IR 05000298/2020004
| ML21034A592 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/03/2021 |
| From: | Jason Kozal NRC/RGN-IV/DRP |
| To: | Dent J Nebraska Public Power District (NPPD) |
| References | |
| IR 2020004 | |
| Download: ML21034A592 (25) | |
Text
February 3, 2021
SUBJECT:
COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2020004
Dear Mr. Dent:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On January 22, 2021, 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, Jason W. Digitally signed by Jason W. Kozal Kozal Date: 2021.02.03 15:03:52 -06'00'
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: 05000298/2020004 Enterprise Identifier: I-2020-004-0006 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, NE Inspection Dates: October 1, 2020 to December 31, 2020 Inspectors: R. Alexander, Senior Emergency Preparedness Inspect B. Baca, Health Physicist J. Drake, Senior Reactor Inspector J. O'Donnell, Senior Health Physicist E. Simpson, Health Physicist A. Siwy, Senior Resident Inspector M. Stafford, Resident Inspector Approved By: Jason W. Kozal, Chief Reactor Projects Branch C Division of Reactor Projects Enclosure
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 in a scheduled refueling outage. The station performed a reactor startup on October 26, 2020, ending the outage. The unit reached rated thermal power on October 29, 2020. On October 30, 2020, the operators lowered power to 70 percent for a control rod sequence exchange. The unit reached rated thermal power on October 31, 2020. The unit was manually scrammed on November 1, 2020, due to an electro-hydraulic fluid leak on the main turbine generator. The unit reached rated thermal power on November 4, 2020. On November 4, 2020, the operators lowered power to 70 percent for a control rod sequence exchange. The unit reached rated thermal power on November 5, 2020.
On November 6, 2020, the operators lowered power to 72 percent for a control rod sequence exchange. The unit reached rated thermal power on November 7, 2020. On December 9, 2020, the operators lowered power to 70 percent for a control rod sequence exchange and to replace the 'A' condensate pump motor due to an oil leak on the motor bearing seal. The unit reached rated thermal power on December 11, 2020. On December 12, 2020, the operators lowered power to 70 percent for a control rod sequence exchange. The unit reached rated thermal power on December 13, 2020. The unit was at 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 Disease 2019 (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; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; 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 portions 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
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 water cleanup system on October 1, 2020
- (2) Fuel pool cooling system A on October 10, 2020
- (3) Division 1 service water system on November 9, 2020
- (4) Core spray A on November 13, 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) Reactor water cleanup valve, pump, and heat exchanger rooms on October 1, 2020
- (2) Fuel pool cooling heat exchanger and pump rooms on October 10, 2020
- (3) Reactor equipment cooling area, reactor building, 931 foot elevation, on November 19, 2020
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 5, 2020 to October 9, 2020:
03.01.a - Nondestructive Examination and Welding Activities.
The inspectors evaluated non-destructive examination activities by reviewing the following records:
- (1) Ultrasonic Examinations a) Reactor Vessel Shell, Weld VLC-BB-2, Longitudinal. This review involved a previous indication that was analytically evaluated and accepted.
b) Reactor Vessel Shell, Weld VLB-BA-3, Longitudinal. This review involved a previous indication that was analytically evaluated and accepted.
c) Reactor Vessel Shell, Weld VLA-BA-3, Longitudinal. This review involved a previous indication that was analytically evaluated and accepted.
d) Reactor Vessel Shell, Weld VCB-BC-5, Vessel to Flange. This review involved a previous indication that was analytically evaluated and accepted.
e) Reactor Recirculation, RRP-1 B-B, Recirculation Pump Studs.
f) Reactor Recirculation, RAS-BJ-11, Elbow to Elbow.
g) Residual Heat Removal, RHA-BJ-6, Valve to Elbow.
- (2) VT-1 Examinations a) RF, Constant Support RFH-71. Supplemental inspection due to rejectable conditions. This review involved a previous indication that was analytically evaluated and accepted.
b) Core Spray, Weld CS-A21@10-P8b, Shell to pipe. This review involved a previous indication that was analytically evaluated and accepted.
- (3) VT-3 Examinations a) Suppression Chamber Bay 13 and 14 Saddle Support , SC-SAD-S13. This review involved a previous indication that was analytically evaluated and accepted.
b) Suppression Chamber Bay 12 and 13 Saddle Support, SC-SAD-S12. This review involved a previous indication that was analytically evaluated and accepted.
c) Primary Containment, DWI-MB, Drywell Interior Moisture Barrier. This review involved a previous indication that was analytically evaluated and accepted.
d) Reactor Feedwater, Constant Support, RFH-71. This review involved a previous indication that was analytically evaluated and accepted.
- (4) Magnetic Particle Examinations a) Core Spray, CSB-CC-57, Elbow Lug
- (5) Dye Penetrant Examinations a) Core Spray, CS-RV-11RV, Weld 1, Socket weld pipe to valve b) Core Spray, CS-RV-11RV, Weld 3, Socket weld pipe to valve c) Core Spray, CS-RV-11RV, Weld 2, Socket weld pipe to flange d) Core Spray, CS-RV-11RV, Weld 4, Socket weld pipe to flange e) Core Spray, CS-RV-13RV, Weld 1, Socket weld pipe to valve f) Core Spray, CS-RV-13RV, Weld 3, Socket weld pipe to valve g) Core Spray, CS-RV-13RV, Weld 2, Socket weld pipe to flange h) Core Spray, CS-RV-13RV, Weld 4, Socket weld pipe to flange The inspectors evaluated welding activities by reviewing the following records:
- (1) Gas Tungsten Arc Welding a) Weld Checklist 19-101, (W.O. 5283283) on Core Spray System, CS-RV-13RV, Weld 1, Socket weld pipe to valve b) Weld Checklist 19-101, (W.O. 5283283) on Core Spray System, CS-RV-13RV, Weld 3, Socket weld pipe to valve c) Weld Checklist 19-139, (W.O. 5283283) on Core Spray System, CS-RV-13RV, Weld 2, Socket weld pipe to flange d) Weld Checklist 19-278, (W.O. 5282883) Core Spray, CS-RV-13RV, Weld 4, Socket weld pipe to flange e) Weld Checklist 19-094, (W.O. 5283284) on Core Spray System, CS-RV-11RV, Weld 1, Socket weld pipe to valve f) Weld Checklist 19-094, (W.O. 5283284) on Core Spray System, CS-RV-11RV, Weld 3, Socket weld pipe to valve g) Weld Checklist 19-119, (W.O. 5283284) on Core Spray System, CS-RV-13RV, Weld 2, Socket weld pipe to flange h) Weld Checklist 19-120, (W.O. 5282884) Core Spray, CS-RV-13RV, Weld 4, Socket weld pipe to flange The inspector evaluated a sample of 43 condition reports associated with inservice inspection activities. The inspector did not identify any findings or violations of more than minor significance.
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 reactor startup on October 26, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification scenario on December 4, 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) Startup station service transformer on November 6, 2020
- (2) Service water system on November 18, 2020
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Emergency diesel generator lube oil heat exchanger on December 7, 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) Work controls for Division 1 work window and lowered reactor pressure vessel inventory to start refueling outage on October 2, 2020
- (2) Yellow risk window while shutdown cooling was unavailable during reactor pressure vessel pressure test on October 20, 2020
- (3) Yellow risk window during Division 2 undervoltage relay testing on November 16, 2020
- (4) Increased aggregate risk window during multiple maintenance activities on December 10, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Residual heat removal valves found un-sealed on December 3, 2020
- (2) Post-work inservice test not performed on control rod drive check valves 25 and 26 on December 16, 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) Main steam isolation valve limit switch wiring assembly change on November 17, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Source range monitor D replacement on October 3, 2020
- (2) Core spray A injection valve maintenance on October 8, 2020
- (3) Core spray pump A discharge relief valve maintenance on October 9, 2020
- (4) Emergency service water return from control room air conditioner maintenance on October 9, 2020
- (5) Outboard main steam isolation valve actuator replacement on October 20, 2020
- (6) Emergency diesel generator 1 governor valve replacement on October 23, 2020
- (7) Control rod scram timing for replaced control rods on November 19, 2020
- (8) Control room emergency filtration system damper maintenance on November 27, 2020
- (9) High pressure coolant injection inboard steam isolation valve repairs on December 18, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Refueling Outage 31 activities from October 1, 2020, to October 26, 2020. The inspectors completed inspection procedure Sections 03.01c, 03.01d, and 03.01e.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) High-pressure coolant injection isolation valve local leak-rate test on October 20, 2020
- (2) Reactor core isolation cooling beginning of cycle test on November 24, 2020
- (3) High pressure coolant injection beginning of cycle test on November 30, 2020
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
- (1) Emergency preparedness Technical Support Center training exercise on December 2, 2020
- (2) Emergency preparedness training evolution on December 8,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Observed licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
- (2) Observed workers exiting the drywell during a refueling outage
- (3) Observed workers exiting the control rod drive mechanism (CRDM) bullpen during a refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities:
- (1) CRDM removal and replacement activities under technical specification high radiation area (LHRA) Radiation Work Permits 2020-506, "Undervessel CRDMs Changeout,"
Revision 0, and 2020-507, "CRDM Work Excluding Changeout," Revision 0
- (2) Local power range monitor (LPRM) exchange activities under technical specification high radiation area (LHRA) Radiation Work Permit 2020-529, "Under Vessel Miscellaneous Activities," Revision 0
- (3) Diving operations to clean and inspect the torus under technical specification high radiation area (LHRA) Radiation Work Permit 2020-509, "Torus Desludge Diving - For Divers Only," Revision 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Reactor water clean up (RWCU) phase separator pump room (reactor building 931 foot elevation)
- (2) Fuel pool cooling heat exchanger room (reactor building 958 foot elevation)
- (3) Spent resin tank room (radwaste basement)
- (4) Travelling in-core probe (TIP) room (reactor building 903 foot elevation)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors evaluated the licensees communication of as low as is reasonably achievable (ALARA) and radiological work controls for the following work activities:
- (1) Control rod drive mechanism removal and replacement activities under ALARA Package 2020-01, "Control Rod Drive Mechanism Exchange," Revision 0, and its associated radiation work permits and specific work permits
- (2) Diving operations to remove sludge in the torus and inspect/repair the torus liner under ALARA Package 2020-08, "Torus Desludge," Revision 0, and its associated radiation work permits and specific work permits
- (3) High pressure core injection (HPCI) motor operated valve [HPCI MO-15] maintenance and repairs under ALARA Package 2020-15, "Refueling Outage 31 Motor Operated Valve, Air Operated Valve, and Solenoid Operated Valve Team Work," Revision 0, and its associated radiation work permits and specific work permits
- (4) Instrument and component repair and replacement and general under vessel maintenance under ALARA Package 2020-16, "Undervessel," Revision 0, and its associated radiation work permits and specific work permits
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during:
- (1) The inspectors evaluated the implementation of ALARA techniques for work activities during Refueling Outage
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12) ===
- (1) April 1, 2019, through June 30, 2020
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2019, through June 30, 2020
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) April 1, 2019, through June 30, 2020
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) April 1, 2019, through September 30, 2020 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) July 1, 2019, through September 30, 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 human performance issues 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) Emergency station service transformer bus fault corrective action follow-up on December 15, 2020
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the manual reactor scram due to an unisolable leak on the main turbine high pressure fluid system and the licensees response on November 3,
INSPECTION RESULTS
Observation: Semi-Annual Trend 71152 The inspectors reviewed trends in the licensee's corrective action program (CAP) and human performance clock resets and observed that issues associated with human performance have been trending upwards for several years. The trend is not specific to any one work group or type of human performance.
The total number of condition reports (CRs) generated each year peaked in 2011 and has been trending downward since. The decreasing trend in CRs from 2011 is expected for several reasons. Among these reasons are the extensive flooding in the area in 2011 as well as the nuclear industry's modifications to their CAPs in order to reduce the number of nonadverse issues entered into the CAPs.
The licensee categorizes their CRs into various levels to prioritize issues based on significance. Category A are the most significant. Categories B, C, and D are less significant, in decreasing order of significance. Categories other than those four are not required to be corrected via the CAP and are often closed to other processes. The inspectors compiled trends using the total of all four of these categories (Group 1) as well as the total of Categories A, B, and C (Group 2). The inspectors did not compile trends using only categories A and/or B since the CRs in these categories make up a small percentage of the total number of CRs. The number of CRs for both Groups 1 and 2 has decreased from 2011, which is expected since the overall number of CRs decreased.
For Groups 1 and 2, the inspectors separated the number of CRs with trend codes relating to human performance from the rest of the CRs to provide meaningful year-over-year comparisons. The inspectors then divided the human-performance-related CRs in each respective group by the total number of CRs in each respective group. This showed that the percentage of human-performance-related CRs for both groups has increased since 2011.
Many factors can affect these numbers, including consistency of trend code application, changes in the total number of CRs, and changes in the number of CRs not related to human performance. Regardless of the driving forces, human performance issues are accounting for a greater percentage of all issues.
The inspectors identified five different human-performance-related sub-trends in CRs from 2020: clearance order issues, radiological controlled area (RCA) access issues, bumped equipment, mispositioned equipment, and security equipment handling issues. Examples of these sub-trends are given subsequently. These sub-trends and examples are not exhaustive.
Examples of clearance order issues include: divers entered a section of the suppression pool that was not protected by their clearance (Condition Report CR-CNS-2020-04392);maintenance staff performed work without all required clearance tags in place (Condition Report CR-CNS-2020-04924); and operation staff removed an incorrect fuse while hanging a clearance (Condition Report CR-CNS-2020-05313). The breakdown in human performance for each of these issues could have led to individuals either receiving higher unexpected radiological doses or working on pressurized or energized equipment.
Examples of RCA access issues include: chemistry staff entered a high radiological area (HRA) on the wrong radiological worker permit (RWP) (Condition Report CR--CNS--2020-
-00980); maintenance staff entered a locked HRA on the wrong RWP (Condition Report CR-CNS-2020-01677); and radiological protection staff improperly allowed maintenance staff to move an administratively posted locked HRA boundary (Condition Report CR-CNS-2020-04533). The breakdown in human performance for each of these issues either allowed or had the potential to allow workers to enter radiological areas for which they had not been properly authorized.
Examples of bumped equipment issues include: maintenance staff bumped service water pump room halon switch (Condition Report CR-CNS-2020-01363); maintenance staff induced vibration on instrument at instrument rack 25-6 (Condition Report CR-CNS-2020-01490); and radiological protection staff bumped refueling floor seismic sensor (Condition Report CR-CNS-2020-04047). The breakdown in human performance for each of these issues resulted in unexpected control room alarms and an inadvertent half scram of the reactor.
Examples of mispositioned equipment issues include: operations staff inadvertently isolated the high-pressure coolant injection (HPCI) system outboard steam isolation valve (Condition Report CR-CNS-2020-00181); operations staff inadvertently started fire protection pump C (Condition Report CR-CNS-2020-02609); and radiological protection staff inadvertently manipulated the incorrect fuel pool cooling valve (Condition Report CR-CNS-2020-05031).
The breakdown in human performance for each of these issues resulted in running a pump with the discharge valve closed, unexpected lowering of the fuel pool skimmer surge tank water level, and an unplanned unavailability of HPCI with an unplanned increase of online risk.
Examples of security equipment handling issues include: dropped equipment was unattended (Condition Report CR-CNS-2020-02524); unsecured equipment (Condition Report CR-CNS-2020-03001); and improper control of equipment (Condition Report CR-CNS-2020-03328). None of these issues resulted in an event reportable under 10 CFR 73.71.
The licensee has periodically identified and documented negative trends in human performance, typically as a bundle of various human performance issues. The licensee and a corporate functional area manager previously identified two sub-trends listed above:
clearance order issues and mispositioned equipment.
The trends from the human-performance-related CRs show that the percentage of adverse human performance CRs has increased. Sub-trends in human performance issues show that they are not attributed to any one workgroup, nor any one type of human performance. The inspectors continue to review CRs in the CAP and monitor for any trends.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 8, 2020, the inspectors presented the occupational radiation safety inspection results to Mr. K. Dia, General Manager of Plant Operations, and other members of the licensee staff.
- On October 9, 2020, the inspectors presented the inservice inspection results to Mr. J. Dent, Vice President and Chief Nuclear Officer, and other members of the licensee staff.
- On November 19, 2020, the inspectors presented the emergency preparedness-related performance indicator verification inspection results to Mr. B. Chapin, Director of Nuclear Safety Assurance, and other members of the licensee staff.
- On January 22, 2021, the inspectors presented the integrated inspection results to Mr. J. Dent, Vice President and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures 2.1.14 Seasonal Weather Preparations 35
2.2.42 HVAC Intake Structure 20
Work Orders WO 5210368
71111.04 Drawings 2030, Sheet 1 Flow Diagram Fuel Pool Cooling and Clean-up System 36
2030, Sheet 2 Flow Diagram Fuel Pool Cooling and Clean-up System 17
Procedures 2.2.32A Fuel Pool Cooling and Demineralizer System Component 22
Checklist
2.2.66A Reactor Water Cleanup Component Checklist 22
2.2A.CS.DIV1 Core Spray Component Checklist (Div 1) 5
2.2A.SW.DIV1 Service Water System Component Checklist (Div 1) 21
71111.05 Corrective Action CR-CNS- 2020-04718, 2020-05705, 2020-05725
Documents
Fire Plans CNS-FP-218 Reactor Building - Second Floor Elevation 931-6 11
CNS-FP-219 Reactor Building - Third Floor Elevation 958-3 14
Procedures 0-BARRIER- Barrier Maps 11
MAPS
71111.08G Corrective Action CR-CNS- 2016-08766, 2018-05684, 2018-05691, 2018-05713, 2018-
Documents 05716, 2018-05856, 2018-05898, 2018-05908, 2018-05909,
2018-05987, 2018-06090, 2018-06138, 2018-06140, 2018-
250, 2018-06475, 2018-06492, 2018-06564, 2018-06706,
2018-07312, 2018-08417, 2019-00495, 2019-00726, 2019-
00727, 2019-00729, 2019-01402, 2019-01664, 2019-01687,
2019-01694, 2019-01697, 2019-01869, 2019-02249, 2020-
00051, 2020-00906, 2020-01083, 2020-01457, 2020-03385,
20-04136, 2020-04194, 2020-04359, 2020-04417, 2020-
04430, 2020-04457,
Corrective Action CR-CNS- 2020-04658, 2020-04659, 2020-04660, 2020-04661
Documents
Resulting from
Inspection
Miscellaneous EPG-17 Engineering Program Guide Welding Program 2
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedures CNS Assessment Welding & Repair/ Replacement Program Assessment Report 12/08/2011
CNSLO-2011-
0013 - 0029
CNS Operations CNS Technical Program Administration 21 and 22
Manual
Administrative
Procedure 0-
CNS-12
CNS Operations Self-Assessment and Benchmarking Process 20
Manual
Administrative
Procedure 0-
CNS-25
CNS Operations Corrective Action Process 8
Manual
Administrative
Procedure 0-
CNS-LI-102
CNS Operations Materials Degradation Management Program (MDMP) 10
Manual
Administrative
Procedure 0-
CNS-MDMP
CNS Operations ASME Section XI Repair/Replacement and Temporary Code 8
Manual and Non-Code Repair Procedure
Administrative
Procedure 0.30
CNS Operations Work Control Program 96
Manual
Administrative
Procedure 0.40
CNS Operations Engineering Programs Control and Oversight 1
Manual
Engineering
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedure 3-
CNS-DC-329
CNS Operations Welding/Repair-Replacements Program 2 and 6
Manual
Engineering
Procedure 3.38
CNS Operations General Welding Standard for ASME And ANSI Code 7
Manual Applications
Maintenance
Procedure 7.7.3.1
CNS Operations ASME Section XI System Leakage Test of The Class 3 19
Manual Service Water (SW) System Loop B
Surveillance
Procedure
6.2SW.501
GEH-UT.717 Procedure for the Examination of Reactor Pressure Vessel 4
Welds from the Inside Surface with MicroTomo in Accordance
with Appendix VIII
GEH-VT-101 Procedure for VT-1 Examination 8.1
GEH-VT-103 Procedure for VT-3 Examination 12
GEH-VT-204 Procedure for In-Vessel Visual Inspection (IVVI) Of BWR 4 18
RPV Internals
GEH.UT.300 Procedure for Manual Examination of Reactor Vessel 12C1
Assembly Welds in Accordance with PDI
Operations P1-B Welding Procedure Specification 6
Manual
Engineering
Maintenance
Procedure
7.7.10.2
Operations P1-B (CVN) Welding Procedure Specification 5
Manual
Engineering
Maintenance
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedure
7.7.10.3
Operations P1-G Welding Procedure Specification 6
Manual
Engineering
Maintenance
Procedure
7.7.10.4
Operations P8-A Welding Procedure Specification 4
Manual
Engineering
Maintenance
Procedure
7.7.10.80
Operations P1-P8a Welding Procedure Specification 4
Manual
Engineering
Maintenance
Procedure
7.7.10.83
Operations Visual Inspection Procedure for ANSI B31.1 3
Manual
Engineering
Maintenance
Procedure
7.7.50.1
Operations Visual Inspection Procedure for ANSI B31.7 3
Manual
Engineering
Maintenance
Procedure
7.7.50.2
Self-Assessments 2017-0033-001 WELD Program Self-Assessment - March 2017 04/27/2017
Inspection Type Designation Description or Title Revision or
Procedure Date
CNS Assessment Welding & Repair/ Replacement Program Assessment Report 12/08/2011
CNSLO-2011-
0013 - 0029
LO-2019-0201 2020 Inservice Inspection Program Self-Assessment 07/01/2020
71111.11Q Miscellaneous SKL052-52-176 Licensed Operator Requalification Exam Scenario 176 0
Procedures 2.4EX-STM Extraction Steam Abnormal 20
2.4PC Primary Containment Control 21
71111.12 Corrective Action CR-CNS- 2019-06302, 2020-00263, 2020-04054, 2020-04069
Documents
Miscellaneous Maintenance Rule Function SW-F01 Performance Criteria 8
Basis
Maintenance Rule Function SW-F03 Performance Criteria 7
Basis
Procedures 12.1 CNS QC Program Description 29
Work Orders WO 5072900, 5283363, 5314819
71111.13 Corrective Action CR-CNS- 2020-04151, 2020-06225
Documents
Miscellaneous Protected Equipment Postings for: Shutdown Cooling,
Division 1 RHR Relay Maintenance
Procedures 0-PROTECT-EQP Protected Equipment Program 56
0.50.5 Outage Shutdown Safety 42
Work Orders WO 5167518, 5302642
71111.15 Corrective Action CR-CNS- 2020-05279, 2020-06086
Documents
Drawings 2040, Sheet 1 Flow Diagram, Residual Heat Removal System 83
Procedures 2.2A.RHR.DIV1 Residual Heat Removal System Component Checklist 10
71111.18 Corrective Action CR-CNS- 2020-04421
Documents
Procedures 7.3.25 NAMCO EA180 Series Limit Switch Installation and Removal 13
7.3.28 Crimping Tool Calibration and Lug Selection Guide 24
7.3.28.1 Lead Removal/Installation and Lug Installation 32
Work Orders WO 5283004, 5365943
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.19 Corrective Action CR-CNS- 2020-04414, 2020-04621, 2020-04680, 2020-04697, 2020-
Documents 04701, 2020-04791, 2020-04792,2020-04856, 2020-05196,
20-05229, 2020-05237, 2020-05250
Procedures 10.9 Control Rod Scram Time Evaluation 72
14.17.1 DG-1 Annual Calibration 41
14.17.GOV-TUN- DG Dynamic Governor Tuning 0
6.1CS.102 Reference Leg Injection Flow Verification and IST Check 11
Valve Testing (Div 1)
6.1CS.202 CS-MO-12A Operability Test with Reactor Pressure < 450 6
6.2SRM.302 SRM Channel Functional Test (Reactor not in Run with 19
Shorting Link Switches Closed) (Div 2)
6.HV.104 Control Room Emergency Filter System Flow Test, Charcoal 19
and HEPA Filter Leak Test, Filter DP Test, and Charcoal
Sample Analysis
6.SW.102 Service Water System Post-LOCA Flow Verification 52
7.0.5 CNS Post-Maintenance Testing 59
7.2.24.1 MSIV Operator Maintenance and Adjustment 24
7.2.24.2 MSIV Speed Adjustment 4
Work Orders WO 5209799, 5211495, 5254654, 5282126, 5282143, 5282155,
282684, 5282923, 5283005, 5283351, 5283385, 5322550,
5365949
71111.20 Corrective Action CR-CNS- 2020-04440, 2020-04531, 2020-04729, 2020-04873, 2020-
Documents 05031, 2020-05033, 2020-05035, 2020-05353
Miscellaneous Shutdown Safety Contingency Plan RE31-0002 RCIC-CV-14
Procedures 0.50.5 Outage Shutdown Safety 42
13.3 ECCS Strainer/Suppression Pool Cleaning Program 8
2.1.20.2 Cycle Specific Fuel Transfer and Alternate Cooling Guideline 22
2.1.6 Primary Containment Access Preparation and Closeout 19
Activities
2.2.32 Fuel Pool Cooling and Demineralizer System 111
2.4FPC Fuel Pool Cooling Trouble 39
2.4SDC Shutdown Cooling Abnormal 18
Inspection Type Designation Description or Title Revision or
Procedure Date
5.10FLEX.11 Spend Fuel Supply FLEX Operations 4
6.PC.501 Primary Containment Leak Rate Tests 44
EN-MA-118 Foreign Material Exclusion 9
WO 5166166, 5210211, 5282884, 5283389, 5333161
71111.22 Corrective Action CR-CNS- 2020-04529, 2020-04413, 2020-04414, 2020-04415, 2020-
Documents 04857
Procedures 6.HPCI.313 HPCI (< or = 165 PSIG) Beginning of Cycle Test 38
6.PC.511 High Pressure Coolant Injection (HPCI) Local Leak Rate Tests 18
6.RCIC.309 RCIC (< or = 165 PSIG) Beginning of Cycle Test 36
Work Orders WO 5210219, 5210635, 5282470
71114.06 Corrective Action CR-CNS- 2020-06195
Documents
Miscellaneous EP Training Exercise Package 12/12/2020
Procedures 5.7.6 Notification 77
5.7.7 Activation of TSC 41
71124.01 Corrective Action CR-CNS- 2019-03953, 2019-04877, 2019-05214, 2019-06305, 2019-
Documents 06473, 2020-00317, 2020-00980, 2020-01114, 2020-01677,
20-03300, 2020-04392, 2020-04533, 2020-04617
Procedures 7.4.32 Work Over, Near, or in Reactor Vessel, Dryer/Separator 20
Storage Pool, or Spent Fuel Storage Pool
9.EN-RP-100 Radiation Worker Expectations 17
9.EN-RP-101 Access Control for Radiologically Controlled Areas 21
9.EN-RP-108 Radiation Protection Posting and Labeling 17
9.EN-RP-123 Radiological Controls for Highly Radioactive Objects 4
9.EN-RP-151 Radiological Diving 3
9.ENN-RP-102 Radiological Control 3
9.ENN-RP-106-1 Radiation and Contamination Surveys 22
9.NISP-RP-03 Radiological Air Sampling 0
9.RADOP.1 Radiation Protection at CNS 15
Radiation Surveys CNS-1810-0089 Dose Rates and Smears taken on RPV Head Flange 10/08/2018
CNS-2009-0071 CNS-RP-920 Inside of Torus 09/28/2020
CNS-2009-0083 CNS-RP-920 Inside of Torus 09/28/2020
CNS-2010-0106 CNS-RP-108E - Drywell - Under Vessel 10/05/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
CNS-2010-0118 Drywell - Under Vessel Subpile 10/06/2020
CNS-2010-0145 CNS-RP-920 Inside of Torus 10/07/2020
CNS-RP-136 Air Sample - Reactor Building 921' for HPCI-15-MOV Breach 10/07/2020
Self-Assessments LO 2019-0204 NRC PI Occupation Exposure Control Effectiveness 06/05/2020
QAD 2020-0019 QA Audit 20-04, "Radiological Controls" 07/22/2020
71124.02 ALARA Plans 2020-01 Control Rod Drive Mechanisms (CRDMs) 0
20-05 Reactor Disassembly, Refueling, Nuclear Instrumentation 0
Exchanges and Reassembly
20-08 Torus Desludge 0
20-15 Refueling (RE) 31: Motor Operated Valves (MOV), Air 0
Operated Valves (AOV) and Solenoid Operated Valves (SOV)
20-16 Undervessel 0
20-20 RP Support Refueling (RE) 31 0
20-21 Operations Activities during RE-31 Refueling Outage 0
Corrective Action CR-CNS- 2019-03247, 2019-03749, 2019-04536, 2020-00661, 2020-
Documents 01050, 2020-01240, 2020-01640, 2020-02536,
20-02828, 2020-03191, 2020-03504
Miscellaneous Radiological Post Outage Report - Refueling Outage 29 0
Radiological Department Post Outage Report - Refueling 0
Outage 30
2018 CNS Average BRAC Trend Since RRS Pipe 0
Replacement
069493 Rate History for ARM: 069493 HPCI-MO-15 10/07/2020
20-04 In-Progress Review: LLRTs in RE-31 at 50% Job Complete 10/06/2020
20-12 In-Progress Review: ISI and FAC at 20% Job Complete 10/06/2020
20-16 In-Progress Review: Undervessel at 50% Job Complete 10/06/2020
Procedures 9.ALARA.1 Dosimetry Administration 48
9.ALARA.4 Radiation Work Permits 24
9.EN-RP-110-04 Radiation Protection Risk Assessment Process 14
9.EN-RP-110-05 ALARA Planning and Controls 7
9.EN-RP-110-06 Outage Dose Estimating and Tracking 0
9.EN-RP-203 Dose Assessment 10
Inspection Type Designation Description or Title Revision or
Procedure Date
9.NISP-RP-03 Radiological Air Sampling 0
9.NISP-RP-08 Use of HEPA Filtration Equipment 0
9.RADOP.16 Source Term Mitigation and Control 5
Radiation Surveys CNS-2010-0141 Drywell 921' - CNS-RP-108C 10/07/2020
Radiation Work 2020-511 ISI and FAC in Drywell (includes Walk-downs, Oversight, 0
Permits (RWPs) Insulation Remove/Install, Surface Preps)20-514 Scaffolds in Refueling (RE) 31 - Specific Radiation Work 0
Permit (SWP) Areas20-515 Scaffolds in Drywell and Angle Valve Room if posted LHRA 0
20-520 All other Turbine Generator Building - LHRAs (not Work Order 0
Number validate)
71151 Corrective Action CR-CNS- 2019-0353, 2019-05214, 2020-04321, 2020-04392
Documents CR-CNS- 2019-02558, 2019-02752, 2019-02755, 2019-02798, 2019-
2841, 2019-03083, 2019-03244, 2019-04436, 2019-05153,
2019-05239, 2019-06564, 2020-00653, 2020-00978
Corrective Action CR-CNS- 2020-05944, 2020-05945, 2020-05946, 2020-05947, 2020-
Documents 054948
Resulting from
Inspection
Miscellaneous Test Results - 2019 Annual Full-Cycle Sounding of Alert and 09/26/2019
Notification System Sirens
Annual Radioactive Effluent Release Report for the period 04/15/2020
January 1, 2019, through December 31, 2019
9.3 - PI Documentation and Data Review Forms:
Occupational Exposure Control
Effectiveness for April 2019 - September 2020
9.3 - PI Documentation and Data Review Forms:
RETS/ODCM Radiological
Effluent Occurrence for July 2019 - September 2020
Basis of Calculated Dose Offsite Due to Liquid Effluent: 09/23/2020
01/01/2019 - 09/23/2020
Basis of Calculated Dose Offsite Due to Airborne Effluent: 10/01/2020
07/01/2020 - 10/01/2020
100 mRem Report: July 2019 - September 29, 2020 09/29/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
0-EN-LI-114, Performance Indicator Process: ERO Drill Participation - 2Q/2019 -
Att. 9.3 Quarterly Forms & Supporting ERO Qualification Data 2Q/2020
0-EN-LI-114, Performance Indicator Process: Alert and Notification System 04/2019 -
Att. 9.3 Reliability - Monthly Forms & Sampled Supporting Data 06/2020
0-EN-LI-114, Performance Indicator Process: Drill and Exercise 04/2019 -
Att. 9.3 Performance (DEP) - Monthly Forms & Sampled DEP 06/2020
Opportunity Scenarios and Supporting Data
Procedures 0-EN-FAP-EP- Emergency Preparedness Performance Indicators 9C0
005
0-EN-LI-114 Regulatory Performance Indicator Process 17C0
EPDG#2, Att. C-1 Semi-Monthly Alert and Notification System Siren Testing 21
EPDG#2, Att. C-5 Annual Full-Cycle Sounding of Alert and Notification System 15
Self-Assessments LO 2019-0204 NRC PI Occupation Exposure Control Effectiveness 06/05/2020
71152 Corrective Action CR-CNS- 2017-00223, 2017-00532, 2020-06341
Documents
Procedures 0-CNS-LI-102 Corrective Action Process 12
0-EN-HU-101 Human Performance Program 11C2
23