IR 05000298/2013005

IR 05000298-13-005; 09/23/2013 12/31/2013; Cooper Nuclear Station, Integrated Resident and Regional Report; Equip Alignment, Maint Risk Assessments & Emergent Work Control, Operability Determinations & Functionality Assessments, Problem Id

ML14044A105
Person / Time
Site:	Cooper
Issue date:	02/13/2014
From:	Allen D B NRC/RGN-IV/DRP/RPB-C
To:	Limpias O A Nebraska Public Power District (NPPD)
Allen D B
References
EA-13-075, EA-13-225 IR-13-005
Preceding documents:	ML14307B038 (3 November 2014)
Download: ML14044A105 (42)

Text

February 13, 2014

EA-13-075

EA-13-225

Mr. 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 - NRC INTEGRATED INSPECTION REPORT 05000298/2013005 AND NRC INVESTIGATION REPORT NO. 2013-009

Dear Mr. Limpias:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Cooper Nuclear Station. On December 20, 2013, the NRC inspectors discussed the results of this inspection with Mr. R. Penfield, Director of Nuclear Safety Assurance, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The NRC inspectors documented four findings of very low safety significance (Green) in this report. All of these findings involved violations of NRC requirements. Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating th ese violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. One of the licensee identified violations referenced above, resulted in an NRC investigation. The enclosed report documents the investigation completed on October 1, 2013, by the Nuclear Regulatory Commission's Office of Investigations. The purpose of this investigation was to determine whether a fire watch was wilfully inattentive while on duty at Nebraska Public Power District's Cooper Nuclear Station, Brownville, Nebraska. Based on the evidence gathered during the investigation, the NRC concluded that on December 5, 2012, a former contract-employee deliberately failed to perform a fire watch at the Cooper Nuclear Station. This was contrary to the fire protection plan that satisfies Criterion 3 of Appendix A of 10 CFR Part 50, and resulted in a violation. Since the former contract-employee's violation was wilful, it was evaluated under the NRC's traditional enforcement process in accordance with the Enforcement Policy. The current Enforcement Policy is included on the NRC's website at:

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. After careful consideration of these factors, the NRC concluded that this violation should be clas sified at Severity Level IV, based on the UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX 76011-4511 example provided in Section 6.1.d.1 of the Enforcement Policy. In reaching this decision, the NRC considered that the event was isolated, it was performed by a low-level, contract-employee, missing of the fire watch was of short duration, did not result in an actual consequence, and occurred while the plant was shut-down. In addition, the significance was mitigated because others were in the area and no actual fire occurred during the time frame that the fire watch was non-observant. In accordance with Section 2.3.2 of the Enforcement Policy, and with the approval of the Director, Office of Enforcement, this issue has been characterized as a non-cited violation, because (1) the violation was identified by the licensee; (2) the violation involved the act of an individual, who would not have been considered a licensee official with oversight of regulated activities as defined in the Enforcement Policy; (3) the violation did not involve a lack of management oversight and was the isolated action of the former, contract-employee; and (4) significant remedial action commensurate with the circumstances was taken by the licensee.

Regarding the corrective actions, the Cooper Nuclear Station conducted an internal investigation to determine the cause and took appropriate corrective actions. The NRC concluded that information regarding: (1) the reason for the violation, (2) the corrective actions that have been taken and results achieved, and (3) the date when full compliance was achieved is already adequately addressed on the docket in the enclosed inspection report. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Cooper Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronicall y for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents 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/

Donald B. Allen, Branch Chief

Project Branch C

Division of Reactor Projects Docket Nos.: 50-298 License Nos: DPR-46

Enclosure:

Inspection Report 05000298/2013005

wAttachment:

Supplemental

Information Electronic Distribution to the Cooper Nuclear Station

SUMMARY

IR 05000298/2013005; 09/23/2013-12/31/2013; Cooper Nuclear Station, Integrated Resident and Regional Report; Equip Alignment, Maint Risk Assessments & Emergent Work Control, Operability Determinations & Functionality Assessments, Problem ID & Resolution.

The inspection activities described in this report were performed between September 23, 2013, and December 31, 2013, by the resident inspectors at the Cooper Nuclear Station, three inspectors from the NRC's Region IV office, and an inspector from the NRC's Office of Nuclear Security and Incident Response. Four findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. Additionally, NRC inspectors documented in this repor t two licensee-identified violations of very low safety significance or Severity Level IV. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," associated with the licensee's failure to promptly identify and correct a condition adverse to quality. Specifically, from July 2010 to present, the licensee failed to properly evaluate the diesel generator fuel oil storage tank vents to demonstrate their ability to perform their specified safety function in the event of a tornado missile. The licensee is in the process of developing corrective actions to restore compliance for this issue. This issue has been entered into the corrective action program as Condition Report CR-CNS-2014-00146.

The licensee's failure to promptly identify and correct a condition adverse to quality was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated July 1, 2012, inspectors determined this finding to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensee's maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with decision-making component because the licensee did not ensure that the proposed action was safe in order to proceed, rather than unsafe to disapprove the action H.1(b) (Section 1R04).

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness for Maintenance at Nuclear Power Plants," for the licensee's failure to implement required risk management actions during maintenance activities affecting the seismic qualification of the safety-related 4160 Vac Bus F and G when the cabinet doors are opened during under voltage relay testing. The licensee corrected this issue by providing procedural guidance for implementation of the required risk management actions. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2013-06870.

The licensee's failure to implement required risk management actions during maintenance activities was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective. Specifically, by failing to implement required risk management actions to restore 4160 Vac Bus F and G to their seismically qualified condition, i.e. cabinet doors closed, this thereby affected the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 5, 2005, Flowchart 2, "Assessment of Risk Management Actions," the inspectors determined the need to calculate a risk deficit to determine the significance of this issue. A senior reactor analyst performed a bounding detailed risk evaluation, which determined that the incremental core damage probability associated with this finding was less than 1 X 10

-6, so the finding has very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the licensee failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel follow procedures H.4(b)(Section 1R13).

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, Drawings," associated with the licensee's failure to perform an adequate operability determination in accordance with Station Procedure 0.5OPS, "Operations Review of Condition Reports/Operability Determination."

Specifically, the licensee failed to evaluate the effect on operability of taking electrical relays for the service water pumps out of their seismically qualified configuration. To correct this issue the licensee directed that the affected service water pump be declared inoperable during Division II under voltage testing. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2014-00122.

The failure to properly assess and document the basis for operability when a degraded or nonconforming condition was identified was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to properly document and assess the basis for operability resulted in a condition of unknown operability for a degraded nonconforming condition. Using Inspection Manual Chapter 0609, Appendix A, "Initial Screening and Characterization of Findings," dated July 1, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separ ate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensee's maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with decision-making component because the licensee did not ensure that the proposed action was safe in order to proceed, rather than unsafe to disapprove the action H.1(b) (Section 1R15).

Cornerstone: Occupational Radiation Safety

Green.

Inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, associated with a radiation protection technician who failed to follow the requirements of Radiation Work Permit 2013-001, "Radiation Protection Activities," Revision 1. This radiation work permit did not authorize entry into areas with dose rates exceeding 80 mrem/hr. The licensee determined that this issue was due to a human performance error and corrected the issue as such. The licensee entered this issue into their corrective action program as Condition Report CR-CNS-2013-07506.

The failure to follow radiation work permit requirements was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and affected the associated cornerstone objective to ensure the adequate protection of the worker's health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, this finding resulted in a radiation protection technician receiving an unintended and unexpected radiation dose.

Using Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined that the finding was of very low safety significance (Green) because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning; (2) it did not involve an overexposure; (3) there was no substantial potential for an overexposure; and (4) the licensee's ability to assess dose was not compromised. The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because licensee personnel failed to use human error prevention techniques, such as pre-job briefs, self-and-peer checking, and proper documentation of activities commensurate with the risk of the assigned task, such that, work activities were performed safely H.4(a) (Section 4OA2).

=

Licensee-Identified Violations===

Violations of very low safety significance or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

The Cooper Nuclear Station began the inspection period at full power on September 23, 2013, and remained at essentially full power through the end of the inspection period December 31, 2013.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

• October 11, 2013, 125 Vdc and 250 Vdc, C battery charger to Division 1 and Division 2 battery

• October 13, 2013, 4160 Vac, Bus F

• November 12, 2013, Core spray Division I and northeast quad fan coil unit

• November 26, 2013, Auxillary steam lines in 4160 switchgear room G, diesel generator rooms 1 and 2, service water pump room, and control room envelope high energy line break requirements The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," associated with the licensee's failure to promptly identify and correct a condition adverse to quality.

Description.

While performing plant walk downs, inspectors noted that the diesel generator fuel oil storage tank vent lines appeared to be susceptible to tornado missiles.

Specifically, the vent lines were approximately 1 foot apart, and inspectors questioned whether a single tornado generated missile could render both vent lines incapable of performing their specified function.

Inspectors reviewed the licensee's USAR and noted the following:

• Appendix F states that the licensee complies with Draft General Design Criteria GDC-2, published July 11, 1967, and the Draft General Design Criteria GDC-2 requires that the systems and components needed for accident mitigation remain fully functional before, during, and after a tornado event.

• USAR Chapter I-5, Section 5.2, defines Class I structures and equipment as, "Structures and equipment whose failure could cause significant release of radioactivity or which are vital to a safe shutdown of the plant and removal of decay and sensible heat."

• USAR Chapter XII-2, Section 2.1.2.3, identifies the Standby Diesel Generator System and Auxiliaries as Class I equipment.

Inspectors were not able to locate an evaluation of the vent lines that demonstrated their ability to withstand a tornado missile impact. Inspectors did, however, note that Station Procedure 5.1WEATHER, "Operations During Weather Watches and Warnings,"

Revision 12, Section 7.4, directed that, in the event of a tornado impact to the site, operators would inspect the vent lines, and if they were damaged, one of the diesel generator fuel oil tank fill lines was to be opened. Inspectors determined this to be a compensatory action, and questioned if the vent lines were adequately protected from tornado generated missiles.

Inspectors informed the licensee of their concerns, and the licensee initiated Condition Report CR-CNS-2013-03720. In this condition report, the licensee identified that during the 2010 NRC component design basis inspection, NRC inspectors had similar questions and Condition Report CR-CNS-2010-05211 had been initiated to address

these questions. The licensee subsequently closed Condition Report CR-CNS-2013-03720 with no further actions being taken.

Inspectors reviewed Condition Report CR-CNS-2010-05211 and noted that it had been initiated due to questions about a statement in the licensee's design control document for the diesel generators which dealt with tornado missile protection for the diesel generator fuel oil storage tank vents. Specifically, the design control document stated, in part, "The vent pipe concerns was satisfactorily resolved during the 1991 EDSFI," and inspectors had requested the station's evaluation for the diesel generator fuel oil storage tank vents and fill valves with respect to tornado missile.

The licensee researched the basis for this statement and determined that it most likely came from their evaluation of a finding at another facility where the NRC had questioned the adequacy of fill and vent connections with respect to impact from a tornado/tornado missile. During their review, the licensee determined that an evaluation of the fill and vent line's ability to withstand a tornado missile impact did not exist.

Corrective action number 2 of Condition Report CR-CNS-2010-05211 was, in part, "to provide a formal analysis of the diesel generator fuel oil storage tank vent lines pertaining to tornado missile protection." The licensee generated Engineering Evaluation 10-060, "Evaluation of the Diesel Generator Fuel Oil Tanks," in response to

this corrective action.

Inspectors reviewed Engineering Evaluation 10-060 and noted that it did not evaluate the vent lines with regard to their ability to withstand tornado generated missiles.

Instead, it assumed that the vents were small runs of pipe and if impacted by a missile there would be no damage to the fueil oil storage tank. The evaluation went on to discuss manual actions that could be implemented if the vent lines were to be damaged by a tornado generated missile.

Inspectors determined that the licensee's assumptions associated with the vent lines ability to withstand a missile impact were not adequate. Therefore, the licensee had failed to correct a previously identified condition adverse to quality. Specifically, Condition Report CR-CNS-2010-05211 identified that the station did not have an evaluation that demonstrated the diesel generator vent line's ability to withstand a tornado missile impact, and the corrective action (corrective action 2) to correct this, did not because of inadequate assumptions by engineering personnel.

Inspectors informed the licensee of their concern, and the licensee initiated Condition Report CR-CNS-2014-00146.

Analysis.

The licensee's failure to promptly identify and correct a condition adverse to quality was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated July 1, 2012, inspectors determined this finding to have very low safety significance (Green) because it:

(1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensee's maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with decision-making component because the licensee did not ensure that the proposed action was safe in order to proceed, rather than unsafe to disapprove the action H.1(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance's are promptly identified and corrected. Contrary to the above, from July 2010 to present, measures established by the licensee failed to assure that an identified condition adverse to quality was corrected. Specifically, the licensee failed to evaluate the lack of tornado missile protection for the diesel generator fuel oil storage tank vents and demonstrate their ability to perform their specified safety function in the event of a tornado missile strike. The licensee is in the process of developing corrective actions to restore compliance for this issue. An immediate safety concern does not exist due to the procedurized compensatory measures. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's corrective action program as Condition Report CR-CNS-2014-00146. (NCV 05000298/2013005-01, "Failure to Promptly Identify and Co rrect a Condition Adverse to Quality")

1R05 Fire Protection

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

• October 3, 2013, Control rod drive units north, Fire Area I, Zone 2A

• October 3, 2013, Residual heat removal heat exchanger 1A, Fire Area I, Zone 2B

• October 3, 2013, Standby liquid control pump tanks and access way, Fire Area I, Zone 5A

• October 8, 2013, Diesel generator room 1A, Fire Area IX, Zone 14A For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On November 6, 2013, the inspectors completed an inspection of a manhole susceptible to flooding. The inspectors selected a manhole that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:

• Manhole 6A The inspectors observed the material condition of the cables and splices contained in the manhole and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables met design requirements.

These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On November 12, 2013, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors reviewed the data from a performance test for the A reactor equipment cooling heat exchanger.

Additionally, the inspectors walked down the A reactor equipment cooling heat exchanger to observe its performance and material condition and verified that the A reactor equipment cooling heat exchanger was correctly categorized under the Maintenance Rule and was receiving the required maintenance.

These activities constitute completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 30, 2013, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On November 29, 2013, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. The inspectors observed the operators' performance of the following activities:

• 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for the reactor core isolation coolant surveillance brief and run

• 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for the control rod operability

• 0.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> for the brief on the solenoid-operated valve replacement for control rods 18-35 and 22-11 In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Inspection

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification program, the inspectors conducted personnel interviews, reviewed the operating tests, reviewed randomly selected medical and watchstanding proficiency records, and observed ongoing operating test activities. The on-site inspection effort occurred from October 21, 2013, to October 24, 2013. During this time, the inspectors interviewed licensee personnel to determine their understanding of the policies and practices for administering requalification examinations. The inspectors also performed observations of portions of the operating tests. These observations included five job performance measures and five scenarios that were administered in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content. The inspectors also performed an in-office review of overall operator performance on the biennial written exams as well as the annual operating tests. The results of these examinations were reviewed to determine the effectiveness of the licensee's appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed minutes of the Operations Training Review Group and Training Advisory Committee meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events. The inspector also reviewed a sample of licensed operator annual medical forms and procedures governing the medical examination process for conformance to 10 CFR 55.53, a sampling of the licensed requalification program feedback system, and reviewed remediation process records. In addition to the above, the inspectors reviewed examination security measures, simulator fidelity, and simulator deficiencies.

From December 1 to December 16, 2013, the inspectors performed an in-office review of the biennial written examinations and reviewed the overall pass/fail results of the individual job performance measure operating tests, simulator operating tests, and written examinations administered by the licensee during the operator licensing requalification cycles and biennial examination. Final examination results were assessed to determine if they were consistent with the guidance contained in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, "Operator

Requalification Human Performance Significance Determination Process." Seven separate crews participated in simulator operating tests, written examinations, and job performance measure operating tests, totaling 41 licensed operators. There was one failure on the written examination, no individual failures on the simulator operating tests, and no failures on the job performance measure operating tests. The one failure on the written examination was successfully remediated prior to returning to shift. The inspectors completed one inspection sample of the biennial licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components:

• November 19, 2013, 4160 Vac Bus F and G unavailability

• November 27, 2013, 10 CFR 50.65(a)(3) evaluation The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structure, system, and component. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the

Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed six risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

• October 16, 2013, Appendix R reactor building local auxiliary safe shutdown control panel availability when reactor temperature rises above 200 degrees Fahrenheit

• November 18, 2013, 4160 Vac Bus F undervoltage relay testing

• November 19, 2013, Inclement weather and off site power

• December 16, 2013, Replacement of service water booster pump C

• December 18, 2013, Control room envelope boundary door seal H305 repair/replacement

• December 31, 2013, Temporary steam exclusion boundaries for control building, 903 feet corridor and door D301 The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

Additionally, on October 13, 2013, the inspectors also observed portions of one emergent work activitiy that had the potential to affect the functional capability of mitigating systems.

• Diesel generator 1 unavailable and Yellow risk for jacket water leak to the lube oil system The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and

components.

These activities constitute completion of seven maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for the licensee's failure to implement required risk management actions for safety-related 4160 Vac Bus F and G under voltage relay testing.

Description.

The inspectors conducted a walk down of the work area and reviewed the risk assessment and risk management actions associated with under voltage relay testing of safety-related 4160 Vac Bus F. Inspectors noted that the cabinet doors were opened during under voltage relay testing and asked the following questions:

(1) Are the safety-related 4160 Vac Bus F and G switchgear seismically qualified when the cabinet doors are open? and

(2) If the buses are not seismically qualified with the doors open, what risk management actions are in place, and where are they documented, to ensure they are returned to their seismically qualified condition and, thereby, maintained

available?

The licensee informed the inspectors that the 4160 Vac Bus F and G had only been evaluated for seismic qualification with the doors closed, therefore, when the doors were opened, the switchgear was not seismically qualified. The licensee also stated that Station Procedure 0.41, "Seismic Housekeeping," Revision 9, requires that unsecured open panel access doors shall be attended by workers at all times and, based on this, they considered the 4160 Vac Bus F and G available when the doors are open.

The inspectors reviewed Station Procedure 0.41, "Seismic Housekeeping," Revision 9, and Station Procedure 0.49, "Scheduled Risk Assessment," Revision 34. Inspectors noted that Station Procedure 0.49 allowed operators to declare equipment "available," provided that, restoration was directed by a procedure, restoration could be done in a few simple actions, restoration did not require diagnosis, and the function could be promptly restored either by an operator in the control room or by a dedicated operator stationed locally for that purpose. Inspectors also noted that neither Station Procedure 0.41 nor the work order instructions associated with 4160 Vac Bus G and F under voltage relay testing contained specific directions to restore the buses to their seismically qualified condition for event response. The inspectors informed the licensee

of their concern, and to capture this concern in the station's corrective action program, the licensee initiated Condition Report CR-CNS-2013-06870.

The licensee implemented the required additional risk management action through a revision to Station Procedure 0.41, which ensured workers are briefed to close panel access doors in the event of an emergency or as directed by control room personnel.

The inspectors determined that the apparent cause of this finding was that the licensee had failed to follow the requirements of Station Procedure 0.49 for maintaining availability of the safety-related 4160 Vac Bus F and G when not in their seismically qualified condition, i.e. cabinet doors open. Specifically, restoration of the 4160 Vac buses was not directed by a procedure, work order instruction, or standing order.

Analysis.

The licensee's failure to implement required risk management actions during maintenance activities was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective. Specifically, by failing to implement required risk management actions to restore 4160 Vac Bus F and G to their seismically qualified condition, i.e. cabinet doors closed, this thereby affected the associated objective to ensure availability, reliability, and capability of systems that responds to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 5, 2005, Flowchart 2, "Assessment of Risk Management Actions," the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. A senior reactor analyst performed a bounding detailed risk evaluation which determined that the incremental core damage probability associated with this finding was less than 1 X 10

-6, so the finding has very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the licensee failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel follow procedures H.4(b).

Enforcement.

Title 10 CFR 50.65(a)(4) states, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, until October 2013, the licensee failed to properly manage the increase in risk that resulted from proposed maintenance activities. Specifically, measures established by the licensee failed to implement required risk management actions for the proposed maintenance activity of under voltage relay testing for the safety-related 4160 Vac Bus F and G when not in their seismically qualified condition. The licensee corrected this issue by providing procedural guidance for implementation of the required risk management actions. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's corrective action program as Condition Report CR-CNS-2013-06870.

(NCV 05000298/2013005-02, "Failure to Implement Risk Management Actions for Proposed Maintenance Activities")

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed four operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components:

• October 4, 2013, Operability determination of the service water booster pump C missing bearing

• October 9, 2013, Operability determination for incorrect grease in the primary containment isolation valves RW-AO-AO82, 83, 94, and 95

• October 23, 2013, Operability determination of the auxiliary steam piping high-energy line break affecting safety related structures, systems, and components outside secondary containment

• November 26, 2013, Operability determination of the 4160 Vac, Bus G and Division II service water pumps The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded structures, systems, and components to be operable, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded structures, systems, and components.

These activities constitute completion of four operability and functionality review samples, as defined in Inspection Procedure 71111.15

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," associated with the licensee's failure to perform an adequate operability determination in accordance with Station Procedure 0.5OPS, "Operations Review of Condition Reports/Operability

Determination."

Description.

While reviewing material associated with NCV 05000298/2013005-02, "Failure to Implement Risk Management Actions for Proposed Maintenance Activities,"

inspectors determined that there were other safety-related relays on the 4160 Vac Bus F and G cabinet doors and questioned why they were not inoperable with the cabinet doors open. Inspectors informed operators of their questions.

Operations evaluated the inspectors' questions as part of their review documented in Condition Report CR-CNS-2013-06870. During this review operations department determined that the relays in question had not previously been evaluated for operability, so an evaluation was performed and documented in this condition report. Operators determined that no other relay's operability was affected by opening the cabinet doors.

During discussions with operators, inspectors questioned this determination.

Specifically, inspectors questioned why the high pressure trip relay associated with the auto position of the service water pumps on the G bus, having the potential to change state during a seismic event and potentially affecting the ability of the pump to start on a low pressure signal, did not affect operability during testing. Operators responded that the auto position on the switch was not discussed in the USAR nor the technical specifications. Therefore, this switch position did not have a credited function. Thus, no operability concerns existed and no further evaluations were required.

Inspectors subsequently reviewed the USAR and technical specifications. During this review, they noted that Surveillance Requirement 3.7.2.4 required the licensee to verify that the service water pumps would start on a low pressure signal when in the auto position. Inspectors determined that operators had failed to adequately evaluate the service water pump relays on the G bus cabinet doors for operability. Inspectors informed the licensee of their concerns and the licensee initiated Condition Report CR-CNS-2014-00122 to capture this issue in the station's corrective action program.

Inspectors noted that Station Procedure 0.5OPS, "Operations Review of Condition Reports/Operability Determinations," Revision 46, provided the guidance used by operations staff at the Cooper Nuclear Station to perform operability determinations. Section 3.1 required, in part, that the shift manager, "document the basis for operability when a degraded or nonconforming condition exists."

Analysis.

The failure to properly assess and document the basis for operability when a degraded or nonconforming condition was identified was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to properly document and assess the basis for operability resulted in a condition of unknown operability for a degraded nonconforming condition. Using Inspection Manual Chapter 0609, Appendix A, "Initial Screening and Characterization of Findings," dated July 1, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding:

(1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensee's maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee did not ensure that the proposed action was safe in order to proceed, rather than unsafe to disapprove the action H.1(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Station Procedure 0.5OPS, "Operations Review of Condition Reports/Operability Determination," a procedure that is appropriate to the circumstances of evaluating the operability of safety-related components, required the licensee to properly assess and document the basis for operability when a degraded or nonconforming condition was identified. Contrary to the above, on December 20, 2013, an activity affecting quality was not accomplished in accordance with a procedure that was appropriate to the circumstances. Specifically, operators failed to adequately evaluate the effect on operability of taking electrical relays for the service water pumps out of their seismically qualified configuration. To correct this issue the licensee directed that the affected service water pump be declared inoperable during Division II under voltage testing. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's correction action program as Condition Report CR-CNS-2014-00122. (NCV 05000298/2013005-03, "Failure to Follow Operability Procedure")

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant structures, systems, or components:

• October 13, 2013, Diesel generator 1 emergent work control

• October 13, 2013, Service water booster pump C

• October 17, 2013, Service water booster pump B maintenance window

• October 31, 2013, Service water pump A and SW-MOV-36MV The inspectors reviewed licensing- and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed two risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

In-service test:

• October 16, 2013, Division I diesel generator fuel oil transfer pump in-service flow test Containment isolation valve surveillance test:

• October 3, 2013, North scram discharge volume vent isolation valve, CRD-AOV-CV38B The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the tests satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.

These activities constitute completion of two surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone:

Emergency Preparedness 1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Pr ocedures (EPIPs) and the Emergency Plan located under ADAMS accession number ML13336A463 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

Mitigating Systems Performance Index: Emergency AC Power Systems (MS06), High Pressure Injection Systems (MS07), Heat Removal Systems (MS08), Residual Heat Removal Systems (MS09), and Cooling Water Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensee's mitigat ing system performance index data for the period from the fourth quarter 2012 through the third quarter 2013 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported

data.

These activities constituted verification of the mitigating system performance index for emergency ac power systems, high pressure injection systems, heat removal systems, residual heat removal systems, and cooling water systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected two issues for an in-depth follow-up:

• On October 16, 2013, the inspectors reviewed corrective actions associated with the standby liquid control system test tank seismic II/I evaluation.

The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

• On December 16, 2013, the inspectors reviewed corrective actions associated with an unplanned dose rate alarm The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of two annual follow-up samples, as defined in Inspection Procedure 71152.

b. Findings

Introduction.

The inspectors reviewed a self-revealing Green non-cited violation of Technical Specification 5.4.1.a, associated with a radiation protection technician's failure to follow the requirements of a radiation work permit.

Description.

On November 4, 2013, a radiation protection technician signed into Radiation Work Permit (RWP) 2013-001, "Radiation Protection Activities," Revision 1, to complete the weekly turbine building high radiation area door and posting inspections.

This radiation work permit had a dose limit of 20 millirem and dose rate limit of 80 millirem per hour, and it did not authorize the access to high radiation areas. The technician had determined prior to entering the radiologically controlled area that the performance of this task did not require entry into a high radiation area.

The inspections included the steam jet air ejector room gate posting. When the technician entered the vestibule to the steam jet air ejector room, the individual failed to notice the high radiation area posting which was between the individual and the steam jet air ejector room gate posting. The technician entered the posted high radiation area to check the posting on the steam jet air ejector room gate and received a dose rate alarm. Upon receiving the dose rate alarm, the technician realized they had entered an area that exceeded the dose rates allowed by the radiation work permit. The technician immediately left the area and reported the alarm to supervision. The licensee determined that the highest dose rate encountered by the technician was 97 millirem per hour, and the total dose received was 0.5 millirem. The licensee entered this issue into their corrective action program as Condition Report CR-CNS-2013-07506.

The licensee subsequently performed an apparent cause evaluation, and determined that the apparent cause for this event was a personnel performance issue regarding effective use of human performance tools. Specifically,

(1) the technician failed to sign in on the correct radiation work permit authorizing access to high radiation areas in accordance with Station Procedure 9.EN-RP-101, "Access Control for Radiologically Controlled Areas," Revision 12;

(2) the technician failed to obtain the required brief prior to entering the high radiation area in accordance with Station Procedure 9.EN-RP-101;

(3) the technician failed to stop and perform a job site review when encountering a posting change from a radiation area to high radiation area; and

(4) the technician failed to use STAR to engage and question this task prior to entering a high radiation area.

Inspectors reviewed the licensee's cause analysis and determined that the identified apparent cause was reasonable for the unplanned dose rate alarm. Inspectors also noted that the technician's actions were contrary to the requirements of Station Procedure 9.ALARA.4, "Radiation Work Permits," Revision 17, Section 7.3, which stated that each individual is responsible for complying with radiation work permits.

Analysis.

The failure to follow radiation work permit requirements was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and affected the associated cornerstone objective to ensure the adequate protection of the worker's health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, this finding resulted in a radiation protection technician receiving an unintended and unexpected radiation dose. Using Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined that the finding was of very low safety significance (Green) because:

(1) it was not associated with as low as is reasonably achievable (ALARA) planning;

(2) it did not involve an overexposure;

(3) there was no substantial potential for an overexposure; and

(4) the licensee's ability to assess dose was not compromised. The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the individual failed to use human error prevention techniques, such as pre-job briefs, self-and-peer checking, and proper documentation of activities commensurate with the risk of the assigned task, such that, work activities were performed safely H.4(a).

Enforcement.

Technical Specification 5.4.1.a requires, in part, implementation of applicable procedures recommended by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 7(e) of Appendix A requires, in part, procedures for access control to radiation areas including a radiation work permit system. Station Procedure 9.ALARA.4, "Radiation Work Permits," Revision 17, implemented this requirement, and Section 7.3 of Procedure 9.ALARA.4 stated that each individual is responsible for complying with radiation work permits. Radiation Work Permit 2013-01, "Radiation Protection Activities," Revision 1, did not authorize entry into a high radiation area and had a dose limit of 20 mrem and a dose rate limit of 80 mrem/hr. Contrary to the above, on November 4, 2013, a radiation protection technician entered an area with dose rates exceeding 80 mrem/hr, a condition not authorized by the radiation work permit. Specifically, the technician failed to see a high radiation area posting and entered an area with a dose rate of 97 mrem/hr. The licensee determined that this issue was due to a human performance error and corrected the issue as such. This finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's corrective action program as Condition Report CR-CNS-2013-07506. (NCV 05000298/2013005-04, "Failure to Implement a Radiation Protection Procedure")

.3 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensee's corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends. The inspectors also reviewed the licensee's progress in addressing existing cross-cutting themes in; the resources component of the human performance area H.2(c), the corrective action program component of the problem identification and resolution area P.1(c), and the decision making component related to the use of conservative assumptions in decision making H.1(b).

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

Cross-Cutting Issues Trend Review

(1) Cross-Cutting Theme in Decision Making H.1(b)

In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 8 findings associated with the decision making component of the human performance area involving the use of conservative decision making H.1(b). The NRC determined that a substantive cross-cutting issue existed because there was a concern with the licensee's scope of effort and progress in addressing this cross-cutting theme, and this theme repeated a theme identified in earlier assessment periods.

In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 13 findings associated with the cross-cutting aspect of H.1(b). The NRC maintained this substantive cross-cutting issue open. The licensee initiated Condition Report CR-CNS-2013-01740, "2012 NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues," on March 4, 2013. The licensee's investigation determined that the root causes were:

• The station's standards related to the resolution of apparently low significance regulatory issues were low and did not meet Entergy fleet or industry expectations. This was evidenced by a lack of urgency to fully understand and resolve substantive cross-cutting issues and NRC findings of low significance (Green).

• The station's Engineering and Operations departments were not adequately proficient in the application of the licensing and design basis of the plant. Weak design basis knowledge together with limited experience related to the application of the design basis, particularly in engineering, resulted in the reduced levels of proficiency.

The licensee's corrective actions for the identified causes were:

• Assign mentors to review key engineering analysis products,

• Revise the stations corrective action program for how violations and substantive cross-cutting issues were evaluated,

• Conduct operability training with the operations department, and

• Conduct training on the station's design and licensing basis with engineering and operations departments.

In the 2013 mid-cycle assessment letter, dated September 3, 2013, the NRC recognized the licensee had implemented some corrective actions and had scheduled other corrective actions for future completion. On October 8, 2013, the NRC was notified of the licensee's readiness for this inspection.

On October 21, 2013, the licensee initiated Condition Report CR-CNS-2013-07205, "NRC Findings with a CCA of H.1(b)," to investigate the most recent findings with

H.1(b). The licensee's investigation determined that the root (common) cause of these findings was that clear standards and expectations for the "burden of proof requirements" for conservative decision making have not been consistently set and reinforced. The licensee determined that the contributing cause was that prior to the changes made by CR-CNS-2013-01740, condition reports that documented NCVs and other NRC Findings of Low Significance had typically not investigated the underlying process, program, or organizational factors that caused the event to become an NCV.

The licensee determined that the corrective actions described in Condition Report CR-CNS-2013-01740 were adequate to address the identified causes.

This baseline inspection semi-annual trend review monitored for sustainable performance improvements as evidenced by e ffective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common

theme. To date the NRC has identified 7 findings with the cross-cutting as pect of H.1(b) and this continues to comprise a cross-cutting theme. The licensee has implemented corrective actions to address this theme and the inspectors will continue to monitor for sustained improvement.

(2) Cross-Cutting Theme in Documentation and Procedures H.2(c)

In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 4 findings with an associated cross-cutting aspect in the resources component of the human performance area of failing to provide complete, accurate and up-to-date design documentation, procedures, and work packages, and correct labeling of components H.2(c). At the time, the NRC did not identify a substantive cross-cutting issue due to the licensee's scope of effort in addressing the theme, and because it was an emergent

performance trend.

In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 4 findings with the associated cross-cutting aspect of H.2(c). The NRC opened a substantive cross-cutting aspect because the corrective actions had not been effective in addressing the issue. The licensee initiated Condition Report CR-CNS-2013-01740.

"2012 NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues," on March 4, 2013. The licensee's investigation determined that the root causes were:

• The station's standards related to the resolution of apparently low significance regulatory issues were low and did not meet Entergy fleet or industry expectations. This was evidenced by a lack of urgency to fully understand and resolve substantive cross-cutting issues and NRC findings of low significance (Green).

• The station's Engineering and Operations departments were not adequately proficient in the application of the licensing and design basis of the plant. Weak design basis knowledge together with limited experience related to the application of the design basis, particularly in engineering, resulted in the

reduced levels of proficiency.

The licensee's corrective actions for the identified causes were:

• Assign mentors to review key engineering analysis products,

• Revise the station's corrective action program for how violations and substantive cross-cutting issues were evaluated,

• Conduct operability training with the operations department, and

• Conduct training on the station's design and licensing basis with engineering and operations departments.

This baseline inspection semi-annual trend review monitored for sustainable performance improvements as evidenced by e ffective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common

theme.

The inspectors have observed sustained improvement in the resources component of the human performance area as demonstrated by no findings with that theme following full implementation of appropriate corrective actions.

(3) Cross-Cutting Theme in Problem Evaluation P.1(c)

In the 2011 mid-cycle assessment letter, dated September 1, 2011, the NRC staff identified 6 findings associated with the corrective action program component of the problem identification and resolution area in the aspect of thoroughness of problem evaluation such that the resolutions address causes and extent of conditions P.1(c). The NRC determined that a substantive cross-cutting issue did not exist because the NRC did not have a concern with the licensee's scope of effort and progress in addressing the cross-cutting theme and because it was a recent performance trend.

In the 2011 end-of-cycle assessment letter, dated March 5, 2012, the NRC identified 7 findings with a cross-cutting aspect in P.1(c). The NRC opened a substantive cross-cutting issue in this cross-cutting theme because the NRC had a concern with the licensee's scope of effort and progress in addressing the issue.

In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 8 findings with a cross-cutting aspect of P.1(c) and maintained this substantive cross-cutting issue open.

In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 8 findings with a cross-cutting aspect of P.1(c) and maintained this substantive cross-cutting issue open. The licensee initiated Condition Report CR-CNS-2013-01740. "2012 NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues," on March 4, 2013. The licensee's investigation determined that the root causes were:

• The station's standards related to the resolution of apparently low significance regulatory issues were low and did not meet Entergy fleet or industry expectations. This was evidenced by a lack of urgency to fully understand and resolve substantive cross-cutting issues and NRC findings of low significance (Green), and

• The station's Engineering and Operations departments were not adequately proficient in the application of the licensing and design basis of the plant. Weak design basis knowledge together with limited experience related to the application of the design basis, particularly in engineering, resulted in the

reduced levels of proficiency.

The licensee's corrective actions for the identified causes were:

• Assign mentors to review key engineering analysis products,

• Revise the station's corrective action program for how violations and substantive cross-cutting issues were evaluated,

• Conduct operability training with the operations department, and

• Conduct training on the station's design and licensing basis with engineering and operations departments.

This baseline inspection semi-annual trend review monitored for sustainable performance improvements as evidenced by e ffective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common theme.

The inspectors have observed sustained improvement in the resources component of the human performance area as demonstrated by one finding with that theme following full implementation of appropriate corrective actions.

4OA5 Other Activities

.1 (Closed) Violation 05000298/2013009-01:

"Failure to Maintain Seismic Qualification of Standby Liquid Control System (EA-13-075)" The inspectors reviewed the licensee's immediate corrective actions and implemented corrective actions to restore the plant to regulatory conformance. The inspectors noted

that the actions implemented by the licensee involved reviewing the seismic II/I qualification of the Standby Liquid Control System test tank. The inspectors determined that these actions have addressed the concerns expressed in the violation. This violation is closed.

.2 IP 92723, "Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period"

a. Inspection Scope

As announced in the Mid-Cycle Performance Review and Inspection Plan letter (ML13246A356) and in accordance with IP 92723, the inspectors reviewed the licensee's responses to the three traditional-enforcement violations identified during the 12-month period that ended on June 30, 2013. These violations were non-cited and were designated as follows:

NCV 05000298/2012004-06, "Failure to Obtain Prior NRC Approval for a Change Regarding the Supplemental Diesel Generator"

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

NCV 05000298/2012301-01; "Failure to Maintain Both Initial Licensing Examination and Licensed Operator Examination Integrity"

The inspectors reviewed the licensee's responses to these violations to verify that the licensee understood the causes of these violations, identified the extent-of-condition and extent-of-cause associated with these violations, and had taken corrective actions that are sufficient to address the causes of the violations.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit Exit Meeting Summary

On October 24, 2013, the inspectors conducted an inspection debrief with Mr. J. Austin, Training Manager, and other members of the licensee's staff, on the results of the licensed operator requalification program inspection. The licensee acknowledged the findings presented. After reviewing the complete biennial requalification cycle examination results, the inspectors conducted a telephonic exit with Mr. C. Herring, Operations Training Superintendent, on December 19, 2013. The licensee acknowledged the results as presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On December 20, 2013, the inspectors presented the inspection results to Mr. R. Penfield, Director of Nuclear Safety Assurance, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations The following violations of very low safety significance (Green) or Severity Level IV were identified by the licensee and are violations of NRC requirements which meets the criteria of the NRC Enforcement Policy Section 2.3.2.a., for be

ing dispositioned as non-cited violation.

• Title 10 CFR 50.65(a)(1), "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," requires, in part, that holders of an operating license shall monitor the performance or conditions of structures, systems, or components within the scope of the monitoring program against licensee established goals in a manner sufficient to provide reasonable assurance that such structures, systems, or components are capable of fulfilling their intended safety function. Contrary to the above, on November 6, 2013, the licensee identified that they failed to establish goals in a manner sufficient to provide reasonable assurance that structures, systems, or components were capable of fulfilling their intended safety function. Specifically, the licensee failed to establish goals for the main condenser when it was placed in an (a)(1) status. This performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone, and affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," inspectors determined that the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This issue was entered into the licensee's corrective action program as Condition Report CR-CNS-2013-07967 for resolution.

• Title 10 CFR 50.48 requires, in part, that licensees must have a fire protection plan that satisfies Criterion 3 of Appendix A of 10 CFR Part 50. Condition 2.C.(4) of the Cooper Nuclear Station (CNS) License Number DPR-46 states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report (USAR) and as approved in the Safety Evaluation dated November 29, 1977, and subsequent supplements. Chapter 9

of the USAR, "Fire Protection System," provides a summary description of the SSCs that are relied on to meet the requirements of General Design Criterion 3, "Fire Protection," in 10 CFR Part 50 Appendix A. USAR Section 9.3.2.6 states that the Service Water Pump

Room is protected by an automatic Halon 1301 fire suppression system. USAR Section 9.6 states that the limiting conditions for operation and surveillance requirements for the Fire Protection System are provided in the CNS Technical Requirements Manual (TRM). TRM T 3.11.5, "Halon 1301 Fire Suppression System," requires that a continuous fire watch be established if the Halon 1301 system in the Service Water Pump Room is inoperable. CNS Administrative Procedure (AP) 0.39.1, "Fire Watches and Fire Impairments," Revision 9, Paragraph 5.1.8, "Responsibilities of Compensatory Continuous Fire Watches," stated, in part, that "Fire Watch shall observe the..'Affected Area' and be alert for signs of fire, smoke, and changing conditions." Contrary to the requirement in CNS AP 0.39.1, Paragraph 5.1.8, on December 5, 2012, an individual assigned to fire watch duty to observe the "Affected Area" was deliberately not alert for signs of fire, smoke, and changing conditions. Specifically, an individual assigned to continuous fire watch duty in the Service Water Pump Room, while the Halon 1301 system was inoperable, was found by a non-licensed operator to be inattentive. This caused the licensee to be in violation of License Condition 2.C.(4) of License No. DPR-46. The licensee identified the violation, performed an internal investigation, and took appropriate corrective actions. This included entering this issue into their corrective action program as Condition Report CR-CNS-2012-10123 for resolution. These corrective actions were completed on December 24, 2012. (EA-13-225)

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Austin, Training Manager

T. Barker, Manager, Engineering Programs and Components

J. Bebb, Staff Health Physicist, Radiation Protection

J. Bednar, Technical Supervisor, Radiation Protection

R. Beilke, Manager, Radiation Protection

D. Buman, Director, Engineering

T. Chard, Manager, Quality Assurance

S. DeRosier, Operator Training Superintendent

J. Dixon, ALARA Supervisor, Radiation Protection

R. Estrada, Manager, Design Engineering

M. Ferguson, Manager, Emergency Preparedness

J. Florence, Simulator Supervisor

C. Herring, Superintendant, Operations Training, Requalification

K. Higginbotham, General Plant Manager, Operations

K. Fike, Plant Chemist, Chemistry

J. Flaherty, Senior Staff Licensing Engineer, Licensing

E. Jackson, Exam Developer

D. Madsen, Senior Staff Engineer, Licensing

R. Morris, Specialist, Radiation Protection

J. Olberding, Licensing Specialist

R. Penfield, Director Nuclear Safety Assurance

J. Stough, Manager, Information Technology

K. Tanner, Radiological Shift Supervisor, Radiation Protection

D. Van Der Kamp, Manager, Licensing

A. Walters, Manager, Chemistry

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000298/2013005-01 NCV Failure to Promptly Identify and Correct a Condition Adverse to

Quality (Section 1R04)

05000298/2013005-02 NCV Failure to Implement Risk Management Actions for Proposed Maintenance Activities (Section 1R13)

05000298/2013005-03 NCV Failure to Follow Operability Procedure (Section 1R15)

05000298/2013005-04 NCV Failure to Implement a Radiation Protection Procedure (Section 4OA2)

Closed

05000298/2013009-01 VIO Failure to Maintain Seismic Qualification of Standby Liquid Control System (EA-13-075)(Section 4OA5)

Section 1R04: Equipment Alignment

Miscellaneous Documents

Number Title Revision

Engineering Evaluation, "Assessment of CNS Compliance with 10

CFR 50.49"

PBD-EQ, "Cooper Nuclear Station Environmental Qualification Program Basis Document"

00-95D NEDC, "HELB EQ - Reactor Building Pressure/Temperature"

02-005 NEDC, "HELB EQ - Mass and Energy Release" 1 02-007 NEDC, "Review of MPR Calculation 315-0030-001" 1

09-102 NEDC, "Internal Flooding - HELB, MELB, and Feedwater Line Break" and 1 13-024 NEDC, "Steam Exclusion Barrier for Building Door D301" 0 13-036 Engineering Evaluation, "Steam Exclusion Boundary for Controlled Corridor Door D301 and Control Building

(EL 903'-06") Corridor and Rooms"

90-031 Design Change, "Smoke/Fire Dampers for Control Room Ventilation"

91-119 Design Change, "DG-Steam Heating Piping System and HV Fan Coil Restraints"

91-227 NEDC, "Code Qualification of AS, ACD, and CH Piping Supports in the CNS Diesel Generator Bldg"

91-277 NEDC, "Diesel Generator Building AS, ACD, and CH Piping Analysis Problem

AS-01"

92-135 NEDC, "Operability Evaluation of Steam Piping in the Cable Spreading Room"

2045 Burns and Roe, Sheet 1, "Flow Diagram Core Spray System Cooper Nuclear Station"

N58

Miscellaneous Documents

Number Title Revision 3002 Burns and Roe, Sheet 1, "Cooper Nuclear Station Auxiliary One Line Diagram, MCC Z, SWGR Bus 1A, 1B, 1E and Critical SWGR Bus 1F, 1G"

N49 3058 Burns and Roe, "Cooper Nuclear Station DC One Line Diagram" N63

Procedures

Number Title Revision 2.2.48.2A Operations Procedure, "Station Heating System Electrode Boilers C and D Component Checklist"

2.2.73 Operations Procedure, "Standby Gas Treatment System" 50 2.2A_125DC.DIV1 Operations Procedure, "125 VDC Power Checklist (Div 1) 7 2.2A_250DC.DIV2 Operations Procedure, "250 VDC Power Checklist (Div 2) 0

2.2A_4160.Div1 Operations Procedure, "4160 VAC Auxilary Power Checklist (Div 1)" 1 2.3_9-3-1 Operations Procedure, "Panel 9-3 Annunciator 9-3-1" 31 2.3_FP-1 Operations Procedure, "Fire Protection-Annunciator 1" 11 2.3_R-2 Operations Procedure, "Panel R - Annunciator R-2" 17 2.3_S-1 Operations Procedure, "Panel S - Annunciator S-1" 18

2.4HVAC Operations Procedure, "Building Ventilation Abnormal" 20

2.4TEC Operations Procedure, "TEC Abnormal" 25

5.1Incident Emergency Procedure, "Site Emergency Incident" 26 6.1EE.302 Surveillance Procedure, "4160V Bus 1F Undervoltage Relay and Relay Timer Functional Test (Div 1)"

Condition Reports

(CRs)

CR-CNS-2002-03802

CR-CNS-2005-04427

CR-CNS-2013-07073

CR-CNS-2013-07142 CR-CNS-2013-07358

Section 1R05: Fire Protection

Miscellaneous Documents

Number Title

2013-281 Barrier Permit

Procedures

Number Title Revision 0.23 Station Procedure, "CNS Fire Protection Plan" 68

Work Orders

4935603

4978976 4978994

Section 1R06: Flood Protection Measures

Procedures

Number Title Revision 2.3_S-1 Operations Procedure, "Panel S - Annunciator S-1" 18

Condition Reports

(CRs)

CR-CNS-2012-05939

CR-CNS-2012-08055

Section 1R07: Heat Sink Performance

Miscellaneouse Documents Number Title Revision

REC-F01 Performance Criteria Basis 2

Procedures

Number Title Revision 13.15.1 Performance Evaluation Procedure, "Reactor Equipment Cooling Heat Exchanger Performance Analysis"

Condition Reports

(CRs)

CR-CNS-2013-07610

Work Orders

4895739

Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

Number Title Revision 6.CRD.301 Surveillance Procedure, "Withdrawn Control Rod Operability IST Test"

6.RCIC.102 Surveillance Procedure, "RCIC IST and 92 Day Test" 31 OTP810

Operations Department Examination Security

OTP812

Conduct of Operator Oral Boards

OTP809

Operator Requalification Examination Administration

OTP808

Open Reference Examination Test Item Development 1 OTP806

Conduct of Simulator Training and Evaluation

OTP805

Licensed Operator Requalification Biennial Written Exam

OTP804

Requalification Scenario Exercise Guide Development

OTP803 Development of Operations Training JPMs

OTP813 Annual Operating Requal. Exam Development and Admin. 2 OTP814 SIMULATOR SCENARIO-BASED TRAINING May 2, 2012

TPP 201 CNS Licensed Personnel Requalification Program 61 2.0.7 CNS Licensed Operator Requalification Program 6

NTP8.2 Preparation and Submittal of Operator and Senior Operator License Applications

NTP8.1 Administration of Licensed Operator Medical Examination Program 14

EN-TQ-201-04 SAT - Implementation Phase 2

Procedures

Number Title Revision

EDP-06 Supporting Requirements for Configuration Change Control 46 3.4 Configuration Change Control 55

Miscellaneous Documents

Number Title Revision/Date

NA Steady State Test - 23%, 75%, 100% August 2, 2013

NA Transient Performance Test #5 October 21, 2013 NA Transient Performance Test #9 October 21, 2013 SKL012-06-01 OPS Simulator Introduction 179

NTD120057 Simulation Configuration Update -

PTL 1207 December 3, 2012

NTD130005 Simulation Configuration Update -

PTL 1301 January 8, 2013

NTD130006 Simulation Configuration Update -

PTL 1302 January 21, 2013

NTD130014 Simulation Configuration Update -

PTL 1304 February 20, 2013

NA Report - Simulator Discrepancies by Due Date October 21, 2013 SKL034-20-127 JPM 1

SDR 13-0061 2 Parameters Out-of-Spec Steady State Test July 19, 2013

SDR 13-0043 Feedwater Heater Leaks March 5, 2013

SMP 13-0010 Implement

SPC 2012-92 to Simulator January 18, 2013

SMP 13-0004 Replace SIM

RHR-FR-143 October 10, 2012

SDP 13-0025 Correct Simulator RWCU Pump Trip Logic February 20, 2013

TQF-210-DD04 Performance Evaluation Reports for 2 ROs October 23, 2013

TQF-210-DD03 LOR Simulator Crew Performance Eval Reports October 23, 2013 OTP813 Att 12 JPM Evaluation Results for 2 ROs October 23, 2013

NA 2013 LOR Bienniel Written Exam Week 1

through 6 (RO/SRO) December 12, 2013

Miscellaneous Documents

Number Title Revision/Date

NA Five Randomly Selected Licensed Operator Medical Records October 22, 2013

Section 1R12: Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision

EN-DC-207 Maintenance Rule Periodic Assessment 2C0

PF03A Engineering Evaluation, "Provides Essential 4160 VAC Power to Critical Station Auxiliary Loads (4160V Division 1

Distribution System"

PF03B Engineering Evaluation, "Provides Essential 4160 VAC Power to Critical Station Auxiliary Loads (4160V Division 2

Distribution System"

Condition Reports

(CRs)

CR-CNS-2012-05249

CR-CNS-2012-06254

CR-CNS-2013-06870 CR-CNS-2013-07967

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Miscellaneous Documents

Number Title Revision

EQDP.2.212 Appendix R MOV Local Auxiliary Safe Shutdown Control Panel Components

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

13-023 NEDC, "HVAC Vent Steam Exclusion Boundary" 0 13-024 NEDC, "Steam Exclusion Barrier for Building Door D301" 0

13-027 NEDC, "Control Building (EL 903'-06")Temperature Rise due to temporary SEB Barrier Installation"

13-036 Engineering Evaluation, "Steam Exclusion Boundary for Controlled Corridor Door D301 and Control Building

(EL 903'-06") Corridor and Rooms"

2013-023 Barrier Control Permit

2013-281 Barrier Control Permit

Miscellaneous Documents

Number Title Revision 2013-0368 Barrier Control Permit

2013-0369 Barrier Control Permit

10977008 Technical Evaluation 0

Procedures

Number Title Revision 0-Barrier Station Procedure, "Barrier Control Process" 7 and 9 0-Barrier-Misc Station Procedure, "Miscellaneous Buildings" 3

0.41 Station Procedure, "Seismic Housekeeping" 9 and 10

0.49 Station Procedure, "Schedule Risk Assessment" 34

6.1EE.302 Surveillance Procedure, "4160V Bus 1F Undervoltage Relay and Relay Timer Functional Test (Div 1)"

Condition Reports

(CRs)

CR-CNS-2013-00281

CR-CNS-2013-02682

CR-CNS-2013-06870

CR-CNS-2013-06949

CR-CNS-2013-06954

CR-CNS-2013-06979

CR-CNS-2013-07022

Work Orders

4889242

4910617

4910701

4920901

4922893

4921123

4935603

4941332

4945830

4945831

4958736

4978976 4978994

Section 1R15: Operability Determinations and Functionality Assessments

Miscellaneous Documents

Number Title Revision 71 Book, "Calculations, Crane Runway Beam" 0 71 Book, "Calculations, 2 Ton Overhead Crane" 0

91-119 Design Change, "DG-Steam Heating Piping System and HV Fan Coil Restraints"

Procedures

Number Title Revision 0.5OPS Station Procedure, "Operations Review of Condition Reports/Operability Determination"

2.3_B-3 Operations Procedure, "Panel B - Annunciator B-3" 30 2.3_FP-1 Operations Procedure, "Fire Protection-Annunciator 1" 11

2.3_R-1 Operations Procedure, "Panel R - Annunciator R-1" 14

5.1Break Emergency Procedure, "Pipe Break Outside Secondary Containment"

Condition Reports

(CRs)

CR-CNS-2012-07142

CR-CNS-2013-06843

CR-CNS-2013-06870

CR-CNS-2013-06916 CR-CNS-2013-07073

Section 1R19: Post-Maintenance Testing

Procedures

NUMBER TITLE REVISION 2.20.2 Station Procedure, "Operation of Diesel Generators from Diesel Generator Room"

6.SW.202 Surveillance Procedure, "Service Water Power Operated Valve Operability Test"

6.1SW.101 Surveillance Procedure, "Service Water Surveillance Operation (Div 1)(IST)"

6.2SWBP.101 Surveillance Procedure, "RHR Service Water Booster Pump Flow Test and Valve Operability Test (Div 2)"

7.0.5 Maintenance Procedure, "Post Maintenance Testing" 45 7.2.53.3 Maintenance Procedure, "Diesel Engine Maintenance" 34

Condition Reports

(CRs)

CR-CNS-2013-07035

CR-CNS-2013-07041

CR-CNS-2013-07042

CR-CNS-2013-07047

CR-CNS-2013-07056

CR-CNS-2013-07060

CR-CNS-2013-07061

CR-CNS-2013-07063

CR-CNS-2013-07137

CR-CNS-2013-07397

CR-CNS-2013-07442

Work Orders

4895484

4895569

4895654

4895870

4921123

4932446

4954675

4958736 4978976

Section 1R22: Surveillance Testing

Miscellaneous Documents

Number Title Revision

Appendix A Valve Stroke Time Summary 223

Engineering Evaluation, "Reconfiguration

DGDO-V-19 from Open to Close"

01-081 Engineering Evaluation, "Determination of Fuel Oil Specific Gravity for Use in Diesel Fuel Oil Transfer Pump IST Testing" 0

Procedures

Number Title Revision 3.9 Engineering Procedure, "ASME OM Code Testing of Pumps and Valves"

6.CRD.201 Surveillance Procedure, "North and South SDV Vent and Drain Valve Cycling, Open Verification, and Timing Test"

6.DG.603 Surveillance Procedure, "Diesel Fuel Oil Incoming Truck Sample" 21 6.1DG.401 Surveillance Procedure, "Diesel Generator Fuel Oil Transfer Pump IST Flow Test (Div 1)"

Condition Reports

(CRs)

CR-CNS-2013-06774

Work Orders

4908790

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Number Title Revision

EPIP 5.7.1 Emergency Classification 49

Section 4OA1: Performance Indicator Verification

Miscellaneous Documents

Title Revision

Mitigating Systems Performance Index (MSPI) Basis Document 7

Procedures

Number Title Revision 0-EN-LI-114 Entergy Procedure, "Performance Indicator Process" 5C0

Condition Reports

(CRs)

CR-CNS-2013-07693

Section 4OA2: Problem Identification and Resolution

Miscellaneous Documents

Number Title Revision 13-009 Engineering Evaluation, "Evaluation of the SLC Test, Storage, and Mix Tanks for Seismic"

13-010 NEDC, "CNS SLC Storage, Test, and Mix Tanks Seismic Qualification"

2013-01 Radiation Work Permit, "RP Activities" 1 2013-078 Radiation Work Permit, "RP Activities in SWP Areas" 1

Procedures

Number Title Revision 9.ALARA.4 RAD Protection Procedure, "Radiation Work Permits" 17

9.EN-RP-100 RAD Protection Procedure, "Radiation Worker Expectations"

9.EN-RP-101 RAD Protection Procedure, "Access Control For Radiologically Controlled Areas"

Condition Reports

(CRs)

CR-CNS-2012-10636

CR-CNS-2013-02328

CR-CNS-2013-03572

CR-CNS-2013-07205 CR-CNS-2013-07506