IR 05000298/2013004

IR 05000298-13-004; 06/23/2013 - 09/22/2013; Cooper Nuclear Station; Integrated Resident & Regional Report; Equipment Alignment, Maintenance Effectiveness, Operability Determinations & Functionality Assessments, and Maintenance of Emergency

ML13316B602
Person / Time
Site:	Cooper
Issue date:	11/12/2013
From:	Allen D B NRC/RGN-IV/DRP/RPB-C
To:	Limpias O A Nebraska Public Power District (NPPD)
Allen D B
References
IR-13-004
Download: ML13316B602 (60)

Text

November 12, 2013

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 05000298/2013004

Dear Mr. Limpias:

On September 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. On October 7, 2013, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented four findings of very low safety significance (Green) in this report. All of these findings were determined to involve violations of NRC requirements. Further, inspectors documented a licensee-identified violation, which was determined to be of very low safety significance, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

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 No.: 50-298 License No: DPR-46

Enclosure:

Inspection Report 05000298/2013004 w/

Attachments:

1. Supplemental Information 2. Information Request for Inspection Activities

cc w/ encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000298/2013004; 06/23/2013 -09/22/2013; Cooper Nuclear Station; Integrated Resident & Regional Report; Equipment Alignment, Maintenance Effectiveness, Operability Determinations & Functionality Assessments, and Maintenance of Emergency Preparedness

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Four Green, non-cited violations of significance were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310,

"Components Within the Cross-Cutting Areas." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," associated with the licensee's failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272. Specifically, incompatible grease was introduced into the valve causing increased friction and degrading stroke times. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2013-04327.

The failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272 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. Specifically, the licensee introduced an incompatible grease into HV-AO-272 causing increased friction and degrading stroke times, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 safe ty 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 work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures H.4(b)(Section 1R04).

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," associated with the licensee's failure to establish goals per paragraph (a)(1), and monitor the performance of the drains for the reactor building, control building, and diesel generator building against these goals following the determination that the licensee had failed to adequately monitor the performance of the drains. Specifically, following the identification of NCV 05000298/2012005-02, "Failure to Adequately Monitor the Performance of Roof Drains" in Inspection Report 05000298/2012005, the license moved the systems to 50.65(a)(1) status but failed to establish goals as required. The licensee entered this issue into their corrective action program for resolution as Condition Report CR-CNS-2013-06590.

The failure to establish goals for systems in 50.65(a)(1) status was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against the external factors attribute of the Mitigati ng Systems Cornerstone. Specifically, the failure to establish goals and monitor the drains for the reactor building, control building, and diesel generator buildings against these goals could result the failure to detect deteriorating performance, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609,

Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 work practices component because the licensee failed to define and effectively communicate expectations regarding procedural compliance and personnel follow procedures. Specifically, licensee personnel failed to follow procedural guidance that required goals and monitoring when the systems were placed in 50.65(a)(1) monitoring H.4(b)(Section 1R12).

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 follow Station Procedure 0.5OPS, "Operations Review of Condition Reports/Operability Determination," and properly document the basis for operability when degrading or nonconforming condition was identified.

Specifically, the licensee failed to consider that failure of a relay prevented residual heat removal Division II minimum flow valve RHR-MOV-16B from opening automatically when residual heat removal pump B flow was lowered, and concluded a failure of the replacement relay would not have an adverse effect on nuclear safety. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2013-06455.

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.

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 system, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 adopt a requirement to demonstrate that the proposed action was safe in order to proceed, rather than a requirement to demonstrate that it was unsafe in order to disapprove the action H.1(b)

(Section 1R15).

Cornerstone: Emergency Preparedness

Green.

The inspector identified a non-cited violation of 10 CFR Part 50, Appendix E, IV.E(8)(d), for failure to implement by June 20, 2012, a facility that would be accessible even if the site is under threat of or experiencing hostile action to function as a staging area for augmentation. Specifically, the licensee's implementation of a staging area at the Auburn, Nebraska, Offsite Response Facility would have created impediments to effective Joint Information Center operations.

The failure to provide a facility accessible when the site is experiencing or under threat of hostile action is a performance deficiency within the licensee's ability to foresee and correct. This finding is more than minor because it affected the facilities and equipment attribute of the Emergency Preparedness Cornerstone. The finding is of very low safety significance because it was a failure to comply with NRC requirements and was not a loss of planning standard function. The planning standard function was not lost because the finding affected an alternate facility and the impediments would not have precluded the Joint Information Center from fulfilling its emergency functions. The licensee has entered this issue into their corrective action system as Condition Report CR-CNS-2013-04765. This finding was assigned a cross-cutting aspect in the area of human performance associated with the resource component because the licensee did not provide and maintain adequate emergency facilities, and the finding is reflective of current performance H.2(d) (Section 1EP5).

B. Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and associated corrective action tracking number is listed in Section 4OA7 of this report.

PLANT STATUS

The Cooper Nuclear Station began the inspection period at full power on June 23, 2013. On June 29, 2013, the licensee lowered power to approximately 30 percent to effect repairs to main feedwater heater 4B. On June 30, 2013, while increasing power the licensee discovered a stem to disk separation of main turbine control valve 3. The licensee held power at 95 percent due to this issue. On July 20, 2013, the licensee lowered power to approximately 55 percent to effect repairs to main turbine control valve 3. On July 22, 2013, the licensee increased power to 100 percent where it remained for the rest of the reporting period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors reviewed the licensee's adverse weather procedures for seasonal high temperatures and seasonal cold temperatures, and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of the hot and cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous summer and winter seasons.

The inspectors reviewed plant design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. The inspectors verified that operator actions specified in these procedures maintained readiness of essential equipment and systems to preclude weather induced initiating events. The inspectors reviewed the Updated Final Safety Analysis Report and the performance requirements for selected systems to ensure that selected system components would reasonably remain functional if challenged by adverse weather. The inspectors' reviews focused specifically on the following plant systems:

• September 6, Diesel generators 1 and 2 The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into its corrective action program for resolution. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample to evaluate the readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On September 6, 2013, the inspectors walked down the service water discharge piping because its safety-related function could be affected, as a result of high winds, tornado-generated missiles, or the loss of offsite power. The inspectors evaluated the plant staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant design features and the licensee's procedures to respond to tornados and high winds. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report and performance requirements for the system selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action progr am items to verify that the licensee had identified adverse weather issues at an appropriate threshold and entered them into the corrective action program for resolution. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

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

• July 19, Core spray B and residual heat removal B suction strainer

• August 7, Diesel generator 1 starting air

• September 11, Service water Division 1 strainer and pumps The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected, while considering out of service time, inoperable or degraded conditions, recent system outages, and maintenance, modification, and testing. The inspectors attempted to identify any discrepancies that could affect the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples, as defined in Inspection Procedure 71111.04-05

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," associated with the licensee's failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272.

Description.

The inspectors selected Condition Report CR-CNS-2013-02324, which had been initiated due to degraded stroke times for HV-AO-272, for review based on the valve's risk significance and previously identified issues with degrading stroke times for the valve. The licensee's evaluation determined the likely cause of the degrading stroke times for HV-AO-272 was the use of petroleum based grease, which was not compatible with the ethylene propylene actuator piston seals for HV-AO-272. The petroleum based grease degrades the seal material, causing swelling which resulted in increased actuator friction and longer closing stroke times. The licensee initiated the following corrective actions based on the conclusion of thei r evaluation documented in Condition Report CR-CNS-2013-02324:

(1) refurbish HV-AO-272 using the vendor recommended grease compatible with the ethylene propylene actuator piston seals, completed in September 2013; and

(2) update Station Procedure 7.2.51.7, "Bettis Models N521-SR and N721-SR Actuator Maintenance," Revision 4, to incorporate vendor recommended grease. This procedure was initially issued in 1995, using the incompatible petroleum

based grease. During the inspectors' review of the evaluation documented in Condition Report CR-CNS-2013-02324, and control room emergency system health reports, the inspectors noted that HV-AO-272 degraded strokes times had begun in the 2007 timeframe. The inspectors determined that the incompatible grease was introduced in the 2007 timeframe, after the initial issue date for Station Procedure 7.2.51.7.

The inspectors also noted that HV-AO-272 was refurbished in 2009, for a failed actuator and again in 2011, due to degrading strokes times. The inspectors questioned if the use of petroleum based grease was evaluated in accordance with station procedures and if there was a programmatic issue with the station work planning process. To capture this concern in the station's corrective action program, the licensee initiated Condition Report CR-CNS-2013-04327. The licensee subsequently performed an Apparent Cause Evaluation, and documented it in Condition Report CR-CNS-2013-04327. Their evaluation determined that the contributing cause for the incompatible grease being used during the rebuild of HV-AO-272 in 2007 was that the requirements of Station Procedure 0.40.4, Revision 5, were not followed. Specifically, the procedure required work order materials to be determined adequate for the application by using controlled documents and that mis-matches in material/equipment safety classifications are resolved. This error was not detected and subsequently repeated during planning of the 2009 and 2011 corrective maintenance work orders for HV-AO-272. To capture this concern in the station's corrective action program, the licensee initiated Condition Report CR-CNS-2013-05177. The evaluation, documented in Condition Report CR-CNS-2013-05177, determined that engineering had developed 15 generic Quality (Q) number evaluations, because in the past work was held up while developing specific Q number evaluation for miscellaneous parts. These generic Q numbers covered items such as terminal boxes, conduit, gaskets, and thread lubricants for O-ring. Additionally, Station Procedure 0-CNS-WM-105, "Planning," Revision 6, called for station planners to use these generic Q numbers to resolve mis-matches in safety classifications of materials used in work orders, which superseded Station Procedure 0.40.4. Therefore, the station concluded that this is a legacy issue and it appears station personnel followed the Station Procedure 0.40.4 and used generic Q number Q-Gen-002 that allowed use of the incompatible grease since it was listed in Station Procedure 7.2.51.7. The inspectors noted this was contrary to the contributing cause documented in Condition Report CR-CNS-2013-04327. The inspectors reviewed the procedures, work orders and the generic Q number evaluation. During this review the inspectors determined that the licensee had failed to follow the requirements of Station Procedures 0.40.4 and 0-CNS-WW-105. Inspectors determined that the planners had used Station Procedures 0.40.4 and 0-CNS-WW-105 to identify that Q-GEN-002 existed, but had failed to review Q-GEN-002 to determine if there were any restrictions associated with its use. Specifically, the instructions limited the use of O-ring lubricants on environmental qualified components to Parker Super O-ring lubricant. The use of any other O-ring lubricant shall be approved by engineering and it did not authorize the use of petroleum based grease with the ethylene propylene actuator piston seals for HV-AO-272.

Analysis.

The failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272 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. Specifically, the licensee introduced an incompatible grease into HV-AO-272 causing increased friction and degrading stroke times, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures H.4(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," states, in part, that measures shall be established to assure the design bases are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, from November 2007, to September 2013, the licensee failed to establish measures to assure design bases was correctly translated into specification. Specifically, measures established by the licensee failed to ensure vendor recommended grease was correctly translated into specification for the control room emergency filter system safety-related air operated valves. This violation is being treated as a non-cited violation (NCV), 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-2013-04327. (NCV 05000298/2013004-01, "Failure to Maintain Design Control of the Control Room Emergency Filter System

Safety-related Air Operated Valve")

.2 Complete Walkdown

a. Inspection Scope

On September 13, 2013, the inspectors performed a complete system alignment inspection of the Division II 125 Vdc and 250 Vdc system to verify the functional capability of the system. The inspectors selected this system based on risk-informed insights from site-specific risk studies together with other factors, such as engineering analysis and judgment, operating experience, performance history, current plant mode, and/or previous walkdowns. The inspectors reviewed plant procedures, including abnormal and emergency drawings, the Updated Safety Analysis Report, and vendor manuals to determine the correct lineup. The inspectors also visually inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, and the operability of support systems. Furthermore, the inspectors ensured that ancillary equipment or debris did not interfere with equipment operation. The inspectors also reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved.

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

These activities constitute completion of one complete system walkdown sample, as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• July 9, Battery room 1A, Fire Area IV(A), Zone 8E

• July 9, DC switchgear room 1A, Fire Area IV(A), Zone 8H

• July 9, Diesel generator room 1A, Fire Area IX, Zone 14A

• July 9, Diesel generator 1A diesel oil day tank room, Fire Area IX, Zone 14C The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; had effectively maintained fire detection and suppression capability; had maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition, and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program.

These activities constitute completion of four quarterly fire-protection inspection samples, as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On August 29, 2013, the inspectors observed a fire brigade activation in the 903 feet corrider of the Control Building. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene;

(5) effectiveness of fire brigade leader communications, command, and control;

(6) search for victims and propagation of the fire into other plant areas;

(7) smoke removal operations;

(8) utilization of preplanned strategies;

(9) adherence to the preplanned drill scenario; and

(10) drill objectives.

These activities constitute completion of one annual fire-protection inspection sample, as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the area listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• August 19, Manhole ZHH-44 These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On July 17, 2013, the inspectors observed a crew of licensed operators in the plant's simulator during requalification training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations and the quality of the training provided

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the operators' performance of the following activities:

• July 11, 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for the reactor core isolation cooling inservice test and operability run brief

• July 18, 1.00 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> for light smoke in training support building

• September 3, 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for the diesel generator 1 monthly operability run

• September 6, 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for the Division 1 rod operability checks and brief In addition, the inspectors assessed the operators' adherence to plant procedures, including the 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 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• July 2, Division II 125 and 250 Vdc

• September 13, Division II residual heat removal system pump B maintenance rule function failure evaluations

• September 22, Diesel generator 2 jacket water system The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

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

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1) The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were appropriately handled by a screening and identification process and that issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12-05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants,"

associated with the licensee's failure to establish goals per paragraph (a)(1), and monitor the performance of the drains for the reactor building, control building, and diesel generator building against these goals following the determination that the licensee had failed to adequately monitor the performance of the drains.

Description.

On February 14, 2013, the NRC issued Inspection Report 05000298/2012005 (ML13045A297), which documented non-cited violation NCV 05000298/2012005-02, "Failure to Adequately Monitor the Performance of Roof Drains," for the licensee's failure to adequately monitor the performance of roof drains for the reactor building, control building, and diesel generator building. Specifically, inspectors had determined that the licensee was not appropriately monitoring the roof drains to ensure that their performance or condition had been demonstrated to be effectively controlled. The licensee entered this issue into the corrective action program as Condition Report CR-CNS-2012-05993. The licensee subsequently moved the roof drains into 50.65(a)(1) status and initiated Condition Report CR-CNS-2013-00466 to develop an (a)(1) action plan.

On August 20, 2013, while attending a scheduled meeting of the station's maintenance rule expert panel, inspectors reviewed the licensee's (a)(1) action plan documented in Condition Report CR-CNS-2013-00466. During this review inspectors noted that the licensee had not established goals with monitoring criteria for the roof drains. Instead, the licensee stated that Station Procedure EN-DC-206, "Maintenance Rule (A)(1) Process," Revision 1, Section 5.2[9] allowed the system to be placed in (a)(1) monitoring without goals per System Engineering Management discretion.

Inspectors noted that 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance of a system is being effectively controlled through the performance of appropriate preventive maintenance, such that the system remains capable of performing its intended function. Since NCV 05000298/2012005-02 had been issued because the licensee had failed to adequately monitor the performance of the drains, inspectors determined that the licensee was required to comply with the actions of paragraph (a)(1) which required the establishment of goals and monitoring the drains performance against these goals. Furthermore, inspectors reviewed Procedure EN-DC-206 and noted that Section 5.2[9] provided that a structure, system, or component within the scope of the Maintenance Rule that has not exhibited a monitoring failure may be classified as (a)(1) at management's discretion. However, the section did not alleviate the need to establish goals and monitor against these goals. Section 5.2[9](f) directed that the (a)(1) action plan preparation proceed per Section 5.3 of the procedure, and Section 5.3[4](h) directed the development of performance goals and Section 5.3[4](i) directed monitoring against these goals.

Inspectors determined that the licensee had failed to establish goals, and monitor performance against these goals, for the roof drains on the reactor building, control building, and diesel generator building after placing them in 50.65(a)(1) status.

Inspectors informed the licensee of their concern and the licensee entered this issue into their corrective action program for resolution as Condition Report CR-CNS-2013-06590.

Analysis.

The failure to establish goals for systems in 50.65(a)(1) status was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone. Specifically, the failure to establish goals and monitor the drains for the reactor building, control building, and diesel generator buildings against these goals could result in the failure to detect deteriorating performance, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 work practices component because the licensee failed to define and effectively communicate expectations regarding procedural compliance and personnel follow procedures. Specifically, licensee personnel failed to follow procedural guidance that required goals and monitoring when the systems were placed in 50.65(a)(1) monitoring H.4(b).

Enforcement.

Title 10 CFR 50.65(a)(1) requires, in part, that, holders of an operating license shall monitor the performance or condition 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 functions. Contrary to the above, between January 21, and September 19, 2013, the licensee failed to establish goals in a manner sufficient to provide reasonable assurance that structures, systems or components are capable of fulfilling their intended safety function. Specifically, the licensee failed to establish goals in a manner sufficient to provide reasonable assurance that the roof drains for the reactor building, control building, and diesel generator building are capable of fulfilling their intended safety functions.his 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-2013-06455. (NCV 05000298/2013004-02, "Failure to Establish Goals and Monitor for the Roof Drain Systems")

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• July 2, Residual heat removal service water Division I

• July 18, Residual heat removal Division II valves RHR-MO-16B and -26B Appendix R modifications

• August 30, Diesel generator 2 availability during core spray time delay functional surveillance

• September 6, Service water Division I and II discharge pipe repair

• September 19, Crane operation near loaded spent fuel horizontal storage modules The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• July 3, Main turbine control valve 3 and thermal limits

• August 5, Service water Division I and II discharge piping

• August 9, Diesel generator 2 driven lube oil pump

• September 4, 18 feet feedwater line break on the 903 feet level of the reactor building

• September 16, Residual heat removal pump B GE CR120AD relay The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems along with other factors, such as engineering analysis and judgement, operating experience, and performance history. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and the Updated Final Safety Analysis Report to the licensee's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples, as defined in Inspection Procedure 71111.15-05.

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.

The inspectors selected Condition Reports CR-CNS-2013-04081 and CR-CNS-2013-06203 for review based on their risk significance and previously identified failure of a relay associated with residual heat removal pump B. The relay failure occurred after 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> of operation on June 2, 2013. This failure prevented residual heat removal Division II minimum flow valve RHR-MOV-16B from opening automatically when residual heat removal pump B flow was lowered, and the reactor building southwest quad fan coil unit from starting and operating in conjunction with residual heat removal pump B. The licensee immediately declared residual heat removal pump B inoperable and replaced the relay on June 2, 2013. The licensee entered this issue in the station's corrective action program for resolution as Condition Report CR-CNS-2013-04081.

During their review of the apparent cause evaluation, documented in Condition Report CR-CNS-2013-04081, inspectors noted the following:

(1) the identified apparent cause was a manufacturing defect present at the time of installation causing an infant mortality type failure, as documented in 10 CFR Part 21, Notification 97-62-0, "Short circuit of coil of Type CR120AD relays," issued in June 1997;

(2) the contributing cause was an inadequate qualification/testing process which failed to identify the manufacturing defect; and

(3) from the extent of condition review the replacement relay installed on June 2, 2013, was part of the same equipment batch as the failed relay, and

(4) the licensee concluded that the failure of the relay would not have an adverse effect on nuclear safety. The licensee initiated the following corrective actions:

(1) add to the purchase requirements for CR120AD relays to go through a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> "burn-in" period and then cycle the relay 100 times to prevent infant mortality failures caused by undetected manufacturing detects; and

(2) initiated Condition Report CR-CNS-2013-06203 to create a work order to replace the residual heat removal pump B's relay installed on June 2, 2013, with a relay that has passed a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> burn-in period with 100 cycles at the next available opportunity.

Inspectors reviewed Condition Report CR-CNS-2013-06203 and its documented operability evaluation. During this review they noted that the licensee concluded that this condition report does not identify an equipment deficiency and that residual heat removal pump B remains operable. Specifically, the evaluation stated this is a work order request to replace the relay with one that has undergone a burn-in and cycle test to ensure it has operated beyond a period of infant mortality and that the relay installed on June 2, 2013, would not have an adverse effect on nuclear safety.

The licensee had only evaluated operability associated with the reactor building southwest quad fan coil unit and did not assess operability associated with RHR-MOV-16B. Specifically, the licensee failed to consider that failure of this relay could have prevented residual heat removal Division II minimum flow valve RHR-MOV-16B from opening automatically when residual heat removal pump B flow was lowered. Therefore, the licensee had concluded that a failure of the replacement relay would not have an adverse effect on nuclear safety.

Inspectors questioned the licensee's operability determination. Specifically, if the currently installed relay was part of the same equipment batch as the failed relay, and the failure was caused by a manufacturing defect, why there was assurance that the same condition was not present in the installed relay. Based on this, inspectors determined the licensee's operability evaluation was not adequate to fully establish the pump's operability. Inspectors informed the licensee of their concerns. To capture this concern, in the station's corrective action program, the licensee initiated Condition Report CR-CNS-2013-06455.

As an immediate action, the licensee completed an operability evaluation that considered the relay's hours of operation and burn-in requirement. The licensee determined residual heat removal pump B had been started eleven times with a combined run time of approximately 83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> with no discrepancies noted. From the 83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> of successful run time with no indication of failures and no vendor recommended requirement to perform a "burn-in," the licensee concluded the residual heat removal pump B, and its associated auxiliary functions, remained operable.

The inspectors determined that the apparent cause of this finding was that the licensee had failed to use conservative assumptions and failed to adopt a requirement to demonstrate that the proposed action was safe in order to proceed, rather than a requirement to demonstrate that it was unsafe in order to disapprove the action. The licensee had failed to validate that the failure of the relay installed on June 2, 2013, would have no adverse effect on nuclear safety and considered it acceptable to replace the relay at the next available opportunity as documented in the apparent cause evaluation extent of condition and Condition Report CR-CNS-2013-06203.

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. 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 system, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," and 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 adopt a requirement to demonstrate that the proposed action was safe in order to proceed, rather than a requirement to demonstrate that it was unsafe in order 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, an activity affecting quality was not accomplished in accordance with a procedure that was appropriate to the circumstances. Specifically, on August 30, 2013, when the licensee evaluated the operability of residual heat removal pump B for infant mortality issues from manufacturing defects with relays, the licensee did not properly assess and document the basis for operability. 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 correction action program as Condition Report CR-CNS-2013-06455. (NCV 05000298/2013004-03, "Failure to Follow Operability Procedure")

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed key parameters associated with energy needs, materials, replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as the service water Division I and II discharge pipe repair. The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures, and components' performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample for permanent plant modifications, as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• August 5: Residual heat removal Division II RHR-MO-16B and 26B Appendix R modifications

• August 19: Core spray A limiting condition for operation maintenance window

• August 20: Reactor equipment cooling Division II REC-Pump-D fuse block replacement

• September 10: Control room emerg ency filter system air operatied valve HV-AO-272 The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Updated Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors selected risk-significant surveillance activities based on risk information and reviewed the Updated Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• July 3: Reactor coolant system leak rate detection

• August 22: Reactor equipment cooling pump time delay relay testing

• August 28: Reactor building heating and ventilation secondary containment valves HV-AO-259AV and HV-AO-261AV monthly and quarterly valve operability inservice test

• September 10: Division 1 reactor recirculation flow unit channel calibration

• September 10: Division 1 rod operability checks Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone:

Emergency Preparedness

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspector discussed with licensee staff the operability of offsite emergency warning system sirens, tone alert radios, and backup alerting methods to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee's alert and notification system testing program was compared with criteria in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1; FEMA Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants," and the licensee's current FEMA-approved alert and notification system design report, "A Prompt Alert and Notification System Design Report for the Cooper Nuclear Station," Revision 12, May 2004. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02-06.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

a. Inspection Scope

The inspector discussed with the licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan. The inspector also reviewed licensee procedures for directing staff to report to alternate facilities as necessary. The inspector reviewed the documents and references listed in the attachment to this report, to evaluate the licensee's ability to staff the emergency response facilities in accordance with the licensee's emergency plan, and the requirements of 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one emergency reponse organization staffing and augmentation system sample, as defined in Inspection Procedure 71114.03-06.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

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 numbers ML13161A371 and ML13182A043 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 two samples as defined in Inspection Procedure 71114.04-06.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspector reviewed the licensee's:

• Corrective action program requirements as documented in Procedures 0.5CR, "Condition Report Initiation, Review, and Classification," Revisions 17, 18, and 19, 0-EN-LI-102, "Corrective Action Process," Revisions 19 and 20 (Changes 0, 1, 2), and 0-EN-LI-119, "Apparent Cause Evaluation Process," Revisions 15 and 16 (Changes 0, 1);

• Audit requirements as documented in Procedures 0-QA-02, "Conduct of Internal Audits," Revision 10, 0-QA-05, "QA Audit Requirements, Frequencies, and Scheduling," Revision 11, and 0-EN-QV-135, "Quality Assurance Performance Assessments," Revision 3;

• Program for determining the impact of changes to the site emergency plan as documented in Procedure 0.29.4, "Other Regulatory Reviews," Revision 18; and

• Program for evaluating performance issues identified in drills and exercises as documented in the Cooper Nuclear Station Drill and Exercise Manual, Attachments H-3, "EP Evaluation Process for Licensed Operators," and H-5, "Critique Process," Revision 6.

The inspector reviewed summaries of 323 corrective action program requests (condition reports) initiated between July 2011, and June 2013, related to the emergency preparedness program and selected 23 for detailed review against program requirements to determine the licensee's ability to identify, evaluate, and correct problems in accordance with licensee program requirements, Planning Standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The inspector reviewed summaries of 96 changes to the licensee's emergency plan and implementing procedures made between January 2012 and June 2013, and selected 18 for review against the licensee program requirements to determine the licensee's ability to identify reductions in the effectiveness of the emergency preparedness program in accordance with the requirements of 10 CFR 50.54(q)(4) and 50.54(q)(5). The inspector reviewed 12 after-action reports against program requirements to determine the licensee's ability to identify weaknesses in accordance wi th licensee program requirements and planning standard 50.47(b)(14).

The inspector also observed the licensee's offsite response facility at Auburn, Nebraska, to determine the licensee's capability to assemble emergency response organization members when access to the licensee's site is impeded. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one maintenance of emergency preparedness sample, as defined in Inspection Procedure 71114.05-06.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation for the licensee's failure to implement an alternate staging area for emergency response organization staff normally assigned to onsite emergency response facilities, accessible when the site is under threat of, or experiencing, hostile action, as required by Appendix E to 10 CFR Part 50, IV.E(8)(d).

Description.

The NRC identified that the licensee failed to implement an alternate staging area accessible when the site is under threat of or experiencing hostile action.

Specifically, the licensee's implementation of an alternate staging area for emergency response organization staff normally assigned to onsite emergency response facilities at the Auburn, Nebraska, Offsite Response Facility would have conflicted with the response of the licensee's Joint Information Center.

The Cooper Nuclear Station's Auburn, Nebraska, Offsite Response Facility normally houses the licensee's Emergency Operations Facility and Joint Information Center. The inspector reviewed the licensee's plans for locating an alternative staging area at the Offsite Response Facility for emergency response organization personnel normally assigned to onsite emergency response facilities. The inspector determined the licensee had means to inform all emergency response organization staff to report to the Offsite Response Facility as needed, and had appropriately trained staff about how they would be notified to report to the alternate location. However, the licensee had not described the alternate staging area in Emergency Plan, Revision 63, or prepared procedures or other guidance for implementing the staging area.

The inspector visited the Offsite Response Facility on June 27, 2013, to determine whether licensee plans could be effectively implemented. Licensee representatives described that relocated Technical Support Center staff would be placed in working rooms in the Joint Information Center, and relocated Operations Support Center staff would be placed in the building lobby and adjacent press work room. The licensee stated that Technical Support Center staff would occupy some work stations normally assigned to Joint Information Center staff, potentially displacing or reducing existing staff.

The inspector determined that:

• The licensee had not identified specific locations for Technical Support Center staff and had not evaluated how the Technical Support Center and Joint Information Center staff would function in a co-located space;

• Implementation of the alternate staging area could displace Joint Information Center staff required by the site emergency plan;

• Use of the building lobby and press work room would affect access to the Joint Information Center auditorium;

• The licensee had not trained Joint Information Center, Technical Support Center, or Operations Support staff in implementing the staging area; and

• The licensee had not identified how to provide news organization access to the Joint Information Center auditorium when the building was used as an alternate facility, or how to provide appropriate facility access control or security.

Based on the above, the inspector concluded that implementing an alternate staging area for the relocated onsite emergency response organization at the Auburn, Nebraska, Offsite Response Facility would conflict with functions of the Joint Information Center.

Analysis.

The inspector determined that failure to provide a facility accessible when the site is under threat of or experiencing hostile action is a performance deficiency within the licensee's ability to foresee and correct. This finding is more than minor because it affected the facilities and equipment emergency preparedness cornerstone attribute (maintenance, surveillance, and testing of facilities). The finding had a credible impact on the cornerstone objective because the licensee's ability to implement adequate measures to protect the health and safety of the public during a radiological emergency would be affected if it could not stage personnel to respond to the site during events involving hostile action, or in other events in which access to the site is impeded. The ability to communicate measures to protect the health and safety of the public would also be affected if there were impediments to Joint Information Center operations. The finding was associated with a violation of NRC requirements. This finding was evaluated using IMC 0609, Appendix B, "Emergency Preparedness Significance Determination Process" and was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a loss of planning standard function. The planning standard was not lost because the finding affected an alternate facility and the impediments would not have precluded the Joint Information Center from fulfilling its emergency functions. This finding was assigned a cross-cutting aspect in the area of Human Performance associated with the resources component because the licensee did not provide and maintain adequate emergency facilities, and the finding is reflective of current performance H.2(d).

Enforcement.

Title 10 CFR 50.54(q)(2) states, in part, "a holder of a license-shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E-, and for nuclear power reactor licensees, the planning standards of 50.47(b)." Planning standard 50.47(b)(8) requires that adequate emergency facilities to support the emergency response are provided and maintained. Appendix E to Part 50, Part IV.E(8)(d), requires a licensee to have by June 20, 2012, a facility that would be accessible even if the site is under threat of or experiencing hostile action to function as a staging area for augmentation. The Cooper Nuclear Station Emergency Plan, Revision 63, Section 7.2.4, requires a Joint Information Center. Contrary to the above, between June 20, 2012, and June 27, 2013, the Cooper Nuclear Station did not have a facility accessible even if the site is under threat of or experiencing hostile action.

Specifically, implementation of a staging area accessible when the site is under threat of or experiencing hostile action would have created impediments to the effective operation of the licensee's Joint Information Center. Because this failure is of very low safety significance and has been entered into the licensee's corrective action program CR-CNS-2013- 04765, this violation is being treated as an non-cited violation, consistent with Section 2.3.2a of the NRC Enforcement Policy: NCV 05000298/2013004-04, "Failure to Provide a Staging Area for Augmented Emergency Response Personnel When the Site Is Not Accessible."

RADIATION SAFETY

Cornerstones:

Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

This area was inspected to:

(1) review and assess the licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures;

(2) verify the licensee is properly identifying and reporting Occupational Radiation Safety Cornerstone performance indicators; and

(3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements, and reviewed the following items:

• Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone

• The hazard assessment program, including a review of the licensee's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

• Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

• Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

• Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements

• Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.01-05.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:

• Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

• ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements

• The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

• Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

• Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05.

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

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the first quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."

This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, and NRC integrated insp ection reports for the period of July 2012 through June 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one unplanned scrams with complications sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspector sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period July 2012, through March 2013. The performance indicator guidance and definitions of NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, were used to determine the accuracy of the reported performance indicator data. The inspector reviewed the licensee's records associated with the performance indicator to ve rify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions, performance during the 2012 biennial exercise, and performance during other drills. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspector sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period July 2012 through March 2013.

The performance indicator guidance and definitions of NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, were used to determine the accuracy of the reported performance indicator data. The inspector reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records.

The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the emergency response organization drill participation sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.5 Alert and Notification System (EP03)

a. Inspection Scope

The inspector sampled licensee submittals for the Alert and Notification System performance indicator for the period July 2012, through March 2013. The performance indicator guidance and definitions of NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, were used to determine the accuracy of the reported performance indicator data. The inspector reviewed the licensee's records associated with the performance indicator to ve rify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the alert and notification system sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the third quarter 2012 through the second quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area nonconformances.

The inspectors reviewed radiological, controlled area exit transactions greater than 100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.7 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the fourth quarter 2012 through the second quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensee's corrective action program records and selected individual annual or special reports to identify potential occurrences, such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting residual heat removal Division II residual heat removal pump B, minimum full valve RHR-MOV-16B, and reactor building southwest quad fan coil unit issues due to a relay failure.

During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item dealing with residual heat removal system Division II. The inspectors considered the following, as applicable, during the review of the licensee's actions:

(1) complete and accurate identification of the problem in a timely manner;

(2) evaluation and disposition of operability/reportability issues;

(3) consideration of extent of condition, generic implications, common cause, and previous occurrences;

(4) classification and prioritization of the resolution of the problem;

(5) identification of apparent causes and contributing causes of the problem;

(6) identification of corrective actions; and

(7) completion of corrective action in a timely manner.

These activities constitute completion of one in-depth problem identification and resolution sample, as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA5 Other Activities

(Closed) Violation 05000298/2012004-02, "Failure to Demonstrate that Emergency Diesel Generators can Perform Multiple Air Starts from a Single Air Receiver (EA-12-206)"

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 testing of one diesel generator, and generation of an acceptable analysis demonstrating compliance for the other diesel generator. The inspectors determined that these actions have addressed the concerns expressed in the violation. This violation is closed.

4OA6 Meetings, Including Exit Exit Meeting Summary

On June 28, 2013, the inspector presented the results of the onsite inspection of the licensee's emergency preparedness program to Mr. K. Higginbotham, General Plant Manager, Operations, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On August 8, 2013, the inspectors presented the results of the radiation safety inspections to Mr. D. Buman, Director, Engineering, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. One document was identified as proprietary by licensee personnel, so the document was returned to the licensee after the inspectors' review.

On October 7, 2013, the inspectors presented the inspection results to Mr. O. Limpias, Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

Emergency Response Organization Position not Staffed Title 10 CFR 50.54(q)(2), requires that a power reactor licensee follow an emergency plan that meets the requirements of 10 CFR 50.47(b) and Appendix E to Part 50.

Title 10 CFR 50.47(b)(1), requires that a licensee have staff to augment its initial emergency response. Section 5.3.1 of the Cooper Nuclear Station Emergency Plan, Revision 63, requires Joint Information Center management to be supported by the Joint Information Center Facility Manager. Contrary to the above, between approximately May 1 and July 10, 2012, the Cooper Nuclear Station did not follow an emergency plan that met the requirements of 10 CFR 50.47(b) and Appendix E to Part 50. Specifically, it did not follow emergency plan Section 5.3.1 of the Cooper Nuclear Station Emergency Plan because there were no qualified staff assigned to the position of Joint Information Center Facility Manager. This finding was more than minor because it affected the emergency response organization readiness cornerstone attribute (duty roster). The finding was evaluated by the Emergency Preparedness Significance Determination Process and determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, and was not a loss of planning standard function. The planning standard function was not lost because the Joint Information Center would have been able to perform its emergency function without a Joint Information Center Facility Manager, although in a degraded manner. This finding was entered into the licensee's corrective action program as Condition Report CR-CNS-2012-04492.

A1-

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

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

J. Dixon, ALARA Supervisor, Radiation Protection

M. Ferguson, Manager, Emergency Preparedness

K. Higginbotham, General Plant Manager, Operations

K. Fike, Plant Chemist, Chemistry

J. Flaherty, Senior Staff Licensing Engineer, Licensing

D. Madsen, Senior Staff Engineer, Licensing

R. Morris, Specialist, Radiation Protection

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

05000298/2013004-01 NCV

Failure to Maintain Design Control of the Control Room Emergency Filter System Safety-related Air Operated Valve (Section 1R04)

05000298/2013004-02 NCV Failure to Establish Goals and Monitor for the Roof Drain Systems (Section 1R12)

05000298/2013004-03 NCV Failure to Follow Operability Procedure (Section 1R15)

05000298/2013004-04 NCV Failure to Provide a Staging Area for Augmented Emergency Response Personnel When the Site Is Not Accessible (Section 1EP5)

Closed

05000298/2012004-02 VIO Failure to Demonstrate that Emergency Diesel Generators can Perform Multiple Air Starts from a Single Air Receiver

(EA-12-206) (Section 4OA5)

Section 1R01: Adverse Weather Protection

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION 12-004 Special Procedure, "Service Water Discharge Piping Repair Missile/Freeze Protection"

91-103 NEDC : 4908683 Temporary Configuration Change, "Service Water Discharge Pipe Repair Headwall and Tie-In Cofferdam"

CONDITION REPORTS

CR-CNS-2013-05986

Section 1R04: Equipment Alignment

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION 11-072 NEDC, "Diesel Generator Starting Air Receiver Sizing Basis" 1 12-053 Engineering Evaluation, "Service Water Pumps Deviation Evaluations"

87-131B NEDC, "250 Vdc Division II Load and Voltage Study" 12 88-209 NEDC, "250 V Battery Rack Mounting, Charge Mounting, and Test Reviews"

95-204 NEDC

97-44A NEDC 4C3

97-131D NEDC, "125 Vdc Division II Load and Voltage Study" 13 2077 Burns & Roe, "Diesel Generator Building Service Water, Starting Air, Fuel Oil, Sump System and Roof Drains"

N78 2008-023 Licensing Basis Change Request

2013-00088 Learning Organization

21080 Change Evaluation Document, "Replacement Service Water Pump Bowl Assembly"

PROCEDURES

NUMBER TITLE REVISION 2.2A_125VDC.DIV2 Operations Procedure, "125VDC Power Checklist (DIV2) 6 2.2A_250VDC.DIV2 Operations Procedure, "250VDC Power Checklist (DIV2)" 0

CONDITION REPORTS

CR-CNS-2011-09022

CR-CNS-2012-01963

CR-CNS-2012-03460

CR-CNS-2012-04156

CR-CNS-2012-05937

CR-CNS-2012-09072

CR-CNS-2012-09691

CR-CNS-2013-00386

CR-CNS-2013-00474

CR-CNS-2013-03739 CR-CNS-2013-04379

Section 1R06: Flood Protection Measures

WORK ORDERS

4930558

Section 1R11: Licensed Operator Requalification Program

MISCELLANEOUS DOCUMENTS

NUMBER TITLE

3A Emergency Operating Procedure

5A Emergency Operating Procedure Emergency Action Level

PROCEDURES

NUMBER TITLE REVISION 5.1Incident Emergency Procedure, "Site Emergency Incident" 26

5.1Quake Emergency Procedure, "Earthquake" 11 6.CRD.301 Surveillance Procedure, "Withdrawn Control Rod Operability IST Test"

Section 1R12: Maintenance Effectiveness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

EE-PF01B Engineering Evaluation, "250VDC Charger 1B, from the charger to Div II Bus"

EE-PF01E Engineering Evaluation, "250VDC Div II Station Battery, from the battery to Div II Bus"

EE-PF01G Engineering Evaluation, "250VDC distribution system Div II, from the Div II to the associated loads"

REC-PF01 Maintenance Rule Function Performance Criteria Basis

RHR-F01 Maintenance Rule Function Performance Criteria Basis

93-050 NEDC, "RHR Quad Temperature with Hatches Removed" 5

CONDITION REPORTS

CR-CNS-2012-00722

CR-CNS-2013-04330

CR-CNS-2013-04332

CR-CNS-2013-06082 CR-CNS-2013-04081

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION 12-004 Special Procedure, "Service Water Discharge Piping Repair Missile/Freeze Protection"

13-025 NEDC, "Evaluation of Appendix R LASP Panels with Door Open" 0 31303-0201 "HSM-H Evaluation for a Crane Boom Drop Load" 0

4908683 Temporary Configuration Change, Service Water Discharge Pipe Repair Headwall and Tie-In Cofferdam"

PROCEDURES

NUMBER TITLE REVISION 0.41 Station Procedure, "Seismic Housekeeping" 9 0.49 Station Procedure, "Schedule Risk Assessment" 34

2.2.20 Operations Procedure, "Standby AC Power System (Diesel 88

PROCEDURES

NUMBER TITLE REVISION Generator) 6.2CS.702 Surveillance Procedure, "CS Loop B Pump Time Delay Channel Functional Test (Div 2)

CONDITION REPORTS

CR-CNS-2013-02841

CR-CNS-2013-05923

WORK ORDERS

4874941

4882379 4922893

Section 1R15: Operability Determinations and Functionality Assessments

CONDITION REPORTS

CR-CNS-2013-04081

CR-CNS-2013-04815

CR-CNS-2013-05023

CR-CNS-2013-05492

CR-CNS-2013-06203

CR-CNS-2013-06256

CR-CNS-2013-06272 CR-CNS-2013-06544

Section 1R18: Plant ModificationsMISCELLANEOUS

DOCUMENTS

NUMBER TITLE REVISION

4908683 Temporary Configuration Change

6035080 Change Evaluation Document

CONDITION REPORTS

CR-CNS-2013-05492

Section 1R19: Post-Maintenance Testing

PROCEDURES

NUMBER TITLE REVISION 6.HV.101 Surveillance Procedure, "Control Room Ventilation" 11

6.1CS.101 Surveillance Procedure, "Core Spray Test Mode Surveillance Operation (IST)(DIV 1)"

Section 1R19: Post-Maintenance Testing

PROCEDURES

NUMBER TITLE REVISION 6.1CS.201 Surveillance Procedure, "Core Spray Motor Operated Valve Operability Test (IST)(DIV 1)"

6.1CS.301 Surveillance Procedure, "A Core Spray Loop Flow Instrument Channnel Calibration (DIV 1)"

6.2RHR.201 Surveillance Procedure, "RHR Power Operated Valve Operability Test (IST)(DIV 2)"

7.0.5 Maintenance Procedure, "Post-Maintenance Testing" 45 7.2.51.7 Maintenance Procedure, "Bettis Models N521-SR and N721-SR Actuator Maintenance"

WORK ORDERS

4817788

4889429

4896287

4917843

4922893 4947803

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION 6.CRD.301 Surveillance Procedure, "Withdrawn Control Rod Operability IST Test"

6.LOG.601 Surveillance Procedure, "Daily Surveillance Log - Modes 1, 2, and 3 111 6.SC.201 Surveillance Procedure, "Secondary Containment (Reactor Building H&V) Valve Operability Test"

6.1RR.302 Surveillance Procedure, "Reactor Recirculation Flow Unit Channel Calibration (Div 1)"

6.2REC.302 Surveillance Procedure, "REC Pumps Time Delay Relay Testing and Setting (Div 2)"

CONDITION REPORTS

CR-CNS-2013-06281 CR-CNS-2013-06301

Section 1EP2: Alert and Notification System Evaluation

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

EPDG-2 Attachment C-1, Semi-Monthly Alert and Notification System Siren Testing

EPDG-2 Attachment C-5, Annual Full-Cycle Sounding of Alert and Notification System Sirens 11

EPDG-2 Attachment C-C, Annual Fixed Siren Maintenance 8

EPDG-2 Attachment C-7, Issuance of NOAA/EAS Radio Receivers 1

EPDG-2 Attachment C-8, Quarterly Review and Update of NOAA/EAS Radio Receiver Recipient Data Base

PROCEDURES

NUMBER TITLE REVISION 5.7.27 Emergency Procedure, "Alert and Notification System" 17 5.7.27.1 Emergency Procedure, "NOAA/EAS Radio Malfunction"

5.7.27.2 Emergency Procedure, "False Activation of Alert and Notification System"

Section 1EP3: Emergency Response Organization Staffing and Augmentation SystemMISCELLANEOUS

DOCUMENTS

NUMBER TITLE REVISION / DATE

EPDG-2 Attachment E-3, Bi-Monthly ERO Call-In Test 16

EPDG-2 Attachment E-4, Weekly Pager Test 1

EPDG-2 Attachment E-3, Revision 15, Bi-Monthly ERO Call Out Test

February 29, 2012

EPDG-2 Attachment E-3, Revision 15, Bi-Monthly ERO Call Out Test April 18, 2012

EPDG-2 Attachment E-3, Revision 16, Bi-Monthly ERO Call Out Test June 26, 2012

EPDG-2 Attachment E-3, Revision 16, Bi-Monthly ERO Call Out Test August 30, 2012

EPDG-2 Attachment E-3, Revision 16, Bi-Monthly ERO Call Out Test December 26, 2012

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

EPDG-2 Attachment E-3, Revision 16, Bi-Monthly ERO Call Out Test February 25, 2013

EPDG-2 Attachment E-3, Revision 16, Bi-Monthly ERO Call Out Test April 20, 2013

EPDG-2 Attachment E-4, Revision 1, Weekly Pager Tests 2012

EPDG-2 Attachment E-4, Revision 1, Weekly Pager Tests January 2 to June 11, 2013

PROCEDURES

NUMBER TITLE REVISION 5.7.2 Emergency Procedure, "Emergency Director EPIP" 29, 30, 31, 32

Section 1EP4: Emergency Action Level and Emergency Plan Changes

PROCEDURES

NUMBER TITLE REVISION

Emergency Plan 64

5.7.1 Emergency Plan Implementing Procedure, "Emergency Classification"

Section 1EP5: Maintenance of Emergency Preparedness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE 102 Nuclear Training Procedure: Emergency Preparedness Staff 3, 4

Temporary Instruction - ERO/JIC Augmentation at Alternate Facilities June 27, 2013

CNS On-Shift Staffing Analysis Report, Revision 0 December 20, 2012

EPDG-2 Attachment B-1, Monthly State Notification Telephone System Testing

Section 1EP5: Maintenance of Emergency Preparedness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

Agreement to Provide Annual Updates to the Evacuation Time Estimate Study for Cooper Nuclear Station, Agreement

200002180 June 21, 2013

Licensee Event Report 47760, Notice of Unusual Event, Potentially Hazardous Atmosphere due to Freon Leak March 22, 2012

LO-WTCNS-2011-00025 Regulatory Required Audit Frequency Evaluation September 1, 2011

LO-WTCNS-2011-00025 Regulatory Required Audit Frequency Evaluation April 11, 2012

QAD-2013-

0005 QU Audit 12-07, Emergency Plan January 31, 2013

Entergy Nuclear Cooper, Fundamental Behavior LEL Scorecard, Emergency Preparedness Department Third Quarter

2012

Entergy Nuclear CNS, Emergency Preparedness Department, Fundamentals Windows Fourth Quarter

2012

Cooper Nuclear Station, Quality Assurance Performance Assessment Report, Trimester, March to June 2012

Cooper Nuclear Station, Quality Assurance Performance Assessment Report, Trimester, July to October 2012

Cooper Nuclear Station, Quality Assurance Performance Assessment Report, Trimester, November 2012 to February

2013

Quality Assurance Status Report August 31, 2011

Quality Assurance Status Report November 11, 2011

Quality Assurance Status Report December 29, 2011

Quality Assurance Status Report April 24, 2012

Quality Assurance Status Report September 28, 2012

Section 1EP5: Maintenance of Emergency Preparedness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

Quality Assurance Status Report December 10, 2012 CR-CNS-2013-

29 Recommendations from the 13-04 NIEP QA Audit June 6, 2013

Event Critique; March 22, 2012 Notification of Unusual Event April 15, 2012

Drill Evaluation Report: August 2, 2011, Drill October 10, 2011

Drill Evaluation Report: December 27, 2011 Onsite Medical Drill January 10, 2012

Drill Evaluation Report: August 23, 2011, Drill March 1, 2012

Drill Evaluation Report: February 21, 2012, Exercise March 10, 2012 Drill Evaluation Report: September 27, 2011, Exercise April 1, 2012

Drill Evaluation Report: November 8, 2011 April 6, 2012

Drill Evaluation Report: June 19-20, 2012, Exercise July 10, 2012

Drill Evaluation Report: July 31, 2012, Exercise Drill Evaluation Report: December 18, 2012, Exercise February 16, 2013

Drill Evaluation Report: March 5, 2013, Exercise May 14, 2013

Drill Evaluation Report: May 7, 2013 Exercise May 28, 2013

CNSLO-2011-

2 Focused Assessment - Emergency Preparedness NRC Rule Making August 19, 2011 CNSLO-2012-

00022 Downwind Van Communications Equipment February 22, 2012

LO-2011-0014 CA 3 Snapshot Self-Assessment on Drill Objectives May 29, 2012

CNSLO-2012-00022-CA-00003

Siren Activation Knowledge of the County Emergency Operations Personnel June 29, 2012

LO-2012-22-CA-

Snapshot Assessment - CNS Drill Critique Process November 11, 2012

Section 1EP5: Maintenance of Emergency Preparedness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

CNS-2012-5166 Snapshot Assessment - ERO Team Structure December 31, 2012

CR-CNS-2012-

5166

CA-3 Benchmark on the Structure of OSC Controllers February 12, 2013

CNLSO-20120231 Focused Assessment February 28, 2013

LO-2013-0035-2 Snapshot Assessment on Development and Incorporation of Radiological Data into EP Drill Scenarios June 12, 2013

EPDG-2 Attachment B-1, Monthly State Notification Telephone System Testing, R12

January 8, 2013

EPDG-2 Attachment B-1, Monthly State Notification Telephone System Testing, R12

March 5, 2013

EPDG-2 Attachment B-1, Monthly State Notification Telephone System Testing, R12 May 7, 2013

EPDG-2 Attachment D-1, Revision 8, Annual Nemaha County Hospital Training December 29, 2011

EPDG-2 Attachment D-2, Revision 10, Annual Emergency Plan Training for Local Law Enforcement Agencies October 26, 2012

EPDG-2 Attachment D-4, Revision 9, Annual Volunteer Fire Department Training December 20, 2012

2012 Public Information Brochure for EPZ Residents

Emergency Preparedness Regulatory Review, Evaluation

2012-05, EPIP 5.7.2, Emergency Director, Revision 30

Change 7 March 19, 2012 Emergency Preparedness Regulatory Review, Evaluation

2012-07, EPIP 5.7.2, Emergency Director, Revision 30, Change 9 March 19, 2012 Emergency Preparedness Regulatory Review, Evaluation 2012-14, EPIP 5.7.6, Notification, Revision 54, Change 7 April 27, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012-16, Emergency Plan, Revision 60, Change 1 May 10, 2012

Section 1EP5: Maintenance of Emergency Preparedness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

Emergency Preparedness Regulatory Review, Evaluation 2012-17, Emergency Plan, Revision 60, Change 2 May 10, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012--19, Emergency Plan, Revision 60, Change 4

May 10, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012-25,

EPDG-2, Attachments H-3, EP Evaluation Process

for Limited Scope Drills, H-5, Critique Process May 29, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012-27, Emergency Plan, Revision 62,

EPIP5.7.17, Dose Assessment, Revision 38, EPIP 5.7.6, Notification, Revision Emergency Preparedness Regulatory Review, Evaluation 2012-39, EPIP 5.7.21, Maintaining Emergency Preparedness, Revision 46

Emergency Preparedness Regulatory Review, Evaluation 2012-46, 0-EP-01, Emergency Response Organization Responsibilities, Revision 21 November 9, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012-49,

EPDG-2, Attachment H-5, Critique Process, Revision 6 November 11, 2012

Emergency Preparedness Regulatory Review, Evaluation 2012-52, EPIP 5.7.6, Notification, Revision 56 December 3, 2012

Emergency Preparedness Regulatory Review, 5.7Commun, Revision 19 (addendum)

January 16, 2013

Emergency Preparedness Regulatory Review,

TPP-101, Revision 19

March 2013

PROCEDURES

NUMBER TITLE REVISION 0.40 Station Procedure, "Work Control Program" 87

2.0.3 Operations Procedure, "Conduct of Operations" 79 5.7.8.1 Emergency Procedure, "Activation of Alternate OSC" 6

PROCEDURES

NUMBER TITLE REVISION 5.7.21 Emergency Procedure, "Maintaining Emergency Preparedness - Emergency Exercises, Drills, Tests and Evaluations"

49, 50 5.7.24 Emergency Procedure, "Medical Emergency" 29 5.7Commun Emergency Procedure, "Communications" 20, 21, 22

CONDITION REPORTS

CR-CNS-2011-11099

CR-CNS-2012-01879

CR-CNS-2012-03070

CR-CNS-2012-04492

CR-CNS-2012-05097

CR-CNS-2012-07573

CR-CNS-2012-09949

CR-CNS-2012-09951

CR-CNS-2012-10087

CR-CNS-2012-10152

CR-CNS-2013-00151

CR-CNS-2013-00692

CR-CNS-2013-00694

CR-CNS-2013-01035

CR-CNS-2013-01258

CR-CNS-2013-01618

CR-CNS-2013-02725

CR-CNS-2013-02730

CR-CNS-2013-03007

CR-CNS-2013-03080

CR-CNS-2013-03545

CR-CNS-2013-04229

CR-CNS-2013-04765

CR-CNS-2013-04774

CR-CNS-2013-04777 CR-CNS-2013-04779

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

AIR SAMPLE ANALYSES

NUMBER TITLE DATE

RW 934' "C" Septa Filter System Changeout June 17, 2013

RX 859' NE Quad @

CS-CV-010 August 6, 2013

RX 1001' D.S. Pit April 4, 2013

AUDITS,

SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

Cooper Nuclear Station Mid-Cycle Assessment - 2013 March 14, 2013

LO-WTCNS-2012-42 CA #20 Snapshot Assessment / Benchmark on RAD department ALARA Performance and Projection January 2, 2013

MISCELLANEOUS DOCUMENTS

TITLE DATE

Source Report - Inventory December

18, 2012

Source Report - Leak Test Source December

18, 2012

Source Report - Leak Test Source June 14, 2013

PROCEDURES

NUMBER TITLE REVISION 9.ALARA.1 Radiological Protection Procedure, "Personnel Dosimetry and Occupational Radiation Exposure Program"

9.ENN-RP-102 Radiological Protection Procedure, "Radiological Control" 3 9.ENN-RP-106-1 Radiological Protection Procedure, "Radiation and Contamination Surveys"

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

9.EN-RP-101 Radiological Protection Procedure, "Access Control for Radiologically Controlled Areas" 11 9.EN-RP-108 Radiological Protection Procedure, "Radiation Protection Posting" 7 9.EN-RP-122 Radiological Protection Procedure, "Alpha Monitoring" 2 9.RADOP.1 Radiological Protection Procedure, "Radiation Protection at CNS" 14 9.RADOP.10 Radiological Protection Procedure, "Radioactive Source Control and Accountability"

RADIATION WORK PERMITS

NUMBER TITLE REVISION 2013-007 RCA Satellite Areas - All Crafts Activities 0 2013-100 Reactor Bld - LOCKED HRA Activities 1 2013-052 Radwaste / Augmented Radwaste HRA Activities on 877' and 903' 3 2012-528 Rx Disassemble / Reassemble 1

RADIATION WORK PERMITS

NUMBER TITLE REVISION 2012-555

RE-27 RX Cavity / DS Pit Decon 3 2013-067 Replace RW Filter Septas SWP Areas 1

SURVEY DOCUMENTS

NUMBER TITLE DATE

CNS-1212-0080

TGB 932' - 100% Power Survey December 12, 2012

CNS-1307-0061

TGB 932' - 55% Power - Job Coverage July 20, 2013

CNS-1307-0042

RXB 931' - RWCU Pump Room July 16, 2013

CNS-1306-0050

RXB 931' - RWCU Pump Room June 24, 2013

CNS-1306-0011

RWB 877' - Quarterly June 7, 2013

CNS-1303-0009

RWB 877' - Quarterly March 5, 2013

CONDITION REPORTS

CR-CNS-2012-10432

CR-CNS-2013-00477

CR-CNS-2013-01916

CR-CNS-2013-03685

CR-CNS-2013-03793

CR-CNS-2013-03992

CR-CNS-2013-04497

CR-CNS-2013-04523

CR-CNS-2013-04527

CR-CNS-2013-05708 CR-CNS-2013-05733

Section 2RS2: Occupational

ALARA Planning and Controls

ALARA PLANNING PACKAGES

NUMBER TITLE

2012-01 Control Rod Drive Mechanism Maintenance

2012-05 Refuel Floor

2012-06 Turbine Building Miscellaneous

2012-09 Drywell Fan Coil Unit

2012-15 Valve Team

2012-37 Radiation Protection Drywell and Steam Tunnel Support

2012-40 Main Steam Line Hanger Replacement

AUDITS,

SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

LO 2013-0009 ALARA Planning and Controls April 22, 2012 to May

9, 2013

MISCELLANEOUS DOCUMENTS

TITLE DATE

Cooper Nuclear Station RE27 Post Outage Report September

13, to November 29, 2012

PROCEDURES

NUMBER TITLE DATE 0.ALARA.1 Station Procedure, "CNS ALARA Program"

5

9.ALARA.4 Radiological Protection Procedure, "Radiation Work Permits" 16 9.ALARA.5 Radiological Protection Procedure, "ALARA Planning and Controls"

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

CONDITION REPORTS

CR-CNS-2012-8776

CR-CNS-2012-8399

CR-CNS-2012-9635

CR-CNS-2012-9362

CR-CNS-2012-7317 CR-CNS-2012-9635

Section 4OA1: Performance Indicator Verification

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

Cooper Nuclear Station Emergency Plan 63

EPDG-2 Attachment G-1, Emergency Preparedness Cornerstone Performance Indicator Data Collection Guide

PROCEDURES

NUMBER TITLE REVISION 5.7.1 Emergency Procedure, "Emergency Classification" 45, 46, 47, 485.7.2 Emergency Procedure, "Emergency Director EPIP" 31, 32 5.7.6 Emergency Procedure, "Notification" 54, 55, 56, 57, 58 5.7.20 Emergency Procedure, "Protective Action Recommendations"

2, 23

Section 4OA2: Identification and Resolution of Problems

CONDITION REPORTS

CR-CNS-2008-01748

CR-CNS-2009-06187

CR-CNS-2013-04081

Attachment 2 The following items are requested for the Occupational Radiation Safety Inspection at Cooper Nuclear Station Integrated Report

2013004

Inspection areas are listed in the attachments below.

Please provide the requested information on or before July 8, 2013.

Please submit this information using the same lettering system as below.

For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

"1- A," applicable organization charts in file/folder "1- B," etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.

Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact Larry Ricketson at (817) 200-1165 or Larry.Ricketson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01)

Date of Last Inspection: November 5, 2012

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff and Technicians B. Applicable organization charts

C. Audits, self-assessments, and LERs written since date of last inspection, related to this inspection area D. Procedure indexes for the radiation protection procedures E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations 3. Personnel Dosimetry Program 4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radworker Instructions

7. Conduct of Radiological Surveys 8. Radioactive Source Inventory and Control 9. Declared Pregnant Worker Program F. List of corrective action documents (including corporate and subtiered systems) since date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide documents which are "searchable" so that the inspector can perform word searches. If not covered above, a summary of corrective action documents since date of last inspection involving unmonitored releases, unplanned releases, or releases in which any dose limit or administrative dose limit was exceeded (for Public Radiation Safety Performance Indicator verification in accordance with

IP 71151) G. List of radiologically significant work activities scheduled to be conducted during the inspection period

H. List of active radiation work permits I. Radioactive source inventory list

2.

Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: April 9, 2012

A. List of contacts and telephone numbers for ALARA program personnel B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection, focusing on ALARA D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation/ALARA Planning 4. Radiation Work Permit Adherence

F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the ALARA program.

In addition to ALARA, the summary should also address Radiation Work Permit violations, Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide documents which are "searchable."

G.

List of work activities greater than 1 rem, since date of last inspection.

Include original dose estimate and actual dose.

H. Most recent refueling outage report I. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of record) J. Outline of source term reduction strategy