ML14044A105
| ML14044A105 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/13/2014 |
| From: | Allen D NRC/RGN-IV/DRP/RPB-C |
| To: | Limpias O Nebraska Public Power District (NPPD) |
| Allen D | |
| References | |
| EA-13-075, EA-13-225 IR-13-005 | |
| Download: ML14044A105 (42) | |
See also: IR 05000298/2013005
Text
February 13, 2014
Mr. Oscar A. Limpias, Vice President-Nuclear
and Chief Nuclear Officer
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT
05000298/2013005 AND NRC INVESTIGATION REPORT NO. 2013-009
Dear Mr. Limpias:
On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at the Cooper Nuclear Station. On December 20, 2013, the NRC inspectors
discussed the results of this inspection with Mr. R. Penfield, Director of Nuclear Safety
Assurance, and other members of your staff. Inspectors documented the results of this
inspection in the enclosed inspection report.
The NRC inspectors documented four findings of very low safety significance (Green) in this
report. All of these findings involved violations of NRC requirements. Further, inspectors
documented two licensee-identified violations which were determined to be of very low safety
significance in this report. The NRC is treating these violations as non-cited violations (NCVs)
consistent with Section 2.3.2.a of the Enforcement Policy.
One of the licensee identified violations referenced above, resulted in an NRC investigation.
The enclosed report documents the investigation completed on October 1, 2013, by the Nuclear
Regulatory Commission's Office of Investigations. The purpose of this investigation was to
determine whether a fire watch was wilfully inattentive while on duty at Nebraska Public Power
Districts Cooper Nuclear Station, Brownville, Nebraska. Based on the evidence gathered
during the investigation, the NRC concluded that on December 5, 2012, a former contract-
employee deliberately failed to perform a fire watch at the Cooper Nuclear Station. This was
contrary to the fire protection plan that satisfies Criterion 3 of Appendix A of 10 CFR Part 50,
and resulted in a violation.
Since the former contract-employee's violation was wilful, it was evaluated under the NRC's
traditional enforcement process in accordance with the Enforcement Policy. The current
Enforcement Policy is included on the NRC's website at: http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. After careful consideration of these factors, the
NRC concluded that this violation should be classified at Severity Level IV, based on the
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
O. Limpias
- 2 -
example provided in Section 6.1.d.1 of the Enforcement Policy. In reaching this decision, the
NRC considered that the event was isolated, it was performed by a low-level, contract-
employee, missing of the fire watch was of short duration, did not result in an actual
consequence, and occurred while the plant was shut-down. In addition, the significance was
mitigated because others were in the area and no actual fire occurred during the time frame that
the fire watch was non-observant.
In accordance with Section 2.3.2 of the Enforcement Policy, and with the approval of the
Director, Office of Enforcement, this issue has been characterized as a non-cited violation,
because (1) the violation was identified by the licensee; (2) the violation involved the act of an
individual, who would not have been considered a licensee official with oversight of regulated
activities as defined in the Enforcement Policy; (3) the violation did not involve a lack of
management oversight and was the isolated action of the former, contract-employee; and
(4) significant remedial action commensurate with the circumstances was taken by the licensee.
Regarding the corrective actions, the Cooper Nuclear Station conducted an internal
investigation to determine the cause and took appropriate corrective actions.
The NRC concluded that information regarding: (1) the reason for the violation, (2) the
corrective actions that have been taken and results achieved, and (3) the date when full
compliance was achieved is already adequately addressed on the docket in the enclosed
inspection report. Therefore, you are not required to respond to this letter unless the description
herein does not accurately reflect your corrective actions or your position.
If you contest the violations or significance of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident
inspector at the Cooper Nuclear Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the
Cooper Nuclear Station.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRCs Public
Document Room or from the Publicly Available Records (PARS) component of the NRC's
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA/
Donald B. Allen, Branch Chief
Project Branch C
Division of Reactor Projects
O. Limpias
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Docket Nos.: 50-298
License Nos: DPR-46
Enclosure: Inspection Report 05000298/2013005
wAttachment: Supplemental
Information
Electronic Distribution to the Cooper Nuclear Station
O. Limpias
- 4 -
SUNSI Rev Compl.
Yes No
Yes No
Reviewer Initials
RVA
Publicly Avail.
Yes No
Sensitive
Yes No
Sens. Type Initials
RVA
SRI:DRP/C
RI:DRP/C
C:DRS/EB1
C:DRS/EB2
C:DRS/OB
C:DRS/PSB1
JJosey
CHenderson
TRFarnholtz
GMiller
VGaddy
MSHaire
T-D.Allen for
T-D.Allen for
/RA/
/RA/
/RA/
/RA/
02/13/2014
02/13/2014
02/07/2014
02/12/2014
02/07/2014
02/07/2014
C:DRS/PSB2
C:DRS/TSB
SPE:DRP/C
ACES/C
BC:DRP/C
HGepford
RKellar
RAzua
VCampbell
DAllen
/RA/
/RA/
/RA/
/RA/
/RA/
02/10/2014
02/07/2014
02/06/2014
02/11/2014
02/13/2014
OFFICIAL RECORD COPY
- 1 -
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
05000298
License:
Report:
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
72676 648 A Ave
Brownville, NE
Dates:
September 23 through December 31, 2013
Inspectors: J. Josey, Senior Resident Inspector
S. Garchow, Senior Operations Engineer
C. Henderson, Resident Inspector
D. Strickland, Operations Engineer
C. Steely, Operations Engineer
J. Laughlin, Emergency Preparedness Inspector, NSIR
Approved
By:
Donald B. Allen
Chief, Project Branch C
Division of Reactor Projects
- 2 -
SUMMARY
IR 05000298/2013005; 09/23/2013-12/31/2013; Cooper Nuclear Station, Integrated Resident
and Regional Report; Equip Alignment, Maint Risk Assessments & Emergent Work Control,
Operability Determinations & Functionality Assessments, Problem ID & Resolution.
The inspection activities described in this report were performed between September 23, 2013,
and December 31, 2013, by the resident inspectors at the Cooper Nuclear Station, three
inspectors from the NRCs Region IV office, and an inspector from the NRCs Office of Nuclear
Security and Incident Response. Four findings of very low safety significance (Green) are
documented in this report. All of these findings involved violations of NRC requirements.
Additionally, NRC inspectors documented in this report two licensee-identified violations of very
low safety significance or Severity Level IV. The significance of inspection findings is indicated
by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual
Chapter 0609, Significance Determination Process. Their cross-cutting aspects are
determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting
Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs
Enforcement Policy. The NRC's program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Actions, associated with the licensees failure to promptly identify
and correct a condition adverse to quality. Specifically, from July 2010 to present, the
licensee failed to properly evaluate the diesel generator fuel oil storage tank vents to
demonstrate their ability to perform their specified safety function in the event of a tornado
missile. The licensee is in the process of developing corrective actions to restore
compliance for this issue. This issue has been entered into the corrective action program as
Condition Report CR-CNS-2014-00146.
The licensees failure to promptly identify and correct a condition adverse to quality was a
performance deficiency. This performance deficiency is more than minor, and therefore a
finding, because it is associated with the design control attribute of the Mitigating Systems
Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences.
Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination
Process (SDP) for Findings At-Power, dated July 1, 2012, inspectors determined this
finding to have very low safety significance (Green) because it: (1) was not a deficiency
affecting the design and qualification of a mitigating structure, system, or component, and
did not result in a loss of operability or functionality; (2) did not represent a loss of system
and/or function; (3) did not represent an actual loss of function of at least a single train for
longer allowed outage time, or two separate safety systems out-of-service for longer than
their technical specification allowed outage time; and (4) did not represent an actual loss of
function of one or more nontechnical specification trains of equipment designated as high
safety-significance in accordance with the licensees maintenance rule program. The finding
has a cross-cutting aspect in the area of human performance associated with decision-
making component because the licensee did not ensure that the proposed action was safe
in order to proceed, rather than unsafe to disapprove the action H.1(b) (Section 1R04).
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Green. The inspectors identified a non-cited violation of 10 CFR 50.65(a)(4), Requirements
for Monitoring the Effectiveness for Maintenance at Nuclear Power Plants, for the licensees
failure to implement required risk management actions during maintenance activities
affecting the seismic qualification of the safety-related 4160 Vac Bus F and G when the
cabinet doors are opened during under voltage relay testing. The licensee corrected this
issue by providing procedural guidance for implementation of the required risk management
actions. The licensee entered this deficiency into their corrective action program for
resolution as Condition Report CR-CNS-2013-06870.
The licensees failure to implement required risk management actions during maintenance
activities was a performance deficiency. This performance deficiency was more than minor,
and therefore a finding, because it was associated with the equipment performance attribute
of the Mitigating Systems Cornerstone and affected the associated objective. Specifically,
by failing to implement required risk management actions to restore 4160 Vac Bus F and G
to their seismically qualified condition, i.e. cabinet doors closed, this thereby affected the
associated objective to ensure availability, reliability, and capability of systems that respond
to initiating events to prevent undesirable consequences. Using Inspection Manual
Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management
Significance Determination Process, dated May 5, 2005, Flowchart 2, Assessment of Risk
Management Actions, the inspectors determined the need to calculate a risk deficit to
determine the significance of this issue. A senior reactor analyst performed a bounding
detailed risk evaluation, which determined that the incremental core damage probability
associated with this finding was less than 1 X 10-6, so the finding has very low safety
significance (Green). The finding has a cross-cutting aspect in the area of human
performance associated with the work practices component because the licensee failed to
define and effectively communicate expectations regarding procedural compliance and to
ensure that personnel follow procedures H.4(b)(Section 1R13).
Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, Drawings, associated with the licensees failure to
perform an adequate operability determination in accordance with Station
Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination.
Specifically, the licensee failed to evaluate the effect on operability of taking electrical relays
for the service water pumps out of their seismically qualified configuration. To correct this
issue the licensee directed that the affected service water pump be declared inoperable
during Division II under voltage testing. The licensee entered this deficiency into their
corrective action program for resolution as Condition Report CR-CNS-2014-00122.
The failure to properly assess and document the basis for operability when a degraded or
nonconforming condition was identified was a performance deficiency. The performance
deficiency was more than minor, and therefore a finding, because it was associated with the
equipment performance attribute of the Mitigating Systems Cornerstone and affected the
cornerstone objective to ensure availability, reliability, and capability of systems that respond
to initiating events to prevent undesirable consequences. Specifically, the licensees failure
to properly document and assess the basis for operability resulted in a condition of unknown
operability for a degraded nonconforming condition. Using Inspection Manual
Chapter 0609, Appendix A, Initial Screening and Characterization of Findings,
dated July 1, 2012, inspectors determined that the finding was of very low safety
significance (Green) because the finding: (1) was not a deficiency affecting the design and
qualification of a mitigating structure, system, or component, and did not result in a loss of
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operability or functionality; (2) did not represent a loss of system and/or function; (3) did not
represent an actual loss of function of at least a single train for longer than its technical
specification allowed outage time, or two separate safety systems out-of-service for longer
than their technical specification allowed outage time; and (4) did not represent an actual
loss of function of one or more nontechnical specification trains of equipment designated as
high safety-significance in accordance with the licensees maintenance rule program. The
finding has a cross-cutting aspect in the area of human performance associated with
decision-making component because the licensee did not ensure that the proposed action
was safe in order to proceed, rather than unsafe to disapprove the action H.1(b)
(Section 1R15).
Cornerstone: Occupational Radiation Safety
Green. Inspectors reviewed a self-revealing non-cited violation of Technical
Specification 5.4.1.a, associated with a radiation protection technician who failed to follow
the requirements of Radiation Work Permit 2013-001, Radiation Protection Activities,
Revision 1. This radiation work permit did not authorize entry into areas with dose rates
exceeding 80 mrem/hr. The licensee determined that this issue was due to a human
performance error and corrected the issue as such. The licensee entered this issue into
their corrective action program as Condition Report CR-CNS-2013-07506.
The failure to follow radiation work permit requirements was a performance deficiency. The
performance deficiency was more than minor, and therefore a finding, because it was
associated with the program and process attribute of the Occupational Radiation Safety
Cornerstone and affected the associated cornerstone objective to ensure the adequate
protection of the workers health and safety from exposure to radiation from radioactive
material during routine civilian nuclear reactor operation. Specifically, this finding resulted in
a radiation protection technician receiving an unintended and unexpected radiation dose.
Using Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance
Determination Process, dated August 19, 2008, the inspectors determined that the finding
was of very low safety significance (Green) because: (1) it was not associated with as low
as is reasonably achievable (ALARA) planning; (2) it did not involve an overexposure;
(3) there was no substantial potential for an overexposure; and (4) the licensees ability to
assess dose was not compromised. The finding has a cross-cutting aspect in the area of
human performance associated with the work practices component because licensee
personnel failed to use human error prevention techniques, such as pre-job briefs, self-and-
peer checking, and proper documentation of activities commensurate with the risk of the
assigned task, such that, work activities were performed safely H.4(a) (Section 4OA2).
Licensee-Identified Violations
Violations of very low safety significance or Severity Level IV that were identified by the licensee
have been reviewed by the inspectors. Corrective actions taken or planned by the licensee
have been entered into the licensees corrective action program. These violations and
associated corrective action tracking numbers are listed in Section 4OA7 of this report.
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PLANT STATUS
The Cooper Nuclear Station began the inspection period at full power on September 23, 2013,
and remained at essentially full power through the end of the inspection period
December 31, 2013.
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment (71111.04)
Partial Walkdown
a.
Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant
systems:
October 11, 2013, 125 Vdc and 250 Vdc, C battery charger to Division 1 and
Division 2 battery
October 13, 2013, 4160 Vac, Bus F
November 12, 2013, Core spray Division I and northeast quad fan coil unit
November 26, 2013, Auxillary steam lines in 4160 switchgear room G, diesel
generator rooms 1 and 2, service water pump room, and control room envelope
high energy line break requirements
The inspectors reviewed the licensees procedures and system design information to
determine the correct lineup for the systems. They visually verified that critical portions
of the systems were correctly aligned for the existing plant configuration.
These activities constituted four partial system walk-down samples as defined in
Inspection Procedure 71111.04.
b.
Findings
Introduction. The inspectors identified a Green, non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, associated with the licensees failure to
promptly identify and correct a condition adverse to quality.
Description. While performing plant walk downs, inspectors noted that the diesel
generator fuel oil storage tank vent lines appeared to be susceptible to tornado missiles.
Specifically, the vent lines were approximately 1 foot apart, and inspectors questioned
whether a single tornado generated missile could render both vent lines incapable of
performing their specified function.
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Inspectors reviewed the licensees USAR and noted the following:
Appendix F states that the licensee complies with Draft General Design
Criteria GDC-2, published July 11, 1967, and the Draft General Design
Criteria GDC-2 requires that the systems and components needed for accident
mitigation remain fully functional before, during, and after a tornado event.
USAR Chapter I-5, Section 5.2, defines Class I structures and equipment as,
Structures and equipment whose failure could cause significant release of
radioactivity or which are vital to a safe shutdown of the plant and removal of
decay and sensible heat.
USAR Chapter XII-2, Section 2.1.2.3, identifies the Standby Diesel Generator
System and Auxiliaries as Class I equipment.
Inspectors were not able to locate an evaluation of the vent lines that demonstrated their
ability to withstand a tornado missile impact. Inspectors did, however, note that Station
Procedure 5.1WEATHER, Operations During Weather Watches and Warnings,
Revision 12, Section 7.4, directed that, in the event of a tornado impact to the site,
operators would inspect the vent lines, and if they were damaged, one of the diesel
generator fuel oil tank fill lines was to be opened. Inspectors determined this to be a
compensatory action, and questioned if the vent lines were adequately protected from
Inspectors informed the licensee of their concerns, and the licensee initiated Condition
Report CR-CNS-2013-03720. In this condition report, the licensee identified that during
the 2010 NRC component design basis inspection, NRC inspectors had similar
questions and Condition Report CR-CNS-2010-05211 had been initiated to address
these questions. The licensee subsequently closed Condition Report
CR-CNS-2013-03720 with no further actions being taken.
Inspectors reviewed Condition Report CR-CNS-2010-05211 and noted that it had been
initiated due to questions about a statement in the licensees design control document
for the diesel generators which dealt with tornado missile protection for the diesel
generator fuel oil storage tank vents. Specifically, the design control document stated, in
part, The vent pipe concerns was satisfactorily resolved during the 1991 EDSFI, and
inspectors had requested the stations evaluation for the diesel generator fuel oil storage
tank vents and fill valves with respect to tornado missile.
The licensee researched the basis for this statement and determined that it most likely
came from their evaluation of a finding at another facility where the NRC had questioned
the adequacy of fill and vent connections with respect to impact from a tornado/tornado
missile. During their review, the licensee determined that an evaluation of the fill and
vent lines ability to withstand a tornado missile impact did not exist.
Corrective action number 2 of Condition Report CR-CNS-2010-05211 was, in part, to
provide a formal analysis of the diesel generator fuel oil storage tank vent lines
pertaining to tornado missile protection. The licensee generated Engineering
Evaluation 10-060, Evaluation of the Diesel Generator Fuel Oil Tanks, in response to
this corrective action.
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Inspectors reviewed Engineering Evaluation 10-060 and noted that it did not evaluate
the vent lines with regard to their ability to withstand tornado generated missiles.
Instead, it assumed that the vents were small runs of pipe and if impacted by a missile
there would be no damage to the fueil oil storage tank. The evaluation went on to
discuss manual actions that could be implemented if the vent lines were to be damaged
by a tornado generated missile.
Inspectors determined that the licensees assumptions associated with the vent lines
ability to withstand a missile impact were not adequate. Therefore, the licensee had
failed to correct a previously identified condition adverse to quality. Specifically,
Condition Report CR-CNS-2010-05211 identified that the station did not have an
evaluation that demonstrated the diesel generator vent lines ability to withstand a
tornado missile impact, and the corrective action (corrective action 2) to correct this, did
not because of inadequate assumptions by engineering personnel.
Inspectors informed the licensee of their concern, and the licensee initiated Condition
Report CR-CNS-2014-00146.
Analysis. The licensees failure to promptly identify and correct a condition adverse to
quality was a performance deficiency. This performance deficiency is more than minor,
and therefore a finding, because it is associated with the design control attribute of the
Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Using Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power,
dated July 1, 2012, inspectors determined this finding to have very low safety
significance (Green) because it: (1) was not a deficiency affecting the design and
qualification of a mitigating structure, system, or component, and did not result in a loss
of operability or functionality; (2) did not represent a loss of system and/or function;
(3) did not represent an actual loss of function of at least a single train for longer allowed
outage time, or two separate safety systems out-of-service for longer than their technical
specification allowed outage time; and (4) did not represent an actual loss of function of
one or more nontechnical specification trains of equipment designated as high safety-
significance in accordance with the licensees maintenance rule program. The finding
has a cross-cutting aspect in the area of human performance associated with decision-
making component because the licensee did not ensure that the proposed action was
safe in order to proceed, rather than unsafe to disapprove the action H.1(b).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions,
requires, in part, that measures shall be established to assure that conditions adverse to
quality, such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected. Contrary to
the above, from July 2010 to present, measures established by the licensee failed to
assure that an identified condition adverse to quality was corrected. Specifically, the
licensee failed to evaluate the lack of tornado missile protection for the diesel generator
fuel oil storage tank vents and demonstrate their ability to perform their specified safety
function in the event of a tornado missile strike. The licensee is in the process of
developing corrective actions to restore compliance for this issue. An immediate safety
concern does not exist due to the procedurized compensatory measures. This violation
is being treated as a non-cited violation, consistent with Section 2.3.2.a of the
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Enforcement Policy. The violation was entered into the licensees corrective action
program as Condition Report CR-CNS-2014-00146. (NCV 05000298/2013005-01,
Failure to Promptly Identify and Correct a Condition Adverse to Quality)
1R05 Fire Protection (71111.05)
Quarterly Inspection
a.
Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status
and material condition. The inspectors focused their inspection on four plant areas
important to safety:
October 3, 2013, Control rod drive units north, Fire Area I, Zone 2A
October 3, 2013, Residual heat removal heat exchanger 1A, Fire Area I, Zone 2B
October 3, 2013, Standby liquid control pump tanks and access way, Fire Area I,
Zone 5A
October 8, 2013, Diesel generator room 1A, Fire Area IX, Zone 14A
For each area, the inspectors evaluated the fire plan against defined hazards and
defense-in-depth features in the licensees fire protection program. The inspectors
evaluated control of transient combustibles and ignition sources, fire detection and
suppression systems, manual firefighting equipment and capability, passive fire
protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection
Procedure 71111.05.
b.
Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06)
a.
Inspection Scope
On November 6, 2013, the inspectors completed an inspection of a manhole susceptible
to flooding. The inspectors selected a manhole that contained risk-significant or
multiple-train cables whose failure could disable risk-significant equipment:
Manhole 6A
The inspectors observed the material condition of the cables and splices contained in
the manhole and looked for evidence of cable degradation due to water intrusion. The
inspectors verified that the cables met design requirements.
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These activities constitute completion of one bunker/manhole sample, as defined in
Inspection Procedure 71111.06.
b.
Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07)
a.
Inspection Scope
On November 12, 2013, the inspectors completed an inspection of the readiness and
availability of risk-significant heat exchangers. The inspectors reviewed the data from a
performance test for the A reactor equipment cooling heat exchanger. Additionally, the
inspectors walked down the A reactor equipment cooling heat exchanger to observe its
performance and material condition and verified that the A reactor equipment cooling
heat exchanger was correctly categorized under the Maintenance Rule and was
receiving the required maintenance.
These activities constitute completion of one heat sink performance annual review
sample, as defined in Inspection Procedure 71111.07.
b.
Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1
Review of Licensed Operator Requalification
a.
Inspection Scope
On October 30, 2013, the inspectors observed an evaluated simulator scenario
performed by an operating crew. The inspectors assessed the performance of the
operators and the evaluators critique of their performance.
These activities constitute completion of one quarterly licensed operator requalification
program sample, as defined in Inspection Procedure 71111.11.
b.
Findings
No findings were identified.
.2
Review of Licensed Operator Performance
a.
Inspection Scope
On November 29, 2013, the inspectors observed the performance of on-shift licensed
operators in the plants main control room. The inspectors observed the operators
performance of the following activities:
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2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for the reactor core isolation coolant surveillance brief and run
1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for the control rod operability
0.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> for the brief on the solenoid-operated valve replacement for control
rods 18-35 and 22-11
In addition, the inspectors assessed the operators adherence to plant procedures,
including conduct of operations procedure and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance
sample, as defined in Inspection Procedure 71111.11.
b.
Findings
No findings were identified.
.3
Biennial Inspection
a.
Inspection Scope
To assess the performance effectiveness of the licensed operator requalification
program, the inspectors conducted personnel interviews, reviewed the operating tests,
reviewed randomly selected medical and watchstanding proficiency records, and
observed ongoing operating test activities.
The on-site inspection effort occurred from October 21, 2013, to October 24, 2013.
During this time, the inspectors interviewed licensee personnel to determine their
understanding of the policies and practices for administering requalification
examinations. The inspectors also performed observations of portions of the operating
tests. These observations included five job performance measures and five scenarios
that were administered in the current biennial requalification cycle. These observations
allowed the inspectors to assess the licensee's effectiveness in conducting the operating
test to ensure operator mastery of the training program content. The inspectors also
performed an in-office review of overall operator performance on the biennial written
exams as well as the annual operating tests.
The results of these examinations were reviewed to determine the effectiveness of the
licensees appraisal of operator performance and to determine if feedback of
performance analyses into the requalification training program was being accomplished.
The inspectors interviewed members of the training department and reviewed minutes of
the Operations Training Review Group and Training Advisory Committee meetings to
assess the responsiveness of the licensed operator requalification program to
incorporate the lessons learned from both plant and industry events. The inspector also
reviewed a sample of licensed operator annual medical forms and procedures governing
the medical examination process for conformance to 10 CFR 55.53, a sampling of the
licensed requalification program feedback system, and reviewed remediation process
records. In addition to the above, the inspectors reviewed examination security
measures, simulator fidelity, and simulator deficiencies.
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From December 1 to December 16, 2013, the inspectors performed an in-office review
of the biennial written examinations and reviewed the overall pass/fail results of the
individual job performance measure operating tests, simulator operating tests, and
written examinations administered by the licensee during the operator licensing
requalification cycles and biennial examination. Final examination results were
assessed to determine if they were consistent with the guidance contained in
NUREG 1021, "Operator Licensing Examination Standards for Power Reactors,
Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, "Operator
Requalification Human Performance Significance Determination Process." Seven
separate crews participated in simulator operating tests, written examinations, and job
performance measure operating tests, totaling 41 licensed operators. There was one
failure on the written examination, no individual failures on the simulator operating tests,
and no failures on the job performance measure operating tests. The one failure on the
written examination was successfully remediated prior to returning to shift.
The inspectors completed one inspection sample of the biennial licensed operator
requalification program.
b.
Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
a.
Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-
related structures, systems, and components:
November 19, 2013, 4160 Vac Bus F and G unavailability
November 27, 2013, 10 CFR 50.65(a)(3) evaluation
The inspectors reviewed the extent of condition of possible common cause structure,
system, and component failures and evaluated the adequacy of the licensees corrective
actions. The inspectors reviewed the licensees work practices to evaluate whether
these may have played a role in the degradation of the structure, system, and
component. The inspectors assessed the licensees characterization of the degradation
in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee
was appropriately tracking degraded performance and conditions in accordance with the
Maintenance Rule.
These activities constituted completion of two maintenance effectiveness samples, as
defined in Inspection Procedure 71111.12.
b.
Findings
No findings were identified.
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1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a.
Inspection Scope
The inspectors reviewed six risk assessments performed by the licensee prior to
changes in plant configuration and the risk management actions taken by the licensee in
response to elevated risk:
October 16, 2013, Appendix R reactor building local auxiliary safe shutdown
control panel availability when reactor temperature rises above 200 degrees
Fahrenheit
November 18, 2013, 4160 Vac Bus F undervoltage relay testing
November 19, 2013, Inclement weather and off site power
December 16, 2013, Replacement of service water booster pump C
December 18, 2013, Control room envelope boundary door seal H305
repair/replacement
December 31, 2013, Temporary steam exclusion boundaries for control building,
903 feet corridor and door D301
The inspectors verified that these risk assessments were performed timely and in
accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant
procedures. The inspectors reviewed the accuracy and completeness of the licensees
risk assessments and verified that the licensee implemented appropriate risk
management actions based on the result of the assessments.
Additionally, on October 13, 2013, the inspectors also observed portions of one
emergent work activitiy that had the potential to affect the functional capability of
Diesel generator 1 unavailable and Yellow risk for jacket water leak to the lube oil
system
The inspectors verified that the licensee appropriately developed and followed a work
plan for these activities. The inspectors verified that the licensee took precautions to
minimize the impact of the work activities on unaffected structures, systems, and
components.
These activities constitute completion of seven maintenance risk assessments and
emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b.
Findings
Introduction. The inspectors identified a Green, non-cited violation of
10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants, for the licensees failure to implement required risk management
actions for safety-related 4160 Vac Bus F and G under voltage relay testing.
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Description. The inspectors conducted a walk down of the work area and reviewed the
risk assessment and risk management actions associated with under voltage relay
testing of safety-related 4160 Vac Bus F. Inspectors noted that the cabinet doors were
opened during under voltage relay testing and asked the following questions: (1) Are the
safety-related 4160 Vac Bus F and G switchgear seismically qualified when the cabinet
doors are open? and (2) If the buses are not seismically qualified with the doors open,
what risk management actions are in place, and where are they documented, to ensure
they are returned to their seismically qualified condition and, thereby, maintained
available?
The licensee informed the inspectors that the 4160 Vac Bus F and G had only been
evaluated for seismic qualification with the doors closed, therefore, when the doors were
opened, the switchgear was not seismically qualified. The licensee also stated that
Station Procedure 0.41, Seismic Housekeeping, Revision 9, requires that unsecured
open panel access doors shall be attended by workers at all times and, based on this,
they considered the 4160 Vac Bus F and G available when the doors are open.
The inspectors reviewed Station Procedure 0.41, Seismic Housekeeping, Revision 9,
and Station Procedure 0.49, Scheduled Risk Assessment, Revision 34. Inspectors
noted that Station Procedure 0.49 allowed operators to declare equipment available,
provided that, restoration was directed by a procedure, restoration could be done in a
few simple actions, restoration did not require diagnosis, and the function could be
promptly restored either by an operator in the control room or by a dedicated operator
stationed locally for that purpose. Inspectors also noted that neither Station
Procedure 0.41 nor the work order instructions associated with 4160 Vac Bus G and F
under voltage relay testing contained specific directions to restore the buses to their
seismically qualified condition for event response. The inspectors informed the licensee
of their concern, and to capture this concern in the stations corrective action program,
the licensee initiated Condition Report CR-CNS-2013-06870.
The licensee implemented the required additional risk management action through a
revision to Station Procedure 0.41, which ensured workers are briefed to close panel
access doors in the event of an emergency or as directed by control room personnel.
The inspectors determined that the apparent cause of this finding was that the licensee
had failed to follow the requirements of Station Procedure 0.49 for maintaining
availability of the safety-related 4160 Vac Bus F and G when not in their seismically
qualified condition, i.e. cabinet doors open. Specifically, restoration of the 4160 Vac
buses was not directed by a procedure, work order instruction, or standing order.
Analysis. The licensees failure to implement required risk management actions during
maintenance activities was a performance deficiency. This performance deficiency was
more than minor, and therefore a finding, because it was associated with the equipment
performance attribute of the Mitigating Systems Cornerstone and affected the associated
objective. Specifically, by failing to implement required risk management actions to
restore 4160 Vac Bus F and G to their seismically qualified condition, i.e. cabinet doors
closed, this thereby affected the associated objective to ensure availability, reliability,
and capability of systems that responds to initiating events to prevent undesirable
consequences. Using Inspection Manual Chapter 0609, Appendix K, Maintenance Risk
Assessment and Risk Management Significance Determination Process, dated May 5,
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2005, Flowchart 2, Assessment of Risk Management Actions, the inspectors
determined the need to calculate the risk deficit to determine the significance of this
issue. A senior reactor analyst performed a bounding detailed risk evaluation which
determined that the incremental core damage probability associated with this finding was
less than 1 X 10-6, so the finding has very low safety significance (Green). The finding
has a cross-cutting aspect in the area of human performance associated with the work
practices component because the licensee failed to define and effectively communicate
expectations regarding procedural compliance and to ensure that personnel follow
procedures H.4(b).
Enforcement. Title 10 CFR 50.65(a)(4) states, in part, that before performing
maintenance activities, the licensee shall assess and manage the increase in risk that
may result from the proposed maintenance activities. Contrary to the above, until
October 2013, the licensee failed to properly manage the increase in risk that resulted
from proposed maintenance activities. Specifically, measures established by the
licensee failed to implement required risk management actions for the proposed
maintenance activity of under voltage relay testing for the safety-related 4160 Vac Bus F
and G when not in their seismically qualified condition. The licensee corrected this issue
by providing procedural guidance for implementation of the required risk management
actions. This violation is being treated as a non-cited violation, consistent with
Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees
corrective action program as Condition Report CR-CNS-2013-06870.
(NCV 05000298/2013005-02, Failure to Implement Risk Management Actions for
Proposed Maintenance Activities)
1R15 Operability Determinations and Functionality Assessments (71111.15)
a.
Inspection Scope
The inspectors reviewed four operability determinations that the licensee performed for
degraded or nonconforming structures, systems, or components:
October 4, 2013, Operability determination of the service water booster pump C
missing bearing
October 9, 2013, Operability determination for incorrect grease in the primary
containment isolation valves RW-AO-AO82, 83, 94, and 95
October 23, 2013, Operability determination of the auxiliary steam piping high-
energy line break affecting safety related structures, systems, and components
outside secondary containment
November 26, 2013, Operability determination of the 4160 Vac, Bus G and
Division II service water pumps
The inspectors reviewed the timeliness and technical adequacy of the licensees
evaluations. Where the licensee determined the degraded structures, systems, and
components to be operable, the inspectors verified that the licensees compensatory
measures were appropriate to provide reasonable assurance of operability. The
inspectors verified that the licensee had considered the effect of other degraded
conditions on the operability of the degraded structures, systems, and components.
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These activities constitute completion of four operability and functionality review
samples, as defined in Inspection Procedure 71111.15
b.
Findings
Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the
licensees failure to perform an adequate operability determination in accordance with
Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability
Determination.
Description. While reviewing material associated with NCV 05000298/2013005-02,
Failure to Implement Risk Management Actions for Proposed Maintenance Activities,
inspectors determined that there were other safety-related relays on the 4160 Vac Bus F
and G cabinet doors and questioned why they were not inoperable with the cabinet
doors open. Inspectors informed operators of their questions.
Operations evaluated the inspectors questions as part of their review documented in
Condition Report CR-CNS-2013-06870. During this review operations department
determined that the relays in question had not previously been evaluated for operability,
so an evaluation was performed and documented in this condition report. Operators
determined that no other relays operability was affected by opening the cabinet doors.
During discussions with operators, inspectors questioned this determination.
Specifically, inspectors questioned why the high pressure trip relay associated with the
auto position of the service water pumps on the G bus, having the potential to change
state during a seismic event and potentially affecting the ability of the pump to start on a
low pressure signal, did not affect operability during testing. Operators responded that
the auto position on the switch was not discussed in the USAR nor the technical
specifications. Therefore, this switch position did not have a credited function. Thus, no
operability concerns existed and no further evaluations were required.
Inspectors subsequently reviewed the USAR and technical specifications. During this
review, they noted that Surveillance Requirement 3.7.2.4 required the licensee to verify
that the service water pumps would start on a low pressure signal when in the auto
position. Inspectors determined that operators had failed to adequately evaluate the
service water pump relays on the G bus cabinet doors for operability. Inspectors
informed the licensee of their concerns and the licensee initiated Condition
Report CR-CNS-2014-00122 to capture this issue in the stations corrective action
program.
Inspectors noted that Station Procedure 0.5OPS, Operations Review of Condition
Reports/Operability Determinations, Revision 46, provided the guidance used by
operations staff at the Cooper Nuclear Station to perform operability determinations.
Section 3.1 required, in part, that the shift manager, document the basis for operability
when a degraded or nonconforming condition exists.
Analysis. The failure to properly assess and document the basis for operability when a
degraded or nonconforming condition was identified was a performance deficiency. The
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performance deficiency was more than minor, and therefore a finding, because it was
associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and affected the cornerstone objective to ensure availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the licensees failure to properly document and assess the
basis for operability resulted in a condition of unknown operability for a degraded
nonconforming condition. Using Inspection Manual Chapter 0609, Appendix A, Initial
Screening and Characterization of Findings, dated July 1, 2012, inspectors determined
that the finding was of very low safety significance (Green) because the finding: (1) was
not a deficiency affecting the design and qualification of a mitigating structure, system, or
component, and did not result in a loss of operability or functionality; (2) did not
represent a loss of system and/or function; (3) did not represent an actual loss of
function of at least a single train for longer than its technical specification allowed outage
time, or two separate safety systems out-of-service for longer than their technical
specification allowed outage time; and (4) did not represent an actual loss of function of
one or more nontechnical specification trains of equipment designated as high safety-
significance in accordance with the licensees maintenance rule program. The finding
has a cross-cutting aspect in the area of human performance associated with the
decision-making component because the licensee did not ensure that the proposed
action was safe in order to proceed, rather than unsafe to disapprove the action H.1(b).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that
activities affecting quality shall be accomplished in accordance with documented
instructions, procedures, or drawings, of a type appropriate to the circumstances.
Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability
Determination, a procedure that is appropriate to the circumstances of evaluating the
operability of safety-related components, required the licensee to properly assess and
document the basis for operability when a degraded or nonconforming condition was
identified. Contrary to the above, on December 20, 2013, an activity affecting quality
was not accomplished in accordance with a procedure that was appropriate to the
circumstances. Specifically, operators failed to adequately evaluate the effect on
operability of taking electrical relays for the service water pumps out of their seismically
qualified configuration. To correct this issue the licensee directed that the affected
service water pump be declared inoperable during Division II under voltage testing. This
violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the
Enforcement Policy. The violation was entered into the licensees correction action
program as Condition Report CR-CNS-2014-00122. (NCV 05000298/2013005-03,
Failure to Follow Operability Procedure)
1R19 Post-Maintenance Testing (71111.19)
a.
Inspection Scope
The inspectors reviewed four post-maintenance testing activities that affected risk-
significant structures, systems, or components:
October 13, 2013, Diesel generator 1 emergent work control
October 13, 2013, Service water booster pump C
October 17, 2013, Service water booster pump B maintenance window
October 31, 2013, Service water pump A and SW-MOV-36MV
- 17 -
The inspectors reviewed licensing- and design-basis documents for the structures,
systems, and components and the maintenance and post-maintenance test procedures.
The inspectors observed the performance of the post-maintenance tests to verify that
the licensee performed the tests in accordance with approved procedures, satisfied the
established acceptance criteria, and restored the operability of the affected structures,
systems, and components.
These activities constitute completion of four post-maintenance testing inspection
samples, as defined in Inspection Procedure 71111.19.
b.
Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a.
Inspection Scope
The inspectors observed two risk-significant surveillance tests and reviewed test results
to verify that these tests adequately demonstrated that the structures, systems, and
components were capable of performing their safety functions:
In-service test:
October 16, 2013, Division I diesel generator fuel oil transfer pump in-service
flow test
Containment isolation valve surveillance test:
October 3, 2013, North scram discharge volume vent isolation valve,
CRD-AOV-CV38B
The inspectors verified that these tests met technical specification requirements, that the
licensee performed the tests in accordance with their procedures, and that the results of
the tests satisfied appropriate acceptance criteria. The inspectors verified that the
licensee restored the operability of the affected structures, systems, and components
following testing.
These activities constitute completion of two surveillance testing inspection samples, as
defined in Inspection Procedure 71111.22.
b.
Findings
No findings were identified.
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Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)
a.
Inspection Scope
The NSIR headquarters staff performed an in-office review of the latest revisions of
various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan
located under ADAMS accession number ML13336A463 as listed in the Attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in
the revisions resulted in no reduction in the effectiveness of the Plan, and that the
revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E
to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report
and did not constitute approval of licensee-generated changes; therefore, this revision is
subject to future inspection. The specific documents reviewed during this inspection are
listed in the Attachment.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.04-05.
b.
Findings
No findings were identified.
4.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security
4OA1 Performance Indicator Verification (71151)
Mitigating Systems Performance Index: Emergency AC Power Systems (MS06), High
Pressure Injection Systems (MS07), Heat Removal Systems (MS08), Residual Heat
Removal Systems (MS09), and Cooling Water Systems (MS10)
a.
Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the
period from the fourth quarter 2012 through the third quarter 2013 to verify the accuracy
and completeness of the reported data. The inspectors used definitions and guidance
contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported
data.
These activities constituted verification of the mitigating system performance index for
emergency ac power systems, high pressure injection systems, heat removal systems,
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residual heat removal systems, and cooling water systems, as defined in Inspection
Procedure 71151.
b.
Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152)
.1
Routine Review
a.
Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items
entered into the licensees corrective action program and periodically attended the
licensees condition report screening meetings. The inspectors verified that licensee
personnel were identifying problems at an appropriate threshold and entering these
problems into the corrective action program for resolution. The inspectors verified that
the licensee developed and implemented corrective actions commensurate with the
significance of the problems identified. The inspectors also reviewed the licensees
problem identification and resolution activities during the performance of the other
inspection activities documented in this report.
b.
Findings
No findings were identified.
.2
Annual Follow-up of Selected Issues
a.
Inspection Scope
The inspectors selected two issues for an in-depth follow-up:
On October 16, 2013, the inspectors reviewed corrective actions associated with
the standby liquid control system test tank seismic II/I evaluation.
The inspectors assessed the licensees problem identification threshold, cause
analyses, extent of condition reviews and compensatory actions. The inspectors
verified that the licensee appropriately prioritized the planned corrective actions
and that these actions were adequate to correct the condition.
On December 16, 2013, the inspectors reviewed corrective actions associated
with an unplanned dose rate alarm
The inspectors assessed the licensees problem identification threshold, cause
analyses, extent of condition reviews and compensatory actions. The inspectors
verified that the licensee appropriately prioritized the planned corrective actions
and that these actions were adequate to correct the condition.
These activities constitute completion of two annual follow-up samples, as defined in
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b.
Findings
Introduction. The inspectors reviewed a self-revealing Green non-cited violation of
Technical Specification 5.4.1.a, associated with a radiation protection technicians failure
to follow the requirements of a radiation work permit.
Description. On November 4, 2013, a radiation protection technician signed into
Radiation Work Permit (RWP) 2013-001, Radiation Protection Activities, Revision 1, to
complete the weekly turbine building high radiation area door and posting inspections.
This radiation work permit had a dose limit of 20 millirem and dose rate limit of
80 millirem per hour, and it did not authorize the access to high radiation areas. The
technician had determined prior to entering the radiologically controlled area that the
performance of this task did not require entry into a high radiation area.
The inspections included the steam jet air ejector room gate posting. When the
technician entered the vestibule to the steam jet air ejector room, the individual failed to
notice the high radiation area posting which was between the individual and the steam
jet air ejector room gate posting. The technician entered the posted high radiation area
to check the posting on the steam jet air ejector room gate and received a dose rate
alarm. Upon receiving the dose rate alarm, the technician realized they had entered an
area that exceeded the dose rates allowed by the radiation work permit. The technician
immediately left the area and reported the alarm to supervision. The licensee
determined that the highest dose rate encountered by the technician was 97 millirem per
hour, and the total dose received was 0.5 millirem. The licensee entered this issue into
their corrective action program as Condition Report CR-CNS-2013-07506.
The licensee subsequently performed an apparent cause evaluation, and determined
that the apparent cause for this event was a personnel performance issue regarding
effective use of human performance tools. Specifically, (1) the technician failed to sign
in on the correct radiation work permit authorizing access to high radiation areas in
accordance with Station Procedure 9.EN-RP-101, Access Control for Radiologically
Controlled Areas, Revision 12; (2) the technician failed to obtain the required brief prior
to entering the high radiation area in accordance with Station Procedure 9.EN-RP-101;
(3) the technician failed to stop and perform a job site review when encountering a
posting change from a radiation area to high radiation area; and (4) the technician failed
to use STAR to engage and question this task prior to entering a high radiation area.
Inspectors reviewed the licensees cause analysis and determined that the identified
apparent cause was reasonable for the unplanned dose rate alarm. Inspectors also
noted that the technicians actions were contrary to the requirements of Station
Procedure 9.ALARA.4, Radiation Work Permits, Revision 17, Section 7.3, which stated
that each individual is responsible for complying with radiation work permits.
Analysis. The failure to follow radiation work permit requirements was a performance
deficiency. The performance deficiency was more than minor, and therefore a finding,
because it was associated with the program and process attribute of the Occupational
Radiation Safety Cornerstone and affected the associated cornerstone objective to
ensure the adequate protection of the workers health and safety from exposure to
radiation from radioactive material during routine civilian nuclear reactor operation.
Specifically, this finding resulted in a radiation protection technician receiving an
- 21 -
unintended and unexpected radiation dose. Using Manual Chapter 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, dated August 19,
2008, the inspectors determined that the finding was of very low safety significance
(Green) because: (1) it was not associated with as low as is reasonably achievable
(ALARA) planning; (2) it did not involve an overexposure; (3) there was no substantial
potential for an overexposure; and (4) the licensees ability to assess dose was not
compromised. The finding has a cross-cutting aspect in the area of human performance
associated with the work practices component because the individual failed to use
human error prevention techniques, such as pre-job briefs, self-and-peer checking, and
proper documentation of activities commensurate with the risk of the assigned task, such
that, work activities were performed safely H.4(a).
Enforcement. Technical Specification 5.4.1.a requires, in part, implementation of
applicable procedures recommended by Regulatory Guide 1.33, Revision 2, Appendix A,
February 1978. Section 7(e) of Appendix A requires, in part, procedures for access
control to radiation areas including a radiation work permit system. Station
Procedure 9.ALARA.4, Radiation Work Permits, Revision 17, implemented this
requirement, and Section 7.3 of Procedure 9.ALARA.4 stated that each individual is
responsible for complying with radiation work permits. Radiation Work Permit 2013-01,
Radiation Protection Activities, Revision 1, did not authorize entry into a high radiation
area and had a dose limit of 20 mrem and a dose rate limit of 80 mrem/hr. Contrary to
the above, on November 4, 2013, a radiation protection technician entered an area with
dose rates exceeding 80 mrem/hr, a condition not authorized by the radiation work
permit. Specifically, the technician failed to see a high radiation area posting and
entered an area with a dose rate of 97 mrem/hr. The licensee determined that this issue
was due to a human performance error and corrected the issue as such. This finding is
being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement
Policy. The violation was entered into the licensees corrective action program as
Condition Report CR-CNS-2013-07506. (NCV 05000298/2013005-04, Failure to
Implement a Radiation Protection Procedure)
.3 Semiannual Trend Review
a.
Inspection Scope
The inspectors reviewed the licensees corrective action program, performance
indicators, system health reports, and other documentation to identify trends that might
indicate the existence of a more significant safety issue. The inspectors verified that the
licensee was taking corrective actions to address identified adverse trends. The
inspectors also reviewed the licensees progress in addressing existing cross-cutting
themes in; the resources component of the human performance area H.2(c), the
corrective action program component of the problem identification and resolution
area P.1(c), and the decision making component related to the use of conservative
assumptions in decision making H.1(b).
These activities constitute completion of one semiannual trend review sample, as
defined in Inspection Procedure 71152.
b.
Findings
No findings were identified.
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Cross-Cutting Issues Trend Review
(1)
Cross-Cutting Theme in Decision Making H.1(b)
In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 8
findings associated with the decision making component of the human performance area
involving the use of conservative decision making H.1(b). The NRC determined that a
substantive cross-cutting issue existed because there was a concern with the licensees
scope of effort and progress in addressing this cross-cutting theme, and this theme
repeated a theme identified in earlier assessment periods.
In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 13
findings associated with the cross-cutting aspect of H.1(b). The NRC maintained this
substantive cross-cutting issue open. The licensee initiated Condition
Report CR-CNS-2013-01740, 2012 NRC Annual Assessment Letter Identified 3
Substantive Cross-Cutting Issues, on March 4, 2013. The licensees investigation
determined that the root causes were:
The stations standards related to the resolution of apparently low significance
regulatory issues were low and did not meet Entergy fleet or industry
expectations. This was evidenced by a lack of urgency to fully understand and
resolve substantive cross-cutting issues and NRC findings of low significance
(Green).
The stations Engineering and Operations departments were not adequately
proficient in the application of the licensing and design basis of the plant. Weak
design basis knowledge together with limited experience related to the
application of the design basis, particularly in engineering, resulted in the
reduced levels of proficiency.
The licensees corrective actions for the identified causes were:
Assign mentors to review key engineering analysis products,
Revise the stations corrective action program for how violations and substantive
cross-cutting issues were evaluated,
Conduct operability training with the operations department, and
Conduct training on the stations design and licensing basis with engineering and
operations departments.
In the 2013 mid-cycle assessment letter, dated September 3, 2013, the NRC recognized
the licensee had implemented some corrective actions and had scheduled other
corrective actions for future completion. On October 8, 2013, the NRC was notified of
the licensees readiness for this inspection.
On October 21, 2013, the licensee initiated Condition Report CR-CNS-2013-07205,
NRC Findings with a CCA of H.1(b), to investigate the most recent findings with
H.1(b). The licensees investigation determined that the root (common) cause of these
- 23 -
findings was that clear standards and expectations for the "burden of proof
requirements" for conservative decision making have not been consistently set and
reinforced. The licensee determined that the contributing cause was that prior to the
changes made by CR-CNS-2013-01740, condition reports that documented NCVs and
other NRC Findings of Low Significance had typically not investigated the underlying
process, program, or organizational factors that caused the event to become an NCV.
The licensee determined that the corrective actions described in Condition
Report CR-CNS-2013-01740 were adequate to address the identified causes.
This baseline inspection semi-annual trend review monitored for sustainable
performance improvements as evidenced by effective implementation of an appropriate
corrective action plan that results in no safety significant inspection findings and a
notable reduction in the overall number of inspection findings with the same common
theme.
To date the NRC has identified 7 findings with the cross-cutting aspect of H.1(b) and
this continues to comprise a cross-cutting theme. The licensee has implemented
corrective actions to address this theme and the inspectors will continue to monitor for
sustained improvement.
(2) Cross-Cutting Theme in Documentation and Procedures H.2(c)
In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 4
findings with an associated cross-cutting aspect in the resources component of the
human performance area of failing to provide complete, accurate and up-to-date design
documentation, procedures, and work packages, and correct labeling of components
H.2(c). At the time, the NRC did not identify a substantive cross-cutting issue due to
the licensees scope of effort in addressing the theme, and because it was an emergent
performance trend.
In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 4
findings with the associated cross-cutting aspect of H.2(c). The NRC opened a
substantive cross-cutting aspect because the corrective actions had not been effective in
addressing the issue. The licensee initiated Condition Report CR-CNS-2013-01740.
2012 NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues, on
March 4, 2013. The licensees investigation determined that the root causes were:
The stations standards related to the resolution of apparently low significance
regulatory issues were low and did not meet Entergy fleet or industry
expectations. This was evidenced by a lack of urgency to fully understand and
resolve substantive cross-cutting issues and NRC findings of low significance
(Green).
The stations Engineering and Operations departments were not adequately
proficient in the application of the licensing and design basis of the plant. Weak
design basis knowledge together with limited experience related to the
application of the design basis, particularly in engineering, resulted in the
reduced levels of proficiency.
The licensees corrective actions for the identified causes were:
- 24 -
Assign mentors to review key engineering analysis products,
Revise the stations corrective action program for how violations and substantive
cross-cutting issues were evaluated,
Conduct operability training with the operations department, and
Conduct training on the stations design and licensing basis with engineering and
operations departments.
This baseline inspection semi-annual trend review monitored for sustainable
performance improvements as evidenced by effective implementation of an appropriate
corrective action plan that results in no safety significant inspection findings and a
notable reduction in the overall number of inspection findings with the same common
theme.
The inspectors have observed sustained improvement in the resources component of
the human performance area as demonstrated by no findings with that theme following
full implementation of appropriate corrective actions.
(3)
Cross-Cutting Theme in Problem Evaluation P.1(c)
In the 2011 mid-cycle assessment letter, dated September 1, 2011, the NRC staff
identified 6 findings associated with the corrective action program component of the
problem identification and resolution area in the aspect of thoroughness of problem
evaluation such that the resolutions address causes and extent of conditions P.1(c).
The NRC determined that a substantive cross-cutting issue did not exist because the
NRC did not have a concern with the licensees scope of effort and progress in
addressing the cross-cutting theme and because it was a recent performance trend.
In the 2011 end-of-cycle assessment letter, dated March 5, 2012, the NRC identified 7
findings with a cross-cutting aspect in P.1(c). The NRC opened a substantive cross-
cutting issue in this cross-cutting theme because the NRC had a concern with the
licensees scope of effort and progress in addressing the issue.
In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC identified 8
findings with a cross-cutting aspect of P.1(c) and maintained this substantive cross-
cutting issue open.
In the 2012 end-of-cycle assessment letter, dated March 4, 2013, the NRC identified 8
findings with a cross-cutting aspect of P.1(c) and maintained this substantive cross-
cutting issue open. The licensee initiated Condition Report CR-CNS-2013-01740. 2012
NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues, on
March 4, 2013. The licensees investigation determined that the root causes were:
The stations standards related to the resolution of apparently low significance
regulatory issues were low and did not meet Entergy fleet or industry
expectations. This was evidenced by a lack of urgency to fully understand and
resolve substantive cross-cutting issues and NRC findings of low significance
(Green), and
- 25 -
The stations Engineering and Operations departments were not adequately
proficient in the application of the licensing and design basis of the plant. Weak
design basis knowledge together with limited experience related to the
application of the design basis, particularly in engineering, resulted in the
reduced levels of proficiency.
The licensees corrective actions for the identified causes were:
Assign mentors to review key engineering analysis products,
Revise the stations corrective action program for how violations and substantive
cross-cutting issues were evaluated,
Conduct operability training with the operations department, and
Conduct training on the stations design and licensing basis with engineering and
operations departments.
This baseline inspection semi-annual trend review monitored for sustainable
performance improvements as evidenced by effective implementation of an appropriate
corrective action plan that results in no safety significant inspection findings and a
notable reduction in the overall number of inspection findings with the same common
theme.
The inspectors have observed sustained improvement in the resources component of
the human performance area as demonstrated by one finding with that theme following
full implementation of appropriate corrective actions.
4OA5 Other Activities
.1
(Closed) Violation 05000298/2013009-01: Failure to Maintain Seismic Qualification of
Standby Liquid Control System (EA-13-075)
The inspectors reviewed the licensees immediate corrective actions and implemented
corrective actions to restore the plant to regulatory conformance. The inspectors noted
that the actions implemented by the licensee involved reviewing the seismic II/I
qualification of the Standby Liquid Control System test tank. The inspectors determined
that these actions have addressed the concerns expressed in the violation. This
violation is closed.
.2
IP 92723, Follow Up Inspection for Three or More Severity Level IV Traditional
Enforcement Violations in the Same Area in a 12-Month Period
a.
Inspection Scope
As announced in the Mid-Cycle Performance Review and Inspection Plan letter
(ML13246A356) and in accordance with IP 92723, the inspectors reviewed the
licensees responses to the three traditional-enforcement violations identified during the
12-month period that ended on June 30, 2013. These violations were non-cited and
were designated as follows:
- 26 -
NCV 05000298/2012004-06, Failure to Obtain Prior NRC Approval for a Change
Regarding the Supplemental Diesel Generator
NCV 05000298/2013009-02, Failure to Notify the NRC within Eight Hours of a
Nonemergency Event
NCV 05000298/2012301-01; Failure to Maintain Both Initial Licensing Examination and
Licensed Operator Examination Integrity
The inspectors reviewed the licensees responses to these violations to verify that the
licensee understood the causes of these violations, identified the extent-of-condition and
extent-of-cause associated with these violations, and had taken corrective actions that
are sufficient to address the causes of the violations.
b.
Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 24, 2013, the inspectors conducted an inspection debrief with Mr. J. Austin,
Training Manager, and other members of the licensee's staff, on the results of the licensed
operator requalification program inspection. The licensee acknowledged the findings presented.
After reviewing the complete biennial requalification cycle examination results, the inspectors
conducted a telephonic exit with Mr. C. Herring, Operations Training Superintendent, on
December 19, 2013. The licensee acknowledged the results as presented.
The inspectors asked the licensee whether any materials examined during the inspection should
be considered proprietary. No proprietary information was identified.
On December 20, 2013, the inspectors presented the inspection results to Mr. R. Penfield,
Director of Nuclear Safety Assurance, and other members of the licensee staff. The licensee
acknowledged the issues presented. The licensee confirmed that any proprietary information
reviewed by the inspectors had been returned or destroyed.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) or Severity Level IV were
identified by the licensee and are violations of NRC requirements which meets the criteria of the
NRC Enforcement Policy Section 2.3.2.a., for being dispositioned as non-cited violation.
Title 10 CFR 50.65(a)(1), Requirements for monitoring the effectiveness of maintenance
at nuclear power plants, requires, in part, that holders of an operating license shall
monitor the performance or conditions of structures, systems, or components within the
scope of the monitoring program against licensee established goals in a manner
sufficient to provide reasonable assurance that such structures, systems, or components
are capable of fulfilling their intended safety function. Contrary to the above, on
November 6, 2013, the licensee identified that they failed to establish goals in a manner
sufficient to provide reasonable assurance that structures, systems, or components were
- 27 -
capable of fulfilling their intended safety function. Specifically, the licensee failed to
establish goals for the main condenser when it was placed in an (a)(1) status. This
performance deficiency was more than minor, and therefore a finding, because it was
associated with the equipment performance attribute of the Initiating Events
Cornerstone, and affected the associated cornerstone objective to limit the likelihood of
events that upset plant stability and challenge critical safety functions during shutdown
as well as power operations. Using Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) For Findings At-Power, inspectors
determined that the finding was of very low safety significance (Green) because the
finding did not cause a reactor trip and the loss of mitigation equipment relied upon to
transition the plant from the onset of the trip to a stable shutdown condition. This issue
was entered into the licensees corrective action program as Condition
Report CR-CNS-2013-07967 for resolution.
Title 10 CFR 50.48 requires, in part, that licensees must have a fire protection plan that
satisfies Criterion 3 of Appendix A of 10 CFR Part 50. Condition 2.C.(4) of the Cooper
Nuclear Station (CNS) License Number DPR-46 states, in part, that the licensee shall
implement and maintain in effect all provisions of the approved fire protection program
as described in the Updated Safety Analysis Report (USAR) and as approved in the
Safety Evaluation dated November 29, 1977, and subsequent supplements. Chapter 9
of the USAR, Fire Protection System, provides a summary description of the SSCs that
are relied on to meet the requirements of General Design Criterion 3, Fire Protection, in
10 CFR Part 50 Appendix A. USAR Section 9.3.2.6 states that the Service Water Pump
Room is protected by an automatic Halon 1301 fire suppression system. USAR Section
9.6 states that the limiting conditions for operation and surveillance requirements for the
Fire Protection System are provided in the CNS Technical Requirements Manual (TRM).
TRM T 3.11.5, Halon 1301 Fire Suppression System, requires that a continuous fire
watch be established if the Halon 1301 system in the Service Water Pump Room is
inoperable. CNS Administrative Procedure (AP) 0.39.1, Fire Watches and Fire
Impairments, Revision 9, Paragraph 5.1.8, Responsibilities of Compensatory
Continuous Fire Watches, stated, in part, that Fire Watch shall observe the..Affected
Area and be alert for signs of fire, smoke, and changing conditions. Contrary to the
requirement in CNS AP 0.39.1, Paragraph 5.1.8, on December 5, 2012, an individual
assigned to fire watch duty to observe the Affected Area was deliberately not alert for
signs of fire, smoke, and changing conditions. Specifically, an individual assigned to
continuous fire watch duty in the Service Water Pump Room, while the Halon 1301
system was inoperable, was found by a non-licensed operator to be inattentive. This
caused the licensee to be in violation of License Condition 2.C.(4) of License No. DPR-
46. The licensee identified the violation, performed an internal investigation, and took
appropriate corrective actions. This included entering this issue into their corrective
action program as Condition Report CR-CNS-2012-10123 for resolution. These
corrective actions were completed on December 24, 2012. (EA-13-225)
A-1
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Austin, Training Manager
T. Barker, Manager, Engineering Programs and Components
J. Bebb, Staff Health Physicist, Radiation Protection
J. Bednar, Technical Supervisor, Radiation Protection
R. Beilke, Manager, Radiation Protection
D. Buman, Director, Engineering
T. Chard, Manager, Quality Assurance
S. DeRosier, Operator Training Superintendent
J. Dixon, ALARA Supervisor, Radiation Protection
R. Estrada, Manager, Design Engineering
M. Ferguson, Manager, Emergency Preparedness
J. Florence, Simulator Supervisor
C. Herring, Superintendant, Operations Training, Requalification
K. Higginbotham, General Plant Manager, Operations
K. Fike, Plant Chemist, Chemistry
J. Flaherty, Senior Staff Licensing Engineer, Licensing
E. Jackson, Exam Developer
D. Madsen, Senior Staff Engineer, Licensing
R. Morris, Specialist, Radiation Protection
J. Olberding, Licensing Specialist
R. Penfield, Director Nuclear Safety Assurance
J. Stough, Manager, Information Technology
K. Tanner, Radiological Shift Supervisor, Radiation Protection
D. Van Der Kamp, Manager, Licensing
A. Walters, Manager, Chemistry
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed 05000298/2013005-01
Failure to Promptly Identify and Correct a Condition Adverse to
Quality (Section 1R04)05000298/2013005-02
Failure to Implement Risk Management Actions for Proposed
Maintenance Activities (Section 1R13)05000298/2013005-03
Failure to Follow Operability Procedure (Section 1R15)05000298/2013005-04
Failure to Implement a Radiation Protection Procedure
(Section 4OA2)
A-2
Closed 05000298/2013009-01
Failure to Maintain Seismic Qualification of Standby Liquid
Control System (EA-13-075)(Section 4OA5)
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
Miscellaneous Documents
Number
Title
Revision
Engineering Evaluation, Assessment of CNS Compliance
with 10 CFR 50.49
0
PBD-EQ, Cooper Nuclear Station Environmental
Qualification Program Basis Document
5 00-95D
NEDC, HELB EQ - Reactor Building
Pressure/Temperature
1 02-005
NEDC, HELB EQ - Mass and Energy Release
1 02-007
NEDC, Review of MPR Calculation 315-0030-001
1 09-102
NEDC, Internal Flooding - HELB, MELB, and Feedwater
Line Break
0 and 1 13-024
NEDC, Steam Exclusion Barrier for Building Door D301
0 13-036
Engineering Evaluation, Steam Exclusion Boundary for
Controlled Corridor Door D301 and Control Building
(EL 903-06) Corridor and Rooms
0 90-031
Design Change, Smoke/Fire Dampers for Control Room
Ventilation
0 91-119
Design Change, DG-Steam Heating Piping System and HV
Fan Coil Restraints
0 91-227
NEDC, Code Qualification of AS, ACD, and CH Piping
Supports in the CNS Diesel Generator Bldg
1 91-277
NEDC, Diesel Generator Building AS, ACD, and CH Piping
Analysis Problem AS-01
1 92-135
NEDC, Operability Evaluation of Steam Piping in the Cable
Spreading Room
1
2045
Burns and Roe, Sheet 1, Flow Diagram Core Spray System
Cooper Nuclear Station
N58
A-3
Miscellaneous Documents
Number
Title
Revision
3002
Burns and Roe, Sheet 1, Cooper Nuclear Station Auxiliary
One Line Diagram, MCC Z, SWGR Bus 1A, 1B, 1E and
Critical SWGR Bus 1F, 1G
N49
3058
Burns and Roe, Cooper Nuclear Station DC One Line
Diagram
N63
Procedures
Number
Title
Revision
2.2.48.2A
Operations Procedure, Station Heating System Electrode
Boilers C and D Component Checklist
26
2.2.73
Operations Procedure, Standby Gas Treatment System
50
2.2A_125DC.DIV1 Operations Procedure, 125 VDC Power Checklist (Div 1)
7
2.2A_250DC.DIV2 Operations Procedure, 250 VDC Power Checklist (Div 2)
0
2.2A_4160.Div1
Operations Procedure, 4160 VAC Auxilary Power Checklist
(Div 1)
1
2.3_9-3-1
Operations Procedure, Panel 9-3 Annunciator 9-3-1
31
2.3_FP-1
Operations Procedure, Fire Protection-Annunciator 1
11
2.3_R-2
Operations Procedure, Panel R - Annunciator R-2
17
2.3_S-1
Operations Procedure, Panel S - Annunciator S-1
18
2.4HVAC
Operations Procedure, Building Ventilation Abnormal
20
2.4TEC
Operations Procedure, TEC Abnormal
25
5.1Incident
Emergency Procedure, Site Emergency Incident
26
6.1EE.302
Surveillance Procedure, 4160V Bus 1F Undervoltage Relay
and Relay Timer Functional Test (Div 1)
31
Condition Reports (CRs)
A-4
Section 1R05: Fire Protection
Miscellaneous Documents
Number
Title
2013-281
Barrier Permit
Procedures
Number
Title
Revision
0.23
Station Procedure, CNS Fire Protection Plan
68
Work Orders
4935603
4978976
4978994
Section 1R06: Flood Protection Measures
Procedures
Number
Title
Revision
2.3_S-1
Operations Procedure, Panel S - Annunciator S-1
18
Condition Reports (CRs)
Section 1R07: Heat Sink Performance
Miscellaneouse Documents
Number
Title
Revision
REC-F01
Performance Criteria Basis
2
Procedures
Number
Title
Revision
13.15.1
Performance Evaluation Procedure, Reactor Equipment
Cooling Heat Exchanger Performance Analysis
33
Condition Reports (CRs)
A-5
Work Orders
4895739
Section 1R11: Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number
Title
Revision
6.CRD.301
Surveillance Procedure, Withdrawn Control Rod Operability
IST Test
29
6.RCIC.102
Surveillance Procedure, RCIC IST and 92 Day Test
31
OTP810
Operations Department Examination Security
16
OTP812
Conduct of Operator Oral Boards
12
OTP809
Operator Requalification Examination Administration
16
OTP808
Open Reference Examination Test Item Development
1
OTP806
Conduct of Simulator Training and Evaluation
16
OTP805
Licensed Operator Requalification Biennial Written Exam
12
OTP804
Requalification Scenario Exercise Guide Development
19
OTP803
Development of Operations Training JPMs
4
OTP813
Annual Operating Requal. Exam Development and Admin.
2
OTP814
SIMULATOR SCENARIO-BASED TRAINING
May 2, 2012
TPP 201
CNS Licensed Personnel Requalification Program
61
2.0.7
CNS Licensed Operator Requalification Program
6
NTP8.2
Preparation and Submittal of Operator and Senior Operator
License Applications
6
NTP8.1
Administration of Licensed Operator Medical Examination
Program
14
EN-TQ-201-04
SAT - Implementation Phase
2
A-6
Procedures
Number
Title
Revision
EDP-06
Supporting Requirements for Configuration Change Control 46
3.4
Configuration Change Control
55
Miscellaneous Documents
Number
Title
Revision/Date
NA
Steady State Test - 23%, 75%, 100%
August 2, 2013
NA
Transient Performance Test #5
October 21, 2013
NA
Transient Performance Test #9
October 21, 2013
SKL012-06-01
OPS Simulator Introduction
179
NTD120057
Simulation Configuration Update - PTL 1207
December 3, 2012
NTD130005
Simulation Configuration Update - PTL 1301
January 8, 2013
NTD130006
Simulation Configuration Update - PTL 1302
January 21, 2013
NTD130014
Simulation Configuration Update - PTL 1304
February 20, 2013
NA
Report - Simulator Discrepancies by
Due Date
October 21, 2013
SKL034-20-127
1
SDR 13-0061
2 Parameters Out-of-Spec Steady State Test
July 19, 2013
SDR 13-0043
Feedwater Heater Leaks
March 5, 2013
SMP 13-0010
Implement SPC 2012-92 to Simulator
January 18, 2013
SMP 13-0004
Replace SIM RHR-FR-143
October 10, 2012
SDP 13-0025
Correct Simulator RWCU Pump Trip Logic
February 20, 2013
TQF-210-DD04
Performance Evaluation Reports for 2 ROs
October 23, 2013
TQF-210-DD03
LOR Simulator Crew Performance Eval Reports October 23, 2013
OTP813 Att 12
JPM Evaluation Results for 2 ROs
October 23, 2013
NA
2013 LOR Bienniel Written Exam Week 1
through 6 (RO/SRO)
December 12, 2013
A-7
Miscellaneous Documents
Number
Title
Revision/Date
NA
Five Randomly Selected Licensed Operator
Medical Records
October 22, 2013
Section 1R12: Maintenance Effectiveness
Miscellaneous Documents
Number
Title
Revision
Maintenance Rule Periodic Assessment
2C0
PF03A
Engineering Evaluation, Provides Essential 4160 VAC
Power to Critical Station Auxiliary Loads (4160V Division 1
Distribution System
1
PF03B
Engineering Evaluation, Provides Essential 4160 VAC
Power to Critical Station Auxiliary Loads (4160V Division 2
Distribution System
1
Condition Reports (CRs)
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Miscellaneous Documents
Number
Title
Revision
EQDP.2.212
Appendix R MOV Local Auxiliary Safe Shutdown Control
Panel Components
1 09-102
NEDC, Internal Flooding - HELB, MELB, and Feedwater
Line Break
1 13-023
NEDC, HVAC Vent Steam Exclusion Boundary
0 13-024
NEDC, Steam Exclusion Barrier for Building Door D301
0 13-027
NEDC, Control Building (EL 903-06)Temperature Rise
due to temporary SEB Barrier Installation
0 13-036
Engineering Evaluation, Steam Exclusion Boundary for
Controlled Corridor Door D301 and Control Building
(EL 903-06) Corridor and Rooms
0
2013-023
Barrier Control Permit
2013-281
Barrier Control Permit
A-8
Miscellaneous Documents
Number
Title
Revision
2013-0368
Barrier Control Permit
2013-0369
Barrier Control Permit
10977008
Technical Evaluation
0
Procedures
Number
Title
Revision
0-Barrier
Station Procedure, Barrier Control Process
7 and 9
0-Barrier-Misc
Station Procedure, Miscellaneous Buildings
3
0.41
Station Procedure, Seismic Housekeeping
9 and 10
0.49
Station Procedure, Schedule Risk Assessment
34
6.1EE.302
Surveillance Procedure, 4160V Bus 1F Undervoltage Relay
and Relay Timer Functional Test (Div 1)
31
Condition Reports (CRs)
Work Orders
4889242
4910617
4910701
4920901
4922893
4921123
4935603
4941332
4945830
4945831
4958736
4978976
4978994
Section 1R15: Operability Determinations and Functionality Assessments
Miscellaneous Documents
Number
Title
Revision
71
Book, Calculations, Crane Runway Beam
0
71
Book, Calculations, 2 Ton Overhead Crane
0 91-119
Design Change, DG-Steam Heating Piping System and HV
Fan Coil Restraints
0
A-9
Procedures
Number
Title
Revision
0.5OPS
Station Procedure, Operations Review of Condition
Reports/Operability Determination
44
2.3_B-3
Operations Procedure, Panel B - Annunciator B-3
30
2.3_FP-1
Operations Procedure, Fire Protection-Annunciator 1
11
2.3_R-1
Operations Procedure, Panel R - Annunciator R-1
14
5.1Break
Emergency Procedure, Pipe Break Outside Secondary
Containment
14
Condition Reports (CRs)
Section 1R19: Post-Maintenance Testing
Procedures
NUMBER
TITLE
REVISION
2.20.2
Station Procedure, Operation of Diesel Generators from
Diesel Generator Room
57
6.SW.202
Surveillance Procedure, Service Water Power Operated
Valve Operability Test
18
6.1SW.101
Surveillance Procedure, Service Water Surveillance
Operation (Div 1)(IST)
42
6.2SWBP.101
Surveillance Procedure, RHR Service Water Booster Pump
Flow Test and Valve Operability Test (Div 2)
23
7.0.5
Maintenance Procedure, Post Maintenance Testing
45
7.2.53.3
Maintenance Procedure, Diesel Engine Maintenance
34
Condition Reports (CRs)
A-10
Work Orders
4895484
4895569
4895654
4895870
4921123
4932446
4954675
4958736
4978976
Section 1R22: Surveillance Testing
Miscellaneous Documents
Number
Title
Revision
Appendix A Valve Stroke Time Summary
223
Engineering Evaluation, Reconfiguration DGDO-V-19 from
Open to Close
0 01-081
Engineering Evaluation, Determination of Fuel Oil Specific
Gravity for Use in Diesel Fuel Oil Transfer Pump IST
Testing
0
Procedures
Number
Title
Revision
3.9
Engineering Procedure, ASME OM Code Testing of Pumps
and Valves
27
6.CRD.201
Surveillance Procedure, North and South SDV Vent and
Drain Valve Cycling, Open Verification, and Timing Test
20
6.DG.603
Surveillance Procedure, Diesel Fuel Oil Incoming Truck
Sample
21
6.1DG.401
Surveillance Procedure, Diesel Generator Fuel Oil Transfer
Pump IST Flow Test (Div 1)
31
Condition Reports (CRs)
Work Orders
4908790
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Number
Title
Revision
EPIP 5.7.1
Emergency Classification
49
A-11
Section 4OA1: Performance Indicator Verification
Miscellaneous Documents
Title
Revision
Mitigating Systems Performance Index (MSPI) Basis
Document
7
Procedures
Number
Title
Revision
0-EN-LI-114
Entergy Procedure, Performance Indicator Process
5C0
Condition Reports (CRs)
Section 4OA2: Problem Identification and Resolution
Miscellaneous Documents
Number
Title
Revision 13-009
Engineering Evaluation, Evaluation of the SLC Test,
Storage, and Mix Tanks for Seismic
1 13-010
NEDC, CNS SLC Storage, Test, and Mix Tanks Seismic
Qualification
1
2013-01
Radiation Work Permit, RP Activities
1
2013-078
Radiation Work Permit, RP Activities in SWP Areas
1
Procedures
Number
Title
Revision
9.ALARA.4
RAD Protection Procedure, Radiation Work Permits
17
RAD Protection Procedure, Radiation Worker
Expectations
3
RAD Protection Procedure, Access Control For
Radiologically Controlled Areas
12
Condition Reports (CRs)