IR 05000298/2021012
| ML21203A207 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/27/2021 |
| From: | Ami Agrawal Division of Reactor Safety IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| References | |
| IR 2021012 | |
| Download: ML21203A207 (14) | |
Text
July 27, 2021
SUBJECT:
COOPER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2021012
Dear Mr. Dent,
Jr.:
On July 1, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Cooper Nuclear Station. On July 1, 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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
J. Dent, Jr. 2 Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Agrawal, Ami on 07/27/21 Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety Docket No. 05000298 License No. DPR-46
Enclosure:
As stated
Inspection Report
Docket Number: 05000298 License Number: DPR-46 Report Number: 05000298/2021012 Enterprise Identifier: I-2021-012-0018 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, NE Inspection Dates: June 14, 2021 to July 01, 2021 Inspectors: R. Azua, Senior Reactor Inspector B. Correll, Senior Reactor Inspector J. Mateychick, Senior Reactor Inspector J. Melfi, Project Engineer A. Siwy, Senior Resident Inspector Approved By: Ami N. Agrawal, Insp Prgms & Assessment Team Leader Insp Pgms & Assessment Team Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the residual heat removal system.
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Cooper Nuclear Station developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants residual heat removal system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Entergy fleet notifications, NRC generic communications, and publications from various industry groups such as the Nuclear Energy Institute (NEI) and Electric Power Research Institute (EPRI). The team determined that the Cooper Nuclear Station is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received. However, the team identified that the licensee does not have a procedure to provide guidance for the Security group to monitor for operating experience. The team identified that the licensee did not incorporate guidance similar to Entergy procedure EN-OE-221 "Security Organization, Standards & Expectations," with respect to monitoring for operating experience, when implementing the 0-CNS-OE-100 "Operating Experience Program." The 0-CNS-OE-100 procedure does not apply to the Security organization, but no procedure is provided to the Security organization for conducting operating experience reviews. However, the team did not identify any missed opportunities with respect to security operating experience during this inspection. The licensee captured this observation and will evaluate it in condition report CR-CNS-2021-03053.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also/ reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process. Audits were very detailed, thorough, and identified issues.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed twenty individuals in six group interviews. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a Condition Report or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Instrumentation and Controls organization, and the Security organization. Overall, the Cooper Nuclear Station has an adequate Safety-Conscious Work Environment.
Willingness to Raise Nuclear Safety Issues: In the assessed focus groups, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available. Overall, the team concluded that the Cooper Nuclear Station maintains a healthy SCWE.
Employee Concerns Program: The team looked at Cooper Nuclear Station's Employee Concerns Program (ECP). The team interviewed the ECP manager and an on-site representative and discussed the electronic ECP program and the Lighthouse program, for a sample of ECP cases. The team independently reviewed two ECPs investigative packages. The team provided some observations to the licensee concerning the ECP program for their awareness. Overall, the team did not identify any concerns with the program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 1, 2021, the inspectors presented the biennial problem identification and resolution inspection results to John Dent, Jr. and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations NEDC 19-009 Operability Calculation for an Auxiliary Steam Line Break in G 0
Critical Switchgear Room
71152B Corrective Action CR-CNS- 2015-03519, 2016-04922, 2016-05082, 2016-06050, 2016-07645,
Documents 2017-00324, 2017-00553, 2017-01504, 2017-01505, 2017-01507,
2017-01510, 2017-01519, 2017-01520, 2017-01534, 2017-02326,
2017-02933, 2017-03247, 2017-03248, 2017-04162, 2017-06326,
2017-04564, 2018-00394, 2018-00397, 2018-00435, 2018-05169,
2018-06295, 2018-06420, 2018-07341, 2019-00860, 2019-01161,
2019-01166, 2019-01167, 2019-01335, 2019-01336, 2019-01337,
2019-01338, 2019-01340, 2019-01341, 2019-01361, 2019-01402,
2019-01403, 2019-03147, 2019-03192, 2019-03360, 2019-03631,
2019-03672, 2019-03729, 2019-03802, 2019-03936, 2019-03936,
2019-03940, 2019-03962, 2019-03971, 2019-04194, 2019-04209,
2019-04222, 2019-04317, 2019-04336, 2019-04572, 2019-04573,
2019-04683, 2019-04898, 2019-04945, 2019-04960, 2019-04980,
2019-05210, 2019-05331, 2019-05388, 2019-05528, 2019-05576,
2019-05617, 2019-05619, 2019-05620, 2019-05637, 2019-05638,
2019-05682, 2019-05795, 2019-05870, 2019-05967, 2019-06008,
2019-06064, 2019-06064, 2019-06159, 2019-06278, 2019-06302,
2019-06302, 2019-06322, 2019-06323, 2019-06484, 2019-06521,
20-00181, 2020-00181, 2020-00324, 2020-00446, 2020-00457,
20-00504, 2020-00612, 2020-00721, 2020-00722, 2020-00739,
20-00743, 2020-00747, 2020-00756, 2020-00978, 2020-01249,
20-01383, 2020-01458, 2020-01473, 2020-01532, 2020-01534,
20-01572, 2020-01573, 2020-01618, 2020-01621, 2020-01690,
20-01702, 2020-01703, 2020-01848, 2020-01929, 2020-01990,
20-02046, 2020-02433, 2020-02582, 2020-02757, 2020-02902,
20-03015, 2020-03402, 2020-03522, 2020-03525, 2020-03861,
20-03861, 2020-03862, 2020-04175, 2020-04392, 2020-04511,
20-04533, 2020-04814, 2020-04902, 2020-04924, 2020-04934,
20-04953, 2020-04953, 2020-05313, 2020-05580, 2020-05668,
20-06042, 2020-06058, 2020-06278, 2021-00187, 2021-00211,
Inspection Type Designation Description or Title Revision or
Procedure Date
21-00857, 2021-00923, 2021-01022, 2021-01210, 2021-01212,
21-01214, 2021-01216, 2021-01252, 2021-01253, 2021-01254,
21-01255, 2021-01256, 2021-01257, 2021-01262, 2021-01263,
21-01281, 2021-01282, 2021-01299, 2021-01456, 2021-02100
71152B Corrective Action CR-CNS- 2021-02959, 2021-03008, 2021-03015, 2021-03017, 2021-03053
Documents
Resulting from
Inspection
71152B Drawings CNS-BLDG.-133 Cooper Nuclear Station Penetration Drawing North Wall - 2F 881 10/05/2020
'-9" Reactor Bldg
71152B Engineering EC 20-014 New SW Operational Requirement to Prevent Discharge Canal 0
Changes Sediment Blockage
71152B Engineering ECR 11692576 RHR-MOV-MO31A Overtorque Evaluation 0
Changes
71152B Engineering ER-2015-037 RCIC Governor Control Systems Qualification Report 0
Evaluations
71152B Miscellaneous Operational Focus Meeting Agenda
71152B Miscellaneous Refueling Outage RE31 Regulatory Affairs & Compliance (RA&C) 10/22/2020
Startup Review and Report
71152B Miscellaneous CED 6012122 RHR Steam Condensing Mode Piping Isolation 06/12/2003
71152B Miscellaneous Engineering ER 2020-003 2019 Maintenance Rule Structural Monitoring 0
Report Report
71152B Miscellaneous Engineering Evaluation of December 2019 Service Water Blockage 0
Report 2020-004
71152B Miscellaneous INPO 19-002 Clearance and Tagging 2
71152B Miscellaneous Licensee Event 2016-007-00, Isolation of Shutdown Cooling due to Relay 12/19/2016
Report Maintenance Results in a Loss of Safety Function
71152B Miscellaneous LO 2020-0047- 008, 014, 024
71152B Miscellaneous Meeting Condition Report Screening Committee 6/14/2021
71152B Miscellaneous ML20085H006 Cooper Nuclear Station - NRC Inspection Report 0
71152B Miscellaneous Operations Daily Report 3/18/21
Instruction #17
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Miscellaneous RCR 2002- Review of IN 2002-15 Hydrogen Combustion Events in Foreign 06/06/2002
0796 BWRs
71152B Miscellaneous Standing Order Use of Skill of the Craft is prohibited for all normal plant activities. 8/8/2019
2019-10 Procedure in hand is required when performing any activity in the
plant.
71152B Miscellaneous System Health RHR System Dec-19
Report
71152B Miscellaneous System Health RHR System June - 20
Report
71152B Miscellaneous System Health RHR System April -21
Report
71152B Miscellaneous System Health RHR System Jan-21
Report
71152B Miscellaneous System Health RHR System Nov-20
Report
71152B Miscellaneous System Health RHR System Mar-20
Report
71152B Miscellaneous Training Manual COR002-23-03, Residual Heat Removal 10
71152B Miscellaneous Training Manual COR002-27-03 - Service Water 12
71152B Miscellaneous Training Manual ESP00005027 -ESO System Training 2
71152B Miscellaneous Vendor Manual VM-1012, PRESRAY CORP, Reactor Building Doors R101 AND 10/25/2020
R102 (proprietary)
71152B Miscellaneous WT 2019-0040- Perform a thorough review of Operations Skill of the Craft
210 database which includes re-screening of all activities for
applicability.
71152B Procedures 0-CNS-FAP-LI- Performance Improvement Review Group (PRG) Process 4
001
71152B Procedures 0-CNS-LI-102 Corrective Action Process 07/29/2020
71152B Procedures 0-CNS-LI-104 Self-assessment and Benchmark Process 6
71152B Procedures 0-CNS-LI-118 Cause Evaluation Process 3
71152B Procedures 0-CNS-LI-121 Trending and Performance Review Process 4
71152B Procedures 0-CNS-OE-100 Operating Experience Program 02/03/2021
71152B Procedures 0-CNS-WM-100 Work Order Generation, Screening, and Classification 16
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Procedures 0-EBS-NOT SAP Notifications 29
71152B Procedures 0-EN-EP-306 Drills and Exercises 10C1
71152B Procedures 0-EN-HU-106 Procedure and Work Instruction Use and Adherence 3C2
71152B Procedures 0.4ENTERGY Entergy Procedure Processing 10/30/2019
71152B Procedures 0.5OPS Operations Review of Condition Reports/Operability 01/13/2021
Determination
71152B Procedures 15.RCIC.311 RCIC Control System Calibration Test 1
71152B Procedures 3-EN-DC-147 Engineering Reports 5C1
71152B Procedures 3-EN-DC-150 Condition Monitoring of Maintenance Rule Structures 6C4
71152B Procedures 3-EN-DC-306 Acceptance of Commercial-Grade Items/Services in Safety- 5C1
Related Applications
71152B Procedures 6.RCIC.102 RCIC IST and 92 Day Test 40
71152B Procedures Administrative Barrier Control Process 30
Procedure 0-
Barrier
71152B Procedures Administrative Identification and Trending of Rework 1
Procedure 0-
CNS-MA-123
71152B Procedures Administrative Operating Experience Program 9
Procedure 0-
CNS-OE-100
71152B Procedures Administrative Operating Experience Program 10/11/12
Procedure 0.10
71152B Procedures Administrative CNS Fire Protection Plan 81
Procedure 0.23
71152B Procedures EN-NS-221 Security Organization, Standards & Expectations 013
71152B Procedures EN-OE-100 Operating Experience Program 34
71152B Procedures Engineering Fabrication of Replacement Parts 14
Procedure 3.21
71152B Procedures Engineering MOV Overthrust/Overtorque Evaluation 9
Procedure 3.31
71152B Procedures Engineering Motor Operated Valve Program 27
Procedure 3.33
71152B Procedures Engineering Limitorque Actuator Configuration Control 6
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedure 3.33.6
71152B Procedures Engineering Fire Barrier Control 22
Procedure 3.6.1
71152B Procedures Maintenance HV Moore 353 Controller Configuration Download and Calibration 7
Procedure Check
14.HV.301
71152B Procedures Maintenance Pipe Penetration Seal Installation Using Gasket Placement 5
Procedure
7.2.78.2
71152B Procedures Maintenance MOV Diagnostics 13
Procedure 7.5.3
71152B Procedures System Standby AC Power System (Diesel Generator) 111
Operating
Procedure 2.2.20
71152B Procedures System HVAC Reactor Building 64
Operating
Procedure 2.2.47
71152B Procedures System REC Operations 84
Operating
Procedure
2.2.65.1
71152B Procedures System Service Water System 131
Operating
Procedure 2.2.71
71152B Radiation Work LO 2019-0202 Occupational ALARA Planning and Controls" (IP-71124.02) and 1/24/2020
Permits (RWPs) "Occupational Dose Assessment" (IP-71124.04)
71152B Self- LO 2019-00129- Work Control Self-Assessment 10/31/2019
Assessments 001
71152B Self- LO 2019-0124- Cycle 31 Road to Excellence Priority 1.1 - Nuclear Safety,
Assessments 004 Operations Management and Leadership, IER 17-5
recommendations and IER L3 19-005 self- assessment
71152B Self- LO 2019-0176- 2019 Cooper Crew Performance Evaluation
Assessments 001
71152B Self- LO 2020-0034- Operation Error Pre-Cursor SOER 10-2 Screen
Inspection Type Designation Description or Title Revision or
Procedure Date
Assessments 001
71152B Self- LO 2020-0034- Tagging Focused Self-Assessment
Assessments 010
71152B Self- LO 2020-0117- Cooper Nuclear Station Operations Training Effectiveness Review
Assessments 001
71152B Self- LO 2020-0126 Pre PI&R NRC Inspection Self-Assessment
Assessments
71152B Self- LO-2019-0201 2020 Inservice Inspection Program Self-Assessment 7/01/2020
Assessments
71152B Self- LO-2020-0095- Analysis on Worker Protection Issues 11/17/2020
Assessments 020
71152B Self- QA Audit 19-04 Maintenance 07/11/2019
Assessments
71152B Self- QA Audit 19-07 Chemistry, Effluent and Environmental Monitoring 10/07/2019
Assessments
71152B Self- QA Audit 20-02 Corrective Action Program 05/20/2020
Assessments
71152B Self- QA Audit 20-04 Radiological Controls 08/19/2020
Assessments
71152B Work Orders 5219342,
5319879,
5336962
71152B Work Orders 5306957 (NRC Identified) Fire Seal Discrepancy 0
14