IR 05000298/2016007

NRC Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications Baseline Inspection Report 05000298/2016007

ML16139A288
Person / Time
Site:	Cooper
Issue date:	05/17/2016
From:	Thomas Farnholtz Region 4 Engineering Branch 1
To:	Limpias O Nebraska Public Power District (NPPD)
References
IR 2016007
Download: ML16139A288 (19)

Text

SUBJECT:

COOPER NUCLEAR STATION - NRC EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000298/2016007

Dear Mr. Limpias:

On April 21, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. On April 21, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report.

The NRC inspectors did not identify any findings or violations of more-than-minor significance.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Thomas R. Farnholtz, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-298 License No. DPR-46 Enclosure:

Inspection Report 05000298/2016007 w/Attachment: Supplemental Information

ML16139A288 SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: TRFarnholtz Yes No Non-Publicly Available Sensitive NRC-002 OFFICE SRI:EB1 RI:EB2 PE:DRP/C C:EB1 C:DRP/C C:EBI1 NAME RLatta SMakor LBrandt TFarnholtz SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 5/12/16 5/17/16 5/12/16 5/17/16

Letter to Oscar from Thomas R. Farnholtz, dated May 17, 2016 SUBJECT: COOPER NUCLEAR STATION - NRC EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000298/2016007 Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Patricia.Voss@nrc.gov)

Resident Inspector (Christopher.Henderson@nrc.gov)

Branch Chief, DRP/C (Greg.Warnick@nrc.gov)

Senior Project Engineer (Cale.Young@nrc.gov)

Project Engineer (Lindsay.Brandt@nrc.gov)

Administrative Assistant (Amy.Elam@nrc.gov)

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

Project Manager (Alan.Wang@nrc.gov)

Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

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

Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket(s): 05000298 License(s): DPR-46 Report(s): 05000298/2016007 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave.

Brownville, NE Dates: April 4 through April 21, 2016 Inspectors: R. Latta, Senior Reactor Inspector L. Brandt, Project Engineer S. Makor, Reactor Inspector Approved By: Thomas R. Farnholtz Chief, Engineering Branch 1 Division of Reactor Safety Enclosure

SUMMARY

IR 05000298/2016007; 04/04/2016 - 04/21/2016: Cooper Nuclear Station, Evaluations of

Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a two-week announced baseline inspection on evaluations of changes, tests, and experiments and permanent plant modifications. The inspection was conducted by Region IV based engineering inspectors. No findings of more-than-minor significance were identified. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were determined using IMC 0310,

Aspects Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

NRC-Identified Findings

and Self-Revealed Findings No findings of more-than-minor significance were identified.

Licensee-Identified Violations

No findings of more-than-minor significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant

Modifications (71111.17T)

.1 Evaluations of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed nine evaluations performed pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 50, Section 59, to determine whether the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 30 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests, and experiment was resolved;

• the licensees conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The list of evaluations, screenings, and/or applicability determinations reviewed by the inspectors is included as an attachment to this report.

This inspection constituted 9 samples of evaluations and 30 samples of screenings and/or applicability determinations as defined in IP 71111.17-04.

b. Findings

No findings were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed 13 permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the affected systems. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated;

• the changes were in accordance with the specified design requirements;

• the procedures and training plans affected by the modification had been adequately updated;

• the test documentation as required by the applicable test programs had been updated; and

• post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included in the attachment to this report.

This inspection constituted 13 permanent plant modification samples as defined in IP 71111.17-04.

.2.1 HPCI MOV-14 Valve Replacement

The inspectors reviewed Change Evaluation Document CED 6017820, implemented to replace the high pressure coolant injection steam supply to turbine valve HPCI-MOV-MO14. The valve isolates reactor steam from the turbine inlet and allows the steam supply piping to be kept at an elevated temperature while the high pressure coolant injection system is in standby. The existing valve had a history of steam leakage due to wear on the valve seat and disk. This engineering change involved replacement of the existing valve with a new valve with improved disc guides and actuator with a different overall gear ratio. The engineering change also installed a new variable spring hanger support assembly from the valve to the concrete ceiling to accommodate the increased analyzed weight of the replacement valve. The inspectors did not identify any concerns with the design change package.

.2.2 Reactor Recirculation Pump Impeller Replacements

The inspectors reviewed Change Evaluation Document CED 6030460, implemented to replace the reactor recirculation pump B internals. The reactor recirculation system provides coolant flow to the reactor core for adjusting reactor power level and provides protection against radioactive material release, or loss of coolant, for all normal or abnormal transients or accidents. Industry operating experience indicated that plants with the existing reactor recirculation pump design had experienced shaft and cover cracking caused by thermal cyclic fatigue. General Electric Hitachi Nuclear Energy recommended that licensees with the existing pump design consider implementation of a pump upgrade to eliminate the reactor recirculation pump thermal shaft and cover cracking concern. This engineering change involved replacement of the existing reactor recirculation pump internals with an upgraded pump design. The inspectors did not identify any concerns with the design change package.

.2.3 Strong Motion Accelerograph Replacement

The inspectors reviewed Change Evaluation Document CED 6035941, implemented to replace the analog Kinemetrics seismic monitoring system with a digital SYSCOM system. The seismic monitoring system activates at 0.01g, provides indication of an earthquake to operations personnel, and records seismic acceleration data. The existing Kinemetrics seismic monitoring system was an analog system that recorded data on magnetic tapes and had the potential for corrupting and/or erasing the seismic data while the tapes were contained within the recording unit. This engineering change involved replacement of the existing Kinemetrics system with a new SYSCOM system utilizing digital technology to communicate and record seismic events on Flash memory media. The inspectors did not identify any concerns with the design change package.

.2.4 Reliable Spent Fuel Pool Level Instrumentation

The inspectors reviewed Change Evaluation Document CED 6036741, implemented to install a new spent fuel pool level measurement system in order to comply with NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately). The spent fuel pool level measurement system measures the amount of water covering the spent fuel in the spent fuel pool.

The existing spent fuel pool level monitoring system did not satisfy the requirements of the NRC order as they only indicated if the water level was above or below a certain threshold rather than give an actual water level reading. This engineering change involved installing two new level indication systems that provide actual water level measurements. The engineering change also installed new signal cables, conduit and cable trays, and signal processors for remote indication capability. The inspectors did not identify any concerns with the design change package.

.2.5 HPCI RO-135 Replacement

The inspectors reviewed Change Evaluation Document CED 6036743, implemented to replace the high pressure coolant injection restricting orifice, RO-135. The restricting orifice is designed to simulate reactor pressures and flow rates in the high pressure coolant injection test return line. The existing restricting orifice had become fouled with material released during the previous refueling outage buried pipe inspection of the suction line from the emergency condensate storage tanks. This engineering change involved replacement of the original restricting orifice with a new, equivalent restricting orifice. The engineering change also evaluated the code differences from the original component USAS-B31.7 1969 class II piping requirements which had been superseded by ASME Section II 1989 class II piping requirements. The inspectors did not identify any concerns with the design change package.

.2.6 Revise Control Logic for Reactor Building Doors

The inspectors reviewed Change Evaluation Document CED 6036160, implemented to revise the control logic for the reactor building inner and outer doors, to prevent inadvertent breaches of secondary containment. The previous control logic allowed both doors to be normally unlocked that resulted in numerous breaches of secondary containment and corresponding unplanned entry into Technical Specification Limiting Condition for Operation 3.6.4.1. This engineering change involved revising the control logic such that both doors are normally locked and installation of palm switches and position indication lights on both sides of each door. The inspectors did not identify any concerns with the design change package.

.2.7 Service Water Pump Room Instrument Rack Replacement

The inspectors reviewed Change Evaluation Document CED 6035942, implemented to replace the five instrument racks previously installed in the Service Water Pump Rooms in accordance with Temporary Configuration Change TCC 4881013. The Temporary Configuration Change was necessary to compensate for the presence of excessive corrosion around the post bases and anchorage which impacted the structural integrity of the instrument racks. Specifically, the replacement instrument racks incorporated a corrosion-resistant design, consistent with the design requirements specified in Change Evaluation Document CED 6029209, Zurn Service Water Strainer Replacements.

This revised configuration eliminated carbon steel components from contacting wetted surfaces and the new rack posts were sealed (top and bottom). The inspectors did not identify any concerns with the design change package.

.2.8 Replace Installed Instrumentation for Emergency Condensate Storage Tank

1A(B) Level Indicator The inspectors reviewed Change Evaluation Document (CED) 6034624, implemented to conform with the Overall Integrated Plan for Diverse and Flexible Coping Strategies (FLEX) in response to NRC Order EA-12-049, Modifying Licensees with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events. As described in this design modification, the local pressure indicators for high pressure coolant injection (HPCI)-PI-117A(B) are credited with determining inventory levels of emergency condensate storage tank 1A(B) for coping with the FLEX evaluations.

Specifically, this engineering change involved replacing the non-essential level instrumentation for emergency condensate storage tank 1A(B) with Seismic Class IS, essential grade piping and components. This modification included the capability to monitor Emergency Condensate Storage Tank levels during an extended loss of ac power event consistent with the plan to maintain the requisite core cooling in the FLEX Coping Strategies. The inspectors did not identify any concerns with the design change package.

.2.9 Replace Reactor Recirculation Eagle Signal Timers

The inspectors reviewed Change Evaluation Document CED 6038102, implemented to replace the existing Eagle Signal cam-type timers used in the reactor recirculation system with digital programmable logic control timers. The replacement timers are configured to duplicate the timing function previously performed by the motor driven cam timers, with greater dependability and accuracy. The modification included two timers used to apply excitation to the reactor recirculation motor generator sets and two timers used to jog open the reactor recirculation pump discharge valves when bringing the second loop of reactor recirculation into service. The inspectors did not identify any concerns with the design change package.

.2.10 National Fire Protection Association 805, Cable Tray Radiant Energy Heat Shields

The inspectors reviewed Change Evaluation Document CED 6034801, implemented to install three radiant energy heat shields that provide passive fire protection to safe shutdown equipment. This modification was instituted as a part of the transition to National Fire Protection Association 805. Specifically, the need for this modification was identified after completing two calculations involving multiple areas that contained safe shutdown equipment and required additional fire protection measures. The inspectors did not identify any concerns with the design change package.

.2.11 Electrical Connections

The inspectors reviewed Change Evaluation Document CED 6037041, implemented to modify the power circuit from the transfer switches to the 125 and 250 VDC 1 C battery chargers. Specifically, this modification established a connection from the FLEX equipment diesel generator, to power the battery chargers, in the event that normal sources are not available in an extended loss of ac power (ELAP) beyond design basis event. The inspectors did not identify any concerns with the design change package.

.2.12 National Fire Protection Association (NFPA) 805 Battery Charger Cable Re-Route

The inspectors reviewed Change Evaluation Document CED 6034802, implemented to reroute two power cables to 125V charger 1A and 250V charger 1A. Specifically, the cables were rerouted to provide adequate separation between Division II cables for 125V charger 1B and 250V charger 1B. The inspectors reviewed the design package, discussed the change with the design engineer, and visually inspected the modification.

The inspectors did not identify any concerns with the design change package.

.2.13 Cable Reel Installation for Emergency Procedures

The inspectors reviewed Change Evaluation Document CED 6034623, implemented to install permanent cable reels/racks in the turbine and water treatment building.

These cable reels were designed to store and protect the severe accident management guidelines, diesel fuel oil transfer pump emergency repair cables, associated with the 125V and 250V battery charger 1B emergency repair cables, and the battery room exhaust fan emergency repair cable. The inspectors did not identify any concerns with the design change package.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Review of Corrective Action Program Documents

a. Inspection Scope

The inspectors reviewed 40 corrective action program documents that identified or were related to 10 CFR 50.59 program and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The list of specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings were identified.

4OA6 Meetings

Exit Meeting Summary

On April 21, 2016, the inspectors presented the preliminary inspection results to Mr. O. Limpias, Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensees staff. The licensee acknowledged the results as presented. The inspectors verified no proprietary information was retained or documented in the report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

O. Limpias, Vice President-Nuclear and Chief Nuclear Officer

R. Penfield, Director of Nuclear Safety Assurance

K. Higginbotham, General Manager of Plant Operations

D. Buman, Director of Engineering

J. Houston, Manager, Production

J. Shaw, Manager, Licensing

A. Walters, Manager, Chemistry

K. Dia, Manager, Systems Engineering

R. Estrada, Manager, Design Engineering

L. Dewhirst, Manager, Corrective Action and Assessment

T. Barker, Manager, Engineering Programs and Components

K. Treme, Manager, Finance Manager

J. Horn, Supervisor, Design Engineering - Mechanical

A. Able, Supervisor, Design Engineering - Instrument and Control

M. Van Winkle, Supervisor, Design Engineering - Electrical

K. Kuker, Design Engineering - Mechanical

J. Campbell, Support, Design Engineering

J. Flaherty, Engineer, Senior Staff

T. Forland, Engineer, Licensing

D. Van Der Kamp, Technical Specialist, Licensing

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

None.