IR 05000298/2021001
| ML21124A162 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/05/2021 |
| From: | Jason Kozal NRC/RGN-IV/DRP |
| To: | Dent J Nebraska Public Power District (NPPD) |
| References | |
| IR 2021001 | |
| Download: ML21124A162 (25) | |
Text
May 5, 2021
SUBJECT:
COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2021001
Dear Mr. Dent:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On April 15, 2021, the NRC inspectors discussed the results of this inspection with Mr. K. Dia, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. One of these findings 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 or a finding not associated with a regulatory requirement 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.
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
J. Dent, Jr.
Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 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:
Report Number:
Enterprise Identifier: I-2021-001-0000
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, NE
Inspection Dates:
January 1, 2021, to March 31, 2021
Inspectors:
R. Alexander, Senior Emergency Preparedness Inspector
A. Siwy, Senior Resident Inspector
M. Stafford, Resident Inspector
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 Conduct Emergency Plan-Required Radiological Protection Drills in 2019 and 2020 Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000298/2021001-01 Open/Closed
[P.1] -
Identification 71114.05 The inspectors identified a Green, non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for the licensee's failure to maintain an emergency plan that meets the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b), in particular 10 CFR 50.47(b)(14). Specifically, the licensee did not perform one of two semi-annual Radiological Protection Drills in both 2019 and 2020, as required by the Cooper Emergency Plan, Section 8.2.3.4, and Emergency Plan Implementing Procedure 0-EN-EP-306, Drills and Exercises.
Failure to Provide an Appropriate Level of Supplemental Worker Oversight Results in Manual Reactor Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000298/2021001-02 Open/Closed
[H.5] - Work Management 71153 The inspectors identified a Green finding when the licensee failed to meet the standards of Procedure 7.0.4, "Conduct of Maintenance." Specifically, the licensee failed to provide supplemental workers with an appropriate level of oversight and engagement to ensure performance was commensurate with station standards and expectations. An onsite vendor inadequately installed inspection ports on the actuator of a main turbine governor valve. This resulted in a leak of electro-hydraulic fluid and subsequent manual scram of the reactor.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000298/2020-003-00 Manual Reactor Scram due to Digital Electro-Hydraulic Fluid Leak 71153 Closed LER 05000298/2020-001-00 Reactor Building Doors Opened Simultaneously Could Have Resulted in Loss of Safety Function 71153 Closed
PLANT STATUS
Cooper Nuclear Station began the inspection period at rated thermal power. On January 29, 2021, power was lowered to approximately 70 percent for a control rod sequence exchange. The plant was returned to rated thermal power on January 30, 2021.
On January 31, 2021, power was lowered to approximately 85 percent for a control rod sequence exchange. The plant was returned to rated thermal power on January 31, 2021.
The unit remained 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
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 impending winter weather on February 12, 2021.
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 on March 29, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Residual heat removal service water booster pump C on January 15, 2021
- (2) Service water to reactor equipment cooling heat exchanger A on January 22, 2021
- (3) Division 2 service water system on February 22, 2021
- (4) Service water to reactor equipment cooling heat exchanger B on March 2, 2021
- (5) Division 1 4160 Vac system on March 29, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Division 2 125 Vdc system on March 21, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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) Division 1 diesel generator room, Elevations 917 feet 6 inches and 903 feet 6 inches, on January 7, 2021
- (2) Control building basement floor, Elevation 882 feet 6 inches [residual heat removal service water booster pump room], on January 14, 2021
- (3) Reactor building standby liquid control area, Elevation 976 feet, on February 22, 2021
- (4) Control building ground floor, Elevation 903 feet 6 inches, on February 24, 2021
- (5) Reactor building second floor, Elevation 931 feet 6 inches, on March 2, 2021
- (6) Intake structure, Elevation 903 feet 6 inches, on March 17, 2021
- (7) Control building critical switchgear rooms, Elevation 932 feet 6 inches, on March 21, 2021
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 12, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Division 1 emergency diesel generator room on January 7, 2021
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Reactor equipment cooling heat exchanger A on March 4, 2021
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 a downpower and rod pattern adjustment on January 30, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated the licensed operator requalification scenario on March 16, 2021.
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) Building ventilation rad monitoring, near A(1) on March 3, 2021
- (2) Components used during emergency operating procedures, near A(1), on March 31, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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) Yellow risk during high pressure coolant injection maintenance on January 22, 2021
- (2) Planned maintenance on Division 2 residual heat removal and residual heat removal service water booster pumps on January 29, 2021
- (3) Yellow risk during reactor equipment cooling A maintenance on March 4, 2021
- (4) Yellow risk during reactor core isolation cooling maintenance on March 10, 2021
- (5) Yellow risk during Division 2 emergency diesel generator maintenance on March 24, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) High pressure coolant injection shield box cooling fan on January 8, 2021
- (2) Service water booster pump bearing high oil level on January 13, 2021
- (3) Unexpected indicating light for residual heat removal system on February 19, 2021
- (4) Emergency diesel generator starting air compressor failure to start on March 5, 2021
- (5) Safety relief valve failed vendor testing on March 30, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Division 2 residual heat removal service water booster pump post-work test on January 29, 2021
- (2) Emergency diesel generator 2 starting air compressor on February 23, 2021
- (3) Reactor core isolation cooling valve repair on March 12, 2021
- (4) Reactor equipment cooling heat exchanger A on March 15, 2021
- (5) Service water air release check valve on March 15, 2021
- (6) Division 2 emergency diesel generator startup air, air-operated valve, on March 24, 2021
- (7) Division 2 emergency diesel generator post-maintenance run on March 29, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Standby liquid control pumps A and B on January 14, 2021
- (2) High pressure coolant injection steam line space temperature on January 20, 2021
- (3) Withdrawn control rod operability test on March 17, 2021
- (4) Reactor core isolation cooling pump run on March 19, 2021
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) Service water booster pump D on January 25, 2021
- (2) Residual heat removal pump A on February 4, 2021
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between June 1, 2018, and December 31, 2020.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between June 1, 2018, and December 31, 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 submitted Emergency Action Level and Emergency Plan changes:
- Emergency Plan Implementing Procedure (EPIP) 5.7.1, Emergency Classification, Revision 65 (effective 04/15/2020)
- EPIP 5.7.1, Emergency Classification, Revision 66 (effective 09/23/2020)
- Cooper Nuclear Station Emergency Plan, Revision 76 (effective 12/16/2020)
- EPIP 5.7.1, Emergency Classification, Revision 67 (effective 12/16/2020)
- EPIP 5.7.1.1, Emergency Classification Process, Revision 0 (effective 12/16/2020)
- Cooper On-Shift Staffing Analysis, Revision 2 (effective 12/09/2020)
The inspectors also evaluated the 10 CFR 50.54(q) emergency plan change process and practices between June 1, 2018, and December 31, 2020. This involved review of a selection of additional licensee screening and evaluation documentation. These evaluations and reviews do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between June 1, 2018, and December 31, 2020.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency preparedness drill on February 2,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 03.05)===
- (1) April 1, 2020, through December 31, 2020
MS07: High Pressure Injection Systems (IP Section 03.06) (1 Sample)
- (1) April 1, 2020, through December 31, 2020
MS08: Heat Removal Systems (IP Section 03.07) (1 Sample)
- (1) April 1, 2020, through December 31, 2020
MS09: Residual Heat Removal Systems (IP Section 03.08) (1 Sample)
- (1) April 1, 2020, through December 31, 2020
MS10: Cooling Water Support Systems (IP Section 03.09) (1 Sample)
- (1) April 1, 2020, through December 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 secondary containment issue trends that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Control room deficiency review on March 17, 2021
- (2) Condition Report CR-CNS-2020-03279, corrective actions for single rod scram on March 23, 2021
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000298/2020-001-00, Reactor Building Doors Opened Simultaneously Could Have Resulted in Loss of Safety Function (ADAMS Accession No. ML20192A112).
The circumstances surrounding this LER and an associated minor violation are documented in the Inspection Results section of this report.
- (2) LER 05000298/2020-003-00, Manual Reactor Scram due to Digital Electro-Hydraulic Fluid Leak (ADAMS Accession No. ML21014A446). The circumstances surrounding this LER and an associated Green finding are documented in the Inspection Results section of this report.
INSPECTION RESULTS
Failure to Conduct Emergency Plan-Required Radiological Protection Drills in 2019 and 2020 Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness
Green NCV 05000298/2021001-01 Open/Closed
[P.1] -
Identification 71114.05 The inspectors identified a Green, non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for the licensee's failure to maintain an emergency plan that meets the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b), in particular 10 CFR 50.47(b)(14). Specifically, the licensee did not perform one of two semi-annual Radiological Protection Drills in both 2019 and 2020, as required by the Cooper Emergency Plan, Section 8.2.3.4, and Emergency Plan Implementing Procedure 0-EN-EP-306, Drills and Exercises.
Description:
The inspectors reviewed drill and exercise evaluation reports for the period of June 2019 through December 2020. The inspectors compared the drills described in the evaluation reports with the requirements of Cooper's Emergency Plan (Section 8.2) and Emergency Plan Implementing Procedure 0-EN-EP-306, "Drills and Exercises,"
Revision 10C0, to determine if all drills required by the Emergency Plan had been completed in calendar years 2019 and 2020. Specifically, the Cooper Emergency Plan delineates several types of radiological drills that the licensee is required to complete on an annual basis. Section 8.2.3.3 describes that at least one "Radiological Monitoring Drill" is to be conducted annually for onsite and offsite personnel assigned to the radiation survey and Field Monitoring Teams and will include the use of communications equipment, radiological instruments, and collection of various environmental sample media. Section 8.2.3.4 describes "Radiation Protection (RP) Drills" which are to be conducted semi-annually (i.e.,
twice per year), generally in connection with joint exercises, and will involve analysis of simulated elevated radiation levels (liquid and airborne) as well as direct radiation measurements. This same section also describes that analysis of in-plant liquid samples, including the use of the Post-Accident Sampling System (PASS), will be conducted on an annual basis.
The inspectors verified that the PASS drill (per Section 8.2.3.4) and the Radiological Monitoring Drill (per Section 8.2.3.3) were each conducted and documented as required in both 2019 and 2020. However, the inspectors identified that one of the semi-annual RP Drills (per Section 8.2.3.4) was conducted on June 27, 2019, but there was no report documenting that the second RP Drill was conducted in 2019. The inspectors further identified that one of the semi-annual RP Drills was conducted on February 25, 2020, as part of the full ERO Team 'D' Dress Rehearsal Exercise, but there was no report documenting that the second RP Drill was conducted in 2020.
The inspectors also reviewed two self-assessments completed by the licensee in the time period to determine if the licensee had identified the circumstances regarding the completion of both of the second RP Drills in 2019 and 2020. The inspectors found that in one assessment completed in late 2019 (LO-CLO-2019-00024), the licensee emergency preparedness (EP) staff identified that while one RP Drill was completed on schedule in June 2019, no documentation was reviewed to confirm that the second RP drill had been completed, and documented this "Negative Observation" in Condition Report CR-CNS-2020-00544. The evaluation for Condition Report CR-CNS-2020-00544 indicated that the second RP Drill had been conducted in conjunction with the 2019 Radiation Monitoring Drill completed on August 8, 2019, and the condition report was subsequently closed. However, the inspectors again reviewed the August 8, 2019, Radiation Monitoring Drill report and confirmed that the drill only included elements described in the Cooper Emergency Plan, Section 8.2.3.3, but did not include the elements of an RP Drill (as described in Section 8.2.3.4). In the second self-assessment reviewed (LO-2020-0181, completed in September 2020), the licensee EP assessors state, in part: "For non-exercise drill requirements listed in Procedure 0-EN-EP-306, Attachment 9.1, several sources were used to assess if 2019 drill requirements were performed. Sources were drill reports, objectives, and completed Procedure 5.7.21, Attachment 1 [forms]. All annual and semi-annual drill requirements were performed in 2019. Some drill requirements have been met in 2020 with enough time to complete remaining drill requirements this year.
The inspectors subsequently interviewed licensee staff to determine whether the second RP Drills had been conducted in 2019 and 2020. The licensee ultimately confirmed that the second, semi-annual RP Drills in both 2019 and 2020 had not been completed and appropriately documented as prescribed in Procedure 0-EN-EP-306, despite at least two opportunities to identify the issues in prior self-assessments. Therefore, the inspectors concluded that the required drills had not been performed, and the licensee had not followed the requirements of their approved Emergency Plan.
Corrective Actions: The licensee documented the inspector's findings in the corrective action program. Further, the licensee determined there was an actual resin spill in the plant which the RP staff responded to, and critiqued, in July 2020, which the licensee is evaluating for potential credit as the second RP Drill in 2020 per Procedure 0-EN-EP-306, though there was no formal EP report for this activity documented by the completion of the onsite inspection.
Corrective Action References: Condition Report CR-CNS-2021-00187
Performance Assessment:
Performance Deficiency: The licensee's failure to follow the requirements of the Cooper Emergency Plan, specifically Section 8.2.3.4, is a performance deficiency within the licensee's ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensees ability to take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure adequate emergency response organization proficiency.
Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. Specifically, using Attachment 2, the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The planning standard function was not lost because, while the licensee did not conduct two required drills in the 2-year calendar period, the licensee did conduct other drills and training that addressed portions of the related emergency plan commitments.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee had opportunities to identify, in self-assessments completed in 2019 and 2020, that the second required RP drill had not been completed in both years, and potentially conduct the second required drill before the end of the calendar year. However, in both cases, the licensee's assessors failed to recognize that other drills completed in 2019 and 2020, in fact, did not meet the criteria to be credited as RP Drills, as defined in the licensee's Emergency Plan Section 8.2.3.4.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2) states, in part, that a holder of a license under Part 50 shall follow and maintain the effectiveness of an emergency plan that meets the requirements of Appendix E to Part 50 and the planning standards of 10 CFR 50.47(b).
Title 10 CFR 50.47(b)(14) requires that periodic drills be conducted to develop and maintain key skills; and Appendix E,Section IV.F.1, requires that the program provide for the training of employees and exercising by periodic drills shall be described. Cooper's Emergency Plan and Emergency Plan Implementing Procedure 0-EN-EP-306, "Drill and Exercises," requires that Cooper perform radiation protection drills semi-annually (i.e. twice per year).
Contrary to the above, from January 2020 to present, the licensee failed to follow an emergency plan that met the requirements of Appendix E to Part 50 and the planning standards of 10 CFR 50.47(b). Specifically, Cooper failed to conduct a second, semi-annual RP drill in 2019 and 2020, as required by Cooper's Emergency Plan and Emergency Plan Implementing Procedure 0-EN-EP-306. Only one RP drill was conducted in calendar year 2019, on June 27, 2019; and only one RP drill was conducted in calendar year 2020, on February 25, 2020. Immediate corrective actions included the licensee entering this issue into its corrective action program (Condition Report CR-CNS-2021-00187).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Provide an Appropriate Level of Supplemental Worker Oversight Results in Manual Reactor Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green FIN 05000298/2021001-02 Open/Closed
[H.5] - Work Management 71153 The inspectors identified a Green finding when the licensee failed to meet the standards of Procedure 7.0.4, "Conduct of Maintenance." Specifically, the licensee failed to provide supplemental workers with an appropriate level of oversight and engagement to ensure performance was commensurate with station standards and expectations. An onsite vendor inadequately installed inspection ports on the actuator of a main turbine governor valve. This resulted in a leak of electro-hydraulic fluid and subsequent manual scram of the reactor.
Description:
On November 1, 2020, control room operators inserted a manual reactor scram due to a low fluid tank level for the digital electro-hydraulic (DEH) system for the main turbine generator. A leak had developed at governor valve (GV) 1, and a pencil-sized stream of EH fluid was discovered leaking out of the lower outboard inspection port on the GV1 actuator.
Vendor installation of the GV1 actuator during the September to October 2020 refueling outage left one bolt on the actuator inspection port cover plate bottomed-out and two other bolts loose. These conditions prevented an adequate seal to be formed on the O-ring. The O-ring on this cover plate ruptured at system pressure 5 days after being placed in service, allowing excessive leakage of EH fluid.
This finding is NRC-identified because the inspectors identified a previously unknown weakness in the licensee's causal evaluation associated with this event. The licensee attributed causal factors in the original causal analysis to the offsite vendor for not threading the bolt holes deep enough to meet vendor specifications and to onsite vendor craftmanship for failure to recognize the bottomed-out bolt during installation. The licensee's analysis did not discuss the standard in Procedure 7.0.4, "Conduct of Maintenance," which states, in part, that the licensee, "...ensure that supplemental workers have an appropriate level of oversight and engagement by personnel to ensure performance is commensurate with that of the station's standards and expectations."
In response to this observation, the licensee revised their causal analysis to include an additional causal factor. This causal factor states, "Oversight of turbine work did not ensure discrepancies were identified and appropriately resolved." The licensee also revised their response to the Organizational and Programmatic Screening Checklist in the causal analysis for the following question from 'no' to 'yes': "Are there shortfalls in behaviors and actions that impede achieving the desired results?" The licensee justified the change by stating, "The scram is a clear indicator that desired results were not achieved."
This issue was reviewed using Inspection Procedure 71153, "Follow up of Events and Notices of Enforcement Discretion," and was reported in Licensee Event Report 05000298/2020-003-00, Manual Reactor Scram due to Digital Electro-Hydraulic Fluid Leak (ADAMS Accession No. ML21014A446).
Corrective Actions: The licensee restored the system by re-threading the bolt holes to accept the length of the bolts and replacing the gasket. The licensee revised their causal analysis with supporting information and an additional causal factor relating to the performance deficiency.
Corrective Action References: Condition Reports CR-CNS-2020-05623, CR-CNS-2021-00706, and CR-CNS-2021-02055
Performance Assessment:
Performance Deficiency: The inspectors determined that failure to follow the requirements of Procedure 7.0.4, Conduct of Maintenance, was a performance deficiency that was within the licensees ability to foresee and prevent. The licensee did not provide supplemental workers with an appropriate level of oversight and engagement to ensure performance was commensurate with the station's standards and expectations. Specifically, an onsite vendor inadequately installed inspection ports on the actuator of a main turbine governor valve during the 2020 refueling outage, which resulted in a leak of electro-hydraulic fluid and subsequent manual scram of the reactor.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the leak of the main turbine electro-hydraulic fluid ultimately led to a manual reactor scram. Additionally, because the leak had led to a low level of electro-hydraulic fluid, the main turbine bypass valves were not available to respond to the conditions introduced by the scram.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, to determine that this finding represented a degraded condition which caused a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Therefore, a senior reactor analyst performed a detailed risk evaluation.
The senior reactor analyst performed a detailed risk evaluation by doing an initiating event as called for in Section 8.0, Initiating Event Analyses, of the Risk Assessment of Operational Events Handbook. The analyst used Cooper Nuclear Station SPAR limited use model COOP-EQK-HWD-FLEX-LIM-DEESE-TBV, run on SAPHIRE software, Version 8.2.1, for the evaluation. This limited use model was a modified version of the Cooper Nuclear Station SPAR model, Version 8.58, provided by the Idaho National Laboratory, which reflected the independence of the turbine bypass valves and the main feedwater system.
In reviewing the results provided by the SPAR model, the analyst noted numerous cutsets which contained events where containment venting was not accomplished. Venting containment would prevent containment failure in these cutsets and would be necessary to prevent a late term loss of injection sources. Recognizing that the main condenser would still be available for removing decay heat via miscellaneous steam loads like steam jet air ejectors, main steam drains, reactor feed pump turbines, and gland seal steam, the analyst reviewed Engineering Report 2021-006, End-of-cycle/Beginning-of-cycle Plant Shutdown from 100% Power without Digital Electro-Hydraulic System, Revision 0, prepared by the licensee which attempted to quantify the amount of steam flow these miscellaneous steam loads made up.
The analyst also consulted with the Nuclear Systems Performance Branch in the Office of Nuclear Reactor Regulation to ensure the licensees estimate of decay heat in the engineering report was consistent with mid-to late-cycle decay heat load in an effort to understand when decay heat would fall within the capacity of the miscellaneous steam loads to remove. From this, the analyst concluded that the decay heat load rejected to the suppression pool would not be sufficient to challenge containment if containment venting were not performed. Subsequently, the analyst removed these cut sets from the results of the analysis.
The analyst incorporated these changes and estimated the incremental conditional core damage probability (ICCDP) in accordance with Section 08.02, Treatment of Degraded Conditions and Initiating Events, of NRC Inspection Manual Chapter 0308, Attachment 3, Significance Determination Process Technical Basis, issue date June 16, 2016. The manual chapter prescribes estimating ICCDP using the following formula:
To estimate the conditional core damage probability (CCDP), the analyst ran an initiating event analysis in accordance with Section 8.0, Initiating Events Analyses, from the Risk Assessment of Operational Events Handbook, Volume 1, Internal Events, Revision 2.02.
Specifically, for analyst referred to Section 8.2, Case 3-Initiating Event and Mutually Inclusive SSC Unavailability, and set the transient event to 1.0, all other initiating events to 0.0, and basic events MSS-TBV-CC-BYPS1, -BYPS2, and -BYPS3 (turbine bypass valves fail to open) to TRUE. The analyst then removed containment venting failure cutsets. From these actions, the CCDP was estimated as:
CCDP = 1.04E-6
The baseline core damage probability (CDP) was estimated using the nominal initiating event frequency and nominal failure probabilities of all other components. Similar cutsets which were judged to not challenge containment were removed like in the event estimation. The baseline CDP was estimated as:
Baseline CDP = 7.0E-7
The analyst then obtained the ICCDP as follows:
ICCDP = 1.04E-6 - 7.0E-7
ICCDP = 3.0E-7
This ICCDP value was multiplied by 1 inverse year to equate the ICCDP to an increase in core damage frequency of 3.0E-7/year.
The analyst noted that this detailed risk assessment evaluates an actual event in which no external events occurred. Additionally, the period of time that the events impacted plant equipment was small enough that the probability of an external initiator occurring during this time would be negligible. Therefore, the analyst assumed that the risk from external events, given the subject performance deficiency was insignificant. This resulted a total estimate in the increase of core damage frequency of 3.0E-7 per year putting the performance deficiency in the very low safety significance range (Green).
The increase in large early release frequency from this finding was estimated by use of the SAPHIRE software. The analyst applied the applicable large early release factors from the SPAR model to the dominant sequences from the internal events results to obtain a conditional large early release probability of 8.32E-7. Then the analyst applied the large early release factors to the base transient case to obtain a baseline conditional large early release frequency of 7.88E-7. The analyst multiplied the difference in these two probabilities by 1 inverse year to estimate the increase in large early release frequency to be 4.4E-8/year.
This detailed risk evaluation was peer reviewed by a Risk and Reliability Analyst from the Office of Nuclear Reactor Regulation. As a result of this evaluation, the inspectors determined that the finding had very low safety significance (Green).
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not properly identify all critical turbine generator fluid connections, and therefore, did not identify all critical steps for their maintenance plans related to this system.
Enforcement:
The inspectors did not identify a violation of regulatory requirements associated with this finding.
Minor Violation 71153 Minor Violation: Licensee Event Report 05000298/2020-001-00 described that during routine plant operations on May 1, 2020, both doors in the secondary containment airlock for the reactor building were opened at the same time for approximately 1 second due to the door failing to latch and multiple people trying to access the airlock. Technical Specification (TS)
Surveillance Requirement 3.6.4.1.3 required at least one door in each secondary containment access opening to be closed during the Mode 1 (power operation) conditions at the time.
With both doors open, secondary containment was rendered inoperable. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedure, and Drawings, requires, 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 those instructions, procedures, or drawings. Cooper Nuclear Station Procedure 0-BARRIER, Barrier Control Process, was a procedure affecting quality and required that at least one door in each secondary containment access opening be closed.
Contrary to the above, on May 1, 2021, the licensee failed to ensure at least one door into secondary containment was closed.
Screening: The inspectors determined the performance deficiency was minor. The issue was minor because it did not adversely affect the barrier integrity cornerstone objective. At least one door was able to be closed within 1 second upon discovery of both doors being open, secondary containment pressure was not affected, and there were no other known deficiencies with the secondary containment access doors.
Enforcement:
This failure to comply with Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee closed at least one of the doors at the time of the event, entered the issue into their corrective action program, and took actions to correct the condition.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 14, 2021, the inspectors presented the emergency preparedness program inspection results to Mr. J. Dent, Vice President and Chief Nuclear Officer, and other members of the licensee staff.
- On April 15, 2021, the inspectors presented the integrated inspection results to Mr. K, Dia, General Manager of Plant Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
21-00534, 2021-00538, 2021-00545, 2021-00547, 2021-
00551, 2021-00574, 2021-00578, 2021-00579, 2021-
00587, 2021-00601, 2021-00607, 2021-00624, 2021-00628
Miscellaneous
Operations Instruction #7; Operations Expectation
Procedures
5.1Flood
Flood Emergency Procedure
Corrective Action
Documents
CR-CNS-
21-00211
Drawings
2036, Sheet 1
Reactor Building Service Water System
A6
Drawings
3058
DC One Line Diagram
Procedures
2.2.25.2
25 VDC Electrical System
Procedures
2.2A.REC.DIV2
Reactor Equipment Cooling Water System Component
Checklist (Div 2)
Procedures
2.2A.RHRSW.DIV1 RHR Service Water Booster Pump System Component
Checklist (Div 1)
Procedures
2.2A.SW.DIV 1
Service Water System Component Checklist
Procedures
2.2A.SW.DIV2
Service Water System Component Checklist (Div 2)
Procedures
2.2A_125DC.DIV2
25 VDC Power Checklist
Procedures
2.2A_4160.DIV1
4160 VAC Auxiliary Power Checklist
Fire Plans
CNS-FP-216
Reactor Building - Critical Switchgear Room 1F
Elevation 932-6
Fire Plans
CNS-FP-217
Reactor Building - Critical Switchgear Room 1G
Elevation 932-6
Fire Plans
CNS-FP-218
Reactor Building - Second Floor Elevation 931-6
Fire Plans
CNS-FP-220
Reactor Building - SBLC Area Elevation 976-0
Fire Plans
CNS-FP-224
Control Building Basement Floor Elevation 882-6
Fire Plans
CNS-FP-228
Control Building - Batter/SWGR Rms 1B Elevation 903-6
Fire Plans
CNS-FP-236
Diesel Generator Building - Diesel Generator #1 Elevations
917-6 and 903-6
Fire Plans
CNS-FP-256
Intake Structure Elevation 903-6
Miscellaneous
20A
Fire Brigade Scenario
01/19/2021
Procedures
0-BARRIER-MAPS
Barrier Maps
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-BARRIER-
REACTOR
Reactor Building
Procedures
5.1INCIDENT
Site Emergency Incident
Miscellaneous
NEDC 09-102
Internal Flooding - HELB, MELB, and Feedwater Line
Break
Procedures
2.2.27
Equipment, Floor, and Chemical Drain System
Corrective Action
Documents
CR-CNS-
21-01015, 2021-01024
Procedures
13.15.1
Reactor Equipment Cooling Heat Exchanger Performance
Analysis
Procedures
7.2.42.1
REC Heat Exchanger Maintenance
71111.11Q Procedures
10.13
Control Rod Sequence and Movement Control
71111.11Q Procedures
2.1.10
Station Power Changes
20
71111.11Q Procedures
6.RPS.302
Main Turbine Stop Valve Closure and Steam Valve
Functional Test
Corrective Action
Documents
CR-CNS-
2019-05804
Corrective Action
Documents
CR-CNS-
21-00278, 2021-00343, 2021-00355, 2021-00356, 2021-
00360
Miscellaneous
Protected Equipment Posting for RHR Work Week 2104
Miscellaneous
Protected Equipment Posting for REC Work Week 2109
Miscellaneous
Protected Equipment Posting for RCIC and CS A Work
Week 2110
Miscellaneous
Protected Equipment Posting for Diesel Generator Division
Work Week
Procedures
0-CNS-WM-104
On-Line Schedule Risk Assessment
Procedures
0-CNS-WM-104A
On-Line Fire Risk Management Actions
5, 6
Work Orders
WO 289864, 5290769, 5339132
Corrective Action
Documents
CR-CNS-
20-05961, 2021-00003, 2021-00771, 2021-00777, 2021-
01483, 2021-01511
Miscellaneous
VM-0144
Service Water Booster Pump Vendor Manual
Procedures
2.1.11.1
Turbine Building Data
2
Procedures
2.2.70
RHR Service Water Booster Pump System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
21-00623, 2021-01250
Procedures
14.17.2
DG-2 Annual Calibration
Procedures
6.1RHR.101
RHR Test Mode Surveillance Operation
Procedures
6.2DG.101
Diesel Generator 31 Day Operability Test (IST) (Div 2)
Procedures
6.2DG.105
Diesel Generator Starting Air Compressor Operability
Procedures
6.RCIC.201
RCIC Power Operated Valve Operability Test
Work Orders
WO 273779, 5276164, 5335243, 5342515
Corrective Action
Documents
CR-CNS-
21-01484
Procedures
6.1RHR.101
RHR Test Mode Surveillance Operation (Div 1)
Procedures
6.2SWBP.101
RHR Service Water Booster Pump Flow Test and Valve
Operability Test
Procedures
6.CRD.301
Withdrawn Control Rod Operability IST Test
Procedures
6.HPCI.301
HPCI Steam Line Pace Temperature Switch Functional
Test
Procedures
6.RCIC.102
Procedures
6.SLC.101
SLC Pump Operability Test
Work Orders
Corrective Action
Documents
CR-CNS-
2019-03074, 2019-03083, 2019-03244, 2019-03444, 2019-
06361, 2020-00653, 2020-03613, 2020-03894
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-
21-00125
Miscellaneous
Prompt Alert and Notification System Design Report for
Cooper Nuclear Station
Procedures
EPDG #2, Att. C-1
Semi-Monthly Alert and Notification System Siren Testing
Procedures
EPDG #2, Att. C-5
Annual Full-Cycle Sounding Of Alert and Notification
System Sirens
Procedures
EPDG #2, Att. C-6
Annual Fixed Siren Maintenance
Procedures
EPIP 5.7.20
Alert and Notification System
Corrective Action
Documents
WT-2019-0037-063
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
2019-03592, 2019-05324, 2020-01104, 2020-03508, 2020-
05915
Miscellaneous
Cooper Nuclear Station 10 CFR 50 Appendix E, On-Shift
Staffing Analysis
Procedures
0-EP-01
Emergency Response Organization Responsibilities
Procedures
0-EP-02
Configuration Control of the Automated Notification System
Procedures
EPDG #2, Att. E-3
Quarterly ERO Call-In Test
20, 21
Procedures
EPDG #2, Att. E-3
Records of CNS Quarterly ERO Call-In Testing (7 quarters
of data)
2Q/2019 -
4Q/2020
Procedures
EPIP 5.7.2
Emergency Director EPIP
Corrective Action
Documents
CR-CNS-
2019-04180, 2020-00128, 2020-00349, 2020-00526, 2020-
00546, 2020-00670, 2020-01442, 2020-02438
Miscellaneous
50.54(q) Screen &
Evaluation No.
2019-49
Semi-Monthly Alert and Notification System Siren
Testing/EOF Siren Encoder Upgrade
07/29/2019
Miscellaneous
50.54(q) Screen &
Evaluation No.
20-14
EPIP 5.7COMMUN Communications, Rev 32
03/10/2020
Miscellaneous
50.54(q) Screen &
Evaluation No.
20-26
EPIP 5.7.1 Emergency Classification, Rev 66
08/27/2020
Miscellaneous
50.54(q) Screen
No. 2019-43
CNS E-Plan Rev 74, Back-up Alert and Notification System
Methods Added
07/25/2019
Miscellaneous
50.54(q) Screen
No. 2020-18
EPIP 5.7.1, Classification, Rev. 65
03/05/2020
Miscellaneous
50.54(q) Screen
No. 2020-25
EPIP 5.7.1, Emergency Classification, Rev. 66
05/12/2020
Miscellaneous
50.54(q) Screen
No. 2020-41
Various (E-Plan, Rev. 76; EPIP 5.7.1, Rev. 67; EPIP
5.7.1.1, Rev. 0)
11/13/2020
Miscellaneous
50.54(q) Screen
No. 2020-46
CNNS 10 CFR 50 Appendix E On-Shift Staffing Analysis,
Rev. 2
11/17/2020
Procedures
0.29.4
Other Regulatory Reviews
Corrective Action
Documents
CR-CNS-
2019-03253, 2019-03263, 2019-03366, 2019-03480, 2019-
03982, 2019-04219, 2019-04857, 2019-05060, 2019-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
05456, 2019-06478, 2020-00036, 2020-00542, 2020-
00544, 2020-00545, 2020-05822, 2020-06147, 2020-
212, 2021-00052
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-
20-00180, 2020-00181, 2021-00179, 2021-00187
Engineering
Changes
KLD TR-1166
KLD Engineering, Cooper Nuclear Station 2020 Population
Update Analysis (Final Report, Rev 0)
09/19/2020
Engineering
Evaluations
KLD TR-1100
KLD Engineering, Cooper Nuclear Station 2019 Population
Update Analysis (Final Report, Rev 0)
09/21/2019
Engineering
Evaluations
KLD TR-520
KLD Engineering, Cooper Nuclear Station Development of
Evacuation Time Estimates (Final Report, Rev. 1)
11/2012
Miscellaneous
June 27, 2019 Radiological Protection Drill Report
07/16/2019
Miscellaneous
August 8, 2019 Radiological Monitoring Drill Report
09/25/2019
Miscellaneous
Feb. 25, 2020 Full Team (D) Dress Rehearsal Exercise
Report
03/16/2020
Miscellaneous
December 16, 2020 Medical Drill Report
2/17/2020
Miscellaneous
2/11/2020 Post-Accident Sampling Scenario for 2020
(Report)
2/11/2020
Miscellaneous
2/28/2020 Radiation Monitoring/Environmental Sampling
Drill (Report)
2/28/2020
Miscellaneous
IDOCS (procedure
change requests)
81976
Miscellaneous
QAD 2019-019
QA Audit 19-06, "Emergency Preparedness (EP) Program"
09/16/2019
Miscellaneous
QAD 2020-026
QA Audit 20-05, "Emergency Preparedness (EP) Program"
09/30/2020
Procedures
0-CNS-LI-102
Corrective Action Process
Procedures
0-CNS-WM-100
Work Order Generation, Screening, and Classification
(specifically Att. 2 - Compensatory Measures for EP-
Related Equipment)
Procedures
0-EN-EP-202
Equipment Important to Emergency Preparedness
1C0
Procedures
0-EN-EP-306
Drills and Exercises
10C0
Procedures
0-EN-EP-308
Emergency Planning Critiques
5C1
Procedures
EPDG #2, Att. E-2
Monthly and Post Drill Emergency Response Facility (ERF)
11/23/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Walkdowns and Testing of Facility Equipment
Procedures
EPDG #2, Att. F-3
Maintenance of Emergency Plan Letters of Agreement
(including current copies of LOAs listed in the CNS
Emergency Plan, Appendix D)
2/31/2020
Procedures
EPDG #2, Att. I-1
Monthly EOF Diesel Generator Run
2/24/2020
Procedures
EPDG #2, Att. I-2
Annual EOF Diesel Generator Run
10/28/2020
Procedures
EPDG #2, Att. I-5
EOF Fire Protection
04/23/2020
Procedures
EPIP 5.7.17
CNS-Dose Assessment
Procedures
EPIP 5.7.20
Protective Action Recommendations
Procedures
EPIP 5.7.21
Maintaining Emergency Preparedness - Emergency
Exercises, Drills, Tests, and Evaluations
Procedures
EPIP 5.7.6
Notification
Procedures
TPP 101
Emergency Response Organization
Procedures
TPP 102
Emergency Preparedness Staff Training and Qualification
Self-Assessments LO-2020-0181
20 Pre-NRC Emergency Planning Program Inspection
Assessment
09/30/2020
Self-Assessments LO-CLO-2019-
00024
Pre-NRC Evaluated Exercise Assessment
2/04/2020
Self-Assessments WT 2019-0037-
20
10CFR50.54(q) Implementation for EP Related Changes -
January 2019 - December 2019
01/22/2020
Work Orders
WO 5054874, 5236857, 5319877, 5321556, 533774, 5349105,
5362219
Corrective Action
Documents
CR-CNS-
21-00492
71151
Miscellaneous
Operator Logs 2Q20 thru 4Q20
71151
Miscellaneous
MSPI Derivation Reports 2Q20 thru 4Q20
71151
Procedures
0-EN-LI-114
Regulatory Performance Indicator Process
17C0
Corrective Action
Documents
CR-CNS-
2018-07347, 2020-00071, 2020-02230, 2020-03279, 2020-
03402, 2020-04172, 2020-04872, 2020-05279, 2020-
05500, 2020-05645, 2020-05668, 2021-00573, 2021-01525
Procedures
0-CNS-LI-102
Corrective Action Process
Procedures
0-CNS-LI-121
Trending and Performance Review Process
Procedures
2.0.12
Operator Challenges
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
20-01649, 2020-01883, 2020-01929, 2020-01933, 2020-
2487, 2020-02620, 2020-02629, 2020-05623, 2021-00375
Drawings
NEDC 07-056
Review of Alion Calculation ALION-CAL-NPPD-4012-01
Reactor Building Post DBA Pressure Analysis at Cooper
Nuclear Station
Drawings
NEDC 07-082
Radiological Dose Analysis for a Loss of Coolant Accident
(LOCA) at Cooper Nuclear Station
Procedures
0-BARRIER
Barrier Control Process
Procedures
0-BARRIER-
REACTOR
Reactor Building
Procedures
6.SC.701
Technical Specification Verification of Secondary
Containment Access Doors and Hatches
5