IR 05000298/2020002

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Integrated Inspection Report 05000298/2020002
ML20204B004
Person / Time
Site: Cooper 
Issue date: 07/22/2020
From: David Proulx
NRC/RGN-IV/DRP/RPB-C
To: Dent J
Nebraska Public Power District (NPPD)
References
IR 2020002
Download: ML20204B004 (16)


Text

July 22, 2020

SUBJECT:

COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2020002

Dear Mr. Dent:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On July 9, 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.

No findings or violations of more than minor significance were identified during this inspection.

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, David L. Proulx, Acting 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:

05000298/2020002

Enterprise Identifier: I-2020-002-0006

Licensee:

Nebraska Public Power District

Facility:

Cooper Nuclear Station

Location:

Brownville, NE

Inspection Dates:

April 1, 2020 to June 30, 2020

Inspectors:

A. Siwy, Senior Resident Inspector

M. Stafford, Resident Inspector

R. Alexander, Senior Emergency Preparedness Inspector

Approved By:

David L. Proulx, Acting 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Cooper Nuclear Station began the inspection period at rated thermal power. On May 19, 2020, the unit began a coast down to approximately 98 percent power, due to an administrative limit on reactor recirculation pump speed, prior to a planned rod sequence exchange. On May 29, 2020, the unit lowered power to approximately 70 percent for a control rod sequence exchange. The plant was returned to rated thermal power on May 30, 2020. On May 31, 2020, the unit lowered power to approximately 85 percent for a control rod sequence exchange. The plant was returned to rated thermal power on May 31, 2020. On June 12, 2020, the unit lowered power to approximately 80 percent for a control rod sequence exchange. The plant was returned to rated thermal power on June 13, 2020. On June 27, 2020, the unit lowered power to approximately 70 percent for a control rod sequence exchange. The plant was returned to rated thermal power on June 28, 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. 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; observed risk significant activities; and completed on-site portions of IPs. 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 some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from thunderstorms on May 18, 2020.

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding.

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 on April 15, 2020
(2) Reactor equipment cooling B on April 20, 2020
(3) Residual heat removal service water booster pump D on April 23, 2020
(4) Fire protection system hydrants on June 11, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the 24 Vdc electrical system on June 9, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Reactor building northeast quad, 881 foot and 859 foot elevations, on April 15, 2020
(2) Control building basement on April 23, 2020
(3) Intake structure on May 6, 2020
(4) Control building battery and switchgear Room 1B on May 6, 2020
(5) Control building reactor protection system motor generator set rooms on May 14, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Residual heat removal heat exchanger B Room, 931 foot elevation, on April 20, 2020
(2) Service water pump room on June 1, 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 May 30, 2020.

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

(1) The inspectors observed and evaluated the licensed operator requalification scenario on June 17, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Maintenance Rule a(3) periodic assessment on May 29, 2020
(2) Drywell radiation monitor repeat failures on June 29, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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) High pressure coolant injection maintenance window on April 16, 2020
(2) Residual heat removal A subsystem maintenance window on May 1, 2020
(3) Startup station service transformer maintenance window on June 26, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)

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

(1) Residual heat removal heat exchanger B HELB door on April 20, 2020
(2) FLEX 60 kW diesel generator functionality on May 4, 2020
(3) Control rod drive mechanism temperature indication on May 5, 2020
(4) Reactor building airlock door and secondary containment on May 13, 2020
(5) Service water pipe thinning on June 2, 2020
(6) Low bus voltage indication in control room on June 11, 2020
(7) Core spray minimum flow valve environmental qualification on June 24, 2020
(8) Flood barrier control hose routing on June 26, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Spent fuel pool cooling isolation valves on May 7, 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) High pressure coolant injection maintenance post-work testing on April 23, 2020
(2) Standby gas treatment A post work testing on June 8, 2020
(3) Startup station service transformer maintenance post work testing on June 26, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Division 2 emergency diesel generator monthly surveillance on May 11, 2020
(2) Control rod scram time surveillance on May 30, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX fuel transfer trailer surveillance on May 5, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following Emergency Action Level procedure and Emergency Plan changes, of which summaries were submitted to the NRC per 10 CFR 50.54(q)(5) and 10 CFR 50.4.
  • Emergency Plan Implementing Procedure 5.7.1, Emergency Classifications, Revisions 60, 61, 62, 63, and 64

This evaluation does not constitute NRC approval.

71114.08 - Exercise Evaluation Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensee's preliminary exercise scenario, which was submitted to the NRC on March 5, 2020, for the exercise which was scheduled to occur in early May 2020. The inspectors discussed the preliminary scenario with Mr. L. Mocnik, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on April 6, 2020. The inspectors' review does not constitute NRC approval of the scenario.

Due to events surrounding the COVID-19 public health emergency, the licensee and offsite response organizations postponed the scheduled biennial exercise to a date yet to be determined. However, the scenario has been retained and securely controlled, such that it may be utilized when the exercise is conducted at the later date.

OTHER ACTIVITIES - BASELINE

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

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03)===

(1) October 1, 2019 - March 31, 2020

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) April 1, 2019 - March 31, 2020

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) October 1, 2019 - March 31, 2020

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) October 1, 2019 - March 31, 2020

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) October 1, 2019 - March 31, 2020

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) October 1, 2019 - March 31, 2020

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) October 1, 2019 - March 31, 2020 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
(1) April 1, 2019 - March 31, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) April 1, 2019 - March 31, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in emergency preparedness and training performance that might be indicative of a more significant safety issue.

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:

(1) Inadvertent half scram during alternate rod insertion surveillance on May 13, 2020

71153 - Follow-up of Events and Notices of Enforcement Discretion Reporting (IP Section 03.05)

(1) The inspectors reviewed the circumstances surrounding the retraction of Event Notification Report EN 54425 (https://www.nrc.gov/reading-rm/doc-collections/event-status/event/2019/20191231en.html).

INSPECTION RESULTS

Minor Violation 71114.04 Minor Violation: The inspectors reviewed a licensee-identified violation of 10 CFR 50.54(q)(5)where the licensee failed to transmit to the NRC a summary of changes to the Emergency Plan within 30 days of implementation of the revision. Specifically, in a letter to the NRC on March 3, 2020 (ADAMS Accession No. ML20070K637), the licensee indicated that during a site assessment in December 2019, they identified that four revisions to Cooper Nuclear Station Emergency Plan Implementing Procedure (EPIP) 5.7.1, Emergency Classification, (which as defined in 10 CFR 50.54(q)(1)(ii) is a part of the Emergency Plan) had not been transmitted to the NRC within 30 days of implementation. These revisions included Revision 60 (effective April 12, 2018), Revision 62 (effective February 6, 2018),

Revision 63 (effective April 24, 2019), and the current Revision 64 (effective May 17, 2019).

The licensee entered this issue into its corrective action program for resolution (Condition Report CR-CNS-2020-00546).

Screening: The inspectors determined the performance deficiency was minor. The inspectors review of the violation determined that it was most appropriately characterized as having a minor safety significance based on the review of the examples in the NRC Enforcement Policy, Section 6.9.d, and Inspection Manual Chapter 0611, Appendix E. The licensee entered this minor violation into its corrective action program as Condition Report CR-CNS-2020-02438. This minor violation is being documented to acknowledge and close the violation the licensee identified on the docket in its March 3, 2020, letter to the NRC.

Enforcement:

This failure to comply with 10 CFR 50.54(q)(5) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On June 4, 2020, the inspectors presented the emergency plan revisions and exercise scenario review inspection results to Mr. L. Mocnik, Manager, Emergency Preparedness, and other members of the licensee staff.
  • On July 9, 2020, the inspectors presented the integrated inspection results to Mr. J. Dent, Jr., Vice President and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

CR-CNS-

20-02584

Procedures

5.1WEATHER

Operation During Weather Watches and Warnings

7.0.11

Flood Control Barriers

71111.04

Corrective Action

Documents

CR-CNS-

2018-04481, 2018-04635, 2018-06959, 2020-01804, 2020-

2347, 2020-02348

Drawings

2016, Sheet 1A

Fire Protection Service Bldgs & Yard

2016, Sheet 7

Fire Protection System Site Plan

2031

Flow Diagram Reactor Building - Closed Cooling Water

System

N65

3058

DC One Line Diagram

Fire Plans

CNS-FP-352

Yard Fire Protection

Procedures

15.EE.601

24V and 125V PMIS Battery Weekly Check

15.EE.602

24V and 125V PMIS Battery Quarterly Check

2.2.26

VDC Electrical System

2.2.67B

Reactor Core Isolation Cooling System Instrument Valve

Checklist

2.2A.REC.DIV1

Reactor Equipment Cooling Water System Component

Checklist

2.2A.RHRSW.DIV2 RHR Service Water Booster Pump System Component

Checklist (DIV 2)

2.2A_24DC.DIV1

VDC Power Checklist

2.2A_24DC.DIV2

VDC Power Checklist

71111.05

Fire Plans

CNS-FP-211

Reactor Building Northeast Quadrant Elevations 881-9 and

859-9

CNS-FP-224

Control Building Basement Floor Elevation 882-6

CNS-FP-226

Control Building RPS Room 1B Elevation 903-6

CNS-FP-227

Control Building Corridor, Batt/SWGR Rms. 1A, RPS Rm. 1A

Elevation 903-6

CNS-FP-228

Control Building Battery/SWGR RMS 1B

CNS-FP-256

Intake Structure Elevation 903-6

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

0-BARRIER-MAPS Barrier Maps

71111.06

Miscellaneous

NEDC 09-102

Internal Flooding - HELB, MELB, and Feedwater Line Break

Regulatory Issue

Summary 2001-09

Control of Hazard Barriers

04/02/2001

Procedures

0-BARRIER

Barrier Control Process

71111.11Q Corrective Action

Documents

CR-CNS-

20-02298

Procedures

2.0.3

Conduct of Operations

104

71111.12

Corrective Action

Documents

CR-CNS-

2017-00532, 2017-05821, 2018-01346, 2018-01490, 2020-

00717, 2020-00771, 2020-00872, 2020-00888, 2020-01396,

20-01694, 2020-02009, 2020-02014, 2020-02299

Miscellaneous

CNS Maintenance Rule Periodic Assessment, September

2017 to August 2019

Radiation Monitoring System Health Report

03/2020

DG-PF01

Maintenance Rule Function DG-PF01 Performance Criteria

Basis Document

EE-PF10

Maintenance Rule Function EE-PF10 Performance Criteria

Basis Document

HPCI-PF01

Maintenance Rule Function HPCI-PF01 Performance Criteria

Basis

RMA-F02

Maintenance Rule Function RMA-F02 Performance Criteria

Basis Document

Procedures

3-EN-DC-204

Maintenance Rule Scope and Basis

4C0

3-EN-DC-205

Maintenance Rule Monitoring

7C0

EN-DC-159

System Monitoring Program

6C1

71111.13

Miscellaneous

Protected Equipment List for RHR System Maintenance

Week 2018

Procedures

0-PROTECT-EQP

Protected Equipment Program

Work Orders

WO 5191421, 5209464, 5211245, 5211250, 5287225

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.15

Corrective Action

Documents

CR-CNS-

20-00766, 2020-00769, 2020-01649, 2020-01765, 2020-

01863, 2020-01872, 2020-01883, 2020-01905, 2020-01910,

20-01929, 2020-01933, 2020-02193, 2020-02356, 2020-

2584, 2020-02647

Drawings

CNS-EQ-129,

Sheet 1

Limitorque - Valve Actuator EQ Configuration Detail

CNS-EQ-129,

Sheet 3

Limitorque - Valve Actuator EQ Configuration Detail

Miscellaneous

Master Equipment List

Environmental Qualification Program Basis Document

EQDP.2.129DOR

Environmental Qualification Date Package

NEDC 09-102

Internal Flooding - HELB, MELB, and Feedwater Line Break

Vendor Manual

VM-0986

Limitorque Composite Manual

Procedures

0-CNS-WM-100

Work Order Generation, Screening, and Classification

2.1.12

Control Room Data

139

3.12.1

Environmental Qualification Program Implementation

3.12.2

Environmental Qualification Data Package

3.12.7

Control of Master Equipment List

5.10FLEX

FLEX Support Guidelines

5.10FLEX.21

Shutdown Injection FLEX Operations

5.3GRID

Degraded Grid Voltage

Work Orders

WO 5340245

71111.18

Work Orders

WO 5333835

71111.19

Corrective Action

Documents

CR-CNS-

2019-03873, 2020-01673, 2020-01676, 2020-01679, 2020-

01680

Procedures

2.2.73

Standby Gas Treatment System

6.1SGT.301

SGT Operability Test/Off Gas Flow Monitor Channel

Functional Test IST

6.HPCI.102

HPCI Test Mode Surveillance Operation from ASD-HPCI

Panel

6.HPCI.103

HPCI IST and 92 Day Test Mode

7.0.14.1

Vibration Monitoring Program

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

7.3.14

Thermal Examination of Plant Components

7.3.41

Examination, Repair, and High Pot Testing of Non-

Segregated Buses and Associated Equipment

Work Orders

WO 207766, 5209747, 5211624, 5211625, 5231686, 5243745,

270031, 5315539, 5335313, 5336157, 5345116

71111.22

Procedures

10.9

Control Rod Scram Time Evaluation

5.10FLEX.31

FLEX Equipment Refueling Operations

5.3ALT-

STRATEGY

Alternate Core Cooling Mitigating Strategies

6.2DG.101

Diesel Generator 31 day Operability Test (IST) (DIV 2)

Work Orders

WO 5313763

71114.04

Corrective Action

Documents

CR-CNS-

20-00546

Corrective Action

Documents

Resulting from

Inspection

CR-CNS-

20-02438

Miscellaneous

50.54(q)

Evaluation No.

2018-64

Evaluation for EPIP 5.7.1, Rev 61

09/20/2018

50.54(q)

Evaluation No.

2019-09

Evaluation for CNS Emergency Plan Rev 73 (related to EPIP

5.7.1, Rev 63)

06/24/2019

50.54(q)

Evaluation No.

20-12

Evaluation for CNS Emergency Plan, Rev 75

03/13/2020

50.54(q) Screen

No. 2018-26

Screen for EPIP 5.7.1, Rev 60

03/21/2018

50.54(q) Screen

No. 2018-64

Screen for EPIP 5.7.1, Rev 61

09/18/2018

50.54(q) Screen

No. 2019-02

Screen for EPIP 5.7.1, Rev 62

01/16/2019

50.54(q) Screen

No. 2019-033

Screen for EPIP 5.7.1, Rev 64

05/09/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

50.54(q) Screen

No. 2019-10

Screen for EPIP 5.7.1, Rev 63

2/21/2019

50.54(q) Screen

No. 2019-87

Screen for CNS Emergency Plan, Rev 75

11/15/2019

50.54(q) Screen

No. 2020-12

Screen for CNS Emergency Plan, Rev 75

03/11/2020

Procedures

Administrative

Procedure 0.29.4

Other Regulatory Reviews

30, 31

71151

Miscellaneous

Operator Logs October 1, 2019, to March 31, 2020

Procedures

0-EN-LI-114

Regulatory Performance Indicator Process

17C0

71152

Corrective Action

Documents

CR-CNS-

20-01490, 2020-01494, 2020-01502, 2020-01524

Procedures

0-EN-HU-102

Human Performance Traps and Tools

13C5

6.1ARI.701

ARI/ATWS/RPT Low-Low and PCIS Low-Low-Low Reactor

Water Level Channel Functional Test

13, 14

71153

Corrective Action

Documents

CR-CNS-

2019-06278, 2019-06380

Engineering

Changes

EC 15-013

Classification of Design and Licensing Bases for Auxiliary

Steam Line Breaks Outside of Secondary Containment

Engineering

Evaluations

EE 08-008

Determination of SEB Door Applicability

Miscellaneous

NEDC 19-009

Operability Calculation for Auxiliary Steam Line Break in

Critical Switchgear Room

0