ML060250255: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(One intermediate revision by the same user not shown)
Line 15: Line 15:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES XNUCLEAR                         REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-4005 August 30, 2004 Randall K. Edington, Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
{{#Wiki_filter:UNITED STATES XNUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-4005 August 30, 2004 Randall K. Edington, Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321


==SUBJECT:==
==SUBJECT:==
Line 21: Line 21:


==Dear Mr. Edington:==
==Dear Mr. Edington:==
On August 5, 2004, the NRC staff completed its midcycle plant performance assessment of CNS. The midcycle review for CNS involved the participation of all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of your performance, including the performance indicators (Pis) for the most recent quarter and the inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.
On August 5, 2004, the NRC staff completed its midcycle plant performance assessment of CNS. The midcycle review for CNS involved the participation of all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of your performance, including the performance indicators (Pis) for the most recent quarter and the inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.
This performance review and inspection plan does not include physical protection information.
This performance review and inspection plan does not include physical protection information.
Line 28: Line 27:
At the beginning of the 2004 assessment cycle, CNS was in the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix because there were three White emergency preparedness findings that had existed for more than four quarters. During the second quarter of 2004, the NRC closed these White findings on the basis of the correction of the underlying performance deficiencies. However, NRC concluded that additional NRC oversight was warranted while Nebraska Public Power District (NPPD) completes the actions specified in the CAL. Accordingly, on May 3, 2004, the Executive Director for Operations approved a deviation from the Action Matrix to authorize the NRC to maintain the level of oversight of CNS consistent
At the beginning of the 2004 assessment cycle, CNS was in the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix because there were three White emergency preparedness findings that had existed for more than four quarters. During the second quarter of 2004, the NRC closed these White findings on the basis of the correction of the underlying performance deficiencies. However, NRC concluded that additional NRC oversight was warranted while Nebraska Public Power District (NPPD) completes the actions specified in the CAL. Accordingly, on May 3, 2004, the Executive Director for Operations approved a deviation from the Action Matrix to authorize the NRC to maintain the level of oversight of CNS consistent


Nebraska Public Power District                   with the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix. This enhanced level of oversight includes continued NRC assessment of the strategic improvement plan, continued assessment of the effectiveness of the CAL actions and senior NRC management involvement in site visits and other assessment activities. This increased oversight will continue until NPPD has demonstrated, and the NRC has verified, that the improvement plan actions addressed by the CAL have resulted in sustained improvement in plant performance. The details of this decision were communicated to NPPD in a letter dated July 2, 2004.
Nebraska Public Power District with the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix. This enhanced level of oversight includes continued NRC assessment of the strategic improvement plan, continued assessment of the effectiveness of the CAL actions and senior NRC management involvement in site visits and other assessment activities. This increased oversight will continue until NPPD has demonstrated, and the NRC has verified, that the improvement plan actions addressed by the CAL have resulted in sustained improvement in plant performance. The details of this decision were communicated to NPPD in a {{letter dated|date=July 2, 2004|text=letter dated July 2, 2004}}.
On May 7, 2004, the NRC completed a supplemental inspection to assess the causes for and actions taken related to the Pi for unplanned scrams per 7000 critical hours. This PI crossed the threshold from Green to White in the fourth quarter of 2003 and returned to Green in first quarter of 2004. The NRC concluded that CNS performed thorough evaluations for each of the three scrams, including a thorough root cause analysis, extent of cause, and extent of condition review to identify and implement corrective actions in response to these scrams.
On May 7, 2004, the NRC completed a supplemental inspection to assess the causes for and actions taken related to the Pi for unplanned scrams per 7000 critical hours. This PI crossed the threshold from Green to White in the fourth quarter of 2003 and returned to Green in first quarter of 2004. The NRC concluded that CNS performed thorough evaluations for each of the three scrams, including a thorough root cause analysis, extent of cause, and extent of condition review to identify and implement corrective actions in response to these scrams.
On May 12, 2004, the NRC completed another supplemental inspection conducted in response to the White finding for the high failure rate on the licensed operator biennial requalification written examinations. The NRC determined that NPPD's root cause analyses of the finding was appropriately evaluated and understood. The corrective actions identified as a result of the NPPD evaluations addressed the root and contributing causes and should correct the requalification program weaknesses provided the corrective actions are consistently implemented. However, the inspection also concluded that NPPD's extent of condition and extent of cause evaluations of the high failure rate were not completed at the time of the inspection and that other areas of the root cause lacked in-depth evaluation, including the adequacy of operator knowledge and the establishment of objective criteria to evaluate effectiveness of the corrective actions. A followup inspection will be conducted in the fourth quarter of 2004 to verify the effectiveness of NPPD's additional corrective actions.
On May 12, 2004, the NRC completed another supplemental inspection conducted in response to the White finding for the high failure rate on the licensed operator biennial requalification written examinations. The NRC determined that NPPD's root cause analyses of the finding was appropriately evaluated and understood. The corrective actions identified as a result of the NPPD evaluations addressed the root and contributing causes and should correct the requalification program weaknesses provided the corrective actions are consistently implemented. However, the inspection also concluded that NPPD's extent of condition and extent of cause evaluations of the high failure rate were not completed at the time of the inspection and that other areas of the root cause lacked in-depth evaluation, including the adequacy of operator knowledge and the establishment of objective criteria to evaluate effectiveness of the corrective actions. A followup inspection will be conducted in the fourth quarter of 2004 to verify the effectiveness of NPPD's additional corrective actions.
Line 35: Line 34:
Numerous equipment improvements have been recently completed; however, there are a number of long-standing or repetitive problems that have not been fully resolved. In the area of plant modifications and configuration control, progress in operability determination screening and lessons learned training has provided the potential for enhancing the ability to prioritize and
Numerous equipment improvements have been recently completed; however, there are a number of long-standing or repetitive problems that have not been fully resolved. In the area of plant modifications and configuration control, progress in operability determination screening and lessons learned training has provided the potential for enhancing the ability to prioritize and


Nebraska Public Power District                   perform operability determinations by emphasizing knowledged based tools. In the area of engineering programs, actions taken to date have resulted in several positive performance trends.
Nebraska Public Power District perform operability determinations by emphasizing knowledged based tools. In the area of engineering programs, actions taken to date have resulted in several positive performance trends.
The remaining two CAL focus areas are also addressed by two substantive crosscutting issues in problem identification and resolution, as well as human performance. In our annual assessment letter dated March 3, 2004, we provided you an assessment of these substantive crosscutting issues. Performance in these areas continues to be of concern based on the inspection findings identified during the past 12 months.
The remaining two CAL focus areas are also addressed by two substantive crosscutting issues in problem identification and resolution, as well as human performance. In our annual assessment {{letter dated|date=March 3, 2004|text=letter dated March 3, 2004}}, we provided you an assessment of these substantive crosscutting issues. Performance in these areas continues to be of concern based on the inspection findings identified during the past 12 months.
In the area of problem identification and resolution, our March 3, 2004, annual assessment letter noted that your staff adequately identified issues and that you have implemented a number of actions with the goal of improving the implementation effectiveness of your corrective action, self-assessment, and operating experience review programs. We also noted, however, that there were a number of Green findings involving instances of inadequate corrective actions. Common themes associated with these findings included: inadequate extent of condition reviews, inappropriate symptom-based problem solving, inadequate treatment of plant-specific and industry operating experience, and failures to implement planned corrective actions. Since that time, you have implemented a number of other initiatives to increase management ownership of the corrective action program and improve the timeliness of correction actions. We have observed that the implementation of these improvements has resulted in more timely program reviews of operating experience and more timely closure of significant condition reports. However, a number of plant problems, particularly those involving systems and components, have not been fully resolved. Accordingly, we plan to continue to focus our baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in overall improved corrective action effectiveness.
In the area of problem identification and resolution, our March 3, 2004, annual assessment letter noted that your staff adequately identified issues and that you have implemented a number of actions with the goal of improving the implementation effectiveness of your corrective action, self-assessment, and operating experience review programs. We also noted, however, that there were a number of Green findings involving instances of inadequate corrective actions. Common themes associated with these findings included: inadequate extent of condition reviews, inappropriate symptom-based problem solving, inadequate treatment of plant-specific and industry operating experience, and failures to implement planned corrective actions. Since that time, you have implemented a number of other initiatives to increase management ownership of the corrective action program and improve the timeliness of correction actions. We have observed that the implementation of these improvements has resulted in more timely program reviews of operating experience and more timely closure of significant condition reports. However, a number of plant problems, particularly those involving systems and components, have not been fully resolved. Accordingly, we plan to continue to focus our baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in overall improved corrective action effectiveness.
In the human performance area, our annual assessment letter recognized that your staff had implemented actions to improve human performance and that some improvement had been observed. Notwithstanding these improvements, we indicated that there were instances in which plant staff members failed to follow procedures. Since the beginning of the year, your staff has continued to implement ongoing initiatives, as well as undertake additional actions. In recent months, however, there have been a number of component manipulation errors, one of which is potentially significant. As a result, we will continue to focus baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in improved performance, particularly in the areas of procedural compliance and the reinforcement of expectations and standards in the performance of work.
In the human performance area, our annual assessment letter recognized that your staff had implemented actions to improve human performance and that some improvement had been observed. Notwithstanding these improvements, we indicated that there were instances in which plant staff members failed to follow procedures. Since the beginning of the year, your staff has continued to implement ongoing initiatives, as well as undertake additional actions. In recent months, however, there have been a number of component manipulation errors, one of which is potentially significant. As a result, we will continue to focus baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in improved performance, particularly in the areas of procedural compliance and the reinforcement of expectations and standards in the performance of work.
On August 12, 2004, the NRC staff issued an inspection report with a preliminary Greater Than Green finding. The finding involved the misalignment of the service water system that rendered one train of service water system inoperable for a period of 21 days. A regulatory conference is scheduled for September 27, 2004, at the NRC Region IV office to allow you to provide additional information regarding the significance of this issue. This finding does not present a current safety concern because the valve lineup was restored to the normal configuration.
On August 12, 2004, the NRC staff issued an inspection report with a preliminary Greater Than Green finding. The finding involved the misalignment of the service water system that rendered one train of service water system inoperable for a period of 21 days. A regulatory conference is scheduled for September 27, 2004, at the NRC Region IV office to allow you to provide additional information regarding the significance of this issue. This finding does not present a current safety concern because the valve lineup was restored to the normal configuration.


Nebraska Public Power District                 On August 18, 2004, a meeting was held between NRC and NPPD. At that meeting you provided the results of your self-assessment of the effectiveness of the actions that NPPD has taken in response to the CAL. You also discussed the actions you have taken or planned in response to this self-assessment. We will consider the information provided at this meeting as part of our ongoing and future oversight activities.
Nebraska Public Power District On August 18, 2004, a meeting was held between NRC and NPPD. At that meeting you provided the results of your self-assessment of the effectiveness of the actions that NPPD has taken in response to the CAL. You also discussed the actions you have taken or planned in response to this self-assessment. We will consider the information provided at this meeting as part of our ongoing and future oversight activities.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. In addition to the supplemental inspection discussed previously, the NRC will conduct inspections associated with the CAL. Also, the plan contains an inspection using Temporary Instruction (TI) 2515/159, "Review of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment." This TI is in response to the Davis-Besse Reactor Vessel Head Degradation Lessons-Learned Task Force and is being performed at a sampling of nuclear power plants across the country.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. In addition to the supplemental inspection discussed previously, the NRC will conduct inspections associated with the CAL. Also, the plan contains an inspection using Temporary Instruction (TI) 2515/159, "Review of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment." This TI is in response to the Davis-Besse Reactor Vessel Head Degradation Lessons-Learned Task Force and is being performed at a sampling of nuclear power plants across the country.
The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed because of their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the end-of-cycle review meeting.
The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed because of their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the end-of-cycle review meeting.
Line 50: Line 49:


==Enclosure:==
==Enclosure:==
Cooper Nuclear Station Inspection/Activity Plan
Cooper Nuclear Station Inspection/Activity Plan


Nebraska Public Power District           cc:
Nebraska Public Power District cc:
Clay C. Warren, Vice President of Strategic Programs Nebraska Public Power District 1414 15th Street Columbus, NE 68601 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116
Clay C. Warren, Vice President of Strategic Programs Nebraska Public Power District 1414 15th Street Columbus, NE 68601 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116


Nebraska Public Power District             Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, IA 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Institute of Nuclear Power Operations (INPO)
Nebraska Public Power District Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, IA 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339


Nebraska Public Power District                 Electronic distribution by RIV:
Nebraska Public Power District Electronic distribution by RIV:
Regional Administrator (BSMI)
Regional Administrator (BSMI)
DRP Director (ATH)
DRP Director (ATH)
Line 82: Line 80:
R. A. Gramm, Chief, PDIV-1A, NRR/DLPM (RAG)
R. A. Gramm, Chief, PDIV-1A, NRR/DLPM (RAG)
M. Honcharik, NRR Project Manager (MCH3)
M. Honcharik, NRR Project Manager (MCH3)
ADAMS: XYes             l No       Initials: wcw X Publicly Available 0 Non-PubliclyAvailable         El Sensitive X Non-Sensitive S:\DRP\DRPDIR\MIDCYCLE2004\CNS.wpd
ADAMS: XYes l No Initials:
[WCWalker;mjs;dlf       KMKennedy           DDChamberlain ATHowell           TPGwynn l   _/RA/               WCWalker for     VLOrdaz     for IRA!             /RA/
wcw X Publicly Available 0 Non-PubliclyAvailable El Sensitive X Non-Sensitive S:\\DRP\\DRPDIR\\MIDCYCLE2004\\CNS.wpd
8/18/04               8/18/04             8/25/04         8/27/04         8/27/04
[WCWalker;mjs;dlf KMKennedy DDChamberlain ATHowell TPGwynn l
_MIMI BSMallett                                                 _
_/RA/
8/27/04 R OFFICIAL RECORD COPY                                   T=Telephone       E=E-mail   F=Fax
WCWalker for VLOrdaz for IRA!  
/RA/
8/18/04 8/18/04 8/25/04 8/27/04 8/27/04
_MIMI BSMallett 8/27/04 R OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax


Page 1 of 2                                                                                       Cooper 08/27/2004     07:56:14                                                                 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit                                                                                                                             l No. of Staff I l     Planned Dates       Il Inspection I Number I    1imp-e-&-i n-n-AcVhv-ity-11I                                             Title                                             on Site          Start      End              Type          I
Page 1 of 2 08/27/2004 07:56:14 Report 22 Cooper Inspection / Activity Plan 08/01/2004 - 03/31/2006 Unit I Number I l No. of Staff I l Planned Dates Il Inspection on Site Start End Type I
                                        .1 CAL COA         ANAL CLOSEOUT ASESMEI                                                                                          4 IP 95003                 InFspetion For Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple                   05/10/2004  09/04/2004 Supplemental Prograi TI-SW           - TI-251 5/159 - REVIEW OF GL 89-13                                                                             2 IP 2515/159             Review of Generic Letter 89-13: Service Water System Problems Affecting Safety-Related E,                   09/07/2004  09/16/2004 Safety Issues PEB-07B         - HX & HEAT SINK PERFORMANCE TESTING                                                                           I IP 7111107B             Heat Sink Performance                                                                                       09/13/2004  09/17/2004 Baseline Inspections ACCESS           - ACRSA & PIV                                                                                                   I IP 7112102             ALARA Planning and Controls                                                                                 09/13/2004  09/17/2004 Baseline Inspections OB-EP EX - EP EXERCISE                                                                                                           3 IP 7111401             Exercise Evaluation                                                                                         09/20/2004  09/24/2004 Baseline Inspections IP 7111404             Emergency Action Level and Emergency Plan Changes                                                           09/20/2004  09/24/2004 Baseline Inspections IP 71151               Performance Indicator Verification                                                                           09/20/2004  09/24/2004 Baseline Inspections OB-INIT         - INITIAL EXAM                                                                                                 4 X02288               COOPER (06/05) - INITIAL EXAM                                                                               05/09/2005  05/14/2005 Not Applicable X02288       O       OPQZE 06/05) - INITIAL EXAM                                                                                 06/06/2005  06/17/2005 Not Applicable OB-RQ           CREQUAL INSP _                                                                                                   I IP 711111 B -           icened Operator Requalification Program                                                                     11/01/2004  11/05/2004 Baseline Inspections ALARA           - ALARA PLANNING AND CONTROLS                                                                                   I 1                IP 7112101             Access Control to Radiologically Significant Areas                                                           11/29/2004  12/03/2004 Baseline Inspections EB08G           - ISI                                                                                                           I 1                IP 7111108G             Inservice Inspection Activities - BWR                                                                       01/24/2005  01/28/2005 Baseline Inspections ACRSA           - ACCESS CONTROLS TO RAD SIGNIFICANT AREAS                                                                     I 1                IP 7112101             Access Control to Radiologically Significant Areas                                                           01/24/2005  01/28/2005 Baseline Inspections ALARA2           - ALARA PLANNING AND CONTROLS                                                                                   I 1                IP 7112102             ALARA Planning and Controls                                                                                 04/11/2005  04/15/2005 Baseline Inspections EB21/02         - SSD&PCI/50.59                                                                                                 5 IP 7111121             Safety System Design and Performance Capability                                                             05/02/2005  05/06/2005 Baseline Inspections 1                IP 7111102             Evaluation of Changes, Tests, or Experiments                                                                 05/16/2005  05/20/2005 Baseline Inspections 1
1imp-e-&-i n-n-AcVhv -ity-11I Title
IP 7111121             Safety System Design and Performance Capability                                                             05/16/2005  05/20/2005 Baseline Inspections OB-EP2         - EMERG PREPAREDNESS PROGRAM INSPECTION                                                                         1 IP 7111402             Alert and Notification System Testing                                                                       05/16/2005 05/20/2005 Baseline Inspections 1               IP 7111403              Emergency Response Organization Augmentation Testing                                                        05/16/2005 05/20/2005 Baseline Inspections IP 7111404              Emergency Action Level and Emergency Plan Changes                                                            05/16/2005 05/20/2005 Baseline  Inspections IP 7111405              Correction of Emergency Preparedness Weaknesses and Deficiencies                                            05/16/2005 05/20/2005 Baseline  Inspections IP 71151                Performance Indicator Verification                                                                          05/16/2005 05/20/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
.1 CAL COA ANAL CLOSEOUT ASESME I IP 95003 InFspetion For Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple TI-SW  
- TI-251 5/159 - REVIEW OF GL 89-13 IP 2515/159 Review of Generic Letter 89-13: Service Water System Problems Affecting Safety-Related E, PEB-07B  
- HX & HEAT SINK PERFORMANCE TESTING IP 7111107B Heat Sink Performance ACCESS  
- ACRSA & PIV IP 7112102 ALARA Planning and Controls OB-EP EX  
- EP EXERCISE IP 7111401 Exercise Evaluation IP 7111404 Emergency Action Level and Emergency Plan Changes IP 71151 Performance Indicator Verification OB-INIT  
- INITIAL EXAM X02288 COOPER (06/05) - INITIAL EXAM X02288 O
OPQZE 06/05) - INITIAL EXAM OB-RQ CREQUAL INSP _
IP 711111 B -
icened Operator Requalification Program ALARA  
- ALARA PLANNING AND CONTROLS IP 7112101 Access Control to Radiologically Significant Areas EB08G  
- ISI IP 7111108G Inservice Inspection Activities - BWR ACRSA  
- ACCESS CONTROLS TO RAD SIGNIFICANT AREAS IP 7112101 Access Control to Radiologically Significant Areas ALARA2  
- ALARA PLANNING AND CONTROLS IP 7112102 ALARA Planning and Controls EB21/02  
- SSD&PCI/50.59 IP 7111121 Safety System Design and Performance Capability IP 7111102 Evaluation of Changes, Tests, or Experiments IP 7111121 Safety System Design and Performance Capability OB-EP2  
- EMERG PREPAREDNESS PROGRAM INSPECTION IP 7111402 Alert and Notification System Testing IP 7111403 Emergency Response Organization Augmentation Testing IP 7111404 Emergency Action Level and Emergency Plan Changes IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 71151 Performance Indicator Verification 4
05/10/2004 09/04/2004 Supplemental Prograi 2
09/07/2004 09/16/2004 Safety Issues I
09/13/2004 09/17/2004 Baseline Inspections I
09/13/2004 09/17/2004 Baseline Inspections 3
09/20/2004 09/20/2004 09/20/2004 09/24/2004 09/24/2004 09/24/2004 Baseline Inspections Baseline Inspections Baseline Inspections 4
05/09/2005 05/14/2005 Not Applicable 06/06/2005 06/17/2005 Not Applicable I
11/01/2004 11/05/2004 Baseline Inspections I
1 11/29/2004 12/03/2004 Baseline Inspections I
1 01/24/2005 01/28/2005 Baseline Inspections I
1 01/24/2005 01/28/2005 Baseline Inspections I
1 04/11/2005 04/15/2005 Baseline Inspections 5
11 05/02/2005 05/16/2005 05/16/2005 05/06/2005 05/20/2005 05/20/2005 Baseline Inspections Baseline Inspections Baseline Inspections 1
1 05/16/2005 05/16/2005 05/16/2005 05/16/2005 05/16/2005 05/20/2005 05/20/2005 05/20/2005 05/20/2005 05/20/2005 Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
This report shows only on-site and announced inspection procedures.


Page 2 of 2                                                                                     Cooper 08/2712004     07:56:14                                                               Inspection / Activity Plan Report 22 08/01/2004       03131/2006 Unit                                                                                                           [ No. of Staff i l     Planned Dates         InspectionI tTitle                                                                              on Site l         Start       End           Type
Page 2 of 2 08/2712004 Report 22 07:56:14 Cooper Inspection / Activity Plan 08/01/2004 03131/2006 Unit
_
[ No. of Staff i l Planned Dates InspectionI on Site l
RP TEAM         - RADIATION SAFETY TEAM INSPECTION                                                           4 I                IP 7112103           Radiation Monitoring Instrumentation and Protective Equipment                               06/06/2005 06/10/2005 Baseline Inspections 1                IP 7112201            Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems                    06/06/2005 06/10/2005 Baseline Inspections IP 7112202            Radioactive Material Processing and Transportation                                          06/06/2005 06/10/2005 Baseline Inspections IP 7112203            Radiological Environmental Monitoring Program                                              06/06/2005 06/10/2005 Baseline Inspections 1            PEB-PIR        - PIR INSPECTION                                                                              3 IP 71152B            Identification and Resolution of Problems                                                  06/13/2005 06/17/2005 Baseline Inspections 1
Start End Type I
IP 71152B            Identification and Resolution of Problems                                                  06/20/2005 06/24/2005 Baseline Inspections ALARA3          - ALARA PLANNING AND CONTROLS                                                                1 1
1 1
IP 7112102            ALARA Planning and Controls                                                                08/22/2005 08/26/2005 Baseline Inspections OB-RQ          - REQUAL INSPECTION                                                                          2 IP 7111111 B          Licensed Operator Requalification Program                                                  11/14/2005 11/18/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
1 1
tTitle RP TEAM  
- RADIATION SAFETY TEAM INSPECTION IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112202 Radioactive Material Processing and Transportation IP 7112203 Radiological Environmental Monitoring Program PEB-PIR
- PIR INSPECTION IP 71152B Identification and Resolution of Problems IP 71152B Identification and Resolution of Problems ALARA3
- ALARA PLANNING AND CONTROLS IP 7112102 ALARA Planning and Controls OB-RQ
- REQUAL INSPECTION IP 7111111 B Licensed Operator Requalification Program 4
06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 3
06/13/2005 06/17/2005 Baseline Inspections 06/20/2005 06/24/2005 Baseline Inspections 1
08/22/2005 08/26/2005 Baseline Inspections 2
11/14/2005 11/18/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.}}
This report shows only on-site and announced inspection procedures.}}

Latest revision as of 12:11, 15 January 2025

Midcycle Performance Review and Inspection Plan 8/30/04
ML060250255
Person / Time
Site: Cooper Entergy icon.png
Issue date: 08/30/2004
From: Mallett B
Region 4 Administrator
To: Edington R
Nebraska Public Power District (NPPD)
References
Download: ML060250255 (9)
v • d • e


Text

UNITED STATES XNUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-4005 August 30, 2004 Randall K. Edington, Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

SUBJECT:

MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - COOPER NUCLEAR STATION (CNS)

Dear Mr. Edington:

On August 5, 2004, the NRC staff completed its midcycle plant performance assessment of CNS. The midcycle review for CNS involved the participation of all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of your performance, including the performance indicators (Pis) for the most recent quarter and the inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

This performance review and inspection plan does not include physical protection information.

A separate letter designated and marked as 'Exempt from Public Disclosure in Accordance with 10 CFR 2.390" will include the physical protection review and resultant inspection plan.

Plant performance for the most recent quarter could be assessed as within the Regulatory Response column of the NRC's Action Matrix if you do not factor in our assessment of your actions to improve performance that led you to initiate a strategic improvement plan with actions confirmed in our January 30, 2003, Confirmatory Action Letter (CAL). This is based on a White finding issued in March 2004 for a high failure rate on the licensed operator biennial requalification written examinations. As discussed in the following paragraphs, we have assessed that our oversight of your performance should be equal to that eliciting NRC response consistent with the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix.

At the beginning of the 2004 assessment cycle, CNS was in the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix because there were three White emergency preparedness findings that had existed for more than four quarters. During the second quarter of 2004, the NRC closed these White findings on the basis of the correction of the underlying performance deficiencies. However, NRC concluded that additional NRC oversight was warranted while Nebraska Public Power District (NPPD) completes the actions specified in the CAL. Accordingly, on May 3, 2004, the Executive Director for Operations approved a deviation from the Action Matrix to authorize the NRC to maintain the level of oversight of CNS consistent

Nebraska Public Power District with the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix. This enhanced level of oversight includes continued NRC assessment of the strategic improvement plan, continued assessment of the effectiveness of the CAL actions and senior NRC management involvement in site visits and other assessment activities. This increased oversight will continue until NPPD has demonstrated, and the NRC has verified, that the improvement plan actions addressed by the CAL have resulted in sustained improvement in plant performance. The details of this decision were communicated to NPPD in a letter dated July 2, 2004.

On May 7, 2004, the NRC completed a supplemental inspection to assess the causes for and actions taken related to the Pi for unplanned scrams per 7000 critical hours. This PI crossed the threshold from Green to White in the fourth quarter of 2003 and returned to Green in first quarter of 2004. The NRC concluded that CNS performed thorough evaluations for each of the three scrams, including a thorough root cause analysis, extent of cause, and extent of condition review to identify and implement corrective actions in response to these scrams.

On May 12, 2004, the NRC completed another supplemental inspection conducted in response to the White finding for the high failure rate on the licensed operator biennial requalification written examinations. The NRC determined that NPPD's root cause analyses of the finding was appropriately evaluated and understood. The corrective actions identified as a result of the NPPD evaluations addressed the root and contributing causes and should correct the requalification program weaknesses provided the corrective actions are consistently implemented. However, the inspection also concluded that NPPD's extent of condition and extent of cause evaluations of the high failure rate were not completed at the time of the inspection and that other areas of the root cause lacked in-depth evaluation, including the adequacy of operator knowledge and the establishment of objective criteria to evaluate effectiveness of the corrective actions. A followup inspection will be conducted in the fourth quarter of 2004 to verify the effectiveness of NPPD's additional corrective actions.

In the first two quarters of 2004, the NRC completed two quarterly inspections of the implementation, including effectiveness, of the CAL actions. These inspections were performed to assess your progress in addressing regulatory performance issues in the areas of emergency preparedness, human performance, material condition/equipment reliability, plant modifications/configuration control, corrective action programs, and engineering programs. The second inspection completed in 2004 confirmed that you have taken the actions confirmed by the CAL. These inspections were also conducted to confirm whether these actions have resulted in sustained improved performance within the six CAL focus areas. On the basis of these and other inspections, the NRC determined that the actions taken within the emergency preparedness area have resulted in sustained improved performance.

In other CAL focus areas, our inspections identified a number of positive actions that have been implemented, but that sustained improved performance has not been achieved as of the end of our midcycle review period. Specifically, in the area of material condition and equipment reliability, actions completed to date have provided the necessary processes for improvement.

Numerous equipment improvements have been recently completed; however, there are a number of long-standing or repetitive problems that have not been fully resolved. In the area of plant modifications and configuration control, progress in operability determination screening and lessons learned training has provided the potential for enhancing the ability to prioritize and

Nebraska Public Power District perform operability determinations by emphasizing knowledged based tools. In the area of engineering programs, actions taken to date have resulted in several positive performance trends.

The remaining two CAL focus areas are also addressed by two substantive crosscutting issues in problem identification and resolution, as well as human performance. In our annual assessment letter dated March 3, 2004, we provided you an assessment of these substantive crosscutting issues. Performance in these areas continues to be of concern based on the inspection findings identified during the past 12 months.

In the area of problem identification and resolution, our March 3, 2004, annual assessment letter noted that your staff adequately identified issues and that you have implemented a number of actions with the goal of improving the implementation effectiveness of your corrective action, self-assessment, and operating experience review programs. We also noted, however, that there were a number of Green findings involving instances of inadequate corrective actions. Common themes associated with these findings included: inadequate extent of condition reviews, inappropriate symptom-based problem solving, inadequate treatment of plant-specific and industry operating experience, and failures to implement planned corrective actions. Since that time, you have implemented a number of other initiatives to increase management ownership of the corrective action program and improve the timeliness of correction actions. We have observed that the implementation of these improvements has resulted in more timely program reviews of operating experience and more timely closure of significant condition reports. However, a number of plant problems, particularly those involving systems and components, have not been fully resolved. Accordingly, we plan to continue to focus our baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in overall improved corrective action effectiveness.

In the human performance area, our annual assessment letter recognized that your staff had implemented actions to improve human performance and that some improvement had been observed. Notwithstanding these improvements, we indicated that there were instances in which plant staff members failed to follow procedures. Since the beginning of the year, your staff has continued to implement ongoing initiatives, as well as undertake additional actions. In recent months, however, there have been a number of component manipulation errors, one of which is potentially significant. As a result, we will continue to focus baseline and CAL followup inspection efforts in this area to determine whether your actions have resulted in improved performance, particularly in the areas of procedural compliance and the reinforcement of expectations and standards in the performance of work.

On August 12, 2004, the NRC staff issued an inspection report with a preliminary Greater Than Green finding. The finding involved the misalignment of the service water system that rendered one train of service water system inoperable for a period of 21 days. A regulatory conference is scheduled for September 27, 2004, at the NRC Region IV office to allow you to provide additional information regarding the significance of this issue. This finding does not present a current safety concern because the valve lineup was restored to the normal configuration.

Nebraska Public Power District On August 18, 2004, a meeting was held between NRC and NPPD. At that meeting you provided the results of your self-assessment of the effectiveness of the actions that NPPD has taken in response to the CAL. You also discussed the actions you have taken or planned in response to this self-assessment. We will consider the information provided at this meeting as part of our ongoing and future oversight activities.

The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. In addition to the supplemental inspection discussed previously, the NRC will conduct inspections associated with the CAL. Also, the plan contains an inspection using Temporary Instruction (TI) 2515/159, "Review of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment." This TI is in response to the Davis-Besse Reactor Vessel Head Degradation Lessons-Learned Task Force and is being performed at a sampling of nuclear power plants across the country.

The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed because of their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the end-of-cycle review meeting.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Kriss M. Kennedy at 817-860-8144 with any questions you may have regarding this letter or the inspection plan.

Sincerely, IRA/

Bruce S. Mallett Regional Administrator Dockets: 50-298 Licenses: DPR-46

Enclosure:

Cooper Nuclear Station Inspection/Activity Plan

Nebraska Public Power District cc:

Clay C. Warren, Vice President of Strategic Programs Nebraska Public Power District 1414 15th Street Columbus, NE 68601 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 P. V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Sue Semerena, Section Administrator Nebraska Health and Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116

Nebraska Public Power District Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street, Suite D Des Moines, IA 50309 William J. Fehrman, President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

Nebraska Public Power District Electronic distribution by RIV:

Regional Administrator (BSMI)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (SCS)

Branch Chief, DRP/C (KMK)

Senior Project Engineer, DRP/C (WCW)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (KEG)

Jennifer Dixon-Herrity, OEDO RIV Coordinator (JLD)

RidsNrrDipmLipb V. Dricks, PAO (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (LJS, MPSI, ATG, JAC)

L. Reyes, EDO (LARI)

S. Richards, Chief, NRR/DIPM/IIPB (SAR)

R. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)

C. Carpenter, Deputy Dir. for Inspection and Programs (CAC)

B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

T. Bergman, Chief, ROPMS, OEDO (TAB)

H. Berkow, Director, LPD4, NRR/DLPM (HNB)

R. A. Gramm, Chief, PDIV-1A, NRR/DLPM (RAG)

M. Honcharik, NRR Project Manager (MCH3)

ADAMS: XYes l No Initials:

wcw X Publicly Available 0 Non-PubliclyAvailable El Sensitive X Non-Sensitive S:\\DRP\\DRPDIR\\MIDCYCLE2004\\CNS.wpd

[WCWalker;mjs;dlf KMKennedy DDChamberlain ATHowell TPGwynn l

_/RA/

WCWalker for VLOrdaz for IRA!

/RA/

8/18/04 8/18/04 8/25/04 8/27/04 8/27/04

_MIMI BSMallett 8/27/04 R OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 08/27/2004 07:56:14 Report 22 Cooper Inspection / Activity Plan 08/01/2004 - 03/31/2006 Unit I Number I l No. of Staff I l Planned Dates Il Inspection on Site Start End Type I

1imp-e-&-i n-n-AcVhv -ity-11I Title

.1 CAL COA ANAL CLOSEOUT ASESME I IP 95003 InFspetion For Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple TI-SW

- TI-251 5/159 - REVIEW OF GL 89-13 IP 2515/159 Review of Generic Letter 89-13: Service Water System Problems Affecting Safety-Related E, PEB-07B

- HX & HEAT SINK PERFORMANCE TESTING IP 7111107B Heat Sink Performance ACCESS

- ACRSA & PIV IP 7112102 ALARA Planning and Controls OB-EP EX

- EP EXERCISE IP 7111401 Exercise Evaluation IP 7111404 Emergency Action Level and Emergency Plan Changes IP 71151 Performance Indicator Verification OB-INIT

- INITIAL EXAM X02288 COOPER (06/05) - INITIAL EXAM X02288 O

OPQZE 06/05) - INITIAL EXAM OB-RQ CREQUAL INSP _

IP 711111 B -

icened Operator Requalification Program ALARA

- ALARA PLANNING AND CONTROLS IP 7112101 Access Control to Radiologically Significant Areas EB08G

- ISI IP 7111108G Inservice Inspection Activities - BWR ACRSA

- ACCESS CONTROLS TO RAD SIGNIFICANT AREAS IP 7112101 Access Control to Radiologically Significant Areas ALARA2

- ALARA PLANNING AND CONTROLS IP 7112102 ALARA Planning and Controls EB21/02

- SSD&PCI/50.59 IP 7111121 Safety System Design and Performance Capability IP 7111102 Evaluation of Changes, Tests, or Experiments IP 7111121 Safety System Design and Performance Capability OB-EP2

- EMERG PREPAREDNESS PROGRAM INSPECTION IP 7111402 Alert and Notification System Testing IP 7111403 Emergency Response Organization Augmentation Testing IP 7111404 Emergency Action Level and Emergency Plan Changes IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 71151 Performance Indicator Verification 4

05/10/2004 09/04/2004 Supplemental Prograi 2

09/07/2004 09/16/2004 Safety Issues I

09/13/2004 09/17/2004 Baseline Inspections I

09/13/2004 09/17/2004 Baseline Inspections 3

09/20/2004 09/20/2004 09/20/2004 09/24/2004 09/24/2004 09/24/2004 Baseline Inspections Baseline Inspections Baseline Inspections 4

05/09/2005 05/14/2005 Not Applicable 06/06/2005 06/17/2005 Not Applicable I

11/01/2004 11/05/2004 Baseline Inspections I

1 11/29/2004 12/03/2004 Baseline Inspections I

1 01/24/2005 01/28/2005 Baseline Inspections I

1 01/24/2005 01/28/2005 Baseline Inspections I

1 04/11/2005 04/15/2005 Baseline Inspections 5

11 05/02/2005 05/16/2005 05/16/2005 05/06/2005 05/20/2005 05/20/2005 Baseline Inspections Baseline Inspections Baseline Inspections 1

1 05/16/2005 05/16/2005 05/16/2005 05/16/2005 05/16/2005 05/20/2005 05/20/2005 05/20/2005 05/20/2005 05/20/2005 Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 08/2712004 Report 22 07:56:14 Cooper Inspection / Activity Plan 08/01/2004 03131/2006 Unit

[ No. of Staff i l Planned Dates InspectionI on Site l

Start End Type I

1 1

1 1

tTitle RP TEAM

- RADIATION SAFETY TEAM INSPECTION IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112202 Radioactive Material Processing and Transportation IP 7112203 Radiological Environmental Monitoring Program PEB-PIR

- PIR INSPECTION IP 71152B Identification and Resolution of Problems IP 71152B Identification and Resolution of Problems ALARA3

- ALARA PLANNING AND CONTROLS IP 7112102 ALARA Planning and Controls OB-RQ

- REQUAL INSPECTION IP 7111111 B Licensed Operator Requalification Program 4

06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 06/06/2005 06/10/2005 Baseline Inspections 3

06/13/2005 06/17/2005 Baseline Inspections 06/20/2005 06/24/2005 Baseline Inspections 1

08/22/2005 08/26/2005 Baseline Inspections 2

11/14/2005 11/18/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Retrieved from "https://kanterella.com/w/index.php?title=ML060250255&oldid=5370760"