective action

program, though some weaknesses were noted. The team made the following

observations:

-7-

During the licensees Condition Review Group (CRG) screening process, the

screening group discussed each CR of A, B, or C significance individually.

However, D-significance CRs were only discussed when a CRG member took

exception to the CRs classification or description; the licensee did not do a 100

percent screen of these CRs. The team noted that prior to the end of this

inspection, the licensee changed its process to perform an individual screen of

all CRs, regardless of significance. Though the team had provided this

observation to the licensee prior to the change being implemented, the licensee

made the change independent of the teams observation.

Although CRG and Corrective Action Review Board (CARB) members must be

qualified through a formal training program, no continuing qualification

requirements to maintain proficiency are in place. Further, the licensees CRG

pre-screen group, which provides the initial screening and significance

classification for CRs, lacks a formal qualification program.

The team observed several additional potential weaknesses in the licensees

CARB process. While the team did not identify a specific adverse result from

these potential weaknesses, it determined that the weaknesses could

contribute to the licensees broader issues in the area of prioritization and

evaluation of problems. The licensee documented the teams observations in

CR-CNS-2013-02414.

o The licensee typically lacks documentation for the basis behind decisions

made during CARB meetings, specifically regarding decisions on

significance.

o On March 26, 2013, the team observed a meeting of the licensees CARB.

Per 0-EN-LI-102, Corrective Action Process, revision 20C0, the function of

the CARB is review and approval of root cause evaluations and selected

apparent cause evaluations. However, the team noted that the CARB

seemed to function more as a step in the editing and revision process for

the cause evaluation rather than a management review and approval step.

The team noted one instance where CARB approved a cause evaluation

after a 40-minute discussion of weaknesses in the evaluation.

o Changes to CARB-approved plans do not require further review. The team

noted one instance in which the licensee changed a corrective action for a

CARB-approved cause evaluationwhich included a statement that the

CARB Chairman needs to concur with changes prior to closurebut the

change did not receive CARB review or approval (CR-CNS-2011-09071 CA 7).

The licensee stated that this was acceptable per procedure.

o By process, the CARB provides only a front-end review of significant

corrective actions. CARB is required to review and approve the corrective

action plan and effectiveness review plan for root causes, but CARB does

not review corrective actions to prevent recurrencedesigned to correct

the root causes of significant conditionsor effectiveness reviews once

they are complete.

-8-

During the 2011 problem identification and resolution inspection, the inspection team

had identified weaknesses in the licensees operability evaluations. During this

inspection period, the licensee continued to have weaknesses in the area of

operability evaluations and in subsequent evaluations of whether identified

conditions require reports to the NRC. The licensee has identified and generally

addressed the lack of adequate documentation in operability evaluations. However,

as noted above, opportunities remain for further improvementspecifically in the

incorporation of design basis information into operability evaluations.

Additionally, the 2011 problem identification and resolution inspection team noted a

general weakness in the thoroughness of the licensees evaluations. During the

current inspection, the team noted that the licensees performance in this area had

improved. All evaluations reviewed appeared to be thorough enough to fully address

and correct the identified problems.

Overall, the team determined that the licensees process for screening and

prioritizing issues that had been entered into the corrective action program was

adequate to support nuclear safety. However, as discussed in the NRCs annual

assessment letter dated March 4, 2013 (ML13063A76), the licensee has an open

substantive cross-cutting issue in the area of problem identification and resolution,

associated with a theme in the thoroughness of problem evaluation. This

substantive cross-cutting issue, open since March 5, 2012, further indicates

weaknesses in the licensees effectiveness of prioritization and evaluation of

problems.

3. Assessment - Effectiveness of Corrective Actions

Overall, the team concluded that the licensee implemented effective corrective

actions for the problems identified and evaluated in the corrective action program.

The team reviewed eleven corrective action effectiveness reviews for significant

conditions adverse to quality and determined that the licensee had implemented

effective corrective actions for the conditions.

With the exception of the standby liquid control test tank issue discussed in

section 4OA2.5, the team noted that corrective actions to address the sample of

NRC non-cited violations and findings since the last problem identification and

resolution inspection had been timely and effective. Overall, the team concluded that

the licensee generally developed appropriate corrective actions to address identified

problems. The licensee generally implemented these corrective actions in a timely

manner, commensurate with their safety significance, and reviewed the effectiveness

of the corrective actions appropriately.

The team reviewed several corrective actions that the licensee had evaluated as

having been less than fully effective. However, all these ineffective corrective

actions had been self-identified by the licensee as part of its corrective action review

process. The team determined that the licensee had improved the effectiveness of

its corrective actions since the June 2011 problem identification and resolution

inspection.

-9-

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensees program for reviewing industry operating experience,

including reviewing the governing procedure and self-assessments. The team reviewed

a sample of industry operating experience communications to assess whether the

licensee had appropriately evaluated the communications for relevance to the facility.

The team also reviewed assigned actions to determine whether they were appropriate.

The team reviewed a sample of root and apparent cause evaluations to ensure that the

licensee had appropriately included industry operating experience.

b. Assessment

Overall, the team determined that the licensee appropriately evaluated industry

operating experience for its relevance to the facility. Of the operating experience items

reviewed by the team, the licensee had entered all applicable items into the corrective

action program and had evaluated these items in accordance with station procedures.

The team further determined that the licensee appropriately evaluated industry operating

experience when performing root cause investigations and apparent cause evaluations.

The licensee appropriately incorporated both internal and external operating experience

into lessons-learned for training and pre-job briefs.

In addition, the team reviewed twelve NRC bulletins, regulatory issue summaries, and

information notices issued during the inspection period and found that in all cases, the

licensee wrote a condition report and evaluated the applicability of the bulletin,

regulatory issue summaries, or information notice to their facility. The team found the

assessments were clearly documented and were appropriate for the circumstances.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample size of twenty-four licensee audits and self-assessments to

assess whether the licensee was regularly identifying performance trends and effectively

addressing them. The team reviewed audit reports to assess the effectiveness of

assessments in specific areas. The team evaluated the use of self-assessments and the

role of the quality assurance department. The specific audit and self-assessment

documents reviewed are listed in the Attachment.

b. Assessment

The team concluded that the licensee generally had an adequate audit and self-

assessment process. Audits and self-assessments were performed using station

procedures and were documented thoroughly. Performance elements and standards

were appropriate for the programs and processes evaluated. Attention was given to

assigning team members with the requisite skills and experience, including individuals

from outside organizations, to perform effective audits and self-assessments. Audits

were self-critical, thorough, and identified new findings, performance deficiencies, and

- 10 -

other concerns in addition to evaluating known performance deficiencies across key

functional areas. The licensee generated condition reports to document these findings,

performance deficiencies, and other concerns. However, the team identified a missed

opportunity to identify whether adverse performance trends existed across internal

programs or processes in that CNS did not perform a collective review of audits and self-

assessments. From their review, the team identified collective weaknesses in procedure

adherence and adequate procedures. Specifically, the audits and self-assessments

identified instances of missing torque values, untimely updates of controlled copies of

documents, and failure to include vendor recommendations or industry guidance among

others across programs and processes. The team notes that the licensee does have a

corrective action to perform a common cause analysis of NRC identified findings.

Overall, the team determined that the licensee had generally developed appropriate

corrective actions to address findings from audits and self-assessments, though these

were not always effectively implemented. For example, the team notes that over the

past several years the licensee had performed and documented multiple audits and self-

assessments that identified longstanding programmatic issues with the Quality Control

Program. However, the licensee has developed an Improvement Plan for the Quality

Control Program that would likely remedy these programmatic issues when fully

implemented.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team interviewed thirty-nine individuals in six focus groups. The purpose of these

interviews was (1) to evaluate the willingness of licensee staff to raise nuclear safety

issues, either by initiating a condition report or by another method, (2) to evaluate the

perceived effectiveness of the corrective action program at resolving identified problems,

and (3) to evaluate the licensees safety-conscious work environment (SCWE). The

focus group participants were from Security, Radiation Protection, Chemistry,

Engineering, Operations, and Maintenance. The individuals were selected blindly from

these work groups, based partially on availability. To supplement these focus group

discussions, the team interviewed the Employee Concerns Program (ECP) manager to

assess her perception of the site employees willingness to raise nuclear safety

concerns. Finally, the team reviewed the licensees most recent self-assessment of its

safety-conscious work environment.

b. Assessment

1. Willingness to Raise Nuclear Safety Issues

All individuals interviewed indicated that they had no hesitation raising nuclear safety

and other concerns. All felt that their management is receptive to nuclear safety

concerns and is willing to address them promptly. All of the interviewees further

stated that if they were not satisfied with the response from their immediate

supervisor, they would feel free to escalate the concern. Most expressed positive

experiences after raising issues to their supervisors or documenting issues in

condition reports.

- 11 -

2. Employee Concerns Program

All interviewees were aware of the Employee Concerns Program. Most explained

that they had heard about the program through various means, such as posters,

training, presentations, and discussion by supervisors or management at meetings.

Most did not have any personal experience with the ECP because, as noted above,

they felt free to raise safety concerns to their supervisors; they did not need to use

the ECP in these cases. However, all interviewees stated that they would use the

program if they felt it was necessary. None of the interviewed personnel had heard

of any issues dealing with breaches of confidentiality by the ECP staff, though

several noted that the location of the ECP office in a high-traffic area near

management offices did not lend itself to confidential meetings.

3. Preventing or Mitigating Perceptions of Retaliation

When asked if there have been any instances where individuals experienced

retaliation or other negative reaction for raising issues, all individuals interviewed

stated that they had neither experienced nor heard of an instance of retaliation,

harassment, intimidation or discrimination at the site. The team determined that

licensee management was successfully implementing processes it had in place to

mitigate such issues.

.5 Findings

1. Failure to maintain seismic qualification of standby liquid control

Introduction. The team identified a Green violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to assure that design basis

requirements associated with the standby liquid control (SLC) system test tank were

correctly translated into procedures. As a result, the licensee failed to maintain the

tank empty as required to meet seismic design requirements. This violation did not

meet the criteria to be treated as a non-cited violation because after it had been

previously documented by the NRC, the licensee failed to restore compliance in a

reasonable period of time.

Description. On May 10, 2012, the NRC documented a non-cited violation for the

licensees failure to properly translate the seismic design basis of the SLC system

into specifications, drawings, procedures, and instructions

(NCV 05000298/2012002-04; see ML12131A674). The licensee generated

calculation NEDC 12-015 as its prompt operability evaluation following identification

of the 2012 violation. The licensee determined that NEDC 12-015 provided a

reasonable assurance of SLC system operability while developing a design basis

calculation to fully qualify the SLC system to the licensees seismic requirements.

The licensee initiated calculation NEDC13-010, Cooper Nuclear Station Standby

Liquid Control Storage, Test, and Mix Tanks Seismic Qualification, to evaluate the

full seismic qualification of the SLC tanks and to establish the seismic design basis

for these tanks.

- 12 -

On February 28, 2013, the licensee approved NEDC 13-010, revision 0, and engineering

evaluation 13-009, Standby Liquid Control System/Reactor Equipment Cooling,

revision 0. This calculation and evaluation concluded that the standby liquid control test

tank met Seismic Class I design requirementsas required for safety-related systems

only when empty; the tank did not meet these requirements when full. After approval of

this calculation and engineering evaluation, the licensee closed the CRs related to

NCV 2012002-04, documenting that all corrective actions were complete.

On March 13, 2013, after reviewing the licensees completed corrective actions for the

2012 NCV, including the new design basis information documented in NEDC 13-010, the

team walked down the SLC system to verify corrective actions. During this walk-down,

the team identified that the SLC test tank was full, causing the SLC system to be in a

condition that did not meet the licensees design basis. Following the teams

observation, the licensee immediately drained the tank. The licensee implemented

Standing Order 2013-006 to maintain the test tank drained and to declare the SLC

system inoperable when the tank is filled for testing.

The team determined that after adoption of the new design basis calculation, the

licensee had failed to implement procedure changes or compensatory actions to ensure

the test tank was empty. Instead, the licensee inappropriately relied on a previous,

superseded calculation to justify operability. The licensee had thus failed to maintain

seismic qualification of the SLC system. This failure did not result in an actual loss of

system function. The licensee documented the condition and the teams associated

observations in condition reports CR-CNS-2013-01962, CR-CNS-2013-2027,

and CR CNS-2013-02328.

Analysis. The failure to maintain design control of the standby liquid control system was

a performance deficiency. This performance deficiency was of more than minor safety

significance because it was associated with the design control attribute of the mitigating

systems cornerstone and it adversely affected cornerstone objective to ensure the

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

prevent undesirable consequences. Specifically, the licensees failure to implement

procedures to ensure the SLC test tank remained in a seismically qualified condition

resulted in an inability to provide reasonable assurance of operability following a seismic

event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team

determined that the finding was of very low safety significance (Green) because the

finding did not result in the loss of the system or its function. Using Inspection Manual

Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very

low safety significance (Green) because it was a design deficiency that did not result in

the loss of functionality.

Because licensee personnel improperly decided to use a superseded calculation to

justify operability rather than reevaluating operability using current, more conservative

design information, this finding had a cross-cutting aspect in the area of human

performance associated with the decision-making component. The licensee failed to

use conservative assumptions in decision making and to adopt a requirement to

demonstrate that a proposed action was safe in order to proceed (H.1(b)).

- 13 -

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

in part that measures shall be established to assure that applicable regulatory

requirements and the design basis for those structures, systems, and components to

which the appendix applies are correctly translated into specifications, drawings,

procedures, and instructions. Contrary to this requirement, from May 10, 2012 until

March 13, 2013, the licensee failed to establish measures to assure that applicable

regulatory requirements and the design basis for a component to which the appendix

applied were correctly translated into specifications, drawings, procedures, and

instructions. Specifically, the licensee failed to assure that the design basis for the

standby liquid control system test tank, a component to which 10 CFR 50 Appendix B

applies, was translated into plant procedures to ensure that the standby liquid control

system would be available following a design-basis seismic event.

Following identification of this violation by the team, the licensee documented the

problem in its corrective action program, drained the standby liquid control test tank, and

established a standing order to maintain the test tank drained and to declare system

inoperable when the tank is filled for testing. In accordance with Section 2.3.2.a of the

NRC Enforcement Policy, this finding is being cited because the licensee failed to

restore compliance within a reasonable amount of time after the violation was initially

identified in NRC Inspection Report 05000298/2012002. It therefore did not meet the

criteria to be treated as a non-cited violation: VIO 05000298/2012009-01, Failure to

Maintain Seismic Qualification of Standby Liquid Control System.

2. Failure to make a required report

Introduction. The team identified a Severity Level IV non-cited violation

of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power

Reactors, for the licensees failure to make a required report to the NRC. Specifically,

the licensee failed to report a condition that could have prevented fulfillment of a

systems safety function.

Description. On February 28, 2013, the licensee approved calculation NEDC13-010,

Cooper Nuclear Station Standby Liquid Control Storage, Test, and Mix Tanks Seismic

Qualification, revision 0, and engineering evaluation 13-009, Standby Liquid Control

System/Reactor Equipment Cooling, revision 0. This calculation and evaluation

concluded that the standby liquid control test tank met Seismic Class I design

requirementsas required for safety-related systemsonly when empty; the tank did

not meet these requirements when full. The team noted that the failure of the SLC test

tank would result in the loss of functionality of both trains of SLC, a technical-

specification-required system.

On March 13, 2013, during a walk-down of the system, the team identified that the SLC

test tank was full. After the team informed the control room of the condition, the licensee

immediately drained the tank. The licensee initiated standing order 2013-006 to

maintain the standby liquid control system test tank empty and to declare the system

inoperable when the test tank is filled. The licensee credited this standing order as a

compensatory measure to ensure operability of the SLC system and declared the

system operable with this compensatory measure in place. However, the licensee failed

to recognize that because the compensatory measure was required to provide a

- 14 -

reasonable assurance of operability, the as-found condition of the SLC systemwith the

test tank fullrendered both trains of the system inoperable. Because this could have

prevented the fulfillment of the SLC systems safety function, the licensee was required

to report the condition to the NRC within eight hours of discovery.

On March 28, 2013, the licensee entered this issue into its corrective action program as

condition report CR-CNS-2013-02410. Also on March 28, 2013, the licensee made

Event Notification 48865 to the NRC Operations Center.

Analysis. The failure to make a required report to the NRC within the required time was

a performance deficiency. The team determined that traditional enforcement applied to

this violation because the violation impeded the regulatory process. Specifically, the

NRC relies on the licensee to identify and report conditions or events meeting the criteria

specified in regulations in order to perform its regulatory oversight function. Assessing

the violation in accordance with Enforcement Policy, the team determined it to be of

Severity Level IV because it involved the licensees failure to make a report required

by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9).

Because this was a traditional enforcement violation with no associated finding, no

cross-cutting aspect is assigned to this violation.

Enforcement. Title 10 CFR 50.72(b)(3)(v) requires in part that licensee report within

eight hours of discovery any event or condition that could have prevented the fulfillment

of the safety function of structures or systems that are needed to shutdown the reactor

and maintain it in a safe shutdown condition. Contrary to this requirement, on March 13,

2013, the licensee failed to report within eight hours of discovery an event or condition

that could have prevented the fulfillment of the safety function of a system needed to

shut down the reactor and maintain it in a safe shutdown condition. Specifically, the

standby liquid control test tank was discovered to be full, a condition in which

functionality of the standby liquid control system could not be reasonably assured

following a seismic event. The licensee failed to report this condition to the NRC within

eight hours of discovery.

Following discovery of the condition, the licensee immediately restored the system to a

qualified condition. After acknowledging that the required report had not been made, the

licensee entered the issue into its corrective action program on March 28, 2013, and

made Event Notification 48865. This event notification, though late, restored compliance

with applicable regulations.

Because this violation resulted in no or relatively inappreciable potential safety

consequences (SL-IV) and was entered into the corrective action program as Condition

Report CR-CNS-2013-02410, this violation is being treated as a non-cited violation,

consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000298/2013009-02, Failure to Notify the NRC within Eight Hours of a

Nonemergency Event.

- 15 -

4OA3 Event Follow-up (71153)

(Closed)05000298/2012006-00, Missing Vent Plug Results in Technical Specification

Prohibited Condition

On November 7, 2012, the licensee discovered that a plug was missing from the top of Z

sump vent connection, resulting in a breach of secondary containment integrity. Upon

discovery, the control room and maintenance personnel were notified and the plug was

reinstalled. The licensee later determined that the plug had been removed to obtain an

air sample per procedure. However, the change in configuration had not been

documented. The licensee determined that a procedural inadequacy was the root cause

of this event.

To prevent recurrence of this event, the licensee implemented a corrective action to

revise the procedure and preventive maintenance work items associated with the Z

sump. These revisions will add explicit requirements to replace the plug to reestablish

secondary containment integrity upon completion of work activities. The team reviewed

these planned revisions and determined that when implemented, they would likely

correct the condition.

No findings were identified. LER 05000298/2012006-00 is closed.

4OA6 Meetings

Exit Meeting Summary

On March 28, 2013, the team presented the inspection results to Mr. Oscar Limpias,

Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensee

staff. The licensee acknowledged the issues presented. The licensee confirmed that

any proprietary information that the team reviewed had been returned or destroyed.

ATTACHMENTS:

1. Supplemental Information

2. Information Request

3. Supplemental Information Request

- 16 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Kirkpatrick, Quality Control Program Coordinator

G. Smith, Engineer, Nuclear Steam Supply System

J. Ehlers, Engineering Supervisor, Electrical Systems/I&C

J. Flaherty, Engineer, Licensing

D. Cunningham, Instrument & Control Supervisor, Maintenance

R. Estrada, Design Engineering Manager

R. Penfield, Operations Manager

A. Schroeder, Non-Licensed Nuclear Plant Operator

L. Dewhirst, Corrective Action & Assessments Manager

E. Montgomery, Engineer, Electrical Systems/I&C

NRC personnel

J. Josey, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000298/2013009-01 VIO Failure to Maintain Seismic Qualification of Standby Liquid

Control System (Section 4OA2.5)05000298/2013009-02 NCV Failure to Notify the NRC within Eight Hours of a

Nonemergency Event (Section 4OA2.5)

Closed

05000298/2012006-00 LER Missing Vent Plug Results in Technical Specification

Prohibited Condition (Section 4OA3)

-1- Attachment 1

LIST OF DOCUMENTS REVIEWED

Condition Reports (CRs)

CR-CNS-2008-01352 CR-CNS-2011-08139 CR-CNS-2012-00376

CR-CNS-2008-03338 CR-CNS-2011-08226 CR-CNS-2012-00451

CR-CNS-2008-05767 CR-CNS-2011-08284 CR-CNS-2012-00722

CR-CNS-2008-07340 CR-CNS-2011-08610 CR-CNS-2012-00875

CR-CNS-2009-00613 CR-CNS-2011-08636 CR-CNS-2012-01083

CR-CNS-2009-04042 CR-CNS-2011-08640 CR-CNS-2012-01145

CR-CNS-2009-04819 CR-CNS-2011-08703 CR-CNS-2012-01214

CR-CNS-2009-07191 CR-CNS-2011-09071 CR-CNS-2012-01218

CR-CNS-2009-07519 CR-CNS-2011-09120 CR-CNS-2012-01224

CR-CNS-2009-07775 CR-CNS-2011-09217 CR-CNS-2012-01232

CR-CNS-2009-09023 CR-CNS-2011-09227 CR-CNS-2012-01522

CR-CNS-2009-09486 CR-CNS-2011-09551 CR-CNS-2012-01530

CR-CNS-2009-09548 CR-CNS-2011-09654 CR-CNS-2012-01611

CR-CNS-2009-10691 CR-CNS-2011-09892 CR-CNS-2012-01651

CR-CNS-2010-00314 CR-CNS-2011-09933 CR-CNS-2012-01918

CR-CNS-2010-00361 CR-CNS-2011-09946 CR-CNS-2012-01929

CR-CNS-2010-00656 CR-CNS-2011-10023 CR-CNS-2012-01962

CR-CNS-2010-02709 CR-CNS-2011-10026 CR-CNS-2012-01999

CR-CNS-2010-03195 CR-CNS-2011-10249 CR-CNS-2012-02532

CR-CNS-2010-05924 CR-CNS-2011-10391 CR-CNS-2012-02566

CR-CNS-2010-08242 CR-CNS-2011-10473 CR-CNS-2012-02620

CR-CNS-2010-08409 CR-CNS-2011-10546 CR-CNS-2012-02716

CR-CNS-2010-08960 CR-CNS-2011-10601 CR-CNS-2012-02742

CR-CNS-2011-00461 CR-CNS-2011-10618 CR-CNS-2012-02767

CR-CNS-2011-00684 CR-CNS-2011-10654 CR-CNS-2012-02814

CR-CNS-2011-01333 CR-CNS-2011-11307 CR-CNS-2012-02914

CR-CNS-2011-02021 CR-CNS-2011-11385 CR-CNS-2012-03052

CR-CNS-2011-02084 CR-CNS-2011-11564 CR-CNS-2012-03061

CR-CNS-2011-03106 CR-CNS-2011-11566 CR-CNS-2012-03137

CR-CNS-2011-03890 CR-CNS-2011-11581 CR-CNS-2012-03523

CR-CNS-2011-04065 CR-CNS-2011-11593 CR-CNS-2012-03527

CR-CNS-2011-04575 CR-CNS-2011-11725 CR-CNS-2012-03528

CR-CNS-2011-04643 CR-CNS-2011-11740 CR-CNS-2012-03543

CR-CNS-2011-04780 CR-CNS-2011-11777 CR-CNS-2012-03549

CR-CNS-2011-04891 CR-CNS-2011-11796 CR-CNS-2012-03576

CR-CNS-2011-05201 CR-CNS-2011-11861 CR-CNS-2012-03580

CR-CNS-2011-05251 CR-CNS-2011-12071 CR-CNS-2012-03612

CR-CNS-2011-06136 CR-CNS-2011-12189 CR-CNS-2012-03620

CR-CNS-2011-06686 CR-CNS-2011-12266 CR-CNS-2012-03764

CR-CNS-2011-06771 CR-CNS-2011-12319 CR-CNS-2012-03814

CR-CNS-2011-07175 CR-CNS-2011-12325 CR-CNS-2012-03817

CR-CNS-2011-07339 CR-CNS-2011-12437 CR-CNS-2012-03861

CR-CNS-2011-07475 CR-CNS-2012-00189 CR-CNS-2012-03894

CR-CNS-2011-07712 CR-CNS-2012-00210 CR-CNS-2012-03920

CR-CNS-2011-07898 CR-CNS-2012-00375 CR-CNS-2012-03946

-2-

CR-CNS-2012-04456 CR-CNS-2012-08377 CR-CNS-2013-01365

CR-CNS-2012-04628 CR-CNS-2012-08433 CR-CNS-2013-01457

CR-CNS-2012-04875 CR-CNS-2012-08460 CR-CNS-2013-01628

CR-CNS-2012-04891 CR-CNS-2012-08472 CR-CNS-2013-01734

CR-CNS-2012-04903 CR-CNS-2012-08547 CR-CNS-2013-01804

CR-CNS-2012-05076 CR-CNS-2012-08551 CR-CNS-2013-01820

CR-CNS-2012-05224 CR-CNS-2012-08671 CR-CNS-2013-01824

CR-CNS-2012-05225 CR-CNS-2012-08957 CR-CNS-2013-01837

CR-CNS-2012-05292 CR-CNS-2012-09161 CR-CNS-2013-01876

CR-CNS-2012-05293 CR-CNS-2012-09317 CR-CNS-2013-01893

CR-CNS-2012-05294 CR-CNS-2012-09352 CR-CNS-2013-01901

CR-CNS-2012-05305 CR-CNS-2012-09475 CR-CNS-2013-01920

CR-CNS-2012-05848 CR-CNS-2012-10256 CR-CNS-2013-01962

CR-CNS-2012-05849 CR-CNS-2012-10473 CR-CNS-2013-02003

CR-CNS-2012-05990 CR-CNS-2012-10488 CR-CNS-2013-02027

CR-CNS-2012-06034 CR-CNS-2012-10514 CR-CNS-2013-02149

CR-CNS-2012-06723 CR-CNS-2012-10543 CR-CNS-2013-02328

CR-CNS-2012-06829 CR-CNS-2012-10636 LO-CNSLO-2011-00090

CR-CNS-2012-07174 CR-CNS-2013-00112 LO-CNSLO-2011-00112

CR-CNS-2012-07333 CR-CNS-2013-00123 LO-CNSLO-2011-00114

CR-CNS-2012-07334 CR-CNS-2013-00230 LO-CNSLO-2011-00116

CR-CNS-2012-07365 CR-CNS-2013-00268 LO-CNSLO-2011-00123

CR-CNS-2012-07378 CR-CNS-2013-00452 LO-CNSLO-2011-00129

CR-CNS-2012-07534 CR-CNS-2013-00480 LO-CNSLO-2012-00011

CR-CNS-2012-07881 CR-CNS-2013-00571 LO-CNSLO-2012-00060

CR-CNS-2012-07887 CR-CNS-2013-00734 LO-CNSLO-2012-00061

CR-CNS-2012-07939 CR-CNS-2013-00755 LO-CNSLO-2012-00068

CR-CNS-2012-08139 CR-CNS-2013-00782 LO-CNSLO-2012-00069

CR-CNS-2012-08148 CR-CNS-2013-00936 LO-CNSLO-2012-00076

CR-CNS-2012-08169 CR-CNS-2013-01195 LO-CNSLO-2012-00079

CR-CNS-2012-08292 CR-CNS-2013-01297

CR-CNS-2012-08368 CR-CNS-2013-01318

Work Orders

WO4917843 WO4705009 WO4923630

WO4868494 WO4908111 WO4857089

WO4885920 WO4908120 WO4534594

WO4917853 WO4863752 WO4938028

WO4813254 WO4848307

WO4813256 WO4848588

-3-

Procedures

Number Title Revision/Date

0.10 Operating Experience Program 30

0.12 Working Hour Limitations and Personnel Fatigue 29

Management

0.4 Procedure Change Process 57

0.40 Work Control Program 85

0.4.IDOCS Requesting Procedure Change in IDOCS 4

0.5 Conduct of the Condition Report Process 70

0.5.CR Condition Report Initiation, Review, and Classification 19

0.5.EVAL Preparation of Condition Reports 24

0.5.NAIT Corrective Action Implementation and Nuclear Action Item 45

Tracking

0.5.OPS Operations Review of Condition Reports/Operability 39

Determination

0.5.ROOT- Root Cause Analysis Procedure 15

CAUSE

0.5.TRND Corrective Action Program (CAP) Trending 14

0.5.OPS Operation Review of Condition Reports/Operability 40

Determination

0.9 Tagout 79

0-Barrier Barrier Control Process 0

0-Barrier- Control Building 0

Control

0-Barrier-Misc Miscellaneous Building 0

0-Barrier- Reactor Building 0

Reactor

0-CNS-WM-105 Planning 4

0-EN-DC-205 Maintenance Rule Monitoring 3

0-EN-FAP-LI- Corrective Action Review Board (CARB) Process 8C1

003

0-EN-LI-102 Corrective Action Process 20C0

0-EN-LI-118 Root Cause Evaluation Process 18C0

0-EN-LI-119 Apparent Cause Evaluation (ACE) Process 16C0

-4-

0-EN-OE-100 Operating Experience Program 16C0

0-QA-01 CNS Quality Assurance Program 16

0-QA-02 Conduct of Internal Audits 9

0-QA-05 QA Audit Requirements, Frequencies, and Scheduling 11

0-QA-08 Quality Assurance Training Program 9

13.17.2 Thermal Performance Test Procedure for Residual Heat June 28,

Removal Heat Exchangers 2012

2.0.11 Entering and Exit Technical Specification/TRM/ODAM LCO 36

Condition(s)

2.0.12 Operator Challenges 9

2.0.3 Conduct of Operations 80

2.0.4 Relief Personnel and Shift Turnover 45

2.1.1 Startup Procedure 167

2.1.1.1 Plant Startup Review and Authorization 22

2.1.1.2 Technical Specification Pre-Startup Checks 35

2.2.24.2 250 VDC Electrical System (Div 2) 14

2.2.25.2 125 VDC Electrical System (Div 2) 21

2.2.74A Standby Liquid Control System Component Checklist 10

2.2.A.REC.DIV3 Reactor Equipment Cooling System Common Divisional 2

Component Checklist

6.1HV.303 Division 1 Essential Control Building Ventilation 14

Temperature Switch Change Out and Functional Test

6.2HV.303 Division 2 Essential Control Building Ventilation 17

Temperature Switch Change Out and Function Test

6.Log.601 Daily Surveillance Log - Modes 1, 2, and 3 111

7.0.5 Post Maintenance Testing 44

7.2.42.2 RHR Heat Exchanger Maintenance January 7,

2009

7.3.31.6 Safety-Related 125V/250V Battery Cell Replacement (Off- 4

Line)

7.3.5 EQ Terminal Box Examination and Maintenance 22

EN-DC-345 Equipment Reliability Clock 0C0

Security Personnel Access Control 43

Procedure 2.5

-5-

Audits

Number Area Date

11-03 Procurement July 7, 2011

11-04 Maintenance October 28, 2011

11-05 Radiological Effluents and Environmental Monitoring November 9, 2011

Program and Chemistry

11-06 Quality Assurance September 16, 2011

11-08 Training January 11, 2011

12-01 Engineering April 4, 2012

12-02 Corrective Action Program May 9, 2012

12-03 Radiological Controls July 30, 2012

12-04 Operations and Technical Specifications September 19, 2012

12-05 Document Control and Records November 6, 2012

12-06 Quality Control Re-Audit September 28, 2012

12-07 Emergency Plan January 31, 2013

S12-01 Nuclear Safety Culture May 1, 2012

Other

Number Title Revision/Date

RHR Surveillance Performance History (01/01/2008 -

02/14/2013)

RHR Corrective Maintenance Orders (02/02/2008 -

11/22/2012)

RHR System Health Report January 2013

OE RHRSWBP Performance: Administrative 0

Compensatory Actions to address degraded RHRSWBP

operation

QC Program Improvement Plan March 26, 2013

SW System Health Report January 2013

System Engineer Desktop Guide: Section V - System 7

Trending

4 Dia. T-8B1 Seal per Drawing CF-SP-34126-1 September 2,

1992

-6-

Number Title Revision/Date

RHR System Trend Plan

RHR System Engineering Walkdown February 2013

RHR System Engineering Walkdown January 2013

CED 6032263 Gear Ratio Change for RHR-MO39A and B A

COR002-23-02 OPS Residual Heat Removal System 27

NEDC 95-003 Determination of Allowable Operating Parameters for 27C4

CNS MOV Program MOVs

NEDC09-102 Internal Flooding - HELB, MELB, and Feedwater Line 0

Break

BLDG-F12 Performance Basis Criteria Document 1

BLDG-F13 Performance Basis Criteria Document 3

BLDG-F16 Performance Basis Criteria Document 3

BLDG-F19 Performance Basis Criteria Document 3

HPCI-F01 Performance Basis Criteria Document

NEDC12-012 Turbine Generator Building Siding Blowout Pressure, 0

other than EQ purposes

NEDC03-005 Turbine Generator Building Siding Blowout Pressure 4

NEDC11-135 Qualification of Doors R208, R209, and N104 0

NEDC13-010 CNS SLC Storage, Test, and Mix Tanks Seismic 0

Qualification

Engineering Standby Liquid Control System/Reactor Equipment 0

Evaluation 13-009 Cooling

TCC 4920141 Jumper OMAS on DG1 for Automatic Operation 0

TCC 4895999 Gag Open RHR HX A Inlet Valve SW-V-145 0

Burns and Roe Flow Diagram Reactor Building Service Water System N99

Drawing 2036

Sheet 1

TCC4917859 Temporary Repair on Service Water Booster Pump D

TCC4742749 Install Gag on SW-V-145

Burns and Roe Flow Diagram Reactor Building - Closed Cooling Water N65

2031 Sheet 2 System Cooper Nuclear Station

CNS System HPCI December

Health 2012

-7-

Number Title Revision/Date

CNS System Service Water January 2013

Health

CED 6028000 REC and TEC Oxygen Injection CCN 2

CNS System EE-DC January 2013

Health

Burns and Roe Flow Diagram Standby Liquid Control System N21

2045 Sheet 2

NEDC10-060 DG2 Mechanical Overspeed Governor Assembly Stud 1

Evaluation

CNS System Reactor Equipment Cooling January 2013

Health

LER Missing Vent Plug Results in Technical Specification 0

05000298/2012006 Prohibited Condition

CNSLO-2012-0060 50.59 Program Implementation Focused Self March 12-23,

Assessment 2012

2011 Fatigue Management Program Annual 01/24/2012

Effectiveness Review Summary

2012 Fatigue Management Program Annual 01/29/2013

Effectiveness Review Summary

NEDC 09-102 Internal Flooding- HELB, MELB, and Feedwater Line 0

Break

FAS 2013-003 Fatigue Assessment Summary 03/07/2013

FAS 2013-001 Fatigue Assessment Summary 01/10/2013

Nuclear Safety Culture Assessment December

2010

Snapshot Assessment/Benchmark on: Effectiveness December 28,

Review of Actions Taken to Resolve Issues Identified 2011

During the Nuclear Safety Culture Assessment

Performed in December 2010

Safety Conscience [sic] Work Environment: 2011 Survey

Results

-8-

Information Request

Biennial Problem Identification and Resolution Inspection

Cooper Nuclear Station

January 17, 2013

Inspection Report: 50-298/2013-009

On-site Inspection Dates: March 11-15 & 25-28, 2013

This inspection will cover the period from June 25, 2011 through March 28, 2013. All requested

information should be limited to this period or to the date of this request unless otherwise

specified. To the extent possible, the requested information should be provided electronically in

Adobe PDF (preferred) or Microsoft Office format. Any sensitive information should be provided

in hard copy during the teams first week on site.

Lists of documents should be provided in Microsoft Excel or a similar sortable format. Please

be prepared to provide any significant updates to this information during the teams first week of

on-site inspection. Corrective action documents refers to condition reports, notifications,

action requests, cause evaluations, and/or other similar documents, as applicable to Cooper

Nuclear Station.

Please provide the following information no later than February 22, 2013:

1. Document Lists

Note: For these summary lists, please include the document/reference number, the

document title, initiation date, current status, and long-text description of the issue.

a. Summary list of all corrective action documents related to significant conditions

adverse to quality that were opened, closed, or evaluated during the period

b. Summary list of all corrective action documents related to conditions adverse to

quality that were opened or closed during the period

c. Summary lists of all corrective action documents which were upgraded or

downgraded in priority/significance during the period (these may be limited to

those downgraded from, or upgraded to, apparent-cause level or higher)

d. Summary list of all corrective action documents initiated during the period that

roll up multiple similar or related issues, or that identify a trend

e. Summary lists of operator workarounds, operator burdens, temporary

modifications, and control room deficiencies currently open, or that were

evaluated or closed during the period

f. Summary list of safety system deficiencies that required prompt operability

determinations (or other engineering evaluations) to provide reasonable

assurance of operability

-1- Attachment 2

g. Summary list of plant safety issues raised or addressed by the Employee

Concerns Program (or equivalent) (sensitive information can be made available

during the teams first week on site)

h. Summary list of all Apparent Cause Evaluations completed during the period

i. Summary list of all Root Cause Evaluations planned or in progress but not

complete at the end of the period, with planned completion or due date

2. Full Documents with Attachments

a. Root Cause Evaluations completed during the period

b. Quality Assurance audits performed during the period

c. All audits/surveillances, performed during the period, of the Corrective Action

Program, of individual corrective actions, and of cause evaluations

d. Functional area self-assessments and non-NRC third-party assessments (i.e.,

peer assessments performed as part of routine or focused station self- and

independent assessment activities; do not include INPO assessments) that were

performed or completed during the period; include a list of those that are

currently in progress

e. Corrective action documents generated during the period associated with the

following:

i. NRC findings and/or violations issued to Cooper Nuclear Station

ii. Licensee Event Reports issued by Cooper Nuclear Station

f. Corrective action documents generated for the following, if they were determined

to be applicable to Cooper Nuclear Station (for those that were evaluated but

determined not to be applicable, provide a summary list):

i. NRC Information Notices, Bulletins, and Generic Letters issued or

evaluated during the period

ii. Part 21 reports issued or evaluated during the period

iii. Vendor safety information letters (or equivalent) issued or evaluated

during the period

iv. Other external events and/or Operating Experience evaluated for

applicability during the period

-2-

g. Corrective action documents generated for the following:

i. Emergency planning drills and tabletop exercises performed during the

period

ii. Maintenance preventable functional failures which occurred or were

evaluated during the period

iii. Adverse trends in equipment, processes, procedures, or programs that

were evaluated during the period

iv. Action items generated or addressed by offsite review committees during

the period

3. Logs and Reports

a. Corrective action performance trending/tracking information generated during the

period and broken down by functional organization (if this information is fully

included in item 3.c, it need not be provided separately)

b. Corrective action effectiveness review reports generated during the period

c. Current system health reports, Management Review Meeting package, or similar

information; provide past reports as necessary to include 12 months of

metric/trending data

d. Radiation protection event logs during the period

e. Security event logs and security incidents during the period (sensitive information

can be made available during the teams first week on site)

f. Employee Concern Program (or equivalent) logs (sensitive information can be

made available during the teams first week on site)

g. List of training deficiencies, requests for training improvements, and simulator

deficiencies for the period

Note: For items 3.d-3.g, if there is no log or report maintained separate from the

corrective action program, please provide a summary list of corrective action program

items for the category described.

4. Procedures

a. Corrective action program procedures, to include initiation and evaluation

procedures, operability determination procedures, apparent and root cause

evaluation/determination procedures, and any other procedures that implement

the corrective action program at Cooper Nuclear Station

-3-

b. Quality Assurance program procedures (specific audit procedures are not

necessary)

c. Employee Concerns Program (or equivalent) procedures

d. Procedures which implement/maintain a Safety Conscious Work Environment

5. Other

a. List of risk-significant components and systems, ranked by risk worth

b. Organization charts for plant staff and long-term/permanent contractors

c. For each week the team is on site,

i. Planned work/maintenance schedule for the station

ii. Schedule of management or corrective action review meetings (e.g.

operations focus meetings, CR screening meetings, CARBs, MRMs,

challenge meetings for cause evaluations, etc.)

iii. Agendas for these meetings

Note: The items listed in 5.c may be provided on a weekly or daily basis after the

team arrives on site.

d. Electronic copies of the FSAR, technical specifications, and technical

specification bases, if available

All requested documents should be provided electronically where possible. Regardless of

whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide

copies on CD or DVD. One copy of the CD or DVD should be provided to the resident inspector

at Cooper Nuclear Station; three additional copies should be sent to the team lead, to arrive no

later than February 22, 2013:

Eric A. Ruesch

U.S. NRC Region IV

1600 East Lamar Blvd.

Arlington, TX 76011-4511

-4-

PAPERWORK REDUCTION ACT STATEMENT

This request does not contain new or amended information collection requirements subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by

the Office of Management and Budget, control number -3150-0011.

4-

Supplemental Information Request

Biennial Problem Identification and Resolution Inspection

Cooper Nuclear Station

March 7, 2013

Inspection Report: 50-298/2013-009

On-site Inspection Dates: March 11-15 & 25-28, 2013

This request supplements the original information request. Where possible, the information

should be available to the inspection team immediately following the entrance meeting. The

meeting agendas requested in item 1 should be provided when developed. This inspection will

cover the period from June 25, 2011 through March 28, 2013. All requested information should

be limited to this period or to the date of this request unless otherwise specified.

Please provide the following:

1. For each week the team is on site,

Planned work/maintenance schedule for the station

Schedule of management or corrective action review meetings (e.g. CRB, MRM,

CAR screening meetings, etc.)

Agendas for these meetings

2. As part of the inspection, the team will do a five-year in-depth review of issues and

corrective actions related to the residual heat removal (RHR) system. The following

documents are to support this review (electronic format preferred):

Copies of upper and lower tier cause evaluations performed on the RHR system

within the last 5 years, including root cause evaluations not already provided

List of all surveillances run on the RHR system within the last five years, sortable

by component and including acceptance criteria

List of all corrective maintenance work orders performed on the RHR system

within the last 5 years

List of maintenance rule functional failure assessmentsregardless of the

resultperformed on the RHR system within the last 5 years

System training manual(s) for the RHR system

Engineering forms/logs containing notes from the last two engineering walk-

downs of the RHR system

3. The team will also review the stations implementation of the fatigue rule. These

documents support this review:

List of all fatigue assessments performed during the inspection period separated

by department

List of all work hour rule waivers and violations during the inspection period

separated by department

Fatigue rule implementing procedures

-1- Attachment 3

4. Specific documents:

Documentation of modifications and temporary modifications (include associated

condition reports):

o TCC4896041 Gag Open RHR A Inlet Valve SW-V-145

o TCC4920141 Jumper OMAS on DG1 for Automatic Operation

o TCC4917859 Temporary Repair of Leak on SWBP D

o TCC4908683 Service Water Discharge Pipe Repair

o CED6028000

Procedures

o 2.2.65

o 6.LOG.601

o 10.5

o 10.8

Condition reports:

o CR-CNS-2009-00613 o CR-CNS-2011-09551

o CR-CNS-2009-07191 o CR-CNS-2011-12071

o CR-CNS-2009-10222 o CR-CNS-2012-00210

o CR-CNS-2009-10691 o CR-CNS-2012-00649

o CR-CNS-2010-05023 o CR-CNS-2012-01522

o CR-CNS-2010-05924 o CR-CNS-2012-01530

o CR-CNS-2010-05972 o CR-CNS-2012-01611

o CR-CNS-2010-08193 o CR-CNS-2012-01929

o CR-CNS-2011-00461 o CR-CNS-2012-01999

o CR-CNS-2011-00684 o CR-CNS-2012-02343

o CR-CNS-2011-04643 o CR-CNS-2012-02532

o CR-CNS-2011-08226 o CR-CNS-2012-03704

o CR-CNS-2011-08284 o CR-CNS-2012-05224

o CR-CNS-2011-08636 o CR-CNS-2012-07372

o CR-CNS-2011-08640 o CR-CNS-2012-08368

o CR-CNS-2011-09120 o CR-CNS-2012-09691

-2-

PAPERWORK REDUCTION ACT STATEMENT

This request does not contain new or amended information

- 2 -collection requirements subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by

the Office of Management and Budget, control number 3150-0011.