IR 05000298/2020001

Integrated Inspection Report 05000298/2020001

ML20126G358
Person / Time
Site:	Cooper
Issue date:	05/06/2020
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2020001
Download: ML20126G358 (14)

Text

May 6, 2020

SUBJECT:

COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2020001

Dear Mr. Dent:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On April 16, 2020, the NRC inspectors discussed the results of this inspection with you 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 of the Enforcement Policy.

If you contest the violation or the 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jason W. Kozal, Chief Reactor Projects Branch C Division of Reactor Projects

Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number:

05000298

License Number:

DPR-46

Report Number:

05000298/2020001

Licensee:

Nebraska Public Power District

Facility:

Cooper Nuclear Station

Location:

Brownville, NE

Inspection Dates:

January 1, 2020, to March 31, 2020

Inspectors:

P. Elkmann, Senior Emergency Preparedness Inspector

A. Siwy, Senior Resident Inspector

M. Stafford, Resident Inspector

P. Vossmar, Senior Project Engineer

Approved By:

Jason W. Kozal, Chief

Reactor Projects Branch C

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an 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.

List of Findings and Violations

Failure to Perform Procedural Steps in Sequence during Surveillance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2020001-01 Open/Closed

[H.8] -

Procedure Adherence 71111.13 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Cooper Nuclear Station Technical Specification 5.4.1.a, for the licensees failure to implement Procedure 6.2HPCI.701, High Pressure Coolant Injection (HPCI) Steam Line High Flow Channel Functional Test (Division 2), Revision 9. Specifically, the licensee failed to perform procedural steps in Procedure 6.2HPCI.701 in sequence. As a result, the high pressure coolant injection system steam supply outboard isolation valve closed, which resulted in the unplanned unavailability of the high pressure coolant injection system and a change in online risk from Green to

Yellow.

Additional Tracking Items

None.

PLANT STATUS

Cooper Nuclear Station began the inspection period at rated thermal power. On February 29, 2020, the unit lowered power to approximately 68 percent for a control rod sequence exchange. The plant was returned to rated thermal power on March 1, 2020. On March 6, 2020, the unit lowered power to approximately 68 percent for a control rod sequence exchange. The plant was returned to rated thermal power on March 7, 2020. On March 28, 2020, the unit lowered power to approximately 60 percent for repairs to a main turbine governor valve. The plant was returned to rated thermal power on March 29, 2020 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. From January 1 - March 19, 2020, 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk-significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Residual heat removal A on February 14, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Radwaste building, 918 foot elevation, on January 30, 2020

(2) Reactor building northwest quad, 881 foot and 859 foot elevations, on January 31, 2020

(3) Reactor building southeast quad, 881 foot and 859 foot elevations, on March 17, 2020

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on February 14, 2020.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Reactor equipment cooling A heat exchanger on February 14, 2020

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)

(1) The inspectors observed and evaluated licensed operator performance in the control room during downpower and rod pattern adjustment on February 29, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator requalification scenario on January 29, 2020.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Reactor core isolation cooling maintenance window on January 9, 2020

(2) Unplanned Yellow online risk during high pressure coolant injection maintenance window on January 14, 2020

(3) Reactor equipment cooling maintenance window and control of service water flow on January 30, 2020

(4) Emergency diesel generator 1 maintenance window on February 6, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Service water pump room heating, ventilating, and air conditioning unit not cooling properly on February 21, 2020

(2) Containment high radiation monitors on March 5, 2020

(3) Thermal limit computer failure on March 6, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Service water pump A repack on February 2, 2020

(2) Reactor equipment cooling pump B breaker maintenance on February 27, 2020

(3) Southeast quad fan coil unit maintenance on March 27, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Emergency diesel generator 1 surveillance due to unplanned technical specification entry on February 20, 2020

(2) Main turbine stop valve testing on February 29, 2020

(3) Division 2 reactor protection system response time on March 11, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Residual heat removal A inservice test on February 26, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated Cooper Nuclear Station Emergency Plan, Revision 71.

This evaluation does not constitute NRC approval of the licensee's changes.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Technical Support Center and Emergency Operating Facility watchbill scenario on January 7, 2020

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Emergency preparedness drill on February 25,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) January 1, 2019 - December 31, 2019

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) January 1, 2019 - December 31,

INSPECTION RESULTS

Failure to Perform Procedural Steps in Sequence during Surveillance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000298/2020001-01 Open/Closed

[H.8] -

Procedure Adherence 71111.13 The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Cooper Nuclear Station Technical Specification 5.4.1.a, for the licensees failure to implement Procedure 6.2HPCI.701, High Pressure Coolant Injection (HPCI) Steam Line High Flow Channel Functional Test (Division 2), Revision 9. Specifically, the licensee failed to perform procedural steps in Procedure 6.2HPCI.701 in sequence. As a result, the high pressure coolant injection system steam supply outboard isolation valve closed, which resulted in the unplanned unavailability of the high pressure coolant injection system and a change in online risk from Green to Yellow.

Description:

On January 14, 2020, the licensee was performing a functional test of the high pressure coolant injection (HPCI) steam line high flow channel. Procedure 6.2HPCI.701 detailed the steps required to open the supply breaker to the HPCI steam supply outboard isolation valve (HPCI-MOV-MO16). The supply breaker was opened prior to testing the logic in order to prevent closure of valve HPCI-MOV-MO16 during the test. The HPCI system was available and the augmented off-gas system was in service while the supply breaker was open. Procedure 6.2HPCI.701 detailed the steps to close the supply breaker after the isolation signal was removed; however, the supply breaker for valve HPCI-MOV-MO16 was manually closed while the isolation signal was still present.

Procedure 0-EN-HU-106, Procedure and Work Instruction Use and Adherence, Revision 3C2, required that a document lead be established when multiple copies of a procedure are used, or the work is performed in multiple locations. The document lead was required to maintain the designated controlled document and direct the performance of the procedure by giving direction directly to the performer. The document lead and the concurrent verifier were in direct communication and the field performer was receiving direction from the document lead via the concurrent verifier. The field performer closed the breaker because they thought they were given that direction by the document lead. The document lead did not give direction to close the breaker. The closure of the breaker led to the closure of valve HPCI-MOV-MO16 and an alarm signal in the control room, which alerted operators of the inadvertent closure. The breakdown in procedure use and adherence occurred, in part, due to a lack of formal three-way communication. Failure to follow Procedure 0-EN-HU-106 led to the failure to follow Procedure 6.2HPCI.701.

Corrective Actions: The licensee restored the system by opening the HPCI steam supply outboard isolation valve and returning the system to its normal operating configuration.

Corrective Action References: Condition Report CR-CNS-2020-00181

Performance Assessment:

Performance Deficiency: The licensees failure to implement Procedure 6.2HPCI.701 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in unplanned unavailability of the HPCI system, which resulted in a change in online risk from Green to Yellow.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the finding in accordance with the NRC Inspection Manual Chapter (IMC) 0609, 4, "Initial Characterization of Findings," issued October 7, 2016, for Mitigating Systems, and determined the finding to be of very low safety significance (Green) because it did not maintain operability, did not represent a loss of a probabilistic risk assessment system or function for greater than its technical specification allowed outage time or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not result in the loss of a risk-significant nontechnical specification train.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the communication between the control room and the operators in the field did not meet the requirements for place-keeping and multiple copy/multiple location as specified in Procedure 0-EN-HU-106, Procedure and Work Instruction Use and Adherence.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 8.b.2.j, states, in part, that implementing procedures are required for each surveillance test, inspection, or calibration listed in the technical specifications for emergency core cooling system tests. The licensee established Procedure 6.2HPCI.701, High Pressure Coolant Injection (HPCI) Steam Line High Flow Channel Functional Test (Division 2), Revision 9, to perform surveillance testing of the HPCI steam line high flow channel during power operations as required by technical specifications. Procedure 6.2HPCI.701 provides the following steps:

4.29 Operator DEPRESS 93-23A-S18B, AUTO ISOL SIGNAL, RESET button (Panel 9-3)

4.31 IF Breaker EE-STR-125, HPCI-MO-16 STEAM SUPPLY OUTBD ISOLATION, opened, THEN Operator CLOSE breaker.

Contrary to the above, on January 14, 2020, the licensee failed to implement Procedure 6.2HPCI.701. Specifically, the licensee failed to perform step 4.29 prior to step 4.31.

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 January 9, 2020, the inspectors presented the in-office emergency plan change review inspection results to Mr. L. Mocnik, Emergency Preparedness Manager, and other members of the licensee staff.

On April 16, 2020, the inspectors presented the integrated inspection results to Mr. J. Dent, Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Miscellaneous

Cooper Nuclear Station Fifth Ten-Year Interval Inservice

Inspection Program and 3rd Ten-Year Interval

Containment Inservice Inspection Program

Procedures

2.2A.RHR.DIV1

Residual Heat Removal System Component Checklist

7.2.34.1

Snubber Examination

7.2.57

ASME Category F-A Component Supports Examination and

Adjustments

EN-DC-333

Dynamic Restrain (Snubber) Inspection Program

3C0

71111.05

Fire Plans

CNS-FP-212

Reactor Building Southeast Quadrant Elevations 881-9 and

859-9

AC/06

CNS-FP-213

Reactor Building Northwest Quadrant Elevations 881-9 and

859-9"

AC/06

CNS-FP-233

Office Building Elevation 918

AB/10

CNS-FP-260

Radwaste Building Second Floor Elevation 918

AC/08

CNS-FP-260

Radwaste Building Second Floor Elevation 918

AC/08

Miscellaneous

Fire Drill Report

2/20/2019

Fire Drill Report

2/14/2020

TPP 0225

Structural Fire Response

Procedures

0-BARRIER-

MAPS

Barrier Maps

71111.07A

Procedures

7.2.42.1

Heat Exchanger Maintenance

7.2.42.3

Heat Exchanger Tube Plugging

Work Orders

WO 270046

71111.11Q Corrective Action

Documents

CR-CNS-

20-01003, 2020-01008

Drawings

2002, Sheets 1

and 2

Main, Exhaust & Auxiliary Steam Systems

2, 48

Miscellaneous

Training Material INPO052-00-23, 2019 ECPE Scenario #2

Operations

Instruction #8

Guideline for Successful Transient Mitigation

Training Material

SKL012-06-01

OPS Simulator Introduction

231

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

0-EN-TQ-210

Conduct of Simulator Training

9C3

0-EN-TQ-217

Examination Security

6C1

2.3_9-5-2

Panel 9-5-Annunciator 9-5-2

71111.13

Corrective Action

Documents

CR-CNS-

20-00495, 2020-00592, 2020-00602, 2020-00605, 2020-

00619, 2020-00622

Miscellaneous

RCIC Yellow Risk Protected Equipment List

01/07/2020

REC Protected Equipment List

01/26/2020

OD/OE 19-SW Flow Comp Measure

2/12/2019

DG A Protected Equipment List

2/02/2020

Procedures

0-PROTECT-EQP Protected Equipment Program

2.2.65.1

REC Operations

71111.15

Corrective Action

Documents

CR-CNS-

20-00612, 2020-00717, 2020-01011, 2020-01013, 2020-

01014

Drawings

451202127

Interconnection Diagram High Range Containment Monitor

451213208

Detector Cable Assembly

Miscellaneous

NEDC 91-221

Service Water Pump Room Temperatures After Loss of

Cooling

Procedures

2.4COMP

Computer Malfunction

71111.19

Corrective Action

Documents

CR-CNS-

2019-06318

Procedures

6.1SW.101

Service Water Surveillance Operation (Div 1)(IST)

6.2HV.601

Air Flow Test of Fan Coil Unit FC-R-1E

7.0.5

CNS Post-Maintenance Testing

7.3.14

Thermal Examination of Plant Components

Work Orders

WO 5184377, 5233394, 5303614, 5316979, 5318836

71111.22

Corrective Action

Documents

CR-CNS-

20-00181

Procedures

6.1RHR.101

RHR Test Mode Surveillance Operation (IST)(Div 1)

6.2RPS.311

RPS Instrument Channel Response Time (Run Mode) (Div 2)

6.RPS.302

Main Turbine Stop Valve Closure and Steam Valve Functional

Test

Work Orders

WO 233402, 5237212, 5338497

71114.06

Corrective Action

CR-CNS-

20-00978, 2020-00989, 2020-00996

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Miscellaneous

Letter "Feb. 25, 2020 Full Team Dress Rehearsal Exercise"

03/16/2020

Presentation Cooper Nuclear Station 2020 Dress Rehearsal

03/09/2020

February 2020 Dress Rehearsal Exercise Scenario

Watchbill Scenario 2020-01

01/02/2020

Procedures

5.7.2

Emergency Director EPIP

5.7.6

Notification

71151

Miscellaneous

CNS Narrative Logs from January 1, 2019, through December

31, 2019