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05000298/FIN-2018003-0130 September 2018 23:59:59CooperNRC identifiedFailure to Provide Complete and Accurate Information in a License Amendment RequestThe inspectors identified that the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that was not accurate.
05000298/FIN-2017010-0530 June 2017 23:59:59CooperNRC identifiedFailure to adopt appropriate procedures in accordance with 10 CFR Part 21Severity Level IV. The team identified a violation of 10 CFR 21.21(a), for the licensees failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards. Specifically, Procedure EN-LI-108, 10 CFR 21 Evaluations and Reporting, Revision 5C0, was inadequate to ensure that the correct reportability call was made for a manufacturing flaw discovered in a relay that had resulted in a loss of safety function for the high pressure coolant injection system on April 25, 2016. In particular, the procedure (1) led the licensee to incorrectly conclude that a substantial safety hazard could not be created, (2) allowed a limited extent of condition in performing the substantial safety hazard evaluation such that similarly dedicated parts were not included in the scope, and (3) included incorrect guidance in Attachment 9.3. Corrective actions to restore compliance included re-evaluation of the defect under Part 21 requirements and a procedure adequacy review of the EN-LI-108-01 procedure. The licensee entered this issue into the corrective action program as Condition Reports CR-17-03936 and CR-17-04143. The failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards, in violation of 10 CFR 21.21(a), was a performance deficiency. The NRCs reactor oversight process considers the safety significance of findings by evaluating their potential safety consequences. Using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the team determined that the performance deficiency was of minor safety significance under the reactor oversight process because it involved a failure to make a report; however the underlying equipment failure was previously evaluated as having very low safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The team used the NRC Enforcement Policy, dated November 1, 2016, to determine the significance of the violation. The inspectors determined that the violation was similar to Examples 6.9.d.10 and 6.9.d.13 of the Enforcement Policy, because although the procedure resulted in an inadequate reportability review and the issue was not reported as a manufacturing flaw, the licensee had reported some aspects of the event under the requirements of 10 CFR 50.73. As a result, the team determined that the violation should be classified as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000298/FIN-2015004-0231 December 2015 23:59:59CooperNRC identifiedFailure to Update the Updated Safety Analysis ReportThe inspectors identified two examples of a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, for the licensees failure to update the Updated Safety Analysis Report for the reactor equipment cooling system and fire protection program to ensure that the report contained the latest information. Specifically, licensing personnel failed to update the Updated Safety Analysis Report when implementing License Amendment 232, in May 2009, for changes associated with the reactor equipment cooling system and again in April 2015, when the licensee implemented License Amendment 248 for the fire protection program transition to meet the requirements of NFPA-805. The licensee initiated corrective actions to update the affected sections, and initiated an extent of condition evaluation to identify other similar portions of the Updated Safety Analysis Report that may not have been updated. The licensee entered these deficiencies into the corrective action program as Condition Reports CR-CNS-2015-05948, CR-CNS-2015-06240, and CR-CNS-2015-06483. The licensees failure to update the Updated Safety Analysis Report for the reactor equipment cooling system and fire protection program to ensure that the information included within the report contained the latest information developed in accordance with 10 CFR 50.71(e) was a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was determined to be minor in the Reactor Oversight Process, and therefore, it was not evaluated as a finding using the significance determination process. In accordance with the NRC Enforcement Policy, the performance deficiency was evaluated using the traditional enforcement process because it had the potential for impacting the NRCs ability to perform its regulatory function. Under the traditional enforcement process, this performance deficiency was determined to be more than minor and a Severity Level IV violation because it was consistent with the example in Paragraph 6.1.d.3 of the NRC Enforcement Policy, dated February 4, 2015. Specifically, the licensee failed to update the Updated Safety Analysis Report as required by 10 CFR 50.71(e), but the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. No cross-cutting aspect was assigned to this violation because there was no Reactor Oversight Process finding associated with the performance deficiency.
05000298/FIN-2015003-0430 September 2015 23:59:59CooperNRC identifiedFailure to Make a 10 CFR 50.72(b)(2)(xi) NotificationThe inspectors identified a non-cited violation of 10 CFR 50.72(b)(2)(xi) because the NRC Operations Center was not notified within four hours of a reportable event related to the health and safety of the public for which notification to other government agencies had been made. Specifically, in May 2013, the licensee did not notify the NRC of its notification to the State of Nebraska about an inadvertent release of 14 bags of radioactively contaminated dirt and debris to a public landfill. To correct this condition, the licensee notified the NRC Operations Center of this event on August 26, 2015. This violation was evaluated using traditional enforcement because the failure to make a required report could adversely impact the NRCs regulatory process. Using the criteria contained in Section 6.9(d)(9) of the NRCs Enforcement Policy, this violation was determined to be Severity Level IV. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2015-0544. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000298/FIN-2015007-0330 June 2015 23:59:59CooperNRC identifiedFailure to Update the Final Safety Analysis Report (FSAR)The team identified three examples of a Severity Level IV, non-cited violation, of 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e), which states, in part, each person licensed to operate a nuclear power reactor under the provisions of 10 CFR 50.21 or 10 CFR 50.22 shall update periodically the final safety analysis report (FSAR) originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee since the submittal of the original FSAR, or as appropriate, the last update to the FSAR under this section. Specifically, in January 2012 and February 2015, the licensee failed to update the Updated Safety Analysis Report for changes made to their Anticipated Transient Without Scram analyses and plant conduct of operations procedures. This finding was entered into the licensees corrective action program as Condition Reports CR-CNS-2015-02106, CR-CNS-2015-02090, and CR-CNS-2015-02393. The team determined that the failure to update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This finding was more than minor because each example potentially rendered portions of the safety analyses for Anticipated Transient Without Scram events described in the Updated Safety Analysis Report less conservative or contradicted previous information regarding the licensees flooding analysis contained in the Updated Safety Analysis Report. The traditional enforcement violation was determined to be a Severity Level IV violation consistent with the example in paragraph 6.1.d(3) of the NRC Enforcement Policy. Since this was a traditional enforcement violation, no cross-cutting aspects were assigned per the guidance contained in Inspection Manual Chapter 0612, Section 07.03(c).
05000298/FIN-2014003-0230 June 2014 23:59:59CooperNRC identifiedFailure to Report Conditions Prohibited by Technical SpecificationsInspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73, Licensee Event Report, associated with the licensees failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria. Specifically, a condition prohibited by technical specifications existed for trip and throttle valve RCIC-MOV-14 for a period of time longer than the allowed outage time. This does not represent an immediate safety concern because this issue is only associated with reporting requirements. The licensee entered this deficiency into their corrective action program for resolution as Condition Reports CR-CNS-2014-03387 and CR-CNS-2014-03457. The licensees failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria was a performance deficiency. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, inspectors evaluated the performance deficiency using traditional enforcement. The violation was evaluated using Section 2.3.11 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. In accordance with Section 6.9, Example 9, of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. Inspectors determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation
05000298/FIN-2012301-0131 March 2013 23:59:59CooperNRC identifiedFailure to Maintain Initial Licensing Examination and Licensed Operator Examination IntegrityThe examiners identified a non-cited violation of 10 CFR Part 55.49, Integrity of Examinations and Tests, for the failure of the licensee to ensure the integrity of initial licensing exams and licensed operator annual operating tests from 1997 to 2012. During validation activities being conducted supporting the 2012 initial licensing examination, the NRC identified a failure to implement the sites simulator Security Procedure OTP 810, Operations Department Examination Security (Revision 11). Additional follow up revealed that there was a portion of the licensees computer network tied to their simulator that had not been isolated from the simulator during exam activities (initial and requalification examinations) for a period of approximately 15 years. Both provided plant staff the ability to view exam material in an uncontrolled manner. Providing this ability to view exam material in this manner is considered an exam integrity compromise. However, an evaluation involving site access logs, personal interviews with staff, and review of trends in exam results showed that the compromise did not have an actual effect on the equitable and consistent administration of the affected exams. The licensee entered the finding into the corrective action program as Condition Reports CR-CNS-2012-06335 and -06336. The failure of the licensees training staff to maintain the integrity of examinations administered to initial license applicants and licensed operations personnel was a performance deficiency. The finding was more than minor because it adversely affected the Human Performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency could have become more significant in that allowing licensed operators to return to the control room without valid demonstration of appropriate knowledge on their annual operating tests, or allowing operators to obtain licenses based on a compromised examination, could be a precursor to a more significant event. Using NRC Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1 and 2 worksheets; and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process, the finding was determined to have very low safety significance (Green). Although the 2012 finding resulted in a compromise of the integrity of initial licensing examinations and annual operating tests for approximately 15 years, with no compensatory actions immediately taken when the compromise should have been discovered, the equitable and consistent administration of the examinations in question were not actually affected by this compromise. In addition, the failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process, which resulted in its association with a Severity Level IV violation consistent with Sections 2.2.4 and 6.4.d of the NRC Enforcement Policy. This finding has a cross-cutting aspect in the human performance area associated with the resources component because the licensee failed to ensure that procedures were adequate to assure nuclear safety. Development and maintenance of Procedure OTP 810 had not involved review by the simulator support staff since the procedures inception. The simulator support staff is responsible for the configuration of computer networks that are connected to the simulator facility.
05000298/FIN-2013009-0231 March 2013 23:59:59CooperNRC identifiedFailure to Notify the NRC within Eight Hours of a Nonemergency EventThe 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 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.
05000298/FIN-2012004-0630 September 2012 23:59:59CooperNRC identifiedFailure to Obtain Prior NRC Approval for a Change Regarding the Supplemental Diesel GeneratorThe inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, associated with the licensees failure to adequately evaluate changes in order to ensure that they did not require prior NRC approval. The inspectors determined that a procedure change performed by the licensee to allow the use of the supplemental diesel generator for responding to a station blackout should have required prior NRC approval. Specifically, this change resulted in a more than minimal increase in the likelihood of the occurrence of a malfunction of a structure, system, or component important to safety that had been previously evaluated. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2012-05558. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate the use of the supplemental diesel generator for responding to a station blackout event was a performance deficiency. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the inspectors evaluated it using traditional enforcement. In accordance with section 7.3.E.6 of the NRC Enforcement Policy, the inspectors used Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, to determine that this performance deficiency was of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or 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 outof- service for longer than its technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program. Therefore, in accordance with section 6.1.d.2 of the NRC Enforcement Policy, the inspectors characterized this performance deficiency as a Severity Level IV violation. As described in section 07.03.c of Manual Chapter 0612, Power Reactor Inspection Reports, no cross-cutting aspect was assigned to this violation.
05000298/FIN-2011005-0431 December 2011 23:59:59CooperNRC identifiedFailure to Provide Complete and Accurate Solid Radwaste Shipment Information in Annual ReportsInspectors identified a non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, because the Annual Radiological Effluent Release Reports for 2008, 2009, and 2010 were not complete and accurate in all material respects with regard to solid radwaste shipped offsite from Cooper Nuclear Station. Specifically, the numbers of solid radwaste shipments, locations, burial volumes, and total activity amounts were not correct. This issue was entered in the licensees corrective action program as Condition Reports CR-CNS-2011-06921 and CR-CNS-2011-11740. This issue was dispositioned using traditional enforcement because the failure to provide complete and accurate information in Annual Radiological Effluent Release Reports has the potential to impact the NRCs ability to perform its regulatory function. This violation is characterized as a Severity Level IV violation consistent with Sections 2.2.1 and 6.9 of the NRC Enforcement Policy. This finding was determined to be of very low safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement
05000298/FIN-2011005-0731 December 2011 23:59:59CooperNRC identifiedFailure to Perform Required 10 CFR 50.59 Evaluations for ChangesThe inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, associated with the licensees failure to adequately evaluate changes in order to ensure that they did not require prior NRC approval. Specifically, the inspectors determined that the re-analysis of the turbine building peak pressure in response to a high energy line break event that the licensee had performed used a different calculation method than what had originally been used to support the stations licensing basis. This re-analysis was performed for the purpose of gaining margin on the station doors credited with protecting safety-related equipment from the line break event. This new method resulted in a lower peak turbine building pressure. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2011-10391 and CR-CNS-2011-11861. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes was a performance deficiency. The performance deficiency is greater than minor because the failure to follow the requirements of 10 CFR 50.59 and receive prior NRC approval for changes in licensed actions impacted the NRCs regulatory ability, and is, therefore, a finding. Since violations of 10 CFR 50.59 are considered to impede or impact the regulatory process they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process. As such, the inspectors concluded that this issue also represented a performance deficiency under the Reactor Oversight Process because the licensee failed to appropriately evaluate the proposed change in accordance with the requirements of Station Procedure 0.8, 10CFR50.59 and 10CFR72.48 Reviews. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual and Enforcement Policy and concluded that because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV non-cited violation consistent with the NRC Enforcement Policy. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision-making component in that the licensee failed to use conservative assumptions in decision making when they failed to recognize that the new calculation methodology was a change to a previously approved methodology
05000298/FIN-2011003-0430 June 2011 23:59:59CooperNRC identifiedCommunication of an NRC Inspectors Presence by Station PersonnelThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.70, Inspections, associated with the licensees failure to ensure that the arrival and presence of NRC inspectors was not communicated to persons at the facility. Specifically, a radiation protection technician manning the access point to the drywell informed other individuals entering the drywell to perform work of inspectors presence and location during an unannounced walkdown of the drywell to observe licensee work activities. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2011-4124. Licensee personnels action of announcing the presence and location of NRC inspectors during an unannounced walkdown inspection was a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on its ability to perform unannounced inspections to evaluate licensee performance, and communicating the presence and location of NRC inspectors affects their ability to perform these inspections, and as such the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance because the violation did not affect any of the safety culture components (Section 1R20.3).
05000298/FIN-2011006-0230 June 2011 23:59:59CooperNRC identifiedFailure to Report Conditions Prohibited by Technical Specifications and Safety System Functional FailuresThe inspectors identified a noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the licensees failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, a condition prohibited by technical specifications occurred when a zurn strainer failure rendered the service water system inoperable for longer than the action statement and would have prevented fulfillment of a safety function. The licensee entered the finding into the corrective action program as Condition Report 2011-06778. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action component, in that, the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors associated with the equipment failure.
05000298/FIN-2011006-0330 June 2011 23:59:59CooperNRC identifiedFailure to Perform 10 CFR 50.59 Evaluation for Design ChangeThe inspectors identified a noncited violation of 10 CFR 50.59, Changes, Tests, and Experiments, associated with the failure to adequately evaluate a change in order to ensure that it did not require prior NRC approval. Specifically, the licensee revised a residual heat removal pump motor cable sizing calculation to a smaller sized cable without a change evaluation. The licensee entered the issue into the corrective action program as Condition Report 2011-01730. The finding was determined to be more than minor because the licensee failed to perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore more than minor. Violations of 10 CFR 50.59 are considered to impede or impact the regulatory process, so they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process (SDP). The inspectors performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Therefore, the inspectors categorized the finding as Severity Level IV in accordance with the enforcement manual. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy. The inspectors determined the cause of the finding through interviews and document reviews. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate all factors associated with the design change.
05000298/FIN-2011002-0531 March 2011 23:59:59CooperNRC identifiedFailure to Notify the NRC within Eight Hours of a Nonemergency EventThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours following discovery of an event meeting the reportability criteria as specified. Specifically, on January 18, 2011, while the B train of residual heat removal was inoperable for scheduled maintenance the A train experienced a fault which rendered it inoperable for its low pressure coolant injection function. As a result, both trains of residual heat removal were incapable of performing their system specified safety function of residual heat removal. The licensees evaluation of this condition determined that it was not a reportable event because both core spray pumps were operable and the D residual heat removal pump was available therefore the overall function of decay heat removal was maintained. The inspectors questioned this rational, because the apparent intent of the reporting criteria as described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 2, section 3.2.7, was to cover an event or condition where structures, components, or trains of a safety system could have failed to perform their intended safety function as described in the plant safety analysis. Consultation with the Office of Nuclear Reactor Regulation determined that this was the intent of the criteria. As such, the inspectors determined that the licensee had failed to make a non-emergency 8 hour report as required by 10 CFR 50.72(b)(3)(v). The licensee submitted the 8 hour report on January 21, 2011 and entered this issue into the corrective action program as Condition Report CR-CNS-2011-0618. The failure to make an applicable non-emergency 8-hour event notification report within the required time frame was determined to be a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding had a crosscutting aspect in the area of human performance associated with the decision making component, in that, the licensee failed to use conservative assumptions in their decision making (H.1(b)) (Section 4OA3).
05000298/FIN-2010007-0631 December 2010 23:59:59CooperNRC identifiedFaulty General Electric SwitchesThe team identified a severity level IV noncited violation of 10 CFR Part 21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, for the failure of the licensee to evaluate the deviations in 13 of 23 safety-related switches within 60 days. Specifically, prior to August 10, 2010, the licensee failed to submit a report as required by paragraph 21.21 (a)(1) of 10 CFR Part 21 when 13 of 23 General Electric control switches purchased to support a station modification to the safety-related 4160 kV switchgear were discovered to have a defect that was later determined to create a substantial safety hazard. The defective switches were discovered and documented on Condition Report CNS-2009-09985 dated November 25, 2009 and the evaluation was not completed until August 10, 2010. After the evaluation determined the defect did create a substantial safety hazard, the NRC was notified via an event notification on August 10, 2010. Using the Traditional Enforcement Policy and Manual, this was determined to be a Severity Level IV noncited violation. This finding was entered into the licensees corrective action program as Condition Report CNS-2010- 5629. The finding had a crosscutting aspect of problem identification and resolution, alternative process, because the licensee failed to ensure appropriate and timely resolution of identified problems.
05000298/FIN-2009004-0330 September 2009 23:59:59CooperNRC identifiedWillful Failure to Implement the Fitness for Duty ProgramThe inspectors identified a noncited Severity Level IV violation of 10 CFR 26.27 for the willful failure of a nonlicensed operator to comply with the licensees fitness for duty requirements. As a result, the nonlicensed operator failed to complete required reactor building logs. Specifically, between June 3-6, 2008, a non-licensed operator failed to complete required reactor building rounds. Subsequent rounds verified no missed equipment deficiencies. The licensee initiated Condition Report CR-CNS-2009-06883 to place this item into the corrective action program. The failure to comply with the licensees requirements affecting fitness for duty is a performance deficiency. This issue was dispositioned using traditional enforcement due to the willful aspects of the performance deficiency. In accordance with Section IV.A.4 of the Enforcement Policy, this issue is considered more than minor due to the willful aspects of the performance deficiency. In accordance with the guidance in Supplement I of the Enforcement Policy, this issue is considered a Severity Level IV violation. There were no crosscutting aspects associated with this performance deficienc
05000298/FIN-2008004-0330 September 2008 23:59:59CooperNRC identifiedFailure to Report Safety Relief Valve Test Results Above Technical Specification Allowed SetpointThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73 (a)(1) regarding the licensees failure to submit a licensee event report within 60 days after the discovery of an event. Specifically, the inspectors determined that the licensee had failed to report the discovery that one safety relief valve pilot valve had exceeded its Technical Specification allowable lift setpoint for a time greater than allowed by Technical Specifications. The licensee entered this issue into their corrective action program as Condition Report CR-CNS-2008-07535. This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact the NRCs ability to perform its regulatory function. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violatio
05000298/FIN-2008003-0130 June 2008 23:59:59CooperNRC identifiedFailure to Notify the NRC of the Inability to Meet ASME Code RequirementsThe inspectors identified a noncited violation of 10 CFR 50.55a(g)(5)(iii) for the licensees failure to notify the NRC of the inability to meet the requirements of the American Society of Mechanical Engineers Code for Class 1 and 2 welds performed during Refueling Outage 22 in February 2005. Specifically, on April 21, 2008, the inspectors identified that welds associated with design changes to the reactor feedwater and high pressure core injection systems performed during Refueling Outage 22 did not meet the 90 percent total area coverage, required by ASME Section XI, during the performance of the preservice inspection ultrasonic testing. The licensee failed to notify the NRC of the inability to meet the ASME Code requirements within 12 months from the end of the third 10-year inservice inspection interval as required by 10 CFR 50.55a(g)(5)(iv). The failure to notify the NRC constituted a performance deficiency of 10 CFR 50.55a(g)(5)(iii). In accordance with Manual Chapter 0612, Appendix B, Section 2, this finding has the potential to impact the NRCs ability to perform its regulatory function since the licensee did not notify the NRC within the designated time, and as a result, impeded the NRCs ability to evaluate and decide on the potential ASME code relief in a timely manner. This finding is greater than minor because it is associated with the Mitigating System Cornerstone, in that the licensee failed to ensure the reliability of safety-related equipment due to the failure to meet ASME Code requirements for the Class 1 and 2 system pressure boundary welds since February 2005. In accordance with Supplement 1 of the Enforcement Policy, the violation was characterized as Severity Level IV because it involved a failure to meet regulatory requirements that have more than minor safety significance. This finding is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy, due to the NRCs review and acceptance of the licensees fourth cycle Risk Informed - Inservice Inspection program which no longer requires these welds to be periodically inspected in accordance with ASME Code, Section X
05000298/FIN-2007011-0631 December 2007 23:59:59CooperNRC identifiedSeverity Level Iv for Failure to Comply with the Requirements of 10 CFR 50.71(E) and to Assure the Updated Safety Analysis Report Has the Latest Information DevelopedThe team identified a noncited Severity Level IV violation for the failure to comply with the requirements of 10 CFR 50.71(e). The correct value for the automatic depressurization system accumulator minimum pressure was not used to revise the Updated Safety Analysis Report. Specifically, the licensees technical specifications and Design Calculation NEDC 88-306 require a minimum of 88 psig to assure five actuations of the safety relief valves with the drywell at atmospheric conditions. The Updated Safety Analysis Report lists a minimum pressure of 68.6 psig for this function. The Updated Safety Analysis Report stated pressure of 68.6 psig was incorporated as part of the licensees Updated Safety Analysis Report rebase line project and became effective on March 10, 2000. The licensee was unable to provide a basis for the lower pressure stated in the Updated Safety Analysis Report. This violation was subject to traditional enforcement because it had the potential to impact the regulatory process. This finding is considered more than minor because use of this lower pressure value could render the automatic depressurization feature incapable of performing its design function. In accordance with NRC Enforcement Policy, the NRC has concluded that this is a Severity Level IV violation. Because this violation was of very low safety significance, was not repetitive or willful, and it was entered into the licensees corrective action program as Condition Report CNS-2007-07468, this violation is being treated as an noncited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy.
05000298/FIN-2000007-0131 December 2000 23:59:59CooperNRC identifiedFailure to Maintain Environmental Qualifications of Safety-Related Equipment

This special inspection report covered the activities associated with inspection and assessment of environmental qualification issues. The failures to environmentally qualify, maintain the qualification of, and document qualifications in an auditable form, for equipment important to safety, constituted an apparent violation of 10 CFR 50.49 (Section 2.02)

This item was orginally opened as an apparent violation in IR 00-07. It was later closed per letter from Nebraska Public Power District dated November 8, 2001, Reference #NLS2001104 and reopened as a violation, Severity Level IV.