ML13130A037
| ML13130A037 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/09/2013 |
| From: | Ray Kellar Division of Reactor Safety IV |
| To: | Limpias O Nebraska Public Power District (NPPD) |
| References | |
| EA-13-075 IR-13-009 | |
| Download: ML13130A037 (36) | |
See also: IR 05000298/2013009
Text
N U C LE AR R E GU LA TOR Y C OM MI S S I ON
R E G IO N I V
1600 EAST LAMAR BLVD
AR L I NG TO N , TE X AS 7 60 1 1 - 4511
May 9, 2013
Oscar A. Limpias, Vice President Nuclear and
Chief Nuclear Officer
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION STATION - NRC PROBLEM IDENTIFICATION
AND RESOLUTION INSPECTION REPORT 05000298/2013009 AND NOTICE
OF VIOLATION
Dear Mr. Limpias:
On March 28, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem
Identification and Resolution biennial inspection at your Cooper Nuclear Station facility. The
enclosed inspection report documents the inspection results, which the inspection team
discussed on March 28, 2013, with you and your staff.
This inspection was an examination of activities conducted under your license as they relate to
problem identification and resolution and to compliance with the Commissions rules and
regulations and the conditions of your license. Within these areas, the inspection involved
examination of selected procedures and representative records, observations of activities, and
interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the
corrective action program and the overall performance related to identifying, evaluating, and
resolving problems at Cooper Nuclear Station was adequate to support nuclear safety. The
team noted that you and your staff have made improvements to the stations corrective action
programs, processes, and procedures since the NRCs previous biennial problem identification
and resolution inspection in June 2011.
The team observed that your staff generally identified problems and entered them into the
corrective action program at a low threshold. In most cases, your staff effectively prioritized and
evaluated problems commensurate with their safety significance, resulting in the identification of
appropriate corrective actions. However, the team noted weaknesses in some of the stations
evaluation processes, particularly in your staffs evaluations of the operability of degraded
structures, systems, and components important to safety, as described by the stations design-
basis documents, and the subsequent determinations of whether these degraded conditions
required reports to the NRC. The attached Notice of Violation and inspection report discuss
specific examples of these weaknesses.
O. Limpias -2-
Your staff generally implemented corrective actions timely, commensurate with the safety
significance of the problems they were designed to correct. Most corrective actions reviewed by
the team adequately addressed the causes of identified problems. Your staff appropriately
reviewed and applied lessons learned from industry operating experience. The stations audits
and self-assessments effectively identified problems and appropriate corrective actions, though
the team noted one instance where a problem common to several audits was not evaluated in
the aggregate. Finally, the team determined that your stations management maintains a
healthy safety-conscious work environment where employees feel free to raise nuclear safety
concerns without fear of retaliation.
The team identified one finding of very low safety significance (Green) during this inspection.
This finding involved a violation of NRC requirements. The violation was evaluated in
accordance with the NRC Enforcement Policy; it did not meet the criteria to be treated as a non-
cited violation. The current version of this Policy is available on the NRCs website at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. This violation is cited in
the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in
detail in the subject inspection report. The violation is cited in the Notice in accordance with
Section 2.3.2.a of the Enforcement Policy because after the violation was previously identified
as a non-cited violation, you failed to restore compliance within a reasonable time.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRCs
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
Also based on the results of this inspection, the NRC has determined that a Severity Level IV
violation of NRC requirements occurred. This violation is being treated as a non-cited violation
(NCV), consistent with section 2.3.2.a of the NRCs Enforcement Policy.
If you contest either of these violations, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the
Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at
South Texas Project.
If you disagree with the cross-cutting aspect assigned to the finding, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at
Cooper Nuclear Station.
O. Limpias -3-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Ray L. Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
Docket No.: 50-298
License No.: DPR-46
Enclosure:
1. Notice of Violation
2. Inspection Report 05000298/2013009
w/ Attachments
cc w/ encl: Electronic Distribution
O. Limpias -4-
DISTRIBUTION:
Regional Administrator (Art.Howell@nrc.gov)
Acting Deputy Regional Administrator (Robert.Lewis@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
Acting DRP Deputy Director (Michael.Scott@nrc.gov)
DRS Director (Tom.Blount@nrc.gov)
Acting DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Jeffrey.Josey@nrc.gov)
Resident Inspector (Chris.Henderson@nrc.gov)
Branch Chief, DRP/C (David.Proulx@nrc.gov)
Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)
Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)
CNS Administrative Assistant (Amy.Elam@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Lynnea.Wilkins@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
Senior Reactor Inspector, DRS/TSB (Eric.Ruesch@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV/ETA: OEDO (Doug.Huyck@nrc.gov)
S:\DRS\REPORTS\Reports Drafts\CNS 2013009 RP EAR DRAFT.docx ML13130A037
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials EAR
Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials EAR
DRP/PBC DRS/EB2 DRS/EB1 C:DRP/PBC ORA/ACES DRS/TSB C:DRS/TSB
CHenderson CSpeer JBraisted DProulx RBrowder EARuesch RLKellar
via e-mail via e-mail via e-mail RCH/for /RA/ Via e-mail /RA/
5/6/13 5/2/13 5/6/13 5/9/13 5/9/13 5/9/13 5/9/13
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
Nebraska Public Power District Docket No: 50-298
Cooper Nuclear Station License No: DPR-46
During an NRC Inspection conducted from March 11 through 28, 2013, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that
measures shall be established to assure that applicable regulatory requirements and the
design basis, as defined in 10 CFR 50.2 and as specified in the license application, for
those structures, systems, and components to which the appendix applies, are correctly
translated into specifications, drawings, procedures, and instructions.
Contrary to above, from May 10, 2012 through March 13, 2013, the licensee failed to
establish measures to assure that applicable regulatory requirements and design basis,
as defined in 10 CFR 50.2 and as specified in the license application, for components to
which 10 CFR 50 Appendix B applies, were correctly translated into specifications,
drawings, procedures, and instructions. Specifically, the licensee failed to assure that
the applicable design basis requirements associated with the standby liquid control
system test tank were correctly translated into plant procedures to ensure that the
standby liquid control system would be available following design basis seismic event.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is hereby required
to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region IV (ATTN: Mr. Ray L. Kellar, P.E., Chief, Technical Support Branch,
Division of Reactor Safety, and a copy to the NRC Resident Inspector at Cooper Nuclear
Station within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This
reply should be clearly marked as a "Reply to Notice of Violation EA 13-075," and should
include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or
severity level, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time. If you contest this
enforcement action, you should also provide a copy of your response, with the basis for your
denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission,
Washington, DC 20555-0001.
-1- Enclosure 1
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC website at www.nrc.gov/reading-rm/pdr.html or www.nrc.gov/reading-rm/adams.html, to
the extent possible, it should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the public without redaction. If personal privacy
or proprietary information is necessary to provide an acceptable response, then please provide
a bracketed copy of your response that identifies the information that should be protected and a
redacted copy of your response that deletes such information. If you request withholding of
such material, you must specifically identify the portions of your response that you seek to have
withheld and provide in detail the basis for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.390(b) to support a request for withholding confidential
commercial or financial information).
Dated this 9th day of May, 2013.
-2-
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-298
License: DPR-46
Report: 05000298/2013009
Licensee: Nebraska Public Power District
Facility: Cooper Nuclear Station
Location: 72676 648A Avenue
Brownville, Nebraska 68321
Dates: March 11-28, 2013
Team Leader: E. Ruesch, Senior Reactor Inspector
Inspectors: J. Braisted, Ph.D., Reactor Inspector
C. Henderson, Resident Inspector
C. Speer, Reactor Inspector
Approved By: R.L. Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
-1- Enclosure 2
SUMMARY OF FINDINGS
IR 05000298/2013009; March 11-28, 2013; Cooper Nuclear Station, Biennial Baseline
Inspection of the Identification and Resolution of Problems
The team inspection was performed by one senior reactor inspector, two reactor inspectors, and
one resident inspector. One violation of Green safety significance and one non-cited violation of
Severity Level IV were identified during this inspection. The significance of most findings is
indicated by a color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,
Significance Determination Process. Findings for which the significance determination
process does not apply may be Green or be assigned a severity level after NRC management
review. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated
December 2006.
Identification and Resolution of Problems
The team reviewed approximately 220 condition reports, including associated work orders,
engineering evaluations, root and apparent cause evaluations, and other supporting
documentation. The purpose of this review, focused on documentation of higher-significance
issues, was to determine whether the licensee had properly identified, characterized, and
entered these issues into the corrective action program for evaluation and resolution. The team
reviewed a sample of system health reports, self-assessments, trending reports and metrics,
and various other documents related to the corrective action program. The team concluded that
the licensee maintained a corrective action program in which issues were generally identified at
an appropriately low threshold. Issues entered into the corrective action program were
appropriately evaluated and timely addressed, commensurate with their safety significance.
Corrective actions were generally effective, addressing the causes and extents of condition of
problems.
The team determined that the licensee appropriately evaluated industry operating experience
for relevance to the facility and entered applicable items in the corrective action program. The
licensee used industry operating experience when performing root cause and apparent cause
evaluations. The licensee performed effective quality assurance audits and self-assessments,
as demonstrated by its self-identification of some needed improvements in corrective action
program performance and of ineffective corrective actions.
The licensee maintained a safety-conscious work environment in which personnel felt free to
raise nuclear safety concerns without fear of retaliation. All individuals interviewed by the team
were willing to raise these concerns by at least one of the several methods available.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The team identified a Green violation of 10 CFR Part 50, Appendix B, Criterion
III, Design Control, for the licensees failure to assure that design basis requirements
-2-
associated with the standby liquid control (SLC) system test tank were correctly
translated into procedures. As a result, the licensee failed to maintain the tank empty as
required to meet seismic design requirements. The violation is cited because the
licensee failed to restore compliance in a reasonable time following documentation of the
issue as a non-cited violation in NRC Inspection Report 05000298/2012002, issued
May 10, 2012 (ML12131A674). The licensee entered these issues into its corrective
action program for resolution as Condition Report CR-CNS-2013-01962,
CR-CNS-2013-02027, and CR-CNS-2013-02328.
The failure to maintain design control of the standby liquid control system was a
performance deficiency. This performance deficiency was of more than minor safety
significance because it was associated with the design control attribute of the mitigating
systems cornerstone and it adversely affected cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically, the licensees failure to implement
procedures to ensure the SLC test tank remained in a seismically qualified condition
resulted in an inability to provide reasonable assurance of operability following a seismic
event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team
determined that the finding was of very low safety significance (Green) because it was a
design deficiency that did not result in the loss of functionality.
This finding had a cross-cutting aspect in the area of human performance associated
with the decision-making component because the licensee failed to adopt a requirement
to demonstrate that a proposed action was safe in order to proceed rather than a
requirement to demonstrate it was unsafe in order to disapprove the action (H.1(b)).
(Section 4OA2.5.1)
Cornerstone: Miscellaneous
SL-IV. The team identified a Severity Level IV non-cited violation of 10 CFR 50.72,
Immediate Notification Requirements for Operating Nuclear Power Reactors, for the
licensees failure to make a required report to the NRC. After the licensee determined
that the standby liquid control test tank could not meet Seismic Class I requirements
unless empty, the team discovered that the tank was full. The licensee immediately
drained the tank and implemented a compensatory action to maintain it empty.
However, the licensee failed to recognize that because the compensatory measure was
required to provide a reasonable assurance of operability, the as-found condition of the
SLC systemwith the test tank fullrendered both trains of the system inoperable.
Because this could have prevented the fulfillment of the SLC systems safety function,
the licensee was required to report the condition to the NRC within eight hours of
discovery. After identification, the licensee entered this issue into its corrective action
program and made a late report to the NRC, restoring compliance with the regulation.
The failure to make a required report to the NRC within the required time was a
performance deficiency. The team determined that traditional enforcement applied to
this violation because the violation impeded the regulatory process. Specifically, the
NRC relies on the licensee to identify and report conditions or events meeting the criteria
specified in regulations in order to perform its regulatory oversight function. Assessing
the violation in accordance with Enforcement Policy, the team determined it to be of
-3-
Severity Level IV because it involved the licensees failure to make a report required
by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9). Because this was a traditional
enforcement violation with no associated finding, no cross-cutting aspect is assigned to
this violation. (Section 4OA2.5.2)
B. Licensee-Identified Violations
None
-4-
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152)
The team based the following conclusions on a sample of corrective action documents
that were open during the assessment period, which ranged from June 25, 2011, to the
end of the on-site portion of this inspection on March 28, 2013.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed approximately 220 condition reports (CRs), including associated root
cause, apparent cause, and direct cause evaluations, from approximately 18,000 that
had been initiated between June 25, 2011, and March 28, 2013. The condition reports
selected for review focused on risk-significant issues. In performing its review, the team
evaluated whether the licensee had properly identified, characterized, and entered
issues into the corrective action program, and whether the licensee had appropriately
evaluated and resolved the issues in accordance with the established programs,
processes, and procedures. The team also reviewed these programs, processes, and
procedures to determine if any issues existed that may impair their effectiveness.
The team reviewed a sample of system health reports, operability determinations,
self-assessments, trending reports and metrics, and various other documents related to
the corrective action program. The team evaluated the licensees efforts in establishing
the scope of problems by reviewing selected logs, work orders, self-assessment results,
audits, system health reports, action plans, and results from surveillance tests and
preventive maintenance tasks. The team reviewed daily CRs, and attended the
licensees Condition Review Group meetings to assess the reporting threshold,
prioritization efforts, and significance determination process, and to observe the
interfaces with the operability assessment and work control processes when applicable.
The teams review included verification that the licensee considered the full extent of
cause and extent of condition for problems, as well as a review of how the licensee
assessed generic implications and previous occurrences. The team assessed the
timeliness and effectiveness of corrective actions, completed or planned, and looked for
additional examples of problems similar to those the licensee had previously addressed.
The team conducted interviews with plant personnel to identify other processes that may
exist where problems may be identified and addressed outside the corrective action
program.
The team reviewed corrective action documents that addressed past NRC-identified
violations to ensure that corrective actions addressed the issues described in the
inspection reports. The team reviewed a sample of corrective actions closed to other
corrective action documents to ensure that corrective actions remained appropriate and
timely.
-5-
The team considered risk insights from both the NRCs and Cooper Nuclear Stations
risk assessments to focus the sample selection and plant tours on risk-significant
systems and components. The team focused a portion of its sample on the standby
liquid control systems and the residual heat removal system, which the team selected for
a five-year in-depth review. The samples reviewed by the team focused on but were not
limited to these systems. The team conducted walk-downs of these systems to assess
whether licensee personnel identified problems at a low threshold and entered them into
the corrective action program.
b. Assessments
1. Effectiveness of Problem Identification
During the 21-month inspection period, licensee staff generated approximately
18,000 condition reports. The licensees CR generation rate of approximately 11,000
per year had been relatively constant over the previous four years. The team
determined that most conditions that required generation of a CR by procedure 0.5,
Conduct of the Condition Report Process, and its implementing procedures were
appropriately entered into the corrective action program.
The team noted three exceptions in which the licensee had not identified and
evaluated adverse trends through the corrective action program as required by
procedure 0.5.CR, Condition Report Initiation, Review, and Classification,
revision 19. These failures to identify the trends represented minor performance
deficiencies that were not subject to enforcement action in accordance with the NRC
Enforcement Policy:
In the ten quality assurance audits reviewed by the team, the licensee had self-
identified seven failures to implement industry recommendations or to
incorporate vendor guidance into station procedures. The licensee had
evaluated each of these instances individually, but did not identify and evaluate
the potential adverse trend as required by procedure 0.5.CR, Condition Report
Initiation, Review, and Classification, revision 19. The licensee documented
the teams observation in CR-CNS-2013-02411.
In several condition reports, the licensee documented failures to completely
evaluate design bases in operability evaluations. The licensee reviewed each
of these instances individually, but did not identify and evaluate the potential
adverse trend. This trend of inadequate documentation of operability
evaluations is also referenced in the discussion of weaknesses in the
licensees evaluation processes in section 4OA2.1.b.2 below. The licensee
documented the teams observations in CR-CNS-2013-02413.
The licensee identified cases where it did not incorporate appropriate vendor
guidance into procedures. The licensee evaluated the implementation of
vendor guidance for specific issues, but not for the incorporation of vendor
guidance as a whole. This issue was also discussed in section 4OA2.1.b.1,
above.
-6-
The team concluded that despite this performance deficiency, the licensee
maintained a low threshold for the formal identification of problems and entry into the
corrective action problem for evaluation. All personnel interviewed by the team
understood the requirement and expressed a willingness to enter identified issues
into the corrective action program at a very low threshold.
2. Assessment - Effectiveness of Prioritization and Evaluation of Issues
The team concluded that once the licensee entered issues into its corrective action
program, most issues were appropriately evaluated and prioritized. The licensee
screened approximately 8,400 (46%) of the 18,000 CRs generated during the
inspection period as adverse conditions and approximately 300 (2%) of the CRs as
requiring root or apparent cause evaluations. The sample of CRs reviewed by the
team was focused on these higher-tier issues. The team reviewed a number of
condition reports that involved operability reviews to assess the quality, timeliness,
and prioritization of operability assessments. In general, most immediate and prompt
operability assessments reviewed were adequately completed, and the team noted
improvements in these evaluations since the previous problem identification and
resolution inspection in June 2011.
However, the team noted weaknesses in some of the stations evaluation processes.
Particularly, the team noted weaknesses in the licensees evaluations of the
operability of degraded structures, systems, and components important to safety, as
described by the stations design-basis documents, and the subsequent
determinations of whether these degraded conditions required reports to the NRC.
The licensee documented the teams observations in CR-CNS-2013-02413. These
observations are also referenced in a discussion of the licensees failure to identify
adverse trends in section 4OA2.1.b.1 above. Additionally, section 4OA5.5 below
includes a specific example of an inadequate operability and reportability evaluation
and an associated discussion of the licensees failure to apply updated design
information.
The team also noted an example of the licensees failure to perform a
required 10 CFR 50.59 applicability screen for a procedural change that could have
affected the method for controlling a design function. Specifically, the licensee hung
a caution tag that restricted the allowable modes of operation of backup safety-
related battery chargers. Prior to identification by the team, the licensee had failed to
evaluate whether this restriction, which had been in place for approximately five
months, constituted a change per 10 CFR 50.59. This was a minor performance
deficiency that is not subject to enforcement action in accordance with the NRC
Enforcement Policy. The licensee documented the teams observation in
Overall, the team determined that the licensee had an adequate process for
screening and prioritizing issues that had been entered into the corrective action
program, though some weaknesses were noted. The team made the following
observations:
-7-
During the licensees Condition Review Group (CRG) screening process, the
screening group discussed each CR of A, B, or C significance individually.
However, D-significance CRs were only discussed when a CRG member took
exception to the CRs classification or description; the licensee did not do a 100
percent screen of these CRs. The team noted that prior to the end of this
inspection, the licensee changed its process to perform an individual screen of
all CRs, regardless of significance. Though the team had provided this
observation to the licensee prior to the change being implemented, the licensee
made the change independent of the teams observation.
Although CRG and Corrective Action Review Board (CARB) members must be
qualified through a formal training program, no continuing qualification
requirements to maintain proficiency are in place. Further, the licensees CRG
pre-screen group, which provides the initial screening and significance
classification for CRs, lacks a formal qualification program.
The team observed several additional potential weaknesses in the licensees
CARB process. While the team did not identify a specific adverse result from
these potential weaknesses, it determined that the weaknesses could
contribute to the licensees broader issues in the area of prioritization and
evaluation of problems. The licensee documented the teams observations in
o The licensee typically lacks documentation for the basis behind decisions
made during CARB meetings, specifically regarding decisions on
significance.
o On March 26, 2013, the team observed a meeting of the licensees CARB.
Per 0-EN-LI-102, Corrective Action Process, revision 20C0, the function of
the CARB is review and approval of root cause evaluations and selected
apparent cause evaluations. However, the team noted that the CARB
seemed to function more as a step in the editing and revision process for
the cause evaluation rather than a management review and approval step.
The team noted one instance where CARB approved a cause evaluation
after a 40-minute discussion of weaknesses in the evaluation.
o Changes to CARB-approved plans do not require further review. The team
noted one instance in which the licensee changed a corrective action for a
CARB-approved cause evaluationwhich included a statement that the
CARB Chairman needs to concur with changes prior to closurebut the
change did not receive CARB review or approval (CR-CNS-2011-09071 CA 7).
The licensee stated that this was acceptable per procedure.
o By process, the CARB provides only a front-end review of significant
corrective actions. CARB is required to review and approve the corrective
action plan and effectiveness review plan for root causes, but CARB does
not review corrective actions to prevent recurrencedesigned to correct
the root causes of significant conditionsor effectiveness reviews once
they are complete.
-8-
During the 2011 problem identification and resolution inspection, the inspection team
had identified weaknesses in the licensees operability evaluations. During this
inspection period, the licensee continued to have weaknesses in the area of
operability evaluations and in subsequent evaluations of whether identified
conditions require reports to the NRC. The licensee has identified and generally
addressed the lack of adequate documentation in operability evaluations. However,
as noted above, opportunities remain for further improvementspecifically in the
incorporation of design basis information into operability evaluations.
Additionally, the 2011 problem identification and resolution inspection team noted a
general weakness in the thoroughness of the licensees evaluations. During the
current inspection, the team noted that the licensees performance in this area had
improved. All evaluations reviewed appeared to be thorough enough to fully address
and correct the identified problems.
Overall, the team determined that the licensees process for screening and
prioritizing issues that had been entered into the corrective action program was
adequate to support nuclear safety. However, as discussed in the NRCs annual
assessment letter dated March 4, 2013 (ML13063A76), the licensee has an open
substantive cross-cutting issue in the area of problem identification and resolution,
associated with a theme in the thoroughness of problem evaluation. This
substantive cross-cutting issue, open since March 5, 2012, further indicates
weaknesses in the licensees effectiveness of prioritization and evaluation of
problems.
3. Assessment - Effectiveness of Corrective Actions
Overall, the team concluded that the licensee implemented effective corrective
actions for the problems identified and evaluated in the corrective action program.
The team reviewed eleven corrective action effectiveness reviews for significant
conditions adverse to quality and determined that the licensee had implemented
effective corrective actions for the conditions.
With the exception of the standby liquid control test tank issue discussed in
section 4OA2.5, the team noted that corrective actions to address the sample of
NRC non-cited violations and findings since the last problem identification and
resolution inspection had been timely and effective. Overall, the team concluded that
the licensee generally developed appropriate corrective actions to address identified
problems. The licensee generally implemented these corrective actions in a timely
manner, commensurate with their safety significance, and reviewed the effectiveness
of the corrective actions appropriately.
The team reviewed several corrective actions that the licensee had evaluated as
having been less than fully effective. However, all these ineffective corrective
actions had been self-identified by the licensee as part of its corrective action review
process. The team determined that the licensee had improved the effectiveness of
its corrective actions since the June 2011 problem identification and resolution
inspection.
-9-
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The team examined the licensees program for reviewing industry operating experience,
including reviewing the governing procedure and self-assessments. The team reviewed
a sample of industry operating experience communications to assess whether the
licensee had appropriately evaluated the communications for relevance to the facility.
The team also reviewed assigned actions to determine whether they were appropriate.
The team reviewed a sample of root and apparent cause evaluations to ensure that the
licensee had appropriately included industry operating experience.
b. Assessment
Overall, the team determined that the licensee appropriately evaluated industry
operating experience for its relevance to the facility. Of the operating experience items
reviewed by the team, the licensee had entered all applicable items into the corrective
action program and had evaluated these items in accordance with station procedures.
The team further determined that the licensee appropriately evaluated industry operating
experience when performing root cause investigations and apparent cause evaluations.
The licensee appropriately incorporated both internal and external operating experience
into lessons-learned for training and pre-job briefs.
In addition, the team reviewed twelve NRC bulletins, regulatory issue summaries, and
information notices issued during the inspection period and found that in all cases, the
licensee wrote a condition report and evaluated the applicability of the bulletin,
regulatory issue summaries, or information notice to their facility. The team found the
assessments were clearly documented and were appropriate for the circumstances.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample size of twenty-four licensee audits and self-assessments to
assess whether the licensee was regularly identifying performance trends and effectively
addressing them. The team reviewed audit reports to assess the effectiveness of
assessments in specific areas. The team evaluated the use of self-assessments and the
role of the quality assurance department. The specific audit and self-assessment
documents reviewed are listed in the Attachment.
b. Assessment
The team concluded that the licensee generally had an adequate audit and self-
assessment process. Audits and self-assessments were performed using station
procedures and were documented thoroughly. Performance elements and standards
were appropriate for the programs and processes evaluated. Attention was given to
assigning team members with the requisite skills and experience, including individuals
from outside organizations, to perform effective audits and self-assessments. Audits
were self-critical, thorough, and identified new findings, performance deficiencies, and
- 10 -
other concerns in addition to evaluating known performance deficiencies across key
functional areas. The licensee generated condition reports to document these findings,
performance deficiencies, and other concerns. However, the team identified a missed
opportunity to identify whether adverse performance trends existed across internal
programs or processes in that CNS did not perform a collective review of audits and self-
assessments. From their review, the team identified collective weaknesses in procedure
adherence and adequate procedures. Specifically, the audits and self-assessments
identified instances of missing torque values, untimely updates of controlled copies of
documents, and failure to include vendor recommendations or industry guidance among
others across programs and processes. The team notes that the licensee does have a
corrective action to perform a common cause analysis of NRC identified findings.
Overall, the team determined that the licensee had generally developed appropriate
corrective actions to address findings from audits and self-assessments, though these
were not always effectively implemented. For example, the team notes that over the
past several years the licensee had performed and documented multiple audits and self-
assessments that identified longstanding programmatic issues with the Quality Control
Program. However, the licensee has developed an Improvement Plan for the Quality
Control Program that would likely remedy these programmatic issues when fully
implemented.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The team interviewed thirty-nine individuals in six focus groups. The purpose of these
interviews was (1) to evaluate the willingness of licensee staff to raise nuclear safety
issues, either by initiating a condition report or by another method, (2) to evaluate the
perceived effectiveness of the corrective action program at resolving identified problems,
and (3) to evaluate the licensees safety-conscious work environment (SCWE). The
focus group participants were from Security, Radiation Protection, Chemistry,
Engineering, Operations, and Maintenance. The individuals were selected blindly from
these work groups, based partially on availability. To supplement these focus group
discussions, the team interviewed the Employee Concerns Program (ECP) manager to
assess her perception of the site employees willingness to raise nuclear safety
concerns. Finally, the team reviewed the licensees most recent self-assessment of its
safety-conscious work environment.
b. Assessment
1. Willingness to Raise Nuclear Safety Issues
All individuals interviewed indicated that they had no hesitation raising nuclear safety
and other concerns. All felt that their management is receptive to nuclear safety
concerns and is willing to address them promptly. All of the interviewees further
stated that if they were not satisfied with the response from their immediate
supervisor, they would feel free to escalate the concern. Most expressed positive
experiences after raising issues to their supervisors or documenting issues in
condition reports.
- 11 -
2. Employee Concerns Program
All interviewees were aware of the Employee Concerns Program. Most explained
that they had heard about the program through various means, such as posters,
training, presentations, and discussion by supervisors or management at meetings.
Most did not have any personal experience with the ECP because, as noted above,
they felt free to raise safety concerns to their supervisors; they did not need to use
the ECP in these cases. However, all interviewees stated that they would use the
program if they felt it was necessary. None of the interviewed personnel had heard
of any issues dealing with breaches of confidentiality by the ECP staff, though
several noted that the location of the ECP office in a high-traffic area near
management offices did not lend itself to confidential meetings.
3. Preventing or Mitigating Perceptions of Retaliation
When asked if there have been any instances where individuals experienced
retaliation or other negative reaction for raising issues, all individuals interviewed
stated that they had neither experienced nor heard of an instance of retaliation,
harassment, intimidation or discrimination at the site. The team determined that
licensee management was successfully implementing processes it had in place to
mitigate such issues.
.5 Findings
1. Failure to maintain seismic qualification of standby liquid control
Introduction. The team identified a Green violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the licensees failure to assure that design basis
requirements associated with the standby liquid control (SLC) system test tank were
correctly translated into procedures. As a result, the licensee failed to maintain the
tank empty as required to meet seismic design requirements. This violation did not
meet the criteria to be treated as a non-cited violation because after it had been
previously documented by the NRC, the licensee failed to restore compliance in a
reasonable period of time.
Description. On May 10, 2012, the NRC documented a non-cited violation for the
licensees failure to properly translate the seismic design basis of the SLC system
into specifications, drawings, procedures, and instructions
(NCV 05000298/2012002-04; see ML12131A674). The licensee generated
calculation NEDC 12-015 as its prompt operability evaluation following identification
of the 2012 violation. The licensee determined that NEDC 12-015 provided a
reasonable assurance of SLC system operability while developing a design basis
calculation to fully qualify the SLC system to the licensees seismic requirements.
The licensee initiated calculation NEDC13-010, Cooper Nuclear Station Standby
Liquid Control Storage, Test, and Mix Tanks Seismic Qualification, to evaluate the
full seismic qualification of the SLC tanks and to establish the seismic design basis
for these tanks.
- 12 -
On February 28, 2013, the licensee approved NEDC 13-010, revision 0, and engineering
evaluation 13-009, Standby Liquid Control System/Reactor Equipment Cooling,
revision 0. This calculation and evaluation concluded that the standby liquid control test
tank met Seismic Class I design requirementsas required for safety-related systems
only when empty; the tank did not meet these requirements when full. After approval of
this calculation and engineering evaluation, the licensee closed the CRs related to
NCV 2012002-04, documenting that all corrective actions were complete.
On March 13, 2013, after reviewing the licensees completed corrective actions for the
2012 NCV, including the new design basis information documented in NEDC 13-010, the
team walked down the SLC system to verify corrective actions. During this walk-down,
the team identified that the SLC test tank was full, causing the SLC system to be in a
condition that did not meet the licensees design basis. Following the teams
observation, the licensee immediately drained the tank. The licensee implemented
Standing Order 2013-006 to maintain the test tank drained and to declare the SLC
system inoperable when the tank is filled for testing.
The team determined that after adoption of the new design basis calculation, the
licensee had failed to implement procedure changes or compensatory actions to ensure
the test tank was empty. Instead, the licensee inappropriately relied on a previous,
superseded calculation to justify operability. The licensee had thus failed to maintain
seismic qualification of the SLC system. This failure did not result in an actual loss of
system function. The licensee documented the condition and the teams associated
observations in condition reports CR-CNS-2013-01962, CR-CNS-2013-2027,
and CR CNS-2013-02328.
Analysis. The failure to maintain design control of the standby liquid control system was
a performance deficiency. This performance deficiency was of more than minor safety
significance because it was associated with the design control attribute of the mitigating
systems cornerstone and it adversely affected cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically, the licensees failure to implement
procedures to ensure the SLC test tank remained in a seismically qualified condition
resulted in an inability to provide reasonable assurance of operability following a seismic
event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team
determined that the finding was of very low safety significance (Green) because the
finding did not result in the loss of the system or its function. Using Inspection Manual
Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very
low safety significance (Green) because it was a design deficiency that did not result in
the loss of functionality.
Because licensee personnel improperly decided to use a superseded calculation to
justify operability rather than reevaluating operability using current, more conservative
design information, this finding had a cross-cutting aspect in the area of human
performance associated with the decision-making component. The licensee failed to
use conservative assumptions in decision making and to adopt a requirement to
demonstrate that a proposed action was safe in order to proceed (H.1(b)).
- 13 -
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires
in part that measures shall be established to assure that applicable regulatory
requirements and the design basis for those structures, systems, and components to
which the appendix applies are correctly translated into specifications, drawings,
procedures, and instructions. Contrary to this requirement, from May 10, 2012 until
March 13, 2013, the licensee failed to establish measures to assure that applicable
regulatory requirements and the design basis for a component to which the appendix
applied were correctly translated into specifications, drawings, procedures, and
instructions. Specifically, the licensee failed to assure that the design basis for the
standby liquid control system test tank, a component to which 10 CFR 50 Appendix B
applies, was translated into plant procedures to ensure that the standby liquid control
system would be available following a design-basis seismic event.
Following identification of this violation by the team, the licensee documented the
problem in its corrective action program, drained the standby liquid control test tank, and
established a standing order to maintain the test tank drained and to declare system
inoperable when the tank is filled for testing. In accordance with Section 2.3.2.a of the
NRC Enforcement Policy, this finding is being cited because the licensee failed to
restore compliance within a reasonable amount of time after the violation was initially
identified in NRC Inspection Report 05000298/2012002. It therefore did not meet the
criteria to be treated as a non-cited violation: VIO 05000298/2012009-01, Failure to
Maintain Seismic Qualification of Standby Liquid Control System.
2. Failure to make a required report
Introduction. The team identified a Severity Level IV non-cited violation
of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power
Reactors, for the licensees failure to make a required report to the NRC. Specifically,
the licensee failed to report a condition that could have prevented fulfillment of a
systems safety function.
Description. On February 28, 2013, the licensee approved calculation NEDC13-010,
Cooper Nuclear Station Standby Liquid Control Storage, Test, and Mix Tanks Seismic
Qualification, revision 0, and engineering evaluation 13-009, Standby Liquid Control
System/Reactor Equipment Cooling, revision 0. This calculation and evaluation
concluded that the standby liquid control test tank met Seismic Class I design
requirementsas required for safety-related systemsonly when empty; the tank did
not meet these requirements when full. The team noted that the failure of the SLC test
tank would result in the loss of functionality of both trains of SLC, a technical-
specification-required system.
On March 13, 2013, during a walk-down of the system, the team identified that the SLC
test tank was full. After the team informed the control room of the condition, the licensee
immediately drained the tank. The licensee initiated standing order 2013-006 to
maintain the standby liquid control system test tank empty and to declare the system
inoperable when the test tank is filled. The licensee credited this standing order as a
compensatory measure to ensure operability of the SLC system and declared the
system operable with this compensatory measure in place. However, the licensee failed
to recognize that because the compensatory measure was required to provide a
- 14 -
reasonable assurance of operability, the as-found condition of the SLC systemwith the
test tank fullrendered both trains of the system inoperable. Because this could have
prevented the fulfillment of the SLC systems safety function, the licensee was required
to report the condition to the NRC within eight hours of discovery.
On March 28, 2013, the licensee entered this issue into its corrective action program as
condition report CR-CNS-2013-02410. Also on March 28, 2013, the licensee made
Event Notification 48865 to the NRC Operations Center.
Analysis. The failure to make a required report to the NRC within the required time was
a performance deficiency. The team determined that traditional enforcement applied to
this violation because the violation impeded the regulatory process. Specifically, the
NRC relies on the licensee to identify and report conditions or events meeting the criteria
specified in regulations in order to perform its regulatory oversight function. Assessing
the violation in accordance with Enforcement Policy, the team determined it to be of
Severity Level IV because it involved the licensees failure to make a report required
by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9).
Because this was a traditional enforcement violation with no associated finding, no
cross-cutting aspect is assigned to this violation.
Enforcement. Title 10 CFR 50.72(b)(3)(v) requires in part that licensee report within
eight hours of discovery any event or condition that could have prevented the fulfillment
of the safety function of structures or systems that are needed to shutdown the reactor
and maintain it in a safe shutdown condition. Contrary to this requirement, on March 13,
2013, the licensee failed to report within eight hours of discovery an event or condition
that could have prevented the fulfillment of the safety function of a system needed to
shut down the reactor and maintain it in a safe shutdown condition. Specifically, the
standby liquid control test tank was discovered to be full, a condition in which
functionality of the standby liquid control system could not be reasonably assured
following a seismic event. The licensee failed to report this condition to the NRC within
eight hours of discovery.
Following discovery of the condition, the licensee immediately restored the system to a
qualified condition. After acknowledging that the required report had not been made, the
licensee entered the issue into its corrective action program on March 28, 2013, and
made Event Notification 48865. This event notification, though late, restored compliance
with applicable regulations.
Because this violation resulted in no or relatively inappreciable potential safety
consequences (SL-IV) and was entered into the corrective action program as Condition
Report CR-CNS-2013-02410, this violation is being treated as a non-cited violation,
consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000298/2013009-02, Failure to Notify the NRC within Eight Hours of a
Nonemergency Event.
- 15 -
4OA3 Event Follow-up (71153)
(Closed)05000298/2012006-00, Missing Vent Plug Results in Technical Specification
Prohibited Condition
On November 7, 2012, the licensee discovered that a plug was missing from the top of Z
sump vent connection, resulting in a breach of secondary containment integrity. Upon
discovery, the control room and maintenance personnel were notified and the plug was
reinstalled. The licensee later determined that the plug had been removed to obtain an
air sample per procedure. However, the change in configuration had not been
documented. The licensee determined that a procedural inadequacy was the root cause
of this event.
To prevent recurrence of this event, the licensee implemented a corrective action to
revise the procedure and preventive maintenance work items associated with the Z
sump. These revisions will add explicit requirements to replace the plug to reestablish
secondary containment integrity upon completion of work activities. The team reviewed
these planned revisions and determined that when implemented, they would likely
correct the condition.
No findings were identified. LER 05000298/2012006-00 is closed.
4OA6 Meetings
Exit Meeting Summary
On March 28, 2013, the team presented the inspection results to Mr. Oscar Limpias,
Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensee
staff. The licensee acknowledged the issues presented. The licensee confirmed that
any proprietary information that the team reviewed had been returned or destroyed.
ATTACHMENTS:
1. Supplemental Information
2. Information Request
3. Supplemental Information Request
- 16 -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Kirkpatrick, Quality Control Program Coordinator
G. Smith, Engineer, Nuclear Steam Supply System
J. Ehlers, Engineering Supervisor, Electrical Systems/I&C
J. Flaherty, Engineer, Licensing
D. Cunningham, Instrument & Control Supervisor, Maintenance
R. Estrada, Design Engineering Manager
R. Penfield, Operations Manager
A. Schroeder, Non-Licensed Nuclear Plant Operator
L. Dewhirst, Corrective Action & Assessments Manager
E. Montgomery, Engineer, Electrical Systems/I&C
NRC personnel
J. Josey, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000298/2013009-01 VIO Failure to Maintain Seismic Qualification of Standby Liquid
Control System (Section 4OA2.5)05000298/2013009-02 NCV Failure to Notify the NRC within Eight Hours of a
Nonemergency Event (Section 4OA2.5)
Closed
05000298/2012006-00 LER Missing Vent Plug Results in Technical Specification
Prohibited Condition (Section 4OA3)
-1- Attachment 1
LIST OF DOCUMENTS REVIEWED
Condition Reports (CRs)
CR-CNS-2008-01352 CR-CNS-2011-08139 CR-CNS-2012-00376
CR-CNS-2008-03338 CR-CNS-2011-08226 CR-CNS-2012-00451
CR-CNS-2008-05767 CR-CNS-2011-08284 CR-CNS-2012-00722
CR-CNS-2008-07340 CR-CNS-2011-08610 CR-CNS-2012-00875
CR-CNS-2009-00613 CR-CNS-2011-08636 CR-CNS-2012-01083
CR-CNS-2009-04042 CR-CNS-2011-08640 CR-CNS-2012-01145
CR-CNS-2009-04819 CR-CNS-2011-08703 CR-CNS-2012-01214
CR-CNS-2009-07191 CR-CNS-2011-09071 CR-CNS-2012-01218
CR-CNS-2009-07519 CR-CNS-2011-09120 CR-CNS-2012-01224
CR-CNS-2009-07775 CR-CNS-2011-09217 CR-CNS-2012-01232
CR-CNS-2009-09023 CR-CNS-2011-09227 CR-CNS-2012-01522
CR-CNS-2009-09486 CR-CNS-2011-09551 CR-CNS-2012-01530
CR-CNS-2009-09548 CR-CNS-2011-09654 CR-CNS-2012-01611
CR-CNS-2009-10691 CR-CNS-2011-09892 CR-CNS-2012-01651
CR-CNS-2010-00314 CR-CNS-2011-09933 CR-CNS-2012-01918
CR-CNS-2010-00361 CR-CNS-2011-09946 CR-CNS-2012-01929
CR-CNS-2010-00656 CR-CNS-2011-10023 CR-CNS-2012-01962
CR-CNS-2010-02709 CR-CNS-2011-10026 CR-CNS-2012-01999
CR-CNS-2010-03195 CR-CNS-2011-10249 CR-CNS-2012-02532
CR-CNS-2010-05924 CR-CNS-2011-10391 CR-CNS-2012-02566
CR-CNS-2010-08242 CR-CNS-2011-10473 CR-CNS-2012-02620
CR-CNS-2010-08409 CR-CNS-2011-10546 CR-CNS-2012-02716
CR-CNS-2010-08960 CR-CNS-2011-10601 CR-CNS-2012-02742
CR-CNS-2011-00461 CR-CNS-2011-10618 CR-CNS-2012-02767
CR-CNS-2011-00684 CR-CNS-2011-10654 CR-CNS-2012-02814
CR-CNS-2011-01333 CR-CNS-2011-11307 CR-CNS-2012-02914
CR-CNS-2011-02021 CR-CNS-2011-11385 CR-CNS-2012-03052
CR-CNS-2011-02084 CR-CNS-2011-11564 CR-CNS-2012-03061
CR-CNS-2011-03106 CR-CNS-2011-11566 CR-CNS-2012-03137
CR-CNS-2011-03890 CR-CNS-2011-11581 CR-CNS-2012-03523
CR-CNS-2011-04065 CR-CNS-2011-11593 CR-CNS-2012-03527
CR-CNS-2011-04575 CR-CNS-2011-11725 CR-CNS-2012-03528
CR-CNS-2011-04643 CR-CNS-2011-11740 CR-CNS-2012-03543
CR-CNS-2011-04780 CR-CNS-2011-11777 CR-CNS-2012-03549
CR-CNS-2011-04891 CR-CNS-2011-11796 CR-CNS-2012-03576
CR-CNS-2011-05201 CR-CNS-2011-11861 CR-CNS-2012-03580
CR-CNS-2011-05251 CR-CNS-2011-12071 CR-CNS-2012-03612
CR-CNS-2011-06136 CR-CNS-2011-12189 CR-CNS-2012-03620
CR-CNS-2011-06686 CR-CNS-2011-12266 CR-CNS-2012-03764
CR-CNS-2011-06771 CR-CNS-2011-12319 CR-CNS-2012-03814
CR-CNS-2011-07175 CR-CNS-2011-12325 CR-CNS-2012-03817
CR-CNS-2011-07339 CR-CNS-2011-12437 CR-CNS-2012-03861
CR-CNS-2011-07475 CR-CNS-2012-00189 CR-CNS-2012-03894
CR-CNS-2011-07712 CR-CNS-2012-00210 CR-CNS-2012-03920
CR-CNS-2011-07898 CR-CNS-2012-00375 CR-CNS-2012-03946
-2-
CR-CNS-2012-04456 CR-CNS-2012-08377 CR-CNS-2013-01365
CR-CNS-2012-04628 CR-CNS-2012-08433 CR-CNS-2013-01457
CR-CNS-2012-04875 CR-CNS-2012-08460 CR-CNS-2013-01628
CR-CNS-2012-04891 CR-CNS-2012-08472 CR-CNS-2013-01734
CR-CNS-2012-04903 CR-CNS-2012-08547 CR-CNS-2013-01804
CR-CNS-2012-05076 CR-CNS-2012-08551 CR-CNS-2013-01820
CR-CNS-2012-05224 CR-CNS-2012-08671 CR-CNS-2013-01824
CR-CNS-2012-05225 CR-CNS-2012-08957 CR-CNS-2013-01837
CR-CNS-2012-05292 CR-CNS-2012-09161 CR-CNS-2013-01876
CR-CNS-2012-05293 CR-CNS-2012-09317 CR-CNS-2013-01893
CR-CNS-2012-05294 CR-CNS-2012-09352 CR-CNS-2013-01901
CR-CNS-2012-05305 CR-CNS-2012-09475 CR-CNS-2013-01920
CR-CNS-2012-05848 CR-CNS-2012-10256 CR-CNS-2013-01962
CR-CNS-2012-05849 CR-CNS-2012-10473 CR-CNS-2013-02003
CR-CNS-2012-05990 CR-CNS-2012-10488 CR-CNS-2013-02027
CR-CNS-2012-06034 CR-CNS-2012-10514 CR-CNS-2013-02149
CR-CNS-2012-06723 CR-CNS-2012-10543 CR-CNS-2013-02328
CR-CNS-2012-06829 CR-CNS-2012-10636 LO-CNSLO-2011-00090
CR-CNS-2012-07174 CR-CNS-2013-00112 LO-CNSLO-2011-00112
CR-CNS-2012-07333 CR-CNS-2013-00123 LO-CNSLO-2011-00114
CR-CNS-2012-07334 CR-CNS-2013-00230 LO-CNSLO-2011-00116
CR-CNS-2012-07365 CR-CNS-2013-00268 LO-CNSLO-2011-00123
CR-CNS-2012-07378 CR-CNS-2013-00452 LO-CNSLO-2011-00129
CR-CNS-2012-07534 CR-CNS-2013-00480 LO-CNSLO-2012-00011
CR-CNS-2012-07881 CR-CNS-2013-00571 LO-CNSLO-2012-00060
CR-CNS-2012-07887 CR-CNS-2013-00734 LO-CNSLO-2012-00061
CR-CNS-2012-07939 CR-CNS-2013-00755 LO-CNSLO-2012-00068
CR-CNS-2012-08139 CR-CNS-2013-00782 LO-CNSLO-2012-00069
CR-CNS-2012-08148 CR-CNS-2013-00936 LO-CNSLO-2012-00076
CR-CNS-2012-08169 CR-CNS-2013-01195 LO-CNSLO-2012-00079
CR-CNS-2012-08292 CR-CNS-2013-01297
CR-CNS-2012-08368 CR-CNS-2013-01318
Work Orders
WO4813254 WO4848307
WO4813256 WO4848588
-3-
Procedures
Number Title Revision/Date
0.10 Operating Experience Program 30
0.12 Working Hour Limitations and Personnel Fatigue 29
Management
0.4 Procedure Change Process 57
0.40 Work Control Program 85
0.4.IDOCS Requesting Procedure Change in IDOCS 4
0.5 Conduct of the Condition Report Process 70
0.5.CR Condition Report Initiation, Review, and Classification 19
0.5.EVAL Preparation of Condition Reports 24
0.5.NAIT Corrective Action Implementation and Nuclear Action Item 45
Tracking
0.5.OPS Operations Review of Condition Reports/Operability 39
Determination
0.5.ROOT- Root Cause Analysis Procedure 15
CAUSE
0.5.TRND Corrective Action Program (CAP) Trending 14
0.5.OPS Operation Review of Condition Reports/Operability 40
Determination
0.9 Tagout 79
0-Barrier Barrier Control Process 0
0-Barrier- Control Building 0
Control
0-Barrier-Misc Miscellaneous Building 0
0-Barrier- Reactor Building 0
Reactor
0-CNS-WM-105 Planning 4
0-EN-DC-205 Maintenance Rule Monitoring 3
0-EN-FAP-LI- Corrective Action Review Board (CARB) Process 8C1
003
0-EN-LI-102 Corrective Action Process 20C0
0-EN-LI-118 Root Cause Evaluation Process 18C0
0-EN-LI-119 Apparent Cause Evaluation (ACE) Process 16C0
-4-
0-EN-OE-100 Operating Experience Program 16C0
0-QA-01 CNS Quality Assurance Program 16
0-QA-02 Conduct of Internal Audits 9
0-QA-05 QA Audit Requirements, Frequencies, and Scheduling 11
0-QA-08 Quality Assurance Training Program 9
13.17.2 Thermal Performance Test Procedure for Residual Heat June 28,
Removal Heat Exchangers 2012
2.0.11 Entering and Exit Technical Specification/TRM/ODAM LCO 36
Condition(s)
2.0.12 Operator Challenges 9
2.0.3 Conduct of Operations 80
2.0.4 Relief Personnel and Shift Turnover 45
2.1.1 Startup Procedure 167
2.1.1.1 Plant Startup Review and Authorization 22
2.1.1.2 Technical Specification Pre-Startup Checks 35
2.2.24.2 250 VDC Electrical System (Div 2) 14
2.2.25.2 125 VDC Electrical System (Div 2) 21
2.2.74A Standby Liquid Control System Component Checklist 10
2.2.A.REC.DIV3 Reactor Equipment Cooling System Common Divisional 2
Component Checklist
6.1HV.303 Division 1 Essential Control Building Ventilation 14
Temperature Switch Change Out and Functional Test
6.2HV.303 Division 2 Essential Control Building Ventilation 17
Temperature Switch Change Out and Function Test
6.Log.601 Daily Surveillance Log - Modes 1, 2, and 3 111
7.0.5 Post Maintenance Testing 44
7.2.42.2 RHR Heat Exchanger Maintenance January 7,
2009
7.3.31.6 Safety-Related 125V/250V Battery Cell Replacement (Off- 4
Line)
7.3.5 EQ Terminal Box Examination and Maintenance 22
EN-DC-345 Equipment Reliability Clock 0C0
Security Personnel Access Control 43
Procedure 2.5
-5-
Audits
Number Area Date
11-03 Procurement July 7, 2011
11-04 Maintenance October 28, 2011
11-05 Radiological Effluents and Environmental Monitoring November 9, 2011
Program and Chemistry
11-06 Quality Assurance September 16, 2011
11-08 Training January 11, 2011
12-01 Engineering April 4, 2012
12-02 Corrective Action Program May 9, 2012
12-03 Radiological Controls July 30, 2012
12-04 Operations and Technical Specifications September 19, 2012
12-05 Document Control and Records November 6, 2012
12-06 Quality Control Re-Audit September 28, 2012
12-07 Emergency Plan January 31, 2013
S12-01 Nuclear Safety Culture May 1, 2012
Other
Number Title Revision/Date
RHR Surveillance Performance History (01/01/2008 -
02/14/2013)
RHR Corrective Maintenance Orders (02/02/2008 -
11/22/2012)
RHR System Health Report January 2013
OE RHRSWBP Performance: Administrative 0
Compensatory Actions to address degraded RHRSWBP
operation
QC Program Improvement Plan March 26, 2013
SW System Health Report January 2013
System Engineer Desktop Guide: Section V - System 7
Trending
4 Dia. T-8B1 Seal per Drawing CF-SP-34126-1 September 2,
1992
-6-
Number Title Revision/Date
RHR System Trend Plan
RHR System Engineering Walkdown February 2013
RHR System Engineering Walkdown January 2013
CED 6032263 Gear Ratio Change for RHR-MO39A and B A
COR002-23-02 OPS Residual Heat Removal System 27
NEDC 95-003 Determination of Allowable Operating Parameters for 27C4
NEDC09-102 Internal Flooding - HELB, MELB, and Feedwater Line 0
Break
BLDG-F12 Performance Basis Criteria Document 1
BLDG-F13 Performance Basis Criteria Document 3
BLDG-F16 Performance Basis Criteria Document 3
BLDG-F19 Performance Basis Criteria Document 3
HPCI-F01 Performance Basis Criteria Document
NEDC12-012 Turbine Generator Building Siding Blowout Pressure, 0
other than EQ purposes
NEDC03-005 Turbine Generator Building Siding Blowout Pressure 4
NEDC11-135 Qualification of Doors R208, R209, and N104 0
NEDC13-010 CNS SLC Storage, Test, and Mix Tanks Seismic 0
Qualification
Engineering Standby Liquid Control System/Reactor Equipment 0
Evaluation 13-009 Cooling
TCC 4920141 Jumper OMAS on DG1 for Automatic Operation 0
TCC 4895999 Gag Open RHR HX A Inlet Valve SW-V-145 0
Burns and Roe Flow Diagram Reactor Building Service Water System N99
Drawing 2036
Sheet 1
TCC4917859 Temporary Repair on Service Water Booster Pump D
TCC4742749 Install Gag on SW-V-145
Burns and Roe Flow Diagram Reactor Building - Closed Cooling Water N65
2031 Sheet 2 System Cooper Nuclear Station
Health 2012
-7-
Number Title Revision/Date
CNS System Service Water January 2013
Health
CED 6028000 REC and TEC Oxygen Injection CCN 2
CNS System EE-DC January 2013
Health
Burns and Roe Flow Diagram Standby Liquid Control System N21
2045 Sheet 2
NEDC10-060 DG2 Mechanical Overspeed Governor Assembly Stud 1
Evaluation
CNS System Reactor Equipment Cooling January 2013
Health
LER Missing Vent Plug Results in Technical Specification 0
05000298/2012006 Prohibited Condition
CNSLO-2012-0060 50.59 Program Implementation Focused Self March 12-23,
Assessment 2012
2011 Fatigue Management Program Annual 01/24/2012
Effectiveness Review Summary
2012 Fatigue Management Program Annual 01/29/2013
Effectiveness Review Summary
NEDC 09-102 Internal Flooding- HELB, MELB, and Feedwater Line 0
Break
FAS 2013-003 Fatigue Assessment Summary 03/07/2013
FAS 2013-001 Fatigue Assessment Summary 01/10/2013
Nuclear Safety Culture Assessment December
2010
Snapshot Assessment/Benchmark on: Effectiveness December 28,
Review of Actions Taken to Resolve Issues Identified 2011
During the Nuclear Safety Culture Assessment
Performed in December 2010
Safety Conscience [sic] Work Environment: 2011 Survey
Results
-8-
Information Request
Biennial Problem Identification and Resolution Inspection
Cooper Nuclear Station
January 17, 2013
Inspection Report: 50-298/2013-009
On-site Inspection Dates: March 11-15 & 25-28, 2013
This inspection will cover the period from June 25, 2011 through March 28, 2013. All requested
information should be limited to this period or to the date of this request unless otherwise
specified. To the extent possible, the requested information should be provided electronically in
Adobe PDF (preferred) or Microsoft Office format. Any sensitive information should be provided
in hard copy during the teams first week on site.
Lists of documents should be provided in Microsoft Excel or a similar sortable format. Please
be prepared to provide any significant updates to this information during the teams first week of
on-site inspection. Corrective action documents refers to condition reports, notifications,
action requests, cause evaluations, and/or other similar documents, as applicable to Cooper
Nuclear Station.
Please provide the following information no later than February 22, 2013:
1. Document Lists
Note: For these summary lists, please include the document/reference number, the
document title, initiation date, current status, and long-text description of the issue.
a. Summary list of all corrective action documents related to significant conditions
adverse to quality that were opened, closed, or evaluated during the period
b. Summary list of all corrective action documents related to conditions adverse to
quality that were opened or closed during the period
c. Summary lists of all corrective action documents which were upgraded or
downgraded in priority/significance during the period (these may be limited to
those downgraded from, or upgraded to, apparent-cause level or higher)
d. Summary list of all corrective action documents initiated during the period that
roll up multiple similar or related issues, or that identify a trend
e. Summary lists of operator workarounds, operator burdens, temporary
modifications, and control room deficiencies currently open, or that were
evaluated or closed during the period
f. Summary list of safety system deficiencies that required prompt operability
determinations (or other engineering evaluations) to provide reasonable
assurance of operability
-1- Attachment 2
g. Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent) (sensitive information can be made available
during the teams first week on site)
h. Summary list of all Apparent Cause Evaluations completed during the period
i. Summary list of all Root Cause Evaluations planned or in progress but not
complete at the end of the period, with planned completion or due date
2. Full Documents with Attachments
a. Root Cause Evaluations completed during the period
b. Quality Assurance audits performed during the period
c. All audits/surveillances, performed during the period, of the Corrective Action
Program, of individual corrective actions, and of cause evaluations
d. Functional area self-assessments and non-NRC third-party assessments (i.e.,
peer assessments performed as part of routine or focused station self- and
independent assessment activities; do not include INPO assessments) that were
performed or completed during the period; include a list of those that are
currently in progress
e. Corrective action documents generated during the period associated with the
following:
i. NRC findings and/or violations issued to Cooper Nuclear Station
ii. Licensee Event Reports issued by Cooper Nuclear Station
f. Corrective action documents generated for the following, if they were determined
to be applicable to Cooper Nuclear Station (for those that were evaluated but
determined not to be applicable, provide a summary list):
i. NRC Information Notices, Bulletins, and Generic Letters issued or
evaluated during the period
ii. Part 21 reports issued or evaluated during the period
iii. Vendor safety information letters (or equivalent) issued or evaluated
during the period
iv. Other external events and/or Operating Experience evaluated for
applicability during the period
-2-
g. Corrective action documents generated for the following:
i. Emergency planning drills and tabletop exercises performed during the
period
ii. Maintenance preventable functional failures which occurred or were
evaluated during the period
iii. Adverse trends in equipment, processes, procedures, or programs that
were evaluated during the period
iv. Action items generated or addressed by offsite review committees during
the period
3. Logs and Reports
a. Corrective action performance trending/tracking information generated during the
period and broken down by functional organization (if this information is fully
included in item 3.c, it need not be provided separately)
b. Corrective action effectiveness review reports generated during the period
c. Current system health reports, Management Review Meeting package, or similar
information; provide past reports as necessary to include 12 months of
metric/trending data
d. Radiation protection event logs during the period
e. Security event logs and security incidents during the period (sensitive information
can be made available during the teams first week on site)
f. Employee Concern Program (or equivalent) logs (sensitive information can be
made available during the teams first week on site)
g. List of training deficiencies, requests for training improvements, and simulator
deficiencies for the period
Note: For items 3.d-3.g, if there is no log or report maintained separate from the
corrective action program, please provide a summary list of corrective action program
items for the category described.
4. Procedures
a. Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures that implement
the corrective action program at Cooper Nuclear Station
-3-
b. Quality Assurance program procedures (specific audit procedures are not
necessary)
c. Employee Concerns Program (or equivalent) procedures
d. Procedures which implement/maintain a Safety Conscious Work Environment
5. Other
a. List of risk-significant components and systems, ranked by risk worth
b. Organization charts for plant staff and long-term/permanent contractors
c. For each week the team is on site,
i. Planned work/maintenance schedule for the station
ii. Schedule of management or corrective action review meetings (e.g.
operations focus meetings, CR screening meetings, CARBs, MRMs,
challenge meetings for cause evaluations, etc.)
iii. Agendas for these meetings
Note: The items listed in 5.c may be provided on a weekly or daily basis after the
team arrives on site.
d. Electronic copies of the FSAR, technical specifications, and technical
specification bases, if available
All requested documents should be provided electronically where possible. Regardless of
whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide
copies on CD or DVD. One copy of the CD or DVD should be provided to the resident inspector
at Cooper Nuclear Station; three additional copies should be sent to the team lead, to arrive no
later than February 22, 2013:
Eric A. Ruesch
U.S. NRC Region IV
1600 East Lamar Blvd.
Arlington, TX 76011-4511
-4-
PAPERWORK REDUCTION ACT STATEMENT
This request does not contain new or amended information collection requirements subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by
the Office of Management and Budget, control number -3150-0011.
4-
Supplemental Information Request
Biennial Problem Identification and Resolution Inspection
Cooper Nuclear Station
March 7, 2013
Inspection Report: 50-298/2013-009
On-site Inspection Dates: March 11-15 & 25-28, 2013
This request supplements the original information request. Where possible, the information
should be available to the inspection team immediately following the entrance meeting. The
meeting agendas requested in item 1 should be provided when developed. This inspection will
cover the period from June 25, 2011 through March 28, 2013. All requested information should
be limited to this period or to the date of this request unless otherwise specified.
Please provide the following:
1. For each week the team is on site,
Planned work/maintenance schedule for the station
Schedule of management or corrective action review meetings (e.g. CRB, MRM,
CAR screening meetings, etc.)
Agendas for these meetings
2. As part of the inspection, the team will do a five-year in-depth review of issues and
corrective actions related to the residual heat removal (RHR) system. The following
documents are to support this review (electronic format preferred):
Copies of upper and lower tier cause evaluations performed on the RHR system
within the last 5 years, including root cause evaluations not already provided
List of all surveillances run on the RHR system within the last five years, sortable
by component and including acceptance criteria
List of all corrective maintenance work orders performed on the RHR system
within the last 5 years
List of maintenance rule functional failure assessmentsregardless of the
resultperformed on the RHR system within the last 5 years
System training manual(s) for the RHR system
Engineering forms/logs containing notes from the last two engineering walk-
downs of the RHR system
3. The team will also review the stations implementation of the fatigue rule. These
documents support this review:
List of all fatigue assessments performed during the inspection period separated
by department
List of all work hour rule waivers and violations during the inspection period
separated by department
Fatigue rule implementing procedures
-1- Attachment 3
4. Specific documents:
Documentation of modifications and temporary modifications (include associated
condition reports):
o TCC4896041 Gag Open RHR A Inlet Valve SW-V-145
o TCC4920141 Jumper OMAS on DG1 for Automatic Operation
o TCC4917859 Temporary Repair of Leak on SWBP D
o TCC4908683 Service Water Discharge Pipe Repair
o CED6028000
Procedures
o 2.2.65
o 6.LOG.601
o 10.5
o 10.8
Condition reports:
o CR-CNS-2009-00613 o CR-CNS-2011-09551
o CR-CNS-2009-07191 o CR-CNS-2011-12071
o CR-CNS-2009-10222 o CR-CNS-2012-00210
o CR-CNS-2009-10691 o CR-CNS-2012-00649
o CR-CNS-2010-05023 o CR-CNS-2012-01522
o CR-CNS-2010-05924 o CR-CNS-2012-01530
o CR-CNS-2010-05972 o CR-CNS-2012-01611
o CR-CNS-2010-08193 o CR-CNS-2012-01929
o CR-CNS-2011-00461 o CR-CNS-2012-01999
o CR-CNS-2011-00684 o CR-CNS-2012-02343
o CR-CNS-2011-04643 o CR-CNS-2012-02532
o CR-CNS-2011-08226 o CR-CNS-2012-03704
o CR-CNS-2011-08284 o CR-CNS-2012-05224
o CR-CNS-2011-08636 o CR-CNS-2012-07372
o CR-CNS-2011-08640 o CR-CNS-2012-08368
o CR-CNS-2011-09120 o CR-CNS-2012-09691
-2-
PAPERWORK REDUCTION ACT STATEMENT
This request does not contain new or amended information
- 2 -collection requirements subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by
the Office of Management and Budget, control number 3150-0011.