ML112201499

IR 05000298-11-006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems

ML112201499
Person / Time
Site:	Cooper
Issue date:	08/08/2011
From:	Powers D Division of Reactor Safety IV
To:	O'Grady B Nebraska Public Power District (NPPD)
References
EA-11-176 IR-11-006
Download: ML112201499 (41)

See also: IR 05000298/2011006

Text

August 8, 2011

EA-2011-176

Brian J. OGrady, 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 PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION REPORT 05000298/2011006 AND NOTICE OF

VIOLATION

Dear Mr. OGrady:

On June 24, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Cooper Nuclear Station. The enclosed report documents the inspection findings, which

were discussed on June 24, 2011, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification

and resolution of problems, safety and compliance with the Commissions rules and regulations

and with the conditions of your operating license. The inspectors reviewed selected procedures

and records, observed activities, and interviewed personnel. The inspectors also interviewed a

representative sample of personnel regarding the condition of your safety conscious work

environment.

The inspectors concluded that Cooper Nuclear Station generally identified, evaluated, and

corrected problems according to their safety significance. Cooper Nuclear Station generally

analyzed operating experience appropriately, performed effective self-assessments, and

maintained an effective safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough

evaluations, and the effectiveness of corrective actions. This was evidenced most notably

by repetitive diesel failures in 2009. The inspectors noted that the previous Problem

Identification and Resolution inspection, documented in weaknesses in operability evaluations

and that some root causes should have been more thorough. Therefore, the inspectors

considered the weaknesses in operability evaluations and thorough evaluations to be repetitive

weaknesses.

Based on the results of the inspection, the NRC has identified an issue that was evaluated

under the risk significance determination process as having very low safety significance

(Green). The NRC has also determined that one violation is associated with this issue. The

violation is being cited because Cooper Nuclear Station failed to restore compliance with

UNITED STATES

NUCLEAR REGULATORY COMMISSION

R E GI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

Nebraska Public Power District

- 2 -

NRC requirements within a reasonable time after a previous violation was identified in NRC

Inspection Report 05000298/2010007 (issued December 3, 2010). This is consistent with the

NRC Enforcement Policy; Section 2.3.2, which states, in part, that a cited violation will be

considered if the licensee fails to restore compliance within a reasonable time after a violation is

identified.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

Based on the results of the inspection, the NRC has also identified that two NRC-identified

issues that were evaluated under the risk significance determination process as having very low

safety significance (Green) and two Severity Level IV violations of NRC requirements occurred.

All of these findings were determined to involve violations of NRC requirements. However,

because of the very low safety significance of the violations and because they were entered into

your corrective action program, the NRC is treating these violations as noncited violations

consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest these violations or the characterization of the violations, 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, U.S. Nuclear Regulatory Commission,

Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125; the Director, Office

of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001;

and the NRC Resident Inspector at Cooper Nuclear Station. In addition, if you disagree with

the cross-cutting aspect assigned to any finding 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 your facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web-site at

www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dr. Dale A. Powers, Acting Chief and Senior

Technical Analyst

Technical Support Branch

Division of Reactor Safety

Dockets: 50-298

License: DRP-46

Nebraska Public Power District

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Enclosure 1 - Notice of Violation

Enclosure 2 - Inspection Report 05000298/2011006 w/Attachments:

Attachment 1 - Supplemental Information

Attachment 2 - Initial Information Request

Attachment 3 - Supplemental Information Request

cc w/ Enclosure:

Distribution via Listserv

Nebraska Public Power District

- 4 -

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Jeff.Clark@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Acting DRS Director (Robert.Caldwell@nrc.gov)

DRS Deputy Director (Tom.Blount@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Michael.Chambers@nrc.gov)

Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

Project Engineer, DRP/C (Jonathan.Braisted@nrc.gov)

Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)

CNS Administrative Assistant (Amy.Elam@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Lynnea.Wilkins@nrc.gov)

Acting Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

ACES (Ray.Kellar@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

RIV/ETA: OEDO (John.McHale@nrc.gov)

DRS/TSB STA (Dale.Powers@nrc.gov)

SUNSI Rev Compl.

Yes No

ADAMS

Yes No

Reviewer Initials

DAP

Publicly Avail

Yes No

Sensitive

Yes ; No

Sens. Type Initials

DAP

RI:DRP/A

DRP/C

RI:DRS/EB2

RI:DRS/PSB2

C:DRP/PBC

BTindell

JJosey

NOkonkwo

IAnchondo

VGaddy

/RA/

/RA/

/RA/

/RA/ E

/RA/

7/25/2011

7/28/2011

7/25/2011

7/28/2011

7/29/2011

ACES

C:DRS/TSB

RKellar

DPowers

/RA/

/RA/

8/5/2011

8/8/2011

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

- 1 -

Enclosure 1

NOTICE OF VIOLATION

Nebraska Public Power District

Docket No. 50-298

Cooper Nuclear Station

License No. DPR-46

EA-2011-176

During an NRC inspection conducted June 6 through June 24, 2011, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, measures

shall be established to assure that applicable regulatory requirements and the design

basis, as defined in 10 CFR 50.2 and as specified in the license application, for those

components to which this appendix applies, are correctly translated into specifications,

drawings, procedures, and instructions.

Contrary to the above, since December 3, 2010, the licensee failed to assure that

applicable regulatory requirements and the design basis were correctly translated into

specifications, drawings, procedures, and instructions. Specifically, the licensee failed to

correctly translate regulatory and design basis requirements, associated with tornado

and high wind generated missiles, into design information necessary to protect the

emergency diesel generator fuel oil day tank vent line components.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is hereby required

to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional

Administrator, Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125 and a

copy to the NRC Resident Inspector at Cooper Nuclear Station, within 30 days of the date of the

letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

"Reply to a Notice of Violation; EA-2011-176" and should include: (1) the reason for the

violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective

steps that have been taken and the results achieved, (3) the corrective steps that will be taken,

and (4) the date when full compliance will be achieved. Your response may reference or

include previous docketed correspondence, if the correspondence adequately addresses the

required response. If an adequate reply is not received within the time specified in this Notice,

an order or a Demand for Information may be issued as to why the license should not be

modified, suspended, or revoked, or why such other action as may be proper should not be

taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

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Enclosure 1

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

Dated this 8th day of August 2011.

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Enclosure 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket:

05000298

License:

DRP-46

Report:

05000298/2011006

Licensee:

Nebraska Public Power District

Facility:

Cooper Nuclear Station

Location:

72676 648A Ave.

Brownville, NE 68321

Dates:

June 6 through June 24, 2011

Team Leader:

B. Tindell, Senior Reactor Inspector

Inspectors:

I. Anchondo, Reactor Inspector

J. Josey, Senior Resident Inspector

N. Okonkwo, Reactor Inspector

Approved By:

Dr. Dale A. Powers

Acting Chief and Senior Technical Analyst

Technical Support Branch

Division of Reactor Safety

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Enclosure 2

SUMMARY OF FINDINGS

IR 05000298/2011006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline

Inspection of the Identification and Resolution of Problems.

A senior reactor inspector, two reactor inspectors, and a senior resident inspector performed the

inspection. In this report, the inspectors documented two noncited violations of very low safety

significance (Green), two severity level IV noncited violations, and one cited violation of very low

safety significance (Green). The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination

Process. Findings for which the significance determination process does not apply may be

Green or be assigned a severity level after NRC management review. The NRC's program for

overseeing the safe operation of commercial nuclear power reactors is described in

NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems

The inspectors reviewed approximately 400 condition reports, work orders, cause evaluations,

self-assessments and audits, operating experience evaluations, system health reports, trending

reports, metrics, and other supporting documentation to determine if problems were being

properly identified, prioritized, evaluated, and resolved.

The inspectors concluded that the licensee generally identified, evaluated, and corrected

problems according to their safety significance. The licensee generally analyzed operating

experience appropriately, performed effective self-assessments, and maintained an effective

safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough

evaluations, and the effectiveness of corrective actions. This was evidenced most notably by

repetitive diesel failures in 2009 and three recent cited violations. The inspectors noted that the

previous Problem Identification and Resolution inspection, documented in NRC Inspection

Report 2009007, identified weaknesses in operability evaluations and that some root causes

could have been more thorough. Therefore, the inspectors considered the weaknesses in

operability evaluations and thorough evaluations to be repetitive weaknesses. In addition,

NRC Inspection Report 2011002 documents a repetitive weakness in initiating condition reports

evidenced by multiple noncited violations. The inspectors concluded that the licensee needs to

be more effective at correcting the observed corrective action program weaknesses in

identification, operability evaluations, and thorough evaluations.

A.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, associated with four examples of the licensees failure

to promptly identify and correct conditions adverse to quality. Specifically, the licensee

failed to identify and correct excessive setpoint drift of reactor core isolation cooling

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Enclosure 2

system pressure switches, the leak of oil from the service water booster pump, a

vulnerability that allowed non-quality controlled material to be installed in safety related

applications, and the cause of a failure of the high pressure coolant injection steam line

high flow instrument. The licensee entered the finding into the corrective action program

as Condition Reports 2011-07060, 2011-07105, 2011-07151, and 2011-06653.

The performance deficiency was determined to be more than minor because if left

uncorrected, the continued failure to promptly identify and correct conditions adverse to

quality could result in more risk significant equipment being inoperable, and is therefore

a finding. This finding affected the Mitigating Systems Cornerstone. Using Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, the finding was determined to have very low safety significance because the

finding: (1) was not a design or qualification issue confirmed not to result in a loss of

operability or functionality; (2) did not represent an actual loss of safety function of the

system or train; (3) did not result in the loss of one or more trains of nontechnical

specification equipment; and (4) did not screen as potentially risk significant due to a

seismic, flooding, or severe weather initiating event. The finding was determined to

have a crosscutting aspect in the area of problem identification and resolution,

associated with the corrective action program component, in that, the licensee failed to

implement a corrective action program with a low threshold for identifying issues; issues

are identified completely, accurately and in a timely manner commensurate with their

safety significance P.1(a) (Section 4OA2.5a).

Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality.

Specifically, the licensee determined that an interim corrective action to prevent

recurrence was ineffective, yet it took no effective corrective action. As a result, the

licensee was vulnerable to a repetitive condition adverse to quality. The licensee

entered the issue into the corrective action program as Condition Report 2011-07152.

The finding was determined to be more than minor because the performance deficiency

could be reasonably viewed as a precursor to an event in that the interim action was not

effective as a barrier to prevent recurrence of an event. The finding is associated with

the Mitigating Systems Cornerstone. The inspectors performed a Phase 1 screening in

accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low safety

significance (Green) because the finding: (1) was not a design or qualification issue

confirmed not to result in a loss of operability or functionality; (2) did not represent an

actual loss of safety function of the system or train; (3) did not result in the loss of one or

more trains of nontechnical specification equipment; and (4) did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. The

inspectors determined that this finding had a crosscutting aspect in the area of problem

identification and resolution associated with corrective actions because the licensee

failed to prioritize and thoroughly evaluate a condition report that documented an

inadequate interim corrective action to prevent recurrence P.1(c) (Section 4OA2.5d).

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Enclosure 2

Green. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to assure that the applicable

design basis for applicable structures, systems, and components were correctly

translated into specifications, procedures, and instructions. Specifically, the licensee

failed to justify through evaluation that the diesel generator fuel oil day tanks would be

available following a tornado missile strike on the tank vents. The violation was cited

because the licensee failed to restore compliance in a reasonable time following

documentation of the issue as a noncited violation in NRC Inspection Report 2010007

(issued December 3, 2010). The licensee entered this issue into the corrective action

program as Condition Report 2011-06655.

The performance deficiency was determined to be more than minor because it was

associated with the protection against the external factors attribute of the Mitigating

Systems Cornerstone, and affected the associated cornerstone objective to ensure

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences, and is therefore a finding. Using Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, the finding was determined to have very low safety significance because the

finding: (1) was not a design or qualification issue confirmed not to result in a loss of

operability or functionality; (2) did not represent an actual loss of safety function of the

system or train; (3) did not result in the loss of one or more trains of nontechnical

specification equipment; and (4) did not screen as potentially risk significant due to a

seismic, flooding, or severe weather initiating event. The finding was determined to

have a crosscutting aspect in the area of human performance, associated with the

decision making component in that the licensee failed to use conservative assumptions

in decision making and adopt a requirement to demonstrate that the proposed action is

safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to

disapprove the action H.1(b) (Section 4OA2.5e).

Cornerstone: Miscellaneous

Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.73,

Licensee Event Report System, associated with the licensees failure to submit a

licensee event report within 60 days following discovery of an event meeting the

reportability criteria as specified. Specifically, a condition prohibited by technical

specifications occurred when a zurn strainer failure rendered the service water system

inoperable for longer than the action statement and would have prevented fulfillment of a

safety function. The licensee entered the finding into the corrective action program as

Condition Report 2011-06778.

The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors

determined that traditional enforcement was applicable to this issue because the NRC's

regulatory ability was affected. Specifically, the NRC relies on the licensees to identify

and report conditions or events meeting the criteria specified in regulations in order to

perform its regulatory function; and when this is not done, the regulatory function is

impacted. The inspectors determined that this finding was not suitable for evaluation

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Enclosure 2

using the significance determination process, and as such, was evaluated in accordance

with the NRC Enforcement Policy. The finding was a violation determined to be of very

low safety significance, was not repetitive or willful, and was entered into the corrective

action program. Therefore, this violation is being treated as a Severity Level IV noncited

violation consistent with the NRC Enforcement Policy. This finding had a crosscutting

aspect in the area of problem identification and resolution associated with the corrective

action component, in that, the licensee failed to appropriately and thoroughly evaluate

for reportability aspects all factors associated with the equipment failure P.1(c)

(Section 4OA2.5b).

Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.59,

Changes, Tests, and Experiments, associated with the failure to adequately evaluate a

change in order to ensure that it did not require prior NRC approval. Specifically, the

licensee revised a residual heat removal pump motor cable sizing calculation to a

smaller sized cable without a change evaluation. The licensee entered the issue into the

corrective action program as Condition Report 2011-01730.

The finding was determined to be more than minor because the licensee failed to

perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on

licensees to identify and report conditions or events meeting the criteria specified in

regulations in order to perform its regulatory function, and when this is not done the

regulatory function is impacted, and is therefore more than minor. Violations of

10 CFR 50.59 are considered to impede or impact the regulatory process, so they are

dispositioned using the traditional enforcement process. The enforcement manual

specifies that the severity level is determined in parallel with the Significance

Determination Process (SDP). The inspectors performed a Phase 1 screening in

accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low safety

significance (Green) because the finding: (1) was not a design or qualification issue

confirmed not to result in a loss of operability or functionality; (2) did not represent an

actual loss of safety function of the system or train; (3) did not result in the loss of one or

more trains of nontechnical specification equipment; and (4) did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. Therefore,

the inspectors categorized the finding as Severity Level IV in accordance with the

enforcement manual. The finding was a violation determined to be of very low safety

significance, was not repetitive or willful, and was entered into the corrective action

program. Therefore, this violation is being treated as a noncited violation consistent with

the NRC Enforcement Policy. The inspectors determined the cause of the finding

through interviews and document reviews. This finding was determined to have a

crosscutting aspect in the area of problem identification and resolution associated with

the corrective action program in that the licensee failed to appropriately and thoroughly

evaluate all factors associated with the design change P.1(c) (Section 4OA2.5c).

B.

Licensee-Identified Violations

None

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Enclosure 2

REPORT DETAILS

4.

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The inspectors based the following conclusions on the sample of corrective action

documents that were initiated in the assessment period, which ranged from

April 11, 2009, to the end of the on-site portion of this inspection on June 24, 2011.

.1

Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed documents, interviewed personnel, attended meetings, and

walked down plant equipment to determine if problems were being appropriately

identified, prioritized, evaluated, and resolved.

The inspectors verified that the licensee entered problems into the condition report

system for resolution. The inspectors reviewed the information related to problems to

ensure that the evaluations were thorough. The inspectors verified that the licensee

considered the extent of cause and extent of condition for problems as appropriate, as

well as how the licensee assessed previous occurrences. The inspectors assessed how

the licensee prioritized problems so that corrective actions were appropriate and timely.

In addition, the inspectors verified the effectiveness of corrective actions, completed or

planned, and looked for additional examples of similar problems. The inspectors also

expanded their review to the previous five years for age-related problems to determine

whether they were being effectively addressed.

In order to accomplish the above, the inspectors reviewed approximately 250 condition

reports out of approximately 20,000 that had been issued during the assessment period.

The inspectors also reviewed a sample of system health reports, self-assessments,

trending reports, metrics, selected logs, audits, operability evaluations, and results from

surveillance tests and preventive maintenance tasks. The inspectors reviewed a sample

of corrective actions closed to other corrective action documents. The inspectors

attended the licensees Condition Review Group and the Corrective Action Review

Board to observe the management of prioritizations, evaluations, and corrective actions.

The inspectors interviewed plant personnel to identify other processes that may exist

where problems may be identified and addressed outside the corrective action program.

The inspectors reviewed corrective action documents that addressed past

NRC-identified violations to ensure that the corrective action addressed the issues as

described in the inspection reports. The inspectors considered risk insights and selected

the DC Distribution System for a detailed work order and condition report review, and a

system walkdown.

At the time of the inspection, a potentially greater than green finding was identified in

NRC Inspection Report 2010006. In addition, a special inspection was ongoing due to a

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Enclosure 2

radiation protection event associated with a shuttle tube, as documented in NRC

Inspection Report 2011008. The inspectors excluded these issues from this inspection

due to the predecisional nature of the findings.

b.

Assessments

1.

Assessment - Effectiveness of Problem Identification

The inspectors concluded that the licensee identified conditions adverse to

quality and entered them into the corrective action program in accordance with

the licensees corrective action program guidance and NRC requirements.

During the inspection, the inspectors observed that the licensee identified

problems at a low threshold. However, NRC Inspection Report 2011002, Section

4OA2, documented a programmatic weakness associated with failure to initiate

condition reports. This was evidenced by multiple examples of failure to initiate

condition reports over several years with ineffective programmatic corrective

actions by the licensee.

2.

Assessment - Effectiveness of Prioritization and Evaluation of Issues

The inspectors concluded that generally, the licensee effectively evaluated

problems. However, the inspectors determined that there were two indications of

weak evaluations during this assessment period. Specifically, the inspectors

identified five inadequate operability evaluations, and the inspectors identified

multiple examples of evaluations that were not thorough. The inspectors noted

that the previous Problem Identification and Resolution inspection report, NRC

Inspection Report 2009007, also documented weaknesses in operability

evaluations and that some root causes that were not thorough. Therefore, the

inspectors considered the weaknesses in operability evaluations and thorough

evaluations to be repetitive weaknesses that the licensee had not corrected.

Inadequate Operability Evaluations

In Condition Report 2011-06686, the licensee documented that springs

had been installed on both diesel generator fuel racks, which had not

been evaluated as a modification. The inspectors identified during the

inspection that the licensee had failed to include the moment arm in the

calculation of torque on the fuel rack. The licensee updated the

operability evaluation and concluded that both diesel generators were

operable because the torque applied by the spring was less than

allowable.

In Condition Report 2010-08960, the licensee determined that the control

room handswitch for RHR-MOV-27A, residual heat removal loop A

injection outboard throttle valve, was experiencing an intermittent failure.

However, the station declared the valve operable because the valve had

passed troubleshooting and post maintenance testing. The inspectors

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Enclosure 2

challenged the licensees operability determination because the cause

evaluation did not match the operability statement in that the cause of the

intermittent failure had not been corrected, affecting the reliability of the

valve to reposition by manipulating the handswitch. The licensee updated

the operability evaluation to include the safety function of the valve, which

only included automatic repositioning. The handswitch does not affect

the automatic repositioning; therefore, the valve was operable.

In Condition Report 2009-09486, the licensee documented a water

hammer event in the reactor coolant system. The licensee identified that

the event was a repeat of an event in 1994. However, the inspectors

identified that the licensee had failed to evaluate or act on the operability

concern raised in 1994. Specifically, General Electric recommended that

the licensee test the low pressure coolant injection check valve to ensure

that it was not damaged by the water hammer. The inspectors found that

the licensee had restarted the plant following the 2009 water hammer

without evaluating or testing the check valve. However, the valve passed

an unrelated scheduled surveillance in 2011. Therefore, the valve was

operable.

In Condition Report 2011-04689, operations personnel documented an

initial operability determination for a low oil level in a service water

booster pump. However, the inspectors identified that the licensee failed

to include the level trend and mission time for the pump in the evaluation.

The licensee determined that the pump was inoperable on April 27, 2011,

after revising the operability determination due to the inspectors

questions.

In Condition Report 2010-02213, the licensee documented the failure of a

service water zurn strainer. However, the inspectors identified that the

licensee inappropriately credited manual actions for operability. This

resulted in the licensee failing to submit an event report to the NRC, as

documented in Section 4OA2.5b of this report.

Evaluations That Were Not Thorough

The inspectors identified four examples of the licensees failure to

promptly identify and correct conditions adverse to quality that were

associated with evaluations that were not thorough. Specifically, the

licensee failed to identify and correct excessive setpoint drift of reactor

core isolation cooling system pressure switches, determine and correct

the leak path of oil from a service water booster pump, failed to identify

and correct a vulnerability that allowed non-quality controlled material to

be installed in safety related applications, and failed to identify and correct

the cause of a malfunction of a high pressure coolant injection steam line

high flow instrument. See Section 4OA2.5a of this report for more details.

- 9 -

Enclosure 2

The inspectors identified that the licensee revised a residual heat removal

pump motor cable sizing calculation to a smaller sized cable without a

change evaluation. See Section 4OA2.5c of this report for more details.

In NRC Inspection Report 2009008, inspectors documented that the

licensee incorrectly concluded that a diesel generator lube oil piping

failure was caused by four overstress events. However, two independent

laboratories concluded that the cause was high cycle fatigue. The

licensees evaluation was not thorough, which resulted in ineffective

corrective actions and an additional failure of the diesel generator.

In NRC Inspection Report 2009005, inspectors documented a self-

revealing failure of a diesel generator due to loose fasteners on the

mechanical overspeed governor drive flange. The licensees root cause

found that personnel had failed to identify a trend of oil leaks and other

loose fasteners as a symptom of generic fastener relaxation on the

engines.

3.

Assessment - Effectiveness of Corrective Action Program

The inspectors concluded that actions to correct problems were generally

effective. However, the inspectors identified multiple examples of ineffective

corrective actions, as seen below. In addition, the inspectors noted that the NRC

had documented three cited violations due to ineffective or untimely corrective

actions associated with NRC documented findings within the past two years,

including the cited violation in this report. Therefore, the inspectors considered

that the licensee had a weakness in ensuring effective corrective actions.

Condition Report 2010-05972 was initiated August 19, 2010, because

maintenance personnel had blocked open the steam exclusion barrier

door for the emergency diesel generators without taking the appropriate

compensatory measures. The licensee determined that this issue

represented a significant condition adverse to quality, and had developed

and implemented actions to prevent recurrence of this issue.

Subsequently, the inspectors identified that maintenance personnel

had again disabled a hazard barrier, the steam exclusion barrier doors

for the control room, without taking the appropriate compensatory

measures, as documented in Condition Report 2010-09639, and

Condition Report 2011-00684. The inspectors determined that this was a

recurrence of a significant condition adverse to quality because of

ineffective corrective actions.

The inspectors identified that the licensee revised a residual heat removal

pump motor cable sizing calculation to a smaller sized cable in response

to an NRC finding documented in NRC Inspection Report 2010007.

However, the licensee failed to perform a change evaluation for the

calculation change. Therefore, while the licensees actions corrected the

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Enclosure 2

compliance issue, the corrective actions were not fully effective.

See Section 4OA2.5c of this report for more details.

The inspectors identified that the licensee took no effective corrective

action after determining that an interim corrective action to prevent

recurrence was ineffective. Specifically, after the licensee identified that

the craft lacked sufficient knowledge on the Risk Release for

Maintenance process in a root cause evaluation, the licensee provided

training as corrective action to prevent recurrence. However, the licensee

identified that the training was ineffective and took no other interim

effective corrective action. See Section 4OA2.5d of this report for more

details.

The inspectors identified that the licensee failed to justify that the diesel

generator fuel oil day tanks would be available following a tornado missile

strike on the tank vents. The violation was cited because the licensee

failed to restore compliance in a reasonable time following documentation

of the issue as a noncited violation in NRC Inspection Report 2010007.

See Section 4OA2.5e of this report for more details.

In NRC Inspection Report 2010004, inspectors documented a

self-revealing finding for a breaker fire due to ineffective corrective

actions. The same breaker had a fire the previous year, but the licensee

failed to implement measurable and reasonable corrective actions.

In NRC Inspection Report 2010007, inspectors documented a failure to

correct conditions adverse to quality involving three examples of

inadequate installation and testing of safety-related batteries.

In NRC Inspection Report 2011002, inspectors documented a cited

violation for the repetitive failure to correctly assess and manage the risk

to offsite power equipment during nearby work with heavy equipment as

required by 10 CFR 50.65(a)(4).

In NRC Inspection Report 2010005, inspectors documented a cited

violation for the failure to promptly correct a licensee identified violation

involving inappropriately extending protective action recommendations

when the wind changed direction.

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Enclosure 2

.2

Assessment of the Use of Operating Experience

a.

Inspection Scope

The inspectors examined the licensee's program for reviewing industry operating

experience, including reviewing the governing procedure and self-assessments. The

inspectors reviewed a sample of industry operating experience evaluations to assess

whether the licensee had appropriately evaluated the notifications for relevance to the

facility. The inspectors also reviewed assigned actions to address the applicable

operating experience to ensure they were appropriate. The inspectors reviewed a

sample of root and apparent cause evaluations to ensure that the licensee had

appropriately included industry operating experience.

b.

Assessment

The inspectors concluded that the licensee adequately evaluated industry operating

experience for relevance to the facility and appropriately entered applicable operating

experience, including causal evaluations, into the corrective action program.

.3

Assessment of Self-Assessments and Audits

a.

Inspection Scope

The inspectors reviewed a sample of licensee self-assessments and audits to assess

whether the licensee was regularly identifying performance trends and effectively

addressing them. The inspectors sampled self-assessments and audits in several

different areas of the licensees organization.

b.

Assessment

The inspectors concluded that the licensees self-assessment process was effective.

The licensee had recently taken action to revise the self-assessment process to achieve

better results. In addition, appropriate management attention was given to self-

assessments and audits. Self-assessments and audits included personnel from outside

organizations. Self-assessments and audits were determined to be critical.

.4

Assessment of Safety-Conscious Work Environment

a.

Inspection Scope

The inspectors conducted individual interviews with twenty individuals. The interviewees

represented various functional organizations and included contractor, staff, and

supervisor levels. The inspectors conducted these interviews to assess whether

conditions existed that would challenge the establishment of a safety conscious work

environment.

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Enclosure 2

b.

Assessment

The inspectors concluded that the licensee maintained a safety conscious work

environment. The individuals interviewed were aware of, and indicated that they were

willing to use the various ways to bring problems to managements attention without fear

of retaliation.

.5

Specific Issues Identified During This Inspection

a.

Failure to Promptly Identify and Correct Conditions Adverse to Quality

Introduction. The inspectors identified a noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, associated with four examples of the

licensees failure to promptly identify and correct conditions adverse to quality.

Specifically, the licensee failed to identify and correct excessive setpoint drift of reactor

core isolation cooling system pressure switches, the leak of oil from the service water

booster pump, a vulnerability that allowed non-quality controlled material to be installed

in safety related applications, and the cause of a failure of the high pressure coolant

injection steam line high flow instrument.

Description. The inspectors identified four examples of a noncited violation of

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the

licensees failure to promptly identify and correct conditions adverse to quality.

Example 1) The inspectors reviewed Condition Report 2009-01756, which had been

initiated on March 5, 2009, to document that pressure switch RCIC-PS-87D was found

out of technical specification allowed tolerance while the licensee was performing a

surveillance test of the steam supply pressure monitors for the reactor core isolation

cooling system. The licensee performed an apparent cause evaluation to determine why

the switch had gone outside of its allowed tolerance band. Through this evaluation, the

licensee determined that the mechanistic cause was set point drift. The licensee

identified the apparent cause as inadequate set point monitoring during quarterly

functional testing which allowed the set point to drift beyond the technical specification

limit. The licensee replaced the switch and calibrated the replacement switch in

accordance with the set point calculation.

The inspectors questioned the identified apparent cause. Specifically, the inspectors

noted that the calculation that had established the set point for the switch also accounted

for worse case drift. In doing this, the licensee incorporated a margin to ensure that the

switch would not be outside of the technical specification limit. As such, the inspectors

determined that the identified mechanistic cause was correct, but the identified apparent

cause was incorrect. Therefore, the corrective actions were inadequate and

subsequently, switch RCIC-PS-87D was found outside of its technical specification

allowed tolerance during another surveillance test on December 7, 2009.

The licensee initiated Condition Report 2011-07060 to capture this issue in the

corrective action program.

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Enclosure 2

The inspectors noted that the licensee has since replaced this style pressure switch in

the reactor core isolation cooling system with a switch of a different design.

Example 2) The inspectors reviewed Condition Report 2009-03602, which had been

initiated because on May 7, 2009, the licensee identified that the B service water booster

pumps inboard bearing oil level was below the level required for it to be considered

operable. The licensee classified this condition report as a Category C, broke-fix issue,

and assigned it to the operations department to address the issue of operators failing to

recognize that the level in the bearing was below the operability limit. This classification

required operations to do a fix evaluation. Based on their evaluation, operations

determined that the cause of the issue was a lack of operations personnel knowledge on

the required oil level.

Operations personnel documented that the oil had been drained and refilled one week

prior to being discovered below the operability limit (2 3/4 of an inch below the reference

mark). Prior to a post maintenance pump run, oil level was a "bubble" below the

maximum startup level (2 3/16 of an inch below the reference mark). Operations

personnel had noted that the oil level eventually leveled off near the minimum startup oil

level (2 3/8 of an inch below the reference mark) following the pump run and cool down

period. Subsequently, on May 7, 2009, the oil level was below the operability limit. The

inspectors determined that the operations department evaluation sufficiently addressed

the personnel knowledge issue, however, the cause of the oil level lowering was not

identified or corrected.

The licensee initiated Condition Report 2011-07105 to capture this issue in the

corrective action program.

Example 3) The inspectors reviewed Condition Report 2010-02123, which had been

initiated because on March 23, 2010, when planning a safety related engineering

package, the planner noted that one of the items specified for use, electrical lugs, were

not safety related. Further investigation revealed that these lugs were listed as non-

essential in the material control program; however, they were listed as safety related in

the engineering package list of materials. Through subsequent reviews of previous

packages to determine if these lugs had been installed in the plant, the planner

determined that these same lugs had been incorrectly installed in the plant in safety

related applications. Specifically, they had been installed in three service water booster

pump closing circuitries. The licensee classified this condition report as a Category C,

broke-fix issue, and assigned it to the work control group. This classification required

the work control group to do a fix evaluation. Based on their evaluation, the work control

group determined that two actions needed to be taken; 1) replace the non-safety related

materials installed in the service water booster pumps, and 2) remove the non-safety

related material from the warehouse.

During the inspectors review of this fix evaluation they noted that while the licensee had

taken action to ensure that the material could not be installed in the plant again, they had

not taken action to determine how non-safety related material had been designated for

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Enclosure 2

use in a safety related application in four safety related work orders. Therefore, the

inspectors determined that the licensee had failed to promptly identify and correct a

condition adverse to quality. The inspectors also noted that subsequently, the licensee

had identified more instances where non-safety related materials had been designated

for use in safety related applications through safety related work orders.

The licensee initiated Condition Report 2011-07151 to capture this issue in the

corrective action program.

Example 4) The inspectors reviewed Condition Report 2010-07390, which had been

initiated because on October 6, 2010, during the licensees performance of surveillance

testing of the high pressure coolant injection steam line high flow pressure instrument,

HPCI-DPIS-77, it was found to be out of its technical specification allowed tolerance.

The licensee performed an apparent cause evaluation to determine why the switch had

gone outside of its allowed tolerance band. Based on their evaluation, the licensee

determined that the apparent cause of this issue was the unavailability of spare parts

necessitated an in-field repair.

The inspectors questioned the identified apparent cause. Specifically, during their

review the inspectors noted that one month prior to the failure, HPCI-DPIS-77 had been

taken out of service to replace two internal switch assemblies. This was done as part of

the extent of condition actions resulting from the failure of a similar instrument. During

the replacement of the switches, technicians broke a mounting post for the micro

switches. Due to the unavailability of a complete spare instrument, the licensee had

determined that the only option was to perform an in-field repair (i.e., replacing internal

parts to fix the broken mounting post). An in-field repair required the technicians to

perform a full disassembly and removal of the internal mechanism of the switch. During

the alignment and calibration per station procedure, the technicians had difficulty

adjusting the switches to the correct calibration tolerance, but after several hours of

alignment and adjustment technicians were able to get the switches calibrated to the

tolerance specified in the procedure.

The inspectors determined that the licensee considered an in-field repair acceptable,

and that if done correctly, it would have corrected the condition. The inspectors

determined that the inadequate in-field repair caused the misalignment of the

mechanical components in the switch, which caused the failure to meet the surveillance

requirement. Therefore, the inspectors determined that the licensees conclusion in the

apparent cause was incorrect.

The licensee initiated Condition Report 2011-06653 to capture this issue in the

corrective action program.

These examples demonstrate the licensees failure to have a low threshold for

documenting additional issues in the corrective action program when evaluating existing

conditions.

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Enclosure 2

Analysis. The failure to promptly identify and correct conditions adverse to quality was a

performance deficiency. The performance deficiency was determined to be more than

minor because if left uncorrected, the licensees continued failure to promptly identify

and correct conditions adverse to quality could result in more risk significant equipment

being inoperable, and is therefore a finding. This finding affected the Mitigating Systems

Cornerstone. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening

and Characterization of Findings, the finding was determined to have very low safety

significance because the finding: (1) was not a design or qualification issue confirmed

not to result in a loss of operability or functionality; (2) did not represent an actual loss of

safety function of the system or train; (3) did not result in the loss of one or more trains of

nontechnical specification equipment; and (4) did not screen as potentially risk

significant due to a seismic, flooding, or severe weather initiating event. The inspectors

determined the cause of the finding through interviews and document reviews. The

finding was determined to have a crosscutting aspect in the area of problem

identification and resolution, associated with the corrective action program component,

in that, the licensee failed to implement a corrective action program with a low threshold

for identifying issues; issues are identified completely, accurately and in a timely manner

commensurate with their safety significance P.1(a).

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,

Criterion XVI, Corrective Action, 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, between March 5, 2009, and

October 6, 2010, the licensee failed to promptly identify and correct conditions adverse

to quality. Because this finding is of very low safety significance and has been entered

into the corrective action program as Condition Reports 2011-07060, 2011-06653,

2011-07105, and 2011-07151, this violation is being treated as a noncited violation

consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000298/2011006-01, Failure to Promptly Identify and Correct Conditions Adverse to

Quality.

b.

Failure to Report Conditions Prohibited by Technical Specifications and Safety System

Functional Failures

Introduction. The inspectors identified a Severity Level IV noncited violation of

10 CFR 50.73, Licensee Event Report System, associated with the licensees failure to

submit a licensee event report within 60 days following discovery of an event meeting

the reportability criteria as specified. Specifically, a condition prohibited by technical

specifications occurred when a zurn strainer failure rendered the service water system

inoperable for longer than the action statement and would have prevented fulfillment of a

safety function.

Description. On May 14, 2010, the licensee completed a root cause evaluation of a

component failure associated with the train A service water zurn strainer wiper arm

motor-to-gear box coupling, which had occurred on March 27, 2010, and was

documented in Condition Report 2010-02213. This failure resulted in the strainer motor

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Enclosure 2

not being able to perform its function of rotating the wiper arm for backwash, an

essential function required for Technical Specification 3.7.2, Service Water System and

Ultimate Heat Sink. The licensees evaluation concluded that the failure was due to an

inadequate design of the reduction gear to motor shaft. Through review of previous

maintenance documents and condition reports, the licensee determined that this issue

had existed since initial installation of the system.

The inspectors noted that the licensee had performed an operability evaluation at the

time of the failure and determined the equipment was operable because manual actions

could be taken to rotate the strainer for backwash functions. As such, the inspectors

noted that when licensing personnel reviewed this issue for potential reportability they

noted that this event was not reportable because the equipment was operable.

The inspectors questioned the operability position taken by the licensee. Specifically,

while the strainer essential function could be performed by way of manual actions, this

did not meet the station technical specification definition of operable:

A system, subsystem, division, component, or device shall be OPERABLE or

have OPERABILITY when it is capable of performing its specified safety

function(s), and when all necessary attendant instrumentation, controls, normal

or emergency electrical power, cooling and seal water, lubrication and other

auxiliary equipment that are required for the system, subsystem, division,

component, or device to perform its specified safety function(s) are also capable

of performing their related support function(s).

The identified condition appeared to meet the definition of operable with compensatory

measures required, as defined by station procedure EN-OP-104:

OPERABLE-COM MEAS is a PCRS Flag for Continued Operability/Functionality

based on an evaluation following an initial screening of Operable/Functional-

Judgment or Inoperable. It is a category of identifying and tracking degraded or

nonconforming conditions that represent a challenge to the

Operability/Functionality of an SSC such that additional measures have to be

taken to maintain or assure Operability/Functionality. Additional measures may

involve compensatory measures, operational restraints (i.e., startup restraints,

time limits, MODE change restrictions, and weather changes), further analysis, or

a change to the licensing bases (i.e., CLB change).

As such, the inspectors concluded that the strainer had in fact been inoperable prior to

this event, and the licensee had operated the service water system in a condition

prohibited by technical specifications. Furthermore, through reviews and discussions

with licensee personnel, the inspectors determined that prior maintenance activities

conducted by the licensee had allowed the B train of service water to be taken out of

service while the affected A train of service water was credited as operable. The

inspectors determined that these activities resulted in a condition that prevented the

service water system from performing its safety function. The licensee initiated

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Enclosure 2

Condition Report 2011-06778 to capture this issue in the stations corrective action

program.

The inspectors determined that the licensee failed to appropriately and thoroughly

evaluate for reportability aspects all factors associated with the equipment failure.

Analysis. The failure to submit a required licensee event report within 60 days after

discovery of an event or condition requiring a report to the NRC was a performance

deficiency. The inspectors reviewed this issue in accordance with NRC Inspection

Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the

inspectors determined that traditional enforcement was applicable to this issue because

the NRC's regulatory ability was affected. Specifically, the NRC relies on the licensees

to identify and report conditions or events meeting the criteria specified in regulations in

order to perform its regulatory function; and when this is not done, the regulatory

function is impacted. The inspectors determined that this finding was not suitable for

evaluation using the significance determination process, and as such, was evaluated in

accordance with the NRC Enforcement Policy. The finding was a violation determined to

be of very low safety significance, was not repetitive or willful, and was entered into the

corrective action program. Therefore, this violation is being treated as a Severity Level

IV noncited violation consistent with the NRC Enforcement Policy. The inspectors

determined the cause of the finding through interviews and document reviews. This

finding had a crosscutting aspect in the area of problem identification and resolution

associated with the corrective action component, in that, the licensee failed to

appropriately and thoroughly evaluate for reportability aspects all factors associated with

the equipment failure P.1(c).

Enforcement. Title 10 CFR 50.73(a)(1) requires, in part, that licensees shall submit a

licensee event report for any event of the type described in this paragraph within 60 days

after the discovery of the event. Title 10 CFR 50.73(a)(2)(i)(B) requires, in part, that the

licensee report any operation or condition prohibited by the plant's technical

specification, and Title 10 CFR 50.73(a)(2)(v) requires, in part, that the licensee report

any event or condition that could have prevented the fulfillment of the safety function of

structures or systems that are needed to

Shutdown the reactor and maintain it in a safe condition

Remove residual heat

Control the release of radioactive material

Mitigate the consequences of an accident

Contrary to the above, it was determined that the service water system had been

operated in a condition prohibited by technical specifications due to a design

inadequacy, and the licensee failed to correctly report this inadequacy that could have

prevented the fulfillment of its safety function during past maintenance activities. This

finding was determined to be applicable to traditional enforcement because the failure to

report conditions or events meeting the criteria specified in regulations affects the NRCs

regulatory ability. The finding was evaluated in accordance with the NRC's Enforcement

Policy. The finding was a violation of very low safety significance, was not repetitive or

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Enclosure 2

willful, and was entered into the corrective action program. This violation is being

treated as a Severity Level IV noncited violation, consistent with the NRC Enforcement

Policy: 05000298/2011006-02, Failure to Report Conditions Prohibited by Technical

Specifications and Safety System Functional Failures.

c.

Failure to Perform 10 CFR 50.59 Evaluation for Design Change

Introduction. The inspectors identified a Severity Level IV noncited violation of

10 CFR 50.59, Changes, Tests, and Experiments, associated with the failure to

adequately evaluate a change in order to ensure that it did not require prior NRC

approval. Specifically, the licensee revised a residual heat removal pump motor cable

sizing calculation to a smaller sized cable without a change evaluation.

Description. During an NRC component design basis inspection, inspectors identified

that the licensee had changed residual heat removal pump motor cables from 4/0 to 2/0

power cables without adequate technical justification in the design basis calculations.

The inspection finding was documented in NRC Inspection Report 2010007 and the

licensee documented the concern in Condition Report 2010-05522. In order to resolve

the problem, the licensee performed a calculation documented in NEDC-10-075 to justify

the design change. In processing the corrective action and calculation change, the

licensee did not perform an evaluation in accordance with 10 CFR 50.59 to ensure that

the change did not require prior NRC approval. The inspectors determined that it was

not immediately clear if it would have required prior NRC approval. The licensee

entered the issue in the corrective action program as Condition Report 2011-07130.

The inspectors determined that the licensee failed to thoroughly evaluate the factors

associated with the design change.

Analysis. The inspectors determined that the failure to perform a 10 CFR 50.59

evaluation for design change calculation NEDC-10-075 was a performance deficiency.

The finding was determined to be more than minor because the licensee failed to

perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on

licensees to identify and report conditions or events meeting the criteria specified in

regulations in order to perform its regulatory function, and when this is not done the

regulatory function is impacted, and is therefore more than minor. Violations of 10 CFR

50.59 are considered to impede or impact the regulatory process, so they are

dispositioned using the traditional enforcement process. The enforcement manual

specifies that the severity level is determined in parallel with the Significance

Determination Process (SDP). The inspectors performed a Phase 1 screening in

accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low safety

significance (Green) because the finding: (1) was not a design or qualification issue

confirmed not to result in a loss of operability or functionality; (2) did not represent an

actual loss of safety function of the system or train; (3) did not result in the loss of one or

more trains of nontechnical specification equipment; and (4) did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. Therefore,

the inspectors categorized the finding as Severity Level IV in accordance with the

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Enclosure 2

enforcement manual. The finding was a violation determined to be of very low safety

significance, was not repetitive or willful, and was entered into the corrective action

program. Therefore, this violation is being treated as a noncited violation consistent with

the NRC Enforcement Policy. The inspectors determined the cause of the finding

through interviews and document reviews. This finding was determined to have a

crosscutting aspect in the area of problem identification and resolution associated with

the corrective action program in that the licensee failed to appropriately and thoroughly

evaluate all factors associated with the design change P.1(c).

Enforcement. Title 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1)(i)

states, in part, that a licensee may make changes in the facility as described in the final

safety analysis report (as updated) without obtaining a license amendment pursuant to

10 CFR 50.90 only if the change, test, or experiment does not meet any of the criteria in

paragraph (c)(2). Paragraph (c)(2) states, in part, a licensee shall obtain a license

amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or

experiment if the change, test, or experiment would:

Result in more than a minimal increase in the frequency of occurrence of an

accident previously evaluated in the final safety analysis report (as updated);

Result in more than a minimal increase in the likelihood of occurrence of a

malfunction of a structure, system, or component (SSC) important to safety

previously evaluated in the final safety analysis report (as updated);

Result in more than a minimal increase in the consequences of an accident

previously evaluated in the final safety analysis report (as updated);

Result in more than a minimal increase in the consequences of a malfunction of an

SSC important to safety previously evaluated in the final safety analysis report (as

updated);

Create a possibility for an accident of a different type than any previously evaluated

in the final safety analysis report (as updated);

Create a possibility for a malfunction of an SSC important to safety with a different

result than any previously evaluated in the final safety analysis report (as updated);

Result in a design basis limit for a fission product barrier as described in the FSAR

(as updated) being exceeded or altered; or

Result in a departure from a method of evaluation described in the FSAR (as

updated) used in establishing the design bases or in the safety analyses.

Contrary to the above, on December 27, 2010, the licensee failed to perform an

evaluation that provided a bases for the determination that changing the design of RHR

cable did not require a license amendment. Specifically, the licensee failed to perform a

10 CFR 50.59 evaluation for the calculation to justify the change of residual heat

removal pump 1B and 1C motor power cable from 4/0 to 2/0. Because this finding is of

very low safety significance and has been entered into the licensee's corrective action

program as Condition Report 2011-01730, this violation is being treated as a noncited

violation, consistent with Section VI.A of the NRC Enforcement Policy: 05000289/2011006-03; Failure to Perform 10 CFR 50.59 Evaluation for Design

Change."

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Enclosure 2

d.

Failure to Take Action for an Ineffective Corrective Action

Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for the failure to correct a condition

adverse to quality. Specifically, the licensee determined that an interim corrective action

to prevent recurrence was ineffective, which placed the licensee in a vulnerable

condition until the additional corrective actions were in place.

Description. During root cause investigation, Movement of the Reactor Building Crane

Outside Its Operability Evaluation, documented in Condition Report 2009-03203, the

licensee identified that the reactor building crane had been moved outside the allowance

of station processes, causing a potential concern for equipment located under the crane.

The personnel had incorrectly used the Risk Release for Maintenance process to move

the crane. The licensee identified, as a root cause, that supervisory oversight and craft

knowledge of the Risk Release for Maintenance process was lacking. The root cause

evaluation implemented an interim corrective action to prevent recurrence in an effort to

correct the lack of knowledge in the short term, as well as other long term corrective

actions.

The licensee conducted a tailgate session that included a review of Procedure 3.4,

Configuration Change Control, Revision 48, with an emphasis on Risk Release for

Maintenance. Subsequently, the licensee also revised training material, SKL0610102,

Project Management Training, from classroom instruction to a required qualification

card to ensure procedural competency.

The licensee completed a corrective action effectiveness review for the above corrective

actions. The reviewer initiated Condition Report 2009-06814 to document the continuing

lack of knowledge on the Risk Release for Maintenance process. The reviewer stated

that this was a result of ineffective tailgate training, which manifested in continued

violations of the process. The Condition Report Group administratively closed this

condition report with the comment that not enough time had elapsed to perform an

effectiveness review. Subsequently, a new action was assigned to perform a new

corrective action effectiveness review three to six months later.

The licensee performed a second corrective action effectiveness review, documented in

LO-CNSLO-2009-00004, CA-25, which also concluded that the training was ineffective.

However, by this time multiple violations of the Risk Release for Maintenance process

had already occurred. In addition to other less significant violations, a root cause

evaluation for a digital electrical hydraulic fluid leak concluded that the Risk Release for

Maintenance process was violated again. The root cause evaluation assigned additional

training.

The inspectors concluded that the licensee had failed to correct the lack of knowledge

of the Risk Release for Maintenance process, which allowed other violations to occur.

The licensee entered the finding into the corrective action program as

Condition Report 2011-07152.

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Enclosure 2

The inspectors determined that the licensee had failed to properly prioritize the condition

report written for the ineffective interim corrective action to prevent recurrence, which

resulted in no evaluation or corrective actions taken.

Analysis. The licensees failure to take action for an ineffective interim corrective action

to prevent recurrence was a performance deficiency, which resulted in a vulnerability to

a repetitive condition adverse to quality. The finding was determined to be more than

minor because the performance deficiency could be reasonably viewed as a precursor to

an event in that the interim action was not effective as a barrier to prevent recurrence of

a significant event until other corrective actions were in place. The finding was

associated with the Mitigating Systems Cornerstone. The inspectors performed a Phase

1 screening in accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial

Screening and Characterization of Findings, and determined that the finding was of very

low safety significance (Green) because the finding: (1) was not a design or qualification

issue confirmed not to result in a loss of operability or functionality; (2) did not represent

an actual loss of safety function of the system or train; (3) did not result in the loss of one

or more trains of nontechnical specification equipment; and (4) did not screen as

potentially risk significant due to a seismic, flooding, or severe weather initiating event.

The inspectors determined the cause of the finding through interviews and document

reviews. The inspectors determined that this finding had a crosscutting aspect in the

area of problem identification and resolution associated with corrective actions because

the licensee failed to prioritize and thoroughly evaluate a condition report that

documented an inadequate interim corrective action to prevent recurrence P.1(c).

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion

XVI, Corrective Action, 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, on September 14, 2009, the licensee

failed to assure that a condition adverse to quality was promptly corrected. Specifically,

the licensee failed to promptly correct an ineffective interim corrective action to prevent

recurrence associated with lack of knowledge of the Risk Release for Maintenance

process. Since this violation was of very low safety significance and was documented in

the licensees corrective action program as Condition Report 2011-07152, it is being

treated as a noncited violation, consistent with Section 2.3.2 of the NRC Enforcement

Policy: NCV 05000298/2011006-04, Failure to Take Action for an Ineffective Corrective

Action.

e.

Failure to Correctly Translate Design Requirements into Installed Plant Configuration

Introduction. The inspectors identified a Green cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the licensees failure to assure that the

applicable design basis for applicable structures, systems, and components were

correctly translated into specifications, procedures, and instructions. Specifically, the

licensee failed to justify through evaluation that the diesel generator fuel oil day tanks

would be available following a tornado missile strike on the tank vents. The violation is

cited because the licensee failed to restore compliance in a reasonable

- 22 -

Enclosure 2

time following documentation of the issue as a noncited violation in

NRC Inspection Report 2010007 (issued December 3, 2010).

Description. During an NRC component design basis inspection in July 2009, an issue

was identified associated with the emergency diesel generator day tank vent lines.

Specifically, the inspectors determined that the licensee did not have a design basis

calculation to show that the fuel oil day tanks would be available following a tornado or

high wind impact event on the day tank vent lines. The licensee entered this issue into

their corrective action program as Condition Report 2010-05350. This issue was

documented as a noncited violation,05000298/2010007-04, for the licensees failure to

demonstrate that the design basis requirements were being met.

As a result of this condition report, corrective action 2 was generated which directed the

station to perform a formal analysis of the diesel generator day tank vent lines pertaining

to missile protection, and generate additional corrective actions if required. Station

calculation NEDC 10-070, Emergency Diesel Day Tank Vent Survival Subsequent to a

Tornado Strike Sealing the Vents, Revision 0 dated November 30, 2010, was generated

in response to this corrective action. With this, corrective action 2 was closed on

December 14, 2010, and Condition Report 2010-05350 was closed on

December 28, 2010.

On June 9, 2011, the inspectors reviewed the licensees corrective actions from the

previous noncited violation. During this review, the inspectors noted that station

calculation NEDC 10-070 contained several assumptions that appeared to be non-

conservative and could have an effect on the outcome of the calculation. The inspectors

informed the licensee of this concern, and the licensee entered this issue into the

corrective action program as Condition Report 2011-06655.

During subsequent re-analysis of NEDC 10-070, the licensee determined that it could

not validate the assumptions that had been used without extensive engineering analysis.

The licensee initiated Condition Report 2011-07064 to capture this issue. The licensee

documented a reasonable justification of continued operation using engineering

judgment, pending further analysis to validate their assumptions and establish a design

basis for the emergency diesel generator fuel oil day tank vent lines relative to tornado

and high wind impacts.

As such, the inspectors determined that the licensee had failed to restore compliance

within a reasonable time after the previous noncited violation was identified on

December 3, 2010.

Analysis. The inspectors determined that the licensees failure to ensure that design

requirements were correctly translated into installed plant equipment was a performance

deficiency. The performance deficiency was determined to be more than minor because

it was associated with the protection against the external factors attribute of the

Mitigating Systems Cornerstone, and affected the associated cornerstone objective to

ensure availability, reliability, and capability of systems that respond to initiating events

- 23 -

Enclosure 2

to prevent undesirable consequences, and is therefore a finding. Using Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, the finding was determined to have very low safety significance because the

finding: (1) was not a design or qualification issue confirmed not to result in a loss of

operability or functionality; (2) did not represent an actual loss of safety function of the

system or train; (3) did not result in the loss of one or more trains of nontechnical

specification equipment; and (4) did not screen as potentially risk significant due to a

seismic, flooding, or severe weather initiating event. The inspectors determined the

cause of the finding through interviews and document reviews. The finding was

determined to have a crosscutting aspect in the area of human performance, associated

with the decision making component in that the licensee failed to use conservative

assumptions in decision making and adopt a requirement to demonstrate that the

proposed action is safe in order to proceed rather than a requirement to demonstrate it is

unsafe in order to disapprove the action H.1(b).

Enforcement. Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in

part, measures shall be established to assure that applicable regulatory requirements

and the design basis, as defined in 10 CFR 50.2 and as specified in the license

application, for those components to which this appendix applies are correctly translated

into specifications, drawings, procedures, and instructions. Contrary to the above, since

December 3, 2010, the licensee failed to assure that applicable regulatory requirements

and the design basis were correctly translated into specifications, drawings, procedures,

and instructions. Specifically, the licensee failed to correctly translate regulatory and

design basis requirements, associated with tornado and high wind generated missiles,

into design information necessary to protect the emergency diesel generator fuel oil day

tank vent line components. This performance deficiency was previously identified by the

NRC and was documented as noncited violation 05000298/2010007-04. The inspectors

determined that the licensee had failed to restore compliance within a reasonable time

following issuance of this noncited violation. Therefore, this violation is being cited,

consistent with the NRC Enforcement Policy, Section 2.3.2, which states, in part, that a

cited violation will be considered if the licensee fails to restore compliance within a

reasonable time after a violation is identified: VIO 05000298/2011006-05, Failure to

Correctly Translate Design Requirements into Installed Plant Configuration.

4OA6 Meetings

Exit Meeting Summary

On June 24, 2011, the inspectors presented the inspection results to B. OGrady, and

other members of the licensee staff. The licensees management initially questioned the

characterization of several findings presented. After further telephonic discussions, the

licensees management acknowledged the issues presented. The inspector asked the

licensees management whether any materials examined during the inspection should

be considered proprietary. No proprietary information was identified.

- 1 -

Attachment 1/Enclosure 2

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Dewhirst, Manager, Corrective Action and Assessments

J. Flaherty, Licensing Engineer

A. Zaremba, Director of Nuclear Safety Assurance

NRC Personnel

D. Powers, Acting Chief, Technical Support Branch

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened 05000298/2011006-05

VIO

Failure to Correctly Translate Design Requirements into

Installed Plant Configuration (Section 4OA2.5e)

Opened and Closed 05000298/2011006-01

NCV

Failure to Promptly Identify and Correct Conditions

Adverse to Quality (Section 4OA2.5a)05000298/2011006-02

NCV

Failure to Report Conditions Prohibited by Technical

Specifications and Safety System Functional Failures

(Section 4OA2.5b)05000298/2011006-03

NCV

Failure to Perform 10 CFR 50.59 Evaluation for Design

Change (Section 4OA2.5c)05000298/2011006-04

NCV

Failure to Take Action for an Ineffective Corrective Action

(Section 4OA2.5d)

- 2 -

Attachment 1/Enclosure 2

LIST OF DOCUMENTS REVIEWED

CONDITION REPORTS

2009-03685

2009-09243

2010-02086

2010-09465

2011-06414

2009-03703

2009-09436

2010-02123

2010-09467

2011-06416

2009-03784

2009-09443

2010-02575

2010-09469

2011-06524

2009-03828

2009-09451

2010-02632

2010-09472

2011-06545

2009-03863

2009-09486

2010-02709

2010-09476

2011-06577

2009-03903

2009-09537

2010-02844

2010-09665

2011-06579

2009-04042

2009-09560

2010-02980

2010-09700

2011-06589

2009-04494

2009-09606

2010-03195

2011-00166

2011-06651

2009-04526

2009-09622

2010-03322

2011-00225

2011-06653

2009-04565

2009-09854

2010-03381

2011-00461

2011-06655

2009-04819

2009-09875

2010-03910

2011-00544

2011-06680

2009-04895

2009-10222

2010-04046

2011-00618

2011-06769

2009-04933

2009-10347

2010-04287

2011-00662

2011-06778

2009-05088

2009-10364

2010-05023

2011-00684

2011-06781

2009-05114

2009-10389

2010-05449

2011-00756

2011-06794

2009-05168

2009-10461

2010-05522

2011-00766

2011-07054

2009-05277

2009-10691

2010-05631

2011-01239

2011-07066

2009-05418

2010-00130

2010-05763

2011-01606

2011-07130

WORK ORDERS

4731279

4731460

4731466

4625525

4689508

4771612

4639731

CALCULATIONS

NUMBER

TITLE

REVISION

NEDC 92-50AI

MS-PS-134 A/B/C/D Setpoint Calculation

1

NEDC 92-50AH

MS-PS-103 A/B/C/D Setpoint Calculation

1

NEDC 10-070

Emergency Diesel Day Tank Vent Survival

Subsequent to a Tornado Strike Sealing the Vents

1

NEDC 97-012

Emergency Diesel Generator Fuel Oil On-Site

Storage Technical Specification Requirements

3

- 3 -

Attachment 1/Enclosure 2

PROCEDURES

NUMBER

TITLE

REVISION

0.31.1

Skill of the Craft Configuration Control

8

0.31.1

Configuration Control During Maintenance Activities

9

3.4

Configuration Change Control

48

0.50.5

Outage Shutdown Safety

14

0.40.9

Work Activity Risk Management Process

2

0.40

Work Control Program

70

2.1.11.1

Turbine Building Data

108

2.2.3.1

Traveling Screen, Screen Wash, and Sparger

Systems

81

2.1.5

Reactor Scram

64

2.2.77

Turbine Generator

100

7.7.1

Special Process Control Maintenance Procedure

15

3.38

Welding/Repair-Replacement Program

2

0-HU-POLICY

Human Performance Policy

2

0-CNS-FAP-OM-002

Continuous Improvement Process

0

0.40.4

Planning

13

0-CHANGE-MGMT

Change Management

2

EPIP 5.7.20

Protective Action Recommended

21

0.9

Tagout

68

- 4 -

Attachment 1/Enclosure 2

PROCEDURES

NUMBER

TITLE

REVISION

0.CNS-09

CNS material Master data Nomenclature Standard

3

0.9A

Tagout forms and Checklists

8

15.PCIS.301

Steam Line Break detection Temperature Switch

Change out for Calibration

15

7.3.24.4

HGA Relay Setup and Pick-Up Test

3

7.0.4

Conduct of Maintenance

33

0.40

Work Control Program

76

0.5

Conduct of the Condition Report Process

67

0.5 CR

Condition Report Initiation, Review, and

Classification

17

0.5 EVAL

Preparation of Condition Reports

22

0.5 ROOT-CAUSE

Root Cause Analysis Procedure

15

0.5 OPS

Operations Review of Condition Report/Operability

Determination

31

0.5 CAER

Corrective Action Effectiveness Reviews

4

MISCELLANEOUS

NUMBER

TITLE

REVISION /

DATE

SKL0610102

Project Manager Training

5

Human Performance Review Board (HURB) Charter

June 1, 2011

Leadership Logbook Reports - Chemistry and RP

May 2011

Leadership Logbook Reports - Chemistry and RP

January 2011

Leadership Logbook Reports - Chemistry and RP

February 2011

CNSLO-2010-0131

Focused Self Assessment, Risk Assessments

July 30, 2010

LO-HQNLO-2010-0009

Final Report for Assessment of Cooper OE Program

High Pressure Coolant Injection System Health Report

May 2011

Reactor Core Isolation Cooling System Health Report

May 2011

KSV-32-26, Sh. 1

Control Linkage (Diesel Non-fail-safe)

Rev. N03

- 1 -

Attachment 2/Enclosure 2

Information Request

May 3, 2011

Biennial Problem Identification and Resolution Inspection

Cooper Nuclear Station

Inspection Report 05000298/2011006

This inspection will cover the period from April 11, 2009, to June 24, 2011. All requested

information should be limited to this period or to date of this request unless otherwise specified.

To the extent possible, the requested information should be provided electronically in Adobe

PDF or Microsoft Office format. Lists of documents should be provided in Microsoft Excel or a

similar sortable format.

A supplemental information request will likely be sent during the week of May 30, 2011.

Please provide the following no later than May 23, 2011:

1.

Document Lists

Note: for these summary lists, please include the document/reference number, the

document title or a description of the issue, initiation date, and current status. Please

include long text descriptions of the issues.

a.

Summary list of all corrective action documents related to significant conditions

adverse to quality that were opened, closed, or evaluated during the period

b.

Summary list of all corrective action documents related to conditions adverse to

quality that were opened or closed during the period

c.

Summary lists of all corrective action documents which were upgraded or

downgraded in priority/significance during the period

d.

Summary list of all corrective action documents that subsume or roll up one or

more smaller issues for the period

e.

Summary lists of operator workarounds, engineering review requests and/or

operability evaluations, temporary modifications, and control room and safety

system deficiencies opened, closed, or evaluated during the period

f.

Summary list of plant safety issues raised or addressed by the Employee

Concerns Program (or equivalent)

g.

Summary list of all Apparent Cause Evaluations completed during the period

h.

Summary list of all Root Cause Evaluations planned or in progress but not

complete at the end of the period

- 2 -

Attachment 2/Enclosure 2

2.

Full Documents, with Attachments

a.

Root Cause Evaluations completed during the period

b.

Quality assurance audits performed during the period

c.

All audits/surveillances performed during the period of the Corrective Action

Program, of individual corrective actions, and of cause evaluations

d.

Corrective action activity reports, functional area self-assessments, and non-

NRC third party assessments completed during the period (do not include INPO

assessments)

e.

Corrective action documents generated during the period for the following:

i.

NCVs and Violations issued to Cooper Nuclear Station

ii.

LERs issued by Cooper Nuclear Station

f.

Corrective action documents generated for the following, if they were determined

to be applicable to Cooper Nuclear Station (for those that were evaluated but

determined not to be applicable, provide a summary list):

i.

NRC Information Notices, Bulletins, and Generic Letters issued or

evaluated during the period

ii.

Part 21 reports issued or evaluated during the period

iii.

Vendor safety information letters (or equivalent) issued or evaluated

during the period

iv.

Other external events and/or Operating Experience evaluated for

applicability during the period

g.

Corrective action documents generated for the following:

i.

Emergency planning drills and tabletop exercises performed during the

period

ii.

Maintenance preventable functional failures which occurred or were

evaluated during the period

iii.

Adverse trends in equipment, processes, procedures, or programs which

were evaluated during the period

iv.

Action items generated or addressed by plant safety review committees

during the period

- 3 -

Attachment 2/Enclosure 2

3.

Logs and Reports

a.

Corrective action performance trending/tracking information generated during the

period and broken down by functional organization

b.

Corrective action effectiveness review reports generated during the period

c.

Current system health reports or similar information

d.

Radiation protection event logs during the period

e.

Security event logs and security incidents during the period (sensitive information

can be provided by hard copy during first week on site)

f.

Employee Concern Program (or equivalent) logs (sensitive information can be

provided by hard copy during first week on site)

g.

List of Training deficiencies, requests for training improvements, and simulator

deficiencies for the period

4.

Procedures

a.

Corrective action program procedures, to include initiation and evaluation

procedures, operability determination procedures, apparent and root cause

evaluation/determination procedures, and any other procedures which implement

the corrective action program at Cooper Nuclear Station

b.

Quality Assurance program procedures

c.

Employee Concerns Program (or equivalent) procedures

d.

Procedures which implement/maintain a Safety Conscious Work Environment

5.

Other

a.

List of risk significant components and systems

b.

Organization charts for plant staff and long-term/permanent contractors

Note: Corrective action documents refers to condition reports, notifications, action requests,

cause evaluations, and/or other similar documents, as applicable to Cooper Nuclear Station.

- 4 -

Attachment 2/Enclosure 2

As it becomes available, but no later than May 23, 2011, this information should be uploaded on

the Certrec IMS website. When these documents have been compiled (and by May 30, 2011),

please download these documents onto a CD or DVD and sent it via overnight carrier to:

Harry A. Freeman

U.S. NRC Region IV

612 E. Lamar Blvd.

Suite 400

Arlington, TX 76011-4125

Please note that the NRC is not able to accept electronic documents on thumb drives or other

similar digital media. However, CDs and DVDs are acceptable.

- 1 -

Attachment 3/Enclosure 2

Supplemental Information Request

June 2, 2011

Biennial Problem Identification and Resolution Inspection

Cooper Nuclear Station

Inspection Report 05000298/2011006

This information should be uploaded on the Certrec IMS website or provided on a CD.

Please provide the following no later than June 6, 2011:

B. Tindells Request:

1. Condition Report(s) associated with Licensee Event Report 2010-01

2. Condition Report(s) associated with CNSLO 2009-00221:

a. Supplemental Work Practices - observation of supplemental valve team

performance decline

b. Outage Scheduling recommendation to accommodate incomplete on-line work

into outage schedule for risk management

c. Critical Equipment Failures due to Preventive Maintenance - Recommendation

to implement an action to perform evaluations on inadequate Preventative

Maintenance causes for potential Preventive Maintenance program impact.

3. List of currently incomplete First Time Perform Preventative Maintenance items and

basis for schedule (reference CNSLO 2009-00221, Critical Equipment Failures due to

Preventive Maintenance)

4. Full Condition Reports for all EE-DC system, as well as RCIC and HPCI systems related

to DC electrical (valve, controller, cabling, etc.) from 1/1/2009 to Present

5. Currently open Work Orders for all the EE-DC system, as well as RCIC and HPCI

systems related to DC electrical (valve, controller, cabling, etc.)

6. Completed Copies of Closed Corrective Work Orders for the EE-DC system, as well as

RCIC and HPCI systems related to DC electrical (MOV, Controller, cabling, etc.) from

January 1, 2009 to Present

7. Full Condition Report(s) associated with NRC Information Notices 2009-06, 2009-16,

2010-06

8. NCR 94-048

9. Current Revision of Training Lesson INT0231001, OPS Shutdown Risk Management

- 2 -

Attachment 3/Enclosure 2

10. Part Evaluation 4649606

11. CNS Vendor Manual 0843

12. Full Condition Reports:

2005-3294

2006-554

2006-3900

2007-1559

2007-4363

2008-1402

2008-3157

2008-4152

2008-7910

2009-189

2009-734

2009-780

2009-937

2009-1756

2009-1855

2009-2238

2009-2626

2009-2643

2009-2644

2009-2645

2009-2646

2009-3057

2009-3150

2009-3828

2009-4895

2009-5168

2009-5246

2009-5375

2009-5449

2009-5607

2009-5727

2009-6392

2009-6471

2009-6536

2009-6716

2009-6883

2009-7519

2009 8398

2009-8667

2009-8678

2009-9243

2009-09486

2009-10139 2009-10161 2009-10222 2009-10226 2009-10239 2009-10310

2009-10347 2009-10389 2009-10691 2009-10810 2009-10805 2009-10816

2009-10831 2010-199

2010-223

2010-974,

2010-975

2010-977

2010-979

2010-1596

2010-1854

2010-1881,

2010-3689

2010-3910

2010-08192 2010-8204

2010-8210

2010-8447,

2010-8763

2010-8771

2010-9188

2010-9350

2011-461

2011-615

2011-618

2011-681

2011-1239

2011-1665,

2011-1779

2011-1783

2011-1784

2011-1793

2011-4330

2011-4694

2011-4589

2011-4758

2011-4767

2011-4776

2011-4780

13. Completed Work Orders:

4624211, 4659630, 4737773, 4638031, 4686573, 4733908, 4705209, 4692514

14. NEDC 92-050AR, Setpoint Calculation, revision 1 and current revision

15. EE-DC, RCIC, HPCI Design Basis Documents

16. One Line Electrical Diagrams of DC System, RCIC, and HPCI

17. 2.1.4, Normal Shutdown, Current Revision and Revision in effect as of

November 7, 2009

18. 2.2.69,2 RHR System Shutdown Operations, Current Revision and Revision in effect

as of November 7, 2009

- 3 -

Attachment 3/Enclosure 2

I. Anchondos Request:

1. Full Condition Reports:

2009-03203

2009-07191

2009-09875

2010-00245

2010-00389

2010-01834

2009-09023

2009-09138

2009-09451

2011-00461

2009-09606

2010-06100

2009-08061

2010-03195

2010-04115

2009-02051

2009-02124

2009-02553

2009-07896

2009-08315

2009-09560

2009-10537

2010-00083

2010-01551

2010-08827

2010-09015

2009-02655

2009-10015

2009-02828 2009-02970

2010-09174

2010-09153

2010-02700

2010-05585

2009-06779

2009-06766

2009-10604

2009-06762

2009-06759

2010-08755

2010-08902

2010-08946

2010-09596

2010-09613

2010-09633

2003-04111

2005-03995

2006-03749

2011-03859

2011-03214

2010-08762

2010-00545

2010-08758

2009-04546

2009-05277

2009-03828

2008-09443

2009-09854

2009-04019

2009-06187

2009-06196

2010-08150

2010-08724

2011-03917

2011-01653

2010-02875

2009-7782

2009-9854

2009-10756

2010-587

2. Full Condition Report(s) related to closed substantive crosscutting issue H.4(a)

3. Full Condition Report(s) associated with adverse trend in apparent cause evaluations

documented in NRC inspection report 2010003

4. Full Condition Report(s) associated with NRC Information Notices:

2010-23 2010-12 2010-08 2009-23 2009-10

5. Full Condition Reports and completed copies of associated Work Order(s):

2009-08610 2009-09023 2009-09606 2010-03195 2009-04115 2010-08364

2010-09015 2009-01874 2009-00232 2009-07008 2009-08061 2010-03091

2010-05631 2010-09146 2010-06100 2010-09146 2008-08645 2009-03714

2008-08695 2009-08890 2009-07770 2010-09173 2010-09678 2011-02775

2011-03214 2010-04515

6. WO 4731460 WO 4731279 WO 4731467 WO 4731466 TTC 4731453

- 4 -

Attachment 3/Enclosure 2

J. Okonkwos Request:

1. Full Condition Reports:

2009-3863

2009-4526

2009-5490

2009-6000

2009-8197

2009-8412

2009-8452

2009-9171

2009-9537

2009-8623

2010-8769

2010-8169

2011-4658

2010-4695

2011-4256

2010-8770

2010-1349

2010-1553

2010-924

2010-314

2010-8093

2010-5815

2010-1688

2010-2980

2010-9065

2009-10347

2009-9003

2009-8552

2010-8193

2010-8242

2010-5023 2011-3763

2009-6063

2009-7538

2009-641

2008-948

2009-166

2009-611

2009-3729

2009-4019

2010-1763

2010-2282

2009-644

2010-3137

2011-0063

2009-3441

2009-3718

2009-3721

2009-3754

2009-4180 2009-4615

2009-5544

2009-6834

2010-167

2010-228

2010-1025

2010-3442

2011-166

2011-1367

2011-3519

2006-9802

2006-3563

2006-3826

2006-6301

2007-1216

2009-3363

2009-2721

2009-312

2009-2297

2011-1175

2009-6375

2009-2800

2010-5936

2010-8555

2010-8310

2010-8328

2010-8764

2010-9113

2011-0662

2009-4923

2010-9412

2011-2226

2011-2724

2010-8759

2011-2084

2010-8764

2009-741

2009-814

2008-7832

2009-6883

2009-5114

2009-611

2010-5629

2009-6187

2009-625

2009-9192

2010-9070

2009-6034

2010-10133 2010-09700 2010-09665 2011-1324

2010-1891

2010-4208

2010-1812

2010-1934,

2010-2394, , , ,

2. Full Condition Report(s) associated with NRC Information Notices 2011-01, 2010-25,

2010-13, 2009-25, 2009-19, 2009-08, and Regulatory Issue Summary 2009-10

3. Effluent Reports from January 1, 2009, to Present

K. Joseys Request:

1. Full Condition Report(s) associated with NRC Information Notices 2011-04, 2010-20,

2010-03, 2009-22, 2009-09, 2009-02

2. System engineers notebook for HPCI and RCIC

3. NEDC 92-050AB Revision 1 and 2

4. Complete copies of all work orders and surveillance test procedures associated with

HPCI-DPIS-76 and 77, since February 16, 2005.

5. Procedure for manual operation of zurn strainers, and copy of evaluation to credit

manual action of zurn strainers.

6. Completed Work Orders associated with the zurn strainer couplings from 2005 to

present.