IR 05000298/2019002
| ML19219A801 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/05/2019 |
| From: | Cale Young Division of Nuclear Materials Safety IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Cale Young | |
| References | |
| IR 2019002 | |
| Download: ML19219A801 (35) | |
Text
August 5, 2019
SUBJECT:
COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2019002
Dear Mr. Dent,
Jr.:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. On July 16, 2019, the NRC inspectors discussed the results of this inspection with Mr. D. Buman, Director of Nuclear Safety Assurance and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Cooper Nuclear Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Cooper Nuclear Station.
J. Dent, Jr.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Cale H. Young, Acting Chief Reactor Project Branch C
Docket No.: 05000298 License No.: DPR-46
Enclosure:
As stated
Inspection Report
Docket Number:
05000298
License Number:
Report Number:
Enterprise Identifier: I-2019-002-0003
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, Nebraska
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
J. Cassidy, Senior Health Physicist
P. Elkmann, Senior Emergency Preparedness Inspector
J. Rivera, Health Physicist
M. Stafford, Resident Inspector
P. Vossmar, Senior Resident Inspector
Approved By:
Cale H. Young, Acting Chief
Reactor Project Branch C
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a integrated inspection at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC finding, violation, and an additional item are summarized in the tables below.
List of Findings and Violations
Failure to Evaluate Operability in Accordance with Procedures for a High Pressure Coolant Injection System Degraded Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2019002-01 Open/Closed
[H.7] -
Documentation 71111.15 The inspectors identified a finding of very low safety significance and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the licensees failure to evaluate operability of the high pressure coolant injection system in accordance with Procedure 0.5.OPS, Operations Review of Condition Reports / Operability Determination,
Revision 62. Specifically, on January 25, 2019, when the high pressure coolant injection pump low discharge flow instrument failed to generate the required minimum flow valve closure signal during surveillance testing, the licensee failed to recognize that high pressure coolant injection surveillance requirements for pump flow could not be met. As a result, the instrument was inoperable, and although it was repaired within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of discovery, the inoperability was not recognized until inspectors challenged the initial determination.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000298/2017-004-01 Torus to Drywall Vacuum Breaker Failure to Indicate Full Closed Causes Loss of Safety Function.
71153 Closed
PLANT STATUS
Cooper Nuclear Station began the inspection period at rated thermal power. On May 17, 2019, the unit was down powered to 65 percent for a control rod sequence exchange. The plant was returned to rated thermal power on May 18, 2019, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems on June 20, 2019.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Reactor core isolation cooling while high pressure coolant injection out of service on April 18, 2019;
- (2) Residual heat removal B during residual heat removal A work week on May 3, 2019;
- (3) Service water during service water pump D replacement on May 17, 2019;
- (4) Standby gas treatment A during standby gas treatment B maintenance on June 11, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Northwest quad 859 feet and 881 feet elevations, Division 1 residual heat removal on April 3, 2019;
- (2) Cable expansion room on April 15, 2019;
- (3) Alternate shutdown panel area on May 1, 2019;
- (4) Southwest quad 859 feet and 881 feel elevations, Division 2 residual heat removal on May 2, 2019;
- (5) Reactor building 976 standby liquid control area on June 10, 2019.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
Core spray A and reactor core isolation cooling area on June 3, 2019.
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
The inspectors evaluated readiness and performance of:
Residual heat removal A heat exchanger inspection and maintenance on May 2, 2019.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
The inspectors observed and evaluated licensed operator performance in the control room during control rod drive exercising, standby gas treatment troubleshooting, and emergency diesel generator 1 service water inservice testing on June 8, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated the licensed operator qualification simulator scenario on April 23, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Reactor building quad sumps on June 18, 2019;
- (2) Turbine system on June 25, 2019;
- (3) Reactor recirculation system on June 27, 2019.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Emergent reactor feed vent line leak on April 5, 2019;
- (2) Emergency diesel generator 2 jacket water heat exchanger flange service water leak repair on April 12, 2019;
- (3) High pressure coolant injection planned maintenance work week on April 18, 2019;
- (4) Residual heat removal B and residual heat removal service water B work week on April 24, 2019;
- (5) Residual heat removal A planned maintenance work week on May 3, 2019;
- (6) Main generator reactive load verification on June 21, 2019;
- (7) Recirculation motor generator set B potentiometer replacement on June 27, 2019.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Reactor equipment cooling C operability on April 25, 2019;
- (2) Condition Report CR-CNS-2018-02061 battery results operability evaluation on April 29, 2019;
- (3) Inadequate station battery technical specification on April 30, 2019;
- (4) FP2 barriers found with combustible sealant on May 1, 2019;
- (5) High pressure coolant injection minimum flow valve instrumentation failed testing and calibration on June 19, 2019.
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) High pressure coolant injection control system card replacement post maintenance test on April 19, 2019;
- (2) Residual heat removal pump B post maintenance test following planned system maintenance on April 24, 2019;
- (3) Residual heat removal service water pump B leakage testing following maintenance April 24, 2019;
- (4) Reactor equipment cooling pump C post maintenance test following pump replacement on April 25, 2019;
- (5) Residual heat removal pump A post maintenance test following planned system maintenance on May 3, 2019;
- (6) SGT-AO-271 standby gas treatment B dilution air valve post maintenance test on June 12, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
Elevated release point sump pump functional test on April 17, 2019.
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
Particulate and iodine sample collection for drywell atmosphere monitor and increased drywell unidentified leakage on April 4, 2019.
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
- (1) Reactor core isolation cooling pump low discharge flow channel calibration on April 10, 2019;
- (2) High pressure coolant injection quarterly pump flow test on April 26, 2019.
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
The inspectors evaluated the maintenance and testing of the alert and notification system, including outdoor warning sirens and tone alert radios, for the period July 2017 through May 2019. The inspectors also observed a silent test of the outdoor emergency warning sirens conducted June 18, 2019.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
The inspectors evaluated the readiness of the Emergency Preparedness Organization for the period July 2017 through May 2019.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
The inspectors evaluated Revisions 72 and 73 of the Cooper Nuclear Station Emergency Plan. These evaluations do not constitute NRC approval of the changes made by the licensee.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
The inspectors evaluated the maintenance of the emergency preparedness program for the period July 2017 through May 2019. The inspectors observed a quarterly meeting between licensee staff and state and county offsite emergency response organizations on June 20, 2019, which included a discussion of the quality of interfaces between the licensee and offsite response organizations led by the licensee's Quality Assurance organization.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
Emergency preparedness drill on May 14,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors verified the following sealed sources are accounted for and are intact:
- S741;
- S256.
High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Instructions to Workers (IP Section 02.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
Radiation work packages:
- 2018-106; Transverse Incore Probe; Radiation Protection High Risk Activities;
- 2019-100; Reactor Building; LOCKED High Radiation Area Activities;
- 2019-102; High Integrity Container Preparation / Shipments.
Electronic alarming dosimeter alarms:
- no alarms occurred during the period of this inspection.
Labeling of containers:
- Three Main Steam Relief Valves;
- Dry Active Waste Pump;
- Box of Hoses and Fittings in Radioactive Waste Processing Area.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
Radiological Hazard Assessment (IP Section 02.01) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls. The inspectors reviewed the following:
Radiological surveys:
- Reactor Water Clean-Up Heat Exchanger Room;
- Radwaste Collector Tanks;
- Refuel Floor;
- High Pressure Core Injection Pump Room.
Risk significant radiological work activities:
- Locked High Radiation Area Verification Surveillance;
- Spent Resin Sample Collection;
- Residual Heat Removal Heat Exchanger Inspection and Eddy Current.
Air sample survey records:
- Reactor Head Bolt Cleaning;
- Cavity Decontamination;
- Reactor Water Clean-Up Heat Exchanger Room Decontamination.
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
Radiological work package for areas with airborne radioactivity:
- No work packages were available for review during this inspection.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (IP Section 02.01) (1 Sample)
The inspectors evaluated airborne controls and radioactive monitoring. The inspectors reviewed the following:
Installed Ventilation Systems
- Control Room Emergency Filter System
- Standby Gas Treatment (SGT) System
Temporary Ventilation System Setups
- None were available during this inspection
Portable or Installed Monitoring Systems
- Continuous air monitor (AMS-4) in the Augmented Radwaste Building
- Continuous air monitor (AMS-4) on the Refuel Floor
Self-Contained Breathing Apparatus (SCBA) for Emergency Use (IP Section 02.03) (1 Sample)
The inspectors evaluated SCBA program implementation. The inspectors reviewed the following:
Status and Surveillance Records for Self-Contained Breathing Apparatus
- SCBA No. IL845597
- SCBA No. IL845658
- SCBA No. IL846625
- SCBA No. IL846876
- SCBA No. IL846907 Self-Contained Breathing Apparatus Fit for On-Shift Operators
Self-Contained Breathing Apparatus Maintenance Check
- Due to the entire fleet of SCBAs (Scott X-3) being newly purchased in June 2018, the time frame for the maintenance checks has not been reached. Therefore, none were available during this inspection.
Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)
The inspectors evaluated respiratory protection. The inspectors reviewed the following:
Evaluations for the Use of Respiratory Protection
- None were available during this inspection
Respiratory Protection Use During Work Activities
- None were available during this inspection
Medical Fitness for Use of Respiratory Protection Devices
- One nonlicensed operator
- One Maintenance Support individual
- One Electrical Maintenance individual
Observation of Donning, Doffing and Functional Test
- Observed demonstration of donning, doffing, and functional test of an SCBA unit and full face respirator by a radiation protection technician
Respiratory Protection Device Evaluation
- Five Scott AV 30000HT full face respirators
- One Versaflo Powered Air Purifying Respirator (PAPR)
- One Delta Mururoa Delta Suite
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
April 1, 2018 - March 31, 2019
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
April 1, 2018 - March 31, 2019
EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)
July 1, 2018 - March 31, 2019
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
July 1, 2018 - March 31, 2019
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
July 1, 2018 - March 31, 2019
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
April 1, 2018 - March 31, 2019
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
October 31, 2018 - March 31, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
Post event flooding technical requirements manual changes on June 19, 2019.
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the licensee's retraction of Event Notification 53646 regarding main steam isolation valve local leak-rate test values on June 11, 2019;
- (2) The inspectors evaluated the unplanned trip of a reactor recirculation pump and the resulting single loop operations on June 12, 2019.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
1. LER 05000298/2017-004-01, Torus to Drywall Vacuum Breaker Failure to Indicate
Full Closed Causes Loss of Safety Function (ADAMS Accession No. ML19031B333).
The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
INSPECTION RESULTS
Failure to Evaluate Operability in Accordance with Procedures for a High Pressure Coolant Injection System Degraded Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000298/2019002-01 Open/Closed
[H.7] -
Documentation 71111.15 The inspectors identified a finding of very low safety significance and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the licensees failure to evaluate operability of the high pressure coolant injection system in accordance with Procedure 0.5.OPS, Operations Review of Condition Reports / Operability Determination, Revision 62. Specifically, on January 25, 2019, when the high pressure coolant injection pump low discharge flow instrument failed to generate the required minimum flow valve closure signal during surveillance testing, the licensee failed to recognize that high pressure coolant injection surveillance requirements for pump flow could not be met. As a result, the instrument was inoperable, and although it was repaired within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of discovery, the inoperability was not recognized until inspectors challenged the initial determination.
Description:
On January 25, 2019, during technical specification (TS) surveillance-required functional testing, the licensee discovered that Switch 2 on HPCI-FIS-78, HPCI pump discharge low flow switch, did not actuate within calibration tolerances. The licensee subsequently performed a calibration of the instrument, and technicians were unable to get the switch to actuate or calibrate. As a result, later that day, maintenance personnel removed the switch cover and inspected the internals and linkages within the instrument, and then adjusted the actuation plunger on Switch 2. These actions restored the instrument's ability to function. Until then, the switch was unable to perform its function for a total of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
Because there is only one of these instruments, loss of the instrument results in a loss of the function. With the loss of function of Switch 2, the high pressure coolant injection (HPCI)minimum flow valve would open upon pump start, as required, but would fail to close when the pump reached higher flows and approached operating conditions. This failure would cause a diversion of flow through the minimum flow line when all flow should be directed into the reactor vessel during an emergency event. Operations personnel determined that HPCI-FIS-78 was operable for the condition, despite the loss of Switch 2s function.
Specifically, operations personnel noted that the successful operation of Switch 2 was not a surveillance procedure acceptance criterion. They also noted that the TS Bases for Limiting Condition for Operation (LCO) 3.3.5.1 - Function 3f, HPCI Pump Discharge Flow - Low, stated, The valve is automatically closed if flow is above the minimum flow setpoint. It is not necessary for the minimum flow valve to close to achieve adequate system flow assumed in the accident analysis (Ref. 4).
The inspectors reviewed the licensees operability evaluation. The inspectors noted that the instrument in question opens and closes the minimum flow valve automatically based on HPCI flow, and both of these functions were covered under LCO 3.3.5.1 - Function 3f. They also noted that the General Electric Standard TS Bases stated for Function 3f, The HPCI Pump Discharge Flow - Low Function is assumed to be OPERABLE and capable of closing the minimum flow valve to ensure that the emergency core cooling system flow assumed during the transients and accidents analyzed in References 2, 3, and 4 are met. Next, the inspectors reviewed the Ref. 4 cited in Coopers TS Basis document, Calculation NEDC 97-023, "HPCI Minimum Flow Line Evaluation, Revision 3. The inspectors identified that in the section labeled, Conclusions and Recommendations, the calculation stated, in part, that the HPCI system minimum flow line bypass valve must close for the system to be able to meet an injection flowrate of 4250 gpm at lower reactor pressures. However, closure is not required to ensure that the HPCI minimum injection flow rate assumed in the accident and transient analysis is met. The inspectors observed that TS Surveillance Requirements 3.5.1.7 and 3.5.1.8 for HPCI pump flow require HPCI to develop 4250 gpm of injection flow against reactor pressure when reactor pressure is between 150 psig and 1020 psig. Therefore, with the instrument failed, HPCI would not be able to meet its TS surveillance-required flow rates. The inspectors also observed that Cooper TS Surveillance Requirement 3.0.1 states, Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.
The inspectors reviewed the licensees operability Procedure 0.5.OPS, Operations Review of Condition Reports / Operability Determination, Revision 62. Section 5 of this procedure describes the requirements for performance of immediate operability determinations.
Section 5.1.13.6 states, in part, that when a degraded condition is identified, operability evaluations should include documentation of a reasonable expectation of operability and the basis for that determination. Section 5.1.13.6.a, states, select and use appropriate references to ensure the scope of the SSC function is identified. Reference to program documents, calculations, alarm cards, or other documents may provide additional insights into SSC performance requirements. The inspectors noted that the operations personnel performing the evaluation in this case had failed to reference the calculation that was listed as the reference for the erroneous TS Basis document statement. Step 5.1.13.6 states, Ensure all Tech Spec Surveillance Requirements can be met. The inspectors determined that this step was not accomplished in accordance with the procedure, in that with the degraded condition on HPCI-FIS-78, TS Surveillance Requirements 3.5.1.7 and 3.5.1.8 for HPCI pump flow could not be met. The inspectors challenged the licensee's operability determination, and after further review, operations personnel determined that the instrument should have been declared inoperable. As a result, the inspectors concluded that operations personnel had performed an inadequate evaluation of operability for this issue. The inspectors also noted that the TS Basis document lacked clarity and accuracy, and the surveillance procedure for this instrument had incorrectly listed the function in question as not being a TS function.
Corrective Actions: Corrective actions included repair of the degraded instrument; determination that the system was inoperable under LCO 3.3.5.1, Condition E; revision of the surveillance procedure acceptance criteria; and revision of the TS Basis document to more accurately describe the instruments safety functions.
Corrective Action References: Condition Reports CR-CNS-2019-00757 and CR-CNS-2019-02325
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to evaluate operability of the high pressure coolant injection (HPCI) system and pump low discharge flow instrument in accordance with Procedure 0.5.OPS was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone. Specifically, the HPCI pump low discharge flow instrument was not recognized as being inoperable, and if called upon, it would not have generated the signal to close the minimum flow valve when required, allowing for diverted flow and preventing HPCI from generating its TS surveillance-required flow (4250 gpm) at lower reactor pressures.
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors determined this finding was of very low safety significance (Green) because it:
was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. Specifically, although the minimum flow valve would not have automatically closed when required, HPCI would have maintained the ability to generate the amount of flow used in the licensees accident analysis (3825 gpm). Therefore, the inspectors concluded that from a probabilistic risk assessment perspective, the actual safety function of HPCI was not lost.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate, and up-to-date documentation. Specifically, the licensee failed to maintain complete and accurate TS basis documents and surveillance procedures to ensure that the function of the HPCI minimum flow valve closure instrumentation was properly described.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Licensee Procedure 0.5.OPS, Operations Review of Condition Reports / Operability Determination, Revision 62, an Appendix B quality related procedure, was established to control the operability evaluation process for technical specification equipment. Step 5.1.13.6.d. includes operability determination requirements for degraded conditions, and states, ensure all Tech Spec Surveillance Requirements can be met.
Contrary to the above, on January 25, 2019, operations personnel failed to ensure all technical specification surveillance requirements could be met for a degraded condition.
Specifically, when the HPCI pump low discharge flow instrument failed to generate the minimum flow valve closure signal during surveillance testing, the licensee failed to recognize that HPCI surveillance requirements for pump flow could not be met. As a result, the instrument was inoperable, and although it was repaired within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of discovery, the inoperability was not recognized until inspectors challenged the initial determination.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 23, 2019, the inspectors presented the radiation protection inspection results to Mr. J. Dent, Jr., Site Vice President, and other members of the licensee staff.
- On June 20, 2019, the inspectors presented the emergency preparedness program inspection results to Mr. J. Dent, Jr., Site Vice President, and other members of the licensee staff.
- On July 16, 2019, the inspectors presented the integrated inspection results to Mr. D. Buman, Director of Nuclear Safety Assurance, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
2019-03587
Miscellaneous
IOA
Interface Operating Agreement Between NPPD Operations
Business Unit and NPPD Nuclear Power Group Business
Unit - Transmissions Operations
Procedures
5.3GRID
Degraded Grid Voltage
Work Orders
WO 5190544, 5222296, 5286529, 5304348
Corrective Action
Documents
CR-CNS-
2019-02340, 2019-02751, 2019-02754, 2019-02783, 2019-
03125, 2019-03223, 2019-03271
Drawings
2037
H&V Standby Gas Treatment & Offgas Filters
Procedures
2.2.67A
Reactor Core Isolation Cooling System Component
Checklist
Procedures
2.2.67B
Reactor Core Isolation Cooling System Instrument Valve
Checklist
Procedures
2.2.71
Service Water System
25
Procedures
2.2.73
Procedures
2.2A.SGT.DIV1
Standby Gas Treatment System Component Checklist (DIV
1)
Procedures
2.2A.SW.DIV0
Service Water System Non-Divisional Component Checklist
Procedures
2.2A.SW.DIV1
Service Water System Component Checklist (DIV 1)
Procedures
2.4HVAC
Building Ventilation Abnormal
71111.05Q Corrective Action
Documents
CR-CNS-
2019-02058, 2019-02516, 2019-02591, 2019-03195
71111.05Q Miscellaneous
CNS-FP-214
Reactor Building Southwest Quadrant
AD/05
71111.05Q Miscellaneous
CNS-FP-215
Reactor Building First Floor Elevation 903-6
AC/06
71111.05Q Miscellaneous
CNS-FP-220
Reactor Building SBLC Area
AC/08
71111.05Q Procedures
0-BARRIER
Barrier Control Process
71111.05Q Procedures
0-BARRIER-
MAPS
Barrier Maps
71111.05Q Procedures
0-BARRIER-
REACTOR
Reactor Building
71111.05Q Procedures
6.SC.502
Secondary Containment Penetration Examination
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.05Q Procedures
CNS-FP-213
Reactor Building Northwest Quadrant Elevations 881-9 and
859-9
AC/06
71111.05Q Procedures
CNS-FP-234
Office Building Cable Expansion Room Elevation 918 6
Corrective Action
Documents
CR-CNS-
2019-02921, 2019-02931
Drawings
2038
Reactor Building Floor and Roof Drain System
Miscellaneous
NEDC 09-102
Internal Flooding - HELB, MELF, and Feedwater Line Break
Procedures
0-BARRIER
Barrier Control Process
Procedures
2.3_S-1
Panel S - Annunciator S-1
Corrective Action
Documents
CR-CNS-
2018-00541, 2019-02541
Miscellaneous
Generic Letter 89-
Program Commitments
04/30/2019
Procedures
13.17.2
Thermal Performance Test Procedure for Residual Heat
Removal Heat Exchangers
Procedures
3.10
Flow Accelerated Corrosion (FAC) and Microbiologically
Influenced Corrosion (MIC) Program Implementation
Procedures
7.0.5
CNS Post-Maintenance Testing
Procedures
7.2.42.2
RHR Heat Exchanger Maintenance
Work Orders
WO 5164185, 5210951
71111.11Q Corrective Action
Documents
CR-CNS-
2019-03179
71111.11Q Drawings
2.3_K-2
Panel K - Annunciator K-2
71111.11Q Drawings
2.3_M-1
Panel M - Annunciator M-1
71111.11Q Miscellaneous
11614584
Routine Troubleshooting Plan - SGT Train B, Reactor
Building HVAC
71111.11Q Miscellaneous
SKL 05151363
Performance Mode #7
71111.11Q Procedures
2.2.47
HVAC Reactor Building
71111.11Q Procedures
6.1SW.401
Diesel Generator Service Water Check Valve and Sump
Test (IST)
71111.11Q Procedures
6.CRD.301
Withdrawn Control Rod Operability IST Test
71111.11Q Procedures
Emergency
Operating
Procedure 1A
EOP Flow Chart 1A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.11Q Procedures
Emergency
Operating
Procedure 5A
EOP Flow Chart 5A
Corrective Action
Documents
CR-CNS-
2018-07300, 2018-07359, 2018-07893, 2018-07897, 2018-
07935, 2018-07996, 2019-03061, 2019-03256, 2019-03289,
2019-03488
Miscellaneous
Maintenance Rule Meeting Package
06/25/2019
Miscellaneous
Notifications
11384819, 11391486, 11391978, 11470097, 11490991,
11506236, 11540654, 11543417, 11546697, 11546699,
11564325, 11564880, 11569172, 11569244, 11569961,
11579431, 11604580, 11611874, 11611930, 11613897,
11616392
Miscellaneous
RR-F01
Maintenance Rule Function Basis for RR-F01
Miscellaneous
RRMG-F01
Maintenance Rule Function Basis for RRMG-F01
Miscellaneous
RW-F03
Maintenance Rule Function Basis for RW-F03
Miscellaneous
TG-F01
Maintenance Rule Function Basis for TG-F01
Procedures
0-CNS-LI-102
Corrective Action Process
Procedures
0.40
Work Control Program
Corrective Action
Documents
CR-CNS-
2019-02341, 2019-02450, 2019-02510, 2019-03559, 2019-
03561
Miscellaneous
Protected Equipment Tracking Form - SWBP and RHR B
Window Week 1917
Miscellaneous
Protected Equipment Tracking Form - HPCI Window Week
1916
Miscellaneous
Critical Evolutions Meeting PowerPoint for WO 5293548,
Temporary Leak Repair RF-V-527 Reactor Feed Flushing
Line Vent
Miscellaneous
Protected Equipment Tracking Form - Week 1918 RHR A
Window
Miscellaneous
Risk Management Plan - Main Generator MVAR Testing per
15.GEN.602
6/18/2019
Miscellaneous
Critical Evolutions Meeting Presentation - RRMG B
Clamping
Miscellaneous
Protected Equipment Tracking Form - DG2 LCO
04/11/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Risk Management Plan - Repair Diesel Generator 2 Jacket
Water Heat Exchanger Flange Leak
04/11/2019
Miscellaneous
SKL051-51-375
Just-in-time Training - Ops B RRMG Scoop Tube Clamp
and De-clamp JITT
Procedures
0-PROTECT-
EQP
Protected Equipment Program
Procedures
15.GEN.602
Main Generator Power Verification
Procedures
7.2.85
Reactor Recirculation Motor
Procedures
Access Control for Radiologically Controlled Areas
Procedures
Radiation Protection Posting and Labeling
Work Orders
WO 5130544, 5174247, 5210476, 5211716, 5292133, 5293548,
295757
Corrective Action
Documents
CR-CNS-
2005-03329, 2018-04112, 2018-08609, 2018-08614, 2018-
08621, 2018-08638, 2018-08657, 2019-00439, 2019-00443,
2019-00702, 2019-00757, 2019-01928, 2019-02061, 2019-
2073, 2019-02325, 2019-02449, 2019-02467, 2019-02471
Drawings
2044
Flow Diagram High Pressure Coolant Injection and Reactor
Feedwater Systems
Miscellaneous
Admin Letter 98-
Dispositioning of Technical Specifications That Are
Insufficient to Assure Plant Safety
2/29/1998
Miscellaneous
NEDC 10-004
Fire PRA Plant Boundary Definition and Partitioning
Miscellaneous
NEDC 10-080
NFPA 805 Chapter 3 Fundamental Fire Protection Program
and Design Elements Review
Miscellaneous
NEDC 14-043
Fire Safety Analysis for Entire Power Block
Miscellaneous
NEDC 97-023
HPCI Minimum Flow Line Evaluation
1, 2, 3
Miscellaneous
Notification
11583394
Procedures
0-BARRIER
Barrier Control Process
Procedures
0.23
CNS Fire Protection Plan
Procedures
0.26
Surveillance Program
Procedures
0.31
Equipment Status Control
Procedures
0.7.1
Control of Combustibles
Procedures
5.3NBPP
No Break Power Failure
Procedures
6.1EE.602
Div 1 125V/250V Station Battery 92 Day Check
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
6.2EE.602
Div 2 125V/250V Station Battery 92 Day Check
Procedures
6.EE.609
25V/250V Station Battery Intercell Connection Testing
Procedures
6.FP.606
Fire Barrier/Penetration Seal Visual Examination
Procedures
6.HPCI.312
HPCI Pump Low Discharge Flow Channel Calibration
Procedures
6.HPCI.712
HPCI Pump Low Discharge Flow Channel Functional Test
Procedures
7.2.78.2
Pipe Penetration Seal Installation Using Gasket Placement
Corrective Action
Documents
CR-CNS-
2016-07742, 2018-07736, 2018-07780, 2018-08411, 2019-
00668
Miscellaneous
Maintenance Rule Function MS-F04 Performance Criteria
Basis
Miscellaneous
274251
Miscellaneous
DEC-5274251
MS-AOV-739AV Indicating Lights
Work Orders
WO 274155, 5274250
Corrective Action
Documents
CR-CNS-
2019-02154, 2019-02345, 2019-02346, 2019-02462, 2019-
2471, 2019-02477, 2019-03230, 2019-03242
Drawings
791E271, Sheet 6 HPCI System Elementary Diagram
Miscellaneous
FMEA for CR-2019-02345; HPCI Speed Indication Issue
04/19/2019
Miscellaneous
11602479
Routine Troubleshooting Plan - HPCI Speed Indication
Issue
3, 4
Procedures
2.2.18.2
System Operating Procedure 4160V Breaker Operations
Procedures
6.1SGT.301
SGT Operability Test/Offgas Flow Monitor Channel
Functional Test IST (Div 1)
Procedures
6.2REC.101
REC Surveillance Operation
Procedures
6.2RHR.101
RHR Test Mode Surveillance Operation (IST) (Div 2)
Procedures
6.2SGT.301
SGT Operability Test/Offgas Flow Monitor Channel
Functional (Div 2)
Procedures
6.HPCI.103
Procedures
6.HPCI.316
HPCI Control System Calibration Test
Procedures
7.0.1.7
Troubleshooting Plant Equipment
Work Orders
WO 5130544, 5155002, 5155003, 5155004, 5185366, 5187211,
5192542, 5207498, 5210476, 5211419, 5211716
Corrective Action
Documents
CR-CNS-
2019-02038, 2019-02222, 2019-02342, 2019-02345, 2019-
2346, 2019-02381, 2019-02469
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Surveillance Testing Recommendations for HPCI and RCIC
Systems
Miscellaneous
HPCI and RCIC Turbine Control System Calibration
Procedures
6.HPCI.103
Procedures
6.HPCI.316
HPCI Control System Calibration Test
Procedures
6.RCIC.302
RCIC Pump Low Discharge Flow Channel Calibration
Procedures
6.SUMP.101
Z Sump and Air Ejector Holdup Line Drain Test
Procedures
8.8DWAM
Particulate and Iodine Sample Collection for Drywell
Atmosphere Monitor
Procedures
Drywell Leakage
2C0
Work Orders
WO 5183570, 5185369
Corrective Action
Documents
CR-CNS-
2017-04854, 2017-05001, 2018-00160, 2018-00650, 2018-
01477, 2018-02873, 2018-03033, 2018-03695, 2018-06852,
2019-00624, 2019-03074
Miscellaneous
Letter, Mr.
- T. Morgan, Technological Hazards Branch Chief,
FEMA Region VII, to Ms.
- T. Haynes, Emergency
Preparedness Coordinator, Cooper Nuclear Station; Subject:
Cooper Nuclear Station Alert and Notification System Design
Report, Revision 15
8/15/2018
Miscellaneous
Cooper Nuclear Station Alert and Notification System Design
Report, Revision 15
June 2018
Miscellaneous
Letter, Mr.
- T. Morgan, Technological Hazards Branch Chief,
FEMA Region VII, to Ms.
- T. Haynes, Emergency
Preparedness Coordinator, Cooper Nuclear Station; Subject:
Evaluation of Cooper Nuclear Station Alert and Notification
Design Report Revision and Narrative Summary of
Proposed Changes dated 16 April 2019
5/21/19
Miscellaneous
Cooper Nuclear Station Alert and Notification System Design
Report, Revision 16
April 2019
Miscellaneous
WPS 2900 Series High Power Voice and Siren System,
Operating and Troubleshooting Manual
2005
Miscellaneous
EPDG #2,
C-2
Quarterly EAS Newspaper and Radio Advisories
3/5/2018
Miscellaneous
EPDG #2,
Quarterly EAS Newspaper and Radio Advisories
9/6/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
C-2
Miscellaneous
EPDG #2,
C-2
Quarterly EAS Newspaper and Radio Advisories
3/27/2019
Miscellaneous
EPDG #2,
C-2
Quarterly EAS Newspaper and Radio Advisories
6/17/2019
Miscellaneous
EPDG #2,
C-6
Annual Fixed Siren Maintenance
7//19/2017
Miscellaneous
EPDG #2,
C-6
Annual Fixed Siren Maintenance
7/25/2018
EPDG #2,
C-6
Annual Fixed Siren Maintenance
EPDG #2,
C-7
Issuance of NOAA/EAS Radio Receivers
EPDG #2,
C-8
Quarterly Update of NOAA/EAS Radio Receiver Recipient
Data Base
Miscellaneous
EPDG #2,
C-8
Quarterly Review/Update of NOAA/EAS Radio Receiver
Recipient Data Base
3/28/2019
Miscellaneous
EPDG #2,
C-8
Quarterly Review/Update of NOAA/EAS Radio Receiver
Recipient Data Base
9/27/2018
Miscellaneous
EPDG #2,
C-8
Quarterly Review/Update of NOAA/EAS Radio Receiver
Recipient Data Base
3/22/2018
Miscellaneous
EPDG #2,
C-8
Quarterly Review/Update of NOAA/EAS Radio Receiver
Recipient Data Base
2/20/2017
Procedures
5.7.27
Alert and Notification System, Revisions 19 & 20
2/5/2018
Procedures
5.7.27.1
False Activation of the Alert and Notification System,
Revision 9
2/5/2018
Procedures
5.7.27.2
NOAA/EAS Radio Malfunction, Revisions 10 & 11
2/12/17
Corrective Action
Documents
CR-CNS-
2017-06338, 2017-06676, 2018-00536, 2018-01047, 2018-
01119, 2018-02836, 2018-03795, 2018-03810, 2018-04574,
2018-08060, 2018-08524, 2018-08663, 2019-01594, 2019-
2750
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
8/1/2017
Miscellaneous
EPDG #2,
Bi-Monthly ERO Call-In Test
8/22/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
E-3
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
10/26/2017
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
2/18/2017
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
2/25/2018
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
4/26/2018
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
6/20/18
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
11/27/2018
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
2/10/2018
Miscellaneous
EPDG #2,
E-3
Bi-Monthly ERO Call-In Test
3/1/2019
EPDG #2,
E-3
Quarterly ERO Call-In Test
EPDG #2,
E-4
Weekly Pager Test
Procedures
5.7.6
Notification, Revision 74
7/18/2018
Work Orders
WT-2018-0024-
2
Corrective Action
Documents
CR-CNS-
2017-04238, 2017-04422, 2017-04466, 2017-04696, 2017-
04812, 2017-04854, 2017-05001, 2017-06271, 2018-00524,
2018-00534, 2018-02306, 2018-03069, 2018-03075, 2018-
03080, 2018-03100, 2018-03157, 2018-03445, 2018-03810,
2018-03876, 2018-04581, 2018-04582, 2018-04628, 2018-
04671, 2018-04705, 2018-04859, 2018-05600, 2018-06852,
2018-07340, 2018-08150, 2018-08615, 2018-08638, 2018-
08647, 2018-08657, 2018-08663, 2019-00171, 2019-01118,
2019-01387, 2019-01467, 2019-02739, 2019-02756, 2019-
2791, 2019-02842, 2019-02875
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Cooper Nuclear Station Emergency Plan
71, 72, 73
Miscellaneous
After-Action Report: December 29, 2018, NOUE on HU3.1
1/8/2019
Miscellaneous
After-Action Report: March 15, 2019, NOUE on HU1.5 River
Level
4/15/2019
Miscellaneous
Media Communication Letter
2/22/2017
Miscellaneous
Evaluation Report for the July 31, 2018, Biennial NRC-
Graded Exercise Summary Report
8/10/2018
Miscellaneous
Evaluation Report for the August and September 2018 Mini-
Drills
9/21/2018
Miscellaneous
Evaluation Report for the September 12, 2018, Medical Drill
9/26/2018
Miscellaneous
Evaluation Report for the September 13, 2018, Qualification
Drill
10/1/2018
Miscellaneous
Evaluation Report for the December 26, 2018, Radiological
Protection Drill
2/26/2018
Miscellaneous
Evaluation Report for the December 18, 2018, Full Team
Drill
2/26/2018
Miscellaneous
Evaluation Report for the February 26, 2019, Full Team Drill
3/12/2019
Miscellaneous
Evaluation Report for the May 14, 2019, Full Team Drill
5/21/2019
Miscellaneous
Evaluation Report for the January 30, 2018, Full Team Drill,
Radiological Monitoring and Protection Drill
2/14/2018
Miscellaneous
Evaluation Report for the February and March 2018 Mini-
Drills Critique
6/15/2018
Miscellaneous
2016-0183
2017 Emergency Preparedness Pre-NRC Focused Self-
Assessment Report
2/10/2017
Miscellaneous
2017-048
Emergency Preparedness Regulatory Review: Training
Qualification Documents, Courses ERO0010105Q and
ERO0010105/CT66103
8/24/2017
Miscellaneous
2017-054
Emergency Preparedness Regulatory Review: CNS
Emergency Plan Revision 70
8/24/2017
Miscellaneous
2017-08
Emergency Preparedness Regulatory Review: Procedure
5.7.6, Notification, Revision 73
2/14/2017
Miscellaneous
2017-084
Emergency Preparedness Regulatory Review: Commercial
Change CC-5229779, MET Alarm Remediation
1/3/2018
Miscellaneous
2018-077
Emergency Preparedness Regulatory Review: Procedure
11/11/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
8.11.1 Effects Program, Revision 21
Miscellaneous
2018-086
Emergency Preparedness Regulatory Review: Procedure
5.7.20, Protective Action Recommendations, Revision 31
2/10/2018
Miscellaneous
2018-088
Emergency Preparedness Regulatory Review: Training
Qualification Document 0675, ERO Designated
Spokesperson, Revision 4
3/4/2019
Miscellaneous
2019-003
Emergency Preparedness Regulatory Review: Procedure
5.7.25, Recovery Operations, Revision 23
1/21/2019
Miscellaneous
2019-011
Emergency Preparedness Regulatory Review: Procedure
5.7.10, Personnel Assembly and Accountability, Revision 42
2/22/2019
Miscellaneous
2019-023
Emergency Preparedness Regulatory Review: Position
Instruction Manual EOF17, Field Team Driver, Revision 0
4/16/2019
Miscellaneous
EPDG #2 E-2
Monthly and Post-Drill Emergency Response
Facility Walkdowns and Testing of Facility Equipment
6/28/2018
Miscellaneous
EPDG #2,
B-1
Monthly State Notification Telephone System Testing
2/5/2019
Miscellaneous
EPDG #2,
B-1
Monthly State Notification Telephone System Testing
6/5/2018
Miscellaneous
EPDG #2,
B-1
Monthly State Notification Telephone System Testing
11/6/2018
Miscellaneous
EPDG #2,
B-1
Monthly State Notification Telephone System Testing
2/5/2017
Miscellaneous
EPDG #2,
B-3
Monthly Testing of Cell Phones and Headsets
2/18/2017
Miscellaneous
EPDG #2,
B-3
Monthly Testing of Cell Phones and Headsets
11/6/2018
Miscellaneous
EPDG #2,
B-3
Monthly Testing of Cell Phones and Headsets
6/27/2018
Miscellaneous
EPDG #2,
B-3
Monthly Testing of Cell Phones and Headsets
2/19/2019
Miscellaneous
EPDG #2,
B-4
Monthly Testing of Alternate Intercom
2/19/2019
Miscellaneous
EPDG #2,
B-4
Monthly Testing of Alternate Intercoms
6/27/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
EPDG #2,
B-4
Monthly Testing of Alternate Intercom
11/6/2018
Miscellaneous
EPDG #2,
B-4
Monthly Testing of Alternate Intercom
2/15/2017
Miscellaneous
EPDG #2,
B-5
Monthly Testing 2-Way Radios
2/19/2017
Miscellaneous
EPDG #2,
B-5
Monthly Testing of 2-Way Radios
11/6/2018
Miscellaneous
EPDG #2,
B-5
Monthly Testing of 2-Way Radios
6/27/2018
Miscellaneous
EPDG #2,
B-8
Quarterly Satellite Phone Test and Battery Swap
3/27/2018
Miscellaneous
EPDG #2,
B-8
Quarterly Satellite Phone Test and Battery Swap
3/25/2019
Miscellaneous
EPDG #2,
C-4
Semi-Annual Alert and Notification System Sig and
Evacuation Map Verification
5/31/2018
Miscellaneous
EPDG #2,
C-4
Semi-Annual Alert and Notification System Sig and
Evacuation Map Verification
11/13/18
Miscellaneous
EPDG #2,
E-1
Weekly/Monthly/Semi-Annual Emergency Vehicle
Maintenance
11/20/2018
Miscellaneous
EPDG #2,
E-1
Weekly/Monthly/Semi-Annual Emergency Vehicle
Maintenance
6/29/2018
Miscellaneous
EPDG #2,
E-1
Weekly/Monthly/Semi-Annual Emergency Vehicle
Maintenance
2/20/2017
Miscellaneous
EPDG #2,
E-1
Weekly/Monthly/Semi-Annual Emergency Vehicle
Maintenance
2/28/2019
Miscellaneous
EPDG #2,
E-2
Monthly and Post-Drill Emergency Response Facility
Walkdowns and Testing of Facility Equipment
2/27/2019
Miscellaneous
EPDG #2,
E-2
Monthly and Post-Drill Emergency Response Facility
Walkdowns and Testing of Facility Equipment
2/20/2017
Miscellaneous
EPDG #2,
E-2
Monthly and Post-Drill Emergency Response Facility
Walkdowns and Testing of Facility Equipment
11/6/2018
Miscellaneous
EPDG #2,
F-1
Quarterly Emergency Telephone Directory Revisions
1/31/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
EPDG #2,
F-1
Quarterly Emergency Telephone Directory Revisions
7/31/2018
Miscellaneous
EPDG #2,
F-1
Quarterly Emergency Telephone Directory Revisions
1/31/2019
Miscellaneous
EPDG #2,
F-1
Quarterly Emergency Telephone Directory Revisions
4/13/2019
Miscellaneous
EPDG #2,
I-1
Monthly EOF Diesel Generator Run
6/27/2018
Miscellaneous
EPDG #2,
I-1
Monthly EOF Diesel Generator Run
11/13/2018
Miscellaneous
EPDG #2,
I-1
Monthly EOF Diesel Generator Run
2/29/2017
Miscellaneous
EPO001-01-01
Lesson Plan: Drill Exercise Controller Training
Miscellaneous
KLD TR-1023
Cooper Nuclear Station 2018 Population Update Analysis
9/22/2018
Miscellaneous
KLD TR-939
Cooper Nuclear Station 2017 Population Update Analysis
9/23/2017
Miscellaneous
LO2016-0183
2017 Emergency Preparedness Pre-NRC Focused Self-
Assessment Report
2/10/2017
Miscellaneous
LO2018-0074
Pre-NRC Evaluated Exercise Assessment
6/21/2018
Miscellaneous
LO2018-0080
2018 Emergency Preparedness 50.54(Q) Focused Self-
Assessment
3/21/2018
Miscellaneous
Notifications
280194, 11567855, 11590153
Miscellaneous
OTH004-04-03
Lesson Plan: Classification, Notification, and PARs
Miscellaneous
OTH004-04-
03/70926
Training Lesson Plan: Classification, Notifications, and
PARs, Revision 0
2/7/2019
Miscellaneous
QAD 2017-0029
QA Audit 17-06, Emergency Preparedness
9/25/2017
Miscellaneous
QAD 2018-0023
QA Audit 18-06, Emergency Preparedness
9/27/2018
Procedures
Evaluation Report for the December 12, 2018, Post-Accident
Sampling Drill
Procedures
Evaluation Report for the May 22, 2018, Team 3B Dress
Rehearsal
6/6/2018
Procedures
5.7.21
Maintaining Emergency Preparedness, Emergency
Exercises, Drills, Tests, and Evaluations, Revision 58
10/26/2018
Procedures
5.7.28
Administration of the Positional Instruction Manuals,
Revision 9
7/5/2016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
5.7COMMUN
Communications, Revisions 29 & 30
1/19/2019
Procedures
EPDG #2,
B-1
Monthly State Notification Telephone System Testing
Procedures
EPDG #2,
B-2
Monthly Testing of FTS-2001 System Telephones
Procedures
EPDG #2,
B-3
Monthly Testing of Cell Phones and Headsets
Procedures
EPDG #2,
B-5
Monthly Testing of Two-Way Radios
Procedures
EPDG #2,
C-2
Quarterly EAS Newspaper and Radio Advisories
Procedures
EPDG #2,
C-3
Semi-Annual Dissemination of Emergency Public
Information/Transient Population Information
Procedures
EPDG #2,
C-4
Semi-Annual Alert and Notification System Sign and
Evacuation Map Verification
Procedures
EPDG #2,
D-1
Annual Nemaha County Hospital Training
Procedures
EPDG #2,
D-2
Annual Emergency Plan Training for Law Enforcement
Agencies
Procedures
EPDG #2,
D-3
Annual Auburn Rescue Squad and Midwest Medical
Transport Training
Procedures
EPDG #2,
D-4
Annual Volunteer Fire Department Training
Procedures
EPDG #2,
D-5
Annual News Media Orientation/Training
Procedures
EPDG #2,
D-6
Annual Emergency Plan Training for Local Emergency
Management Agencies
Procedures
EPDG #2,
E-2
Monthly and Post-Drill Emergency Response Facility
Walkdowns and Testing of Facility Equipment
Procedures
EPDG #2,
F-2
Annual EAL Review
Procedures
EPDG #2,
F-3
Maintenance of Emergency Plan Letters of Agreement
Procedures
EPDG #2,
Annual CNS Emergency Plan Review
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
F-7
Procedures
EPDG #2,
H-2
Drill and Exercise Guide, Scenario Development
Procedures
EPDG #2,
I-1
Monthly EOF Diesel Generator Run
Work Orders
WO 21615, 5146472, 5148893, 5166231, 5167152, 5167449,
5169963, 5192375, 5197886, 5255090, 5273942, WT-2017-
0040-041
Corrective Action
Documents
CR-CNS-
2019-02739, 2019-02756, 2019-02779, 2019-02791, 2019-
2805
Miscellaneous
Drill Scenario Guide
5/14/2019
Corrective Action
Documents
CR-CNS-
2018-06530, 2018-06811, 2018-07755, 2018-07999, 2019-
00434, 2019-02361
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-
2019-02870
Miscellaneous
CNS-RP-138
Source Report - Leak Test Results
06/27/2018
Miscellaneous
CNS-RP-138
Source Report - Leak Test Results
2/14/2018
Procedures
Job Coverage
Procedures
9.RADOP.5
Airborne Radioactivity Sampling
Radiation
Surveys
Reactor Water Clean-Up Heat Exchanger Room
11/13/2018
Radiation
Surveys
Reactor Water Clean-Up Heat Exchanger Room
11/14/2018
Radiation
Surveys
Reactor Water Clean-Up Heat Exchanger Room
11/14/2018
Radiation
Surveys
Refuel Floor
2/20/2018
Radiation
Surveys
Waste Collector Tanks
2/21/2019
Radiation
Surveys
Waste Collector Tanks
2/21/2019
Radiation
Residual Heat Removal Heat Exchanger
03/20/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Surveys
Radiation
Surveys
Refuel Floor
03/27/2019
Radiation
Surveys
Residual Heat Removal Heat Exchanger
04/20/2019
Radiation Work
Permits (RWPs)
2018-106
TIP - RP HIGH RISK - Activities
Radiation Work
Permits (RWPs)
2019-100
REACTOR BLD - LOCKED HRA Activities
Radiation Work
Permits (RWPs)
2019-102
HIC Prep / Shipments
Self-Assessments LO 2018-0185
Pre-NRC Assessment for Radiological Hazard Assessment
and Exposure Controls-IP 71124.01 and In-Plant Airborne
Radioactivity Control and Mitigation-IP 71124.03
01/21/2019
Corrective Action
Documents
CR-CNS-
2017-04470, 2017-06407, 2017-07491, 2018-01888, 2018-
05697, 2019-02485
07/24/2017
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-
2019-02877
Miscellaneous
CNS RP-402
SCBA Functionals
03/18/2019
Miscellaneous
CNS RP-402
SCBA Functionals
04/02/2019
Miscellaneous
CNS RP-403
Annual Respirator Inspection
10/12/2017
Miscellaneous
CNS RP-403
Annual Respirator Inspection
05/23/2019
Miscellaneous
CNS RP-411
Plant Service Air, Air Quality Data Sheet
07/30/2018
Miscellaneous
CNS RP-411
Plant Service Air, Air Quality Data Sheet
08/28/2017
Miscellaneous
CNS RP-415
Bauer Air Quality Review
01/22/2019
Miscellaneous
CNS RP-415
Bauer Air Quality Review
03/28/2019
Miscellaneous
GEN002-01-13
(CT#47231)
Respiratory Protection SCBA Refresher
Rev. 01
Miscellaneous
Surveillance
5078037
Control Room Emergency Filter System Flow Test, Charcoal
and HEPA Filter Leak Test,
Filter DP Test, and Charcoal Sample Analysis
05/22/2017
Miscellaneous
Surveillance
SGT B Carbon Sample, Carbon Adsorber and HEPA Filter
05/18/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
5132845
In-Place Leak Test, and Components Leak Test
Procedures
Alpha Monitoring
Rev. 4
Procedures
9.RESP.1
Respiratory Protection Program
Rev. 16
Procedures
9.RESP.2
Self-Contained Breathing Apparatus
Rev. 26
Self-Assessments LO 2018-0185
Pre-NRC Assessment for Radiological Hazard Assessment
and Exposure Controls-IP 71124.01 and In-Plant Airborne
Radioactivity Control and Mitigation-IP 71124.03
01/21/2019
71151
Corrective Action
Documents
CR-CNS-
2018-02306, 2018-04184, 2018-04315, 2018-05838, 2018-
05839, 2018-06236, 2018-06546, 2018-06852, 2018-07394,
2019-00111, 2019-00242, 2019-00243, 2019-00352, 2019-
00353, 2019-00623, 2019-01274, 2019-01467, 2019-02752,
2019-02755, 2019-02791, 2019-02841
71151
Miscellaneous
Memorandum, Subject: 2018 Drill and Exercise
Opportunities
6/11/2018
71151
Miscellaneous
Memorandum, Subject: 2019 Drill and Exercise
Opportunities, Revision 3
5/9/2019
71151
Miscellaneous
2Q18 thru 1Q19 PI Verification Package
71151
Miscellaneous
0-EN-LI-114;
9.3
PI Documentation and Data Review Form; Performance
Indicator - Occupational Exposure Effectiveness
10/01/2018
through
03/31/2019
71151
Procedures
5.7.1
Emergency Classification, Revisions 61 & 62
2/6/2019
71151
Procedures
5.7.2
Emergency Director EPIP, Revision 36
2/28/2018
71151
Procedures
5.7.20
Protective Action Recommendations, Revisions 30 & 31
2/13/2018
71151
Procedures
5.7.27
Alert and Notification System, Revisions 19 & 20
2/5/2018
71151
Procedures
5.7.6
Notification, Revision 74
7/18/2018
71151
Procedures
EPDG #.2,
C-1
Semi-Monthly Alert and Notification System Siren Testing
71151
Procedures
EPDG #2,
C-5
Annual Full-Cycle Sounding of the Alert and Notification
System Sirens
71151
Procedures
EPDG #2,
G-1
Emergency Preparedness Performance Indicator Guide
71151
Procedures
EPDG #2,
Drill and Exercise Manual, EP DEP Evaluation Process for
Limited Scope Simulator Drills
71151
Work Orders
WO 255284, 5267418, 5267419, 5273175, 5284182, 5284775,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
285025, 5290430
Corrective Action
Documents
CR-CNS-
2018-07934, 2018-07935, 2018-07996, 2018-08127, 2019-
01754, 2019-01757, 2019-01765, 2019-02773, 2019-03367
Drawings
44D209845
Voltage Regulator
N04
Drawings
44D209846
Static Exciter & Voltage Regulator
N03
Miscellaneous
LBDCR 2007-018
TRM 3.7.1 and Bases River Level Change
06/12/2007
Miscellaneous
LBDCR 2019-007
TRM 3.7.1, River Level Including Bases
4/18/2019
Procedures
5.1FLOOD
Flood
25, 26, 27
Procedures
7.3.30.2
RRMG Set Voltage Regulator Tuning
Work Orders
WO 5057910, 5179313
Corrective Action
Documents
CR-CNS-
2017-03721, 2017-05081, 2018-05904, 2018-05907
Miscellaneous
Containment System Leakage Testing Requirements
1994
Miscellaneous
Engineering
Report 2018-034
RE30 Past Operability of MSIVs and MS Pathway
Procedures
6.PC.207
Torus to Drywell Vacuum Breaker Operation
Work Orders
WO 5054353, 5080846, 5094244, 5096873, 5102515, 5195069