IR 05000298/2022004

Integrated Inspection Report 05000298/2022004

ML23024A125
Person / Time
Site:	Cooper
Issue date:	01/30/2023
From:	Jeffrey Josey NRC/RGN-IV/DORS/PBC
To:	Dia K Nebraska Public Power District (NPPD)
References
IR 2022004
Download: ML23024A125 (33)

Text

January 30, 2023

SUBJECT:

COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2022004

Dear Khalil Dia:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On January 5, 2023, the NRC inspectors discussed the results of this inspection with John Dent, Chief Nuclear Officer, and other members of your staff.

The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Two Severity Level IV violations without an associated finding are also documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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 violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Cooper Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Cooper Nuclear Station. 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, Signed by Josey, Jeffrey on 01/30/23 Jeffrey E. Josey, Chief Projects Branch C Division of Operating Reactor Safety Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number: 05000298 License Number: DPR-46 Report Number: 05000298/2022004 Enterprise Identifier: I-2022-004-0010 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, NE Inspection Dates: October 1, 2022, to December 31, 2022 Inspectors: K. Chambliss, Senior Resident Inspector J. Drake, Senior Reactor Inspector N. Greene, Senior Health Physicist E. Simpson, Health Physicist Approved By: Jeffrey E. Josey, Chief Projects Branch C Division of Operating Reactor Safety 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. A licensee-identified, non-cited violation is documented in the Inspection Results section.

List of Findings and Violations

Failure to Provide Complete and Accurate Information in the 2021 Annual Radioactive Effluent Release Report Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71124.06 NCV 05000298/2022004-01 Open/Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.9(a) for the licensee providing inaccurate information to the Commission in the 2021 Annual Radioactive Effluent Release Report. Specifically, the licensee failed to report all periods of inoperability of greater than 31 days for their elevated release point effluent monitor, as required by their Offsite Dose Assessment Manual for Gaseous and Liquid Effluents. In the licensee's 2021 Annual Radioactive Effluent Release Report, they inaccurately reported that there was only one period of inoperability (associated with this monitor's process flow measuring device),

which was a failure to include the other periods of inoperability for the annual period.

Inadequate Procedure for High-Pressure Coolant Injection Testing Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71153 NCV 05000298/2022004-02 Management Open/Closed The inspectors are documenting a self-revealed finding of very low safety significance (Green)and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions,

Procedures, and Drawings," for the licensees failure to have a procedure appropriate to the circumstance for surveillance testing of the high-pressure coolant injection system.

Specifically, the licensees procedure for testing the high-pressure coolant injection system during reactor startup did not appropriately reset high-pressure coolant injection breaker logic resulting in an inadvertent injection of high-pressure coolant injection into the reactor which caused neutron flux to quickly rise leading to an automatic reactor scram.

Condition Prohibited by Technical Specifications Due to High-Pressure Coolant Injection Minimum Flow Valve Operating Outside of Surveillance Requirement Allowable Value Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000298/2022004-03 Open/Closed The inspectors are documenting a self-revealed, Severity Level IV non-cited violation of Cooper Nuclear Station technical specifications for failing to meet/follow Limiting Condition for Operation 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, and Limiting Condition for Operation 3.5.1, Emergency Core Cooling System (ECCS), RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System. Specifically, the licensee discovered through as-found test results that a flow indicating switch failed to open the high-pressure coolant injection low flow valve within the technical specification surveillance requirement allowable value, rendering the associated instrument inoperable.

The inoperability period was greater than allowed by technical specification limiting condition for operation 3.3.5.1 and 3.5.1.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000298/2021-003-00 Failure of High-Pressure 71153 Closed Coolant Injection Flow Indicating Switch Results in Condition Prohibited by Technical Specifications

PLANT STATUS

Cooper Nuclear Station began the inspection period in a scheduled refueling outage. The station performed a reactor startup on November 12, 2022, ending the outage. The unit was automatically scrammed on November 12, 2022, due to high flux on the intermediate range monitors during startup resulting from unplanned injection of high-pressure coolant. The unit reached rated thermal power on November 17, 2022. On November 17, 2022, the operators lowered power to 65 percent for a control rod sequence exchange. The unit reached rated thermal power on November 18, 2022. On December 15, 2022, the operators lowered power to 15 percent to repair a hydrogen leak on the main generator. The unit was manually scrammed on December 16, 2022, due a turbine generator bypass valve failing open. The unit reached rated thermal power on December 20, 2022. On December 21, 2022, the operators lowered power to 70 percent for a control rod sequence exchange. The unit reached rated thermal power on December 21, 2022. 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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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.

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:

secondary containment standby gas treatment fire protection service water residual heat removal

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) division 2 4160 Vac system on November 1, 2022

(2) high-pressure coolant injection on November 22, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) control building critical switchgear rooms, 932-foot 6-inch elevation, on October 8, 2022

(2) reactor building standby gas treatment room, 976-foot elevation, on October 12, 2022

(3) reactor building second floor, 931-foot 6-inch elevation, on October 12, 2022

(4) control building basement, 882-foot 6-inch elevation, service water booster pump area on November 2, 2022

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) auxiliary relay room on November 17, 2022

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 3, 2022, to October 6, 2022:

03.01.a - Nondestructive Examination and Welding Activities ultrasonic examination, UT-RE32-22-002, NB, PRA-BG1-1 thru PRA-BG1-52, reactor pressure vessel closure studs ultrasonic examination, UT-RE32-APR-01, RCA-BF-1, reactor pressure vessel nozzle to control rod drive cap visual examination, VT-IWE32-22-003, PC, drywell, drywell containment liner accessible surfaces visual examination, IVVI, SD-270B5-HS-A2, Gusset, 275 degrees visual examination, IVVI, lifting lug, SD-LR 35 visual examination, IVVI, lifting lug, SD-LR145 visual examination, IVVI, lifting lug, SD-LR 215 visual examination, IVVI, lifting lug, SD-LR 325 visual examination, IVVI, tie bars, SD-B4B3-TB 3, 4, 5, 6, 7 dye penetrant examination, CS-RV-13RV, core spray, valve to pipe, FW-1 dye penetrant examination, CS-RV-13RV, core spray, pipe to valve, FW-2 dye penetrant examination, CS-RV-13RV, core spray, pipe to elbow, FW-3 dye penetrant examination, CS-RV-13RV, core spray, elbow to pipe, FW-4 the following welding activities were observed and/or records reviewed: gas tungsten arc welding (GTAW), work order 5463897, main steam drain line, weld 2, GTAW, work order 5463897, main steam drain line, weld 5, GTAW, work order 5463897, main steam drain line, weld 6 Problem Identification and Resolution The inspector evaluated a sample of six condition reports associated with in-service 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)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during down power at the beginning of the refueling outage on October 1, 2022.

(2) The inspectors observed and evaluated licensed operator performance in the control room during startup from the refueling outage on November 12, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) instrument air function IA-F01 return to (a)(2) status on November 4, 2022

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structure, system, or component remains capable of performing its intended function:

(1) quality control for electrical maintenance activities including installation of emergency station service transformer, safety-related relay replacement, and safety-related overload heater replacement on November 10, 2022

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) planned Yellow shutdown risk with the emergency station service transformer and supplemental diesel generator unavailable on October 5, 2022

(2) planned Yellow shutdown risk during 4160 Vac G bus outage and division 2 balance of plant work windows on October 13, 2022

(3) planned Yellow shutdown risk during reactor pressure vessel pressure testing on October 31, 2022

(4) planned Yellow shutdown risk during division 1 emergency diesel generator sequential load test on November 6, 2022

(5) planned Yellow online risk during 4160 V bus 1G relay test on November 22, 2022

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) damaged and mislabeled cables for 4160 Vac breaker 1GS on October 15, 2022

(2) foreign material found during initial drywell entry for refueling outage on October 17, 2022

(3) initiation of core spray A due to lowering skimmer surge tank level on October 31, 2022

71111.18 - Plant Modifications

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

(3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) residual heat removal division 2 automatic interlock bypass switches on October 13, 2022

(2) emergency station service transformer replacement testing on October 13, 2022

(3) control rod drive scram discharge volume vent valve CRD-V-275 replaced with different model on October 13, 2022

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were updated in accordance with the boiling-water reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (11 Samples)

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

(1) reactor protection system motor generator B and electrical protection assembly 1B1 and 1B2 maintenance window post work testing on October 2, 2022

(2) 4160 Vac breaker 1GS test control switch post installation testing on October 15, 2022

(3) emergent post work test of source range monitor D on October 18, 2022

(4) emergency station service transformer replacement testing on October 21, 2022

(5) core spray pressure isolation valve CS-MOV-MO12B post leak rate testing on October 31, 2022

(6) post repair vibration testing of 4160 Vac breaker 1FS panel on October 31, 2022

(7) post installation testing of plant temporary modifications for RHR-MO-27B relays on November 14, 2022

(8) residual heat removal division 1 post maintenance window testing on November 14, 2022

(9) replacement of root valve HPCI-V-2795 on November 28, 2022

(10) post motor operator re-installation testing of valve RCIC-MOV-21 on November 28, 2022

(11) post motor operator maintenance testing for drywell exhaust inboard isolation valve PV-MOV-231MV on November 29, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage 32 activities from October 1, 2022, to November 16, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) local leak rate test for high-pressure coolant injection steam inlet containment isolation valve MO-15 on October 8, 2022

(2) source range monitor division 1 weekly functional test on October 19, 2022

(3) supplemental diesel generator operability test on October 21, 2022

(4) residual heat removal valve operability in service test on October 21, 2022

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) local leak rate test for high-pressure coolant injection steam inlet containment isolation valve MO-16 on October 8,

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 how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) surveys of potentially contaminated packages/equipment from the radiologically controlled area and workers exiting potentially contaminated areas

(2) the physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) medium risk (high radiation area) radiological work and job coverage for dryer separator strongback maintenance (radiation work permit (RWP) 2022-545, surveillance 5465386)

(2) medium risk (high radiation area) radiological work and job coverage for traversing in-core probe ball shear valve assembly maintenance (RWP 2022-537, work order 5382615)

(3) high risk (locked high radiation area) radiological work and job coverage for main steam isolation valve repairs (RWP 2022-559, work order 5465451)

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) radioactive waste building, basement, spent resin tank room door B6

(2) radioactive waste building, basement, floor drain/waste collector tank room door B1

(3) reactor building, 931-foot elevation, reactor water clean-up pump room, doors A and B

(4) reactor building, 931-foot elevation, phase separator pump room gate 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.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) technical support center/operational support center emergency ventilation system

(2) control room emergency ventilation system

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) high efficiency particulate air filter system set up on the refuel floor for troubleshoot work on the moisture separator strongback

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Shipment Preparation (IP Section 03.04)

(1) The inspectors observed the preparation of radioactive shipment 22-10E, UN2912, radioactive material, low-specific activity (LSA-1), fissile-excepted, 7, dated October 19,

OTHER ACTIVITIES - BASELINE

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

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) ===

(1) October 1, 2021, through September 30, 2022 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) October 1, 2021, through September 30, 2022

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) emergency diesel generator 1 service water strainer long term impact on operability on November 4, 2022

(2) standby liquid control area heaters staged for greater than 90 days without a process applicability determination (PAD) performed on November 25, 2022

(3) design change resulting from high-pressure coolant injection 250 Vdc loss-of-voltage relay failures on November 30, 2022

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated the automatic reactor scram due to intermediate range monitor high flux resulting from inadvertent high-pressure coolant injection during startup, and the licensees response on November 25, 2022.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000298/2021-003-00, Failure of High Pressure Coolant Injection Flow Indicating Switch Results in Condition Prohibited by Technical Specifications (ML21361A084). The circumstances surrounding this LER and a Severity Level IV non-cited violation is documented in the Inspection Results section of this report.

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Violation: License condition 2.C(4) requires, in part, that, NPPD shall implement and maintain in effect all provisions of the approved fire protection program.

Cooper Nuclear Station (CNS) Procedure 0.23, Fire Protection Plan, attachment 1, states, in part, Compensatory actions are implemented when [fire protection] systems, features, or components and other systems credited by the [fire protection program] cannot perform their intended function and limits on impairment duration are established.

CNS Procedure 0-Barrier, Barrier Control Process, sections 5.2.1.2 and 5.2.1.3 state, in part, Compensatory measure for FP1 [fire protection 1] barriers are identical to those in the TRM [Technical Requirements Manual] (with the exception of prescribed reporting requirements) and shall be implemented within the time frames for TRM barriers. The compensatory measures established by the TRM shall be implemented prior to breaching the fire barrier and in all cases (planned or unplanned) within the prescribed time period (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />)listed in the applicable TRM Limiting Condition for Operation (LCO).

CNS Procedure 0-Barrier-Reactor, Reactor Building, attachments 14 and 17, list door R104 as an FP1 door.

Contrary to the above, for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> on October 2, 2022, through October 3, 2022, the licensee obstructed fire door R104 and failed to implement compensatory actions as required by station procedures.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Appendix F, Fire Protection Significance Determination Process. The finding was determined to be within the Fire Prevention and Administrative Controls using attachment 1 and screened under attachment 2 as having a High Degradation rating for propping a door open. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609.04, Initial Characterization of Findings, and IMC 0609, appendix F, attachment 1, and determined the finding to be of very low safety significance (Green)because there was adequate automatic suppression system on one side of the fire door.

Corrective Action References: condition report CR-CNS-2022-04284 Failure to Provide Complete and Accurate Information in the 2021 Annual Radioactive Effluent Release Report Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71124.06 Applicable NCV 05000298/2022004-01 Applicable Open/Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.9(a) for the licensee providing inaccurate information to the Commission in the 2021 Annual Radioactive Effluent Release Report. Specifically, the licensee failed to report all periods of inoperability of greater than 31 days for their elevated release point effluent monitor, as required by their Offsite Dose Assessment Manual for Gaseous and Liquid Effluents. In the licensee's 2021 Annual Radioactive Effluent Release Report, they inaccurately reported that there was only one period of inoperability (associated with this monitor's process flow measuring device),which was a failure to include the other periods of inoperability for the annual period.

Description:

During the IP 71124.06 inspection in July 2022, NRC inspectors questioned information that was documented in the 2021 Annual Radioactive Effluent Release Report (ARERR). In response, the licensee conducted a full review of the concerns presented. Per technical specification (TS) 5.5.4 for the licensee's Radioactive Effluent Controls Program, which is controlled by their Offsite Dose Assessment Manual (ODAM), it was identified that all requirements of section D 3.3.2 for the ODAM were not met. Specifically, the failure to include all periods of inoperability for the elevated release point (ERP) monitor in the 2021 ARERR resulted in a violation of NRCs 10 CFR 50.9(a).

In 2020 and 2021, there were instances of inoperability for the ERP noble gas activity monitor (per D 3.3.2-4.a), the ERP iodine sample cartridge (per D 3.3.2-4.b), the ERP particulate sample filter (per D 3.3.2-4.c), and the ERP sampler flow rate measuring device (per D 3.3.2-4.e), which occurred from December 4, 2020, to February 12, 2021. These inoperability periods for the ERP monitor were NOT documented in the 2021 ARERR, as required by ODAM, action B.2.2 per D 3.3.2, condition B. Relative to these periods of inoperability, the licensee did confirm that no compensatory actions were missed, and NRC reviewed the log of these actions to verify.

However, the failure to provide complete and accurate information in the 2021 ARERR impeded the regulatory process by impacting the inspection scope and focus of the applicable inspection objectives within the radiation safety area.

The licensee states the failure to identify these instances for inclusion to the 2021 ARERR occurred because licensee personnel misidentified when the conditions of inoperability were restored, and concluded they were restored within 31 days, but they were not.

Corrective Actions: The licensee reviewed the information, enhanced their procedural requirements, and plans to submit an errata to their 2021 Annual Radioactive Effluent Release Report.

Corrective Action References: condition reports CR-CNS-2022-04111 and CR-CNS-2022-04112

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Specifically, based on NRC's review per the significance determination process, the violation associated with the failure to provide complete and accurate information to the NRC did not adversely impact the Public Radiation Safety Cornerstone, but did impact the regulatory process, and is being addressed via the traditional enforcement process.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: This issue was determined to be a Severity Level IV (SLIV), non-cited violation consistent with NRCs Enforcement Policy, dated January 15, 2020, Section 2.3.11, "Inaccurate and Incomplete Information," and Section 6.9.d.1, Inaccurate and Incomplete Information for Failure to Make a Required Report. The NRC Enforcement Policy states the violation is a SLIV if a licensee fails to make a required report that had it been submitted would have resulted in, for instance, increasing the inspection scope of the next regularly scheduled inspection.

There are no cross-cutting aspects associated with a traditional enforcement violation.

Violation: Title 10 CFR 50.9(a) requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects.

Contrary to this requirement, on April 30, 2022, in the licensees submission of the 2021 Annual Radioactive Effluent Release Report to the NRC, the licensee failed to provide complete and accurate information. Specifically, the licensee failed to include all periods of inoperability for the ERP monitor during the 2021 annual period.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Inadequate Procedure for High-Pressure Coolant Injection Testing Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71153 NCV 05000298/2022004-02 Management Open/Closed The inspectors are documenting a self-revealed finding of very low safety significance (Green) and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to have a procedure appropriate to the circumstance for surveillance testing of the high-pressure coolant injection system. Specifically, the licensees procedure for testing the high-pressure coolant injection system during reactor startup did not appropriately reset high-pressure coolant injection breaker logic resulting in an inadvertent injection of high-pressure coolant injection into the reactor which caused neutron flux to quickly rise leading to an automatic reactor scram.

Description:

On November 12, 2022, during reactor startup, the licensee performed licensee Procedure 6.HPCI.313, HPCI (= 165 PSIG) Beginning of Cycle Test, revision 39. This procedure directs the licensee to insert and remove a simulated actuation signal into the high-pressure coolant injection (HPCI) system breaker logic. While performing step 4.87.3 to restore starter power to valve HPCI-MO-19 (HPCI injection valve), the HPCI system injected into the reactor and caused an automatic reactor scram on intermediate range high flux. This was documented in the licensees corrective action program as condition reports CR-CNS-2022-06139 and CR-CNS-2022-06143.

On April 19, 2021, the licensee implemented a design modification (DC 5319938) to remove a loss-of-voltage relay and its associated contacts from eight valves in the HPCI system, including valve HPCI-MO-19. After the modification, the system breaker logic changed due to the removal of a contact inside the 125 Vdc starter for the HPCI motor-operated valves. The licensee did not update procedures affected by this modification to reflect the new system breaker logic.

As part of the system alignment for the surveillance test, the 250 Vdc breaker that supplies power to valve HPCI-MO-19 was opened to prevent the valve from opening during the test.

During the surveillance test, the simulated HPCI activation signal sealed in an open signal for valve HPCI-MO-19. During restoration from the surveillance test, the 250 Vdc breaker for valve HPCI-MO-19 was closed restoring power to the valve. Once power was restored the sealed in open signal to the valve opened the valve. This resulted in the high-pressure coolant injection system sending cold water into the reactor which caused the neutron flux to quickly rise leading to an automatic reactor scram.

The inspectors reviewed the licensee's relevant procedures, design change packages, drawings, work orders, and corrective action documents and determined the following:

Station procedure 6.HPCI.313 failed to be appropriate to the circumstances for testing the high-pressure core injection system because it failed to properly reset the HPCI breaker logic to prevent injection of the HPCI system into the reactor core. This constituted a performance deficiency. Additionally, during the inspectors review it became apparent that the licensee did not have a process for evaluating and implementing the design change of removing the loss-of-voltage relay to ensure procedures affected by the design change were revised.

Corrective Actions: Immediately after the event, the licensee placed all procedures affected by the modification on hold until the licensee revised the procedures to provide guidance for resetting the HPCI breaker logic to prevent reoccurrence. The licensee is performing a root cause analysis to determine the factors that led to the missed procedure revision.

Additionally, the license performed a simulator fidelity run to inform their evaluation of the plant response.

Corrective Action References: condition reports CR-CNS-2022-06139 and CR-CNS-2022-06143

Performance Assessment:

Performance Deficiency: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The inspectors determined that station failed to ensure procedure 6.HPCI.313 to be appropriate to the circumstance for testing the HPCI system and was therefore a performance deficiency. Specifically, the licensees procedure for testing the high-pressure core injection system during reactor start up did not appropriately reset HPCI breaker logic resulting in an inadvertent injection of the HPCI system into the reactor.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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 licensee failed to provide a procedure to reset HPCI breaker logic resulting in an inadvertent injection of the HPCI system into the reactor which caused an automatic reactor scram.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green) because although it caused a reactor trip it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Specifically, the licensee did not use a systematic approach when implementing design change 5319938 resulting in a procedure that could affect nuclear safety.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.

The licensee established station Procedure 6.HPCI.313, "HPCI (= 165 PSIG) Beginning of Cycle Test," revision 39, as the implementing procedure for surveillance testing, an activity affecting quality.

Contrary to the above, on November 12, 2022, the licensee failed to have a procedure appropriate to the circumstance for surveillance testing of the high-pressure coolant injection system. Specifically, the licensee failed to ensure the procedure for testing the high-pressure coolant injection system during reactor startup appropriately reset HPCI breaker logic resulting in injection of HPCI system into the reactor vessel which led to an automatic reactor scram.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Condition Prohibited by Technical Specifications Due to High-Pressure Coolant Injection Minimum Flow Valve Operating Outside of Surveillance Requirement Allowable Value Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000298/2022004-03 Applicable Open/Closed The inspectors are documenting a self-revealed, Severity Level IV non-cited violation of Cooper Nuclear Station technical specifications for failing to meet/follow Limiting Condition for Operation 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, and Limiting Condition for Operation 3.5.1, Emergency Core Cooling System (ECCS), RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System. Specifically, the licensee discovered through as-found test results that a flow indicating switch failed to open the high-pressure coolant injection low flow valve within the technical specification surveillance requirement allowable value, rendering the associated instrument inoperable.

The inoperability period was greater than allowed by technical specification limiting condition for operation 3.3.5.1 and 3.5.1.

Description:

Licensee Event Report 05000298/2021-003-00, Failure of High-Pressure Coolant Injection Flow Indicating Switch Results in Condition Prohibited by Technical Specifications, (ML21361A084), was associated with the high-pressure coolant injection (HPCI) flow indicating switch (HPCI-FIS-78) being over-ranged after initial calibration that resulted in the HPCI pump discharge flow - low (bypass) going below the 490 gallons per minute allowable value. This was discovered October 28, 2021, during surveillance testing.

The licensee determined that this flow indicating switch was inoperable from September 21, 2021, to October 31, 2021, and the HPCI system was subsequently inoperable from October 5, 2021, to October 31, 2021. This event was documented in the licensees corrective action program as condition report CR-CNS-2021-05067.

The licensee determined that the new flow indicating switch for the HPCI pump discharge flow - low (bypass) installed on July 27, 2021, was over-ranged during a full flow HPCI surveillance on September 14, 2021. The surveillance caused the flow indicating switch setpoints to drift due to plastic deformation of the bellows when over-ranged for the first time.

The setpoint drift prevented the pump discharge flow - low (bypass) from reaching the allowable value of greater than or equal to 490 gpm resulting in HPCI instrumentation for the pump discharge flow - low (bypass) being inoperable. The potential for setpoint drift of the limit switch after over-ranging was not a previously published characteristic nor identified in any vendor manual or industry operating experience.

The inspectors reviewed the licensee event report and associated documentation and determined the following:

As a result of the HPCI pump discharge flow - low (bypass) instrumentation becoming inoperable, the required actions for technical specification (TS) 3.3.5.1 and 3.5.1 were not met within the allowed outage time. Specifically:

Limiting condition for operation (LCO) 3.3.5.1, condition A, requires that for one or more channels inoperable, enter the condition referenced in table 3.3.5.1-1 for the channel. From table 3.3.5.1, function 3.f for high pressure core injection pump discharge flow - low (bypass)stated that condition E be entered. Condition E requires restoring the channel to an operable status within 7 days. Condition H requires, required action and associated completion time condition E not met, declare associated supported feature(s) inoperable. In this case, the supported feature was the high-pressure coolant injection system.

LCO 3.5.1, condition C, requires that for the HCPI system inoperable, verify by administrative means reactor core isolation cooling (RCIC) system is operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and restore HPCI system to operable status within 14 days. Condition G, requires, required action and associated completion time condition C not met, be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to less than or equal to 150 psig in 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.

Based on the information reviewed by the inspectors, they determined that there was no performance deficiency associated with the limit switch since the licensee could not have reasonably foreseen and prevented the issue of potentially over-ranging of the bellows based on the existing information available to the licensee at the time of limit switch installation; however, a violation of TS 3.3.5.1 and 3.5.1 had occurred.

Corrective Actions: The licensee contacted the vendor to determine the cause of the set point drift. The licensee then calibrated the flow indicating switch with the as-left tolerance, followed by an over-range pressure equivalent to the HPCI system at full flow for 45 minutes, then tested it and found it to be within the as-left tolerance. The licensee also incorporated the operating experience into their calibration procedure and their copy of the vendor manual.

Corrective Action References: condition report CR-CNS-2021-05067

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee, and therefore, is not a performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: The inspectors reviewed this issue in accordance with Inspection Manual Chapter (IMC) 0612 and the Enforcement Manual. Reactor violations without a performance deficiency are dispositioned using the traditional enforcement process. The inspectors reviewed section 6.1.d.1 of the Enforcement Policy and determined this violation was Severity Level IV because it was a failure to comply with a TS action requirement for an LCO in TS, section 3.0.

Violation: Cooper TS LCO 3.3.5.1, Emergency Core Cooling System (ECCS)

Instrumentation, requires that the ECCS instrumentation for each function in table 3.3.5.1-1 shall be OPERABLE.

Condition A, One or more channels inoperable, required action A.1, Enter the condition referenced in table 3.3.5.1-1 for the channel completion time, Immediately.

Condition E, As required by Required Action A.1 and referenced in Table 3.3.5.1-1, required action E.2, Restore channel to OPERABLE status, completion time, 7 Days.

Condition H, Required Action and associated Completion Time of Condition E not met, required action, Declare associated support feature(s) inoperable, completion time, Immediately.

Cooper TS LCO 3.5.1, ECCS operating, requires that each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

Condition C, HPCI system inoperable, required action C.1, Verify by administrative means the RCIC system is OPERABLE, completion time, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, AND C.2, Restore HPCI system to OPERABLE status, completion time, 14 days.

Condition G, Required Action and associated Completion Time of condition C not met, required action G.1, Be in mode 3, completion time, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, AND G.2, Reduce reactor steam dome pressure to less than or equal to 150 psig, completion time, 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Contrary to the above, on September 14, 2021, when the limit switch was over-ranged, the licensee was unable to perform remedial actions for greater than the allowed timeframes in TS LCO 3.3.5.1 and subsequently LCO 3.5.1 until the LCO could be met, resulting in a condition prohibited by TS.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On October 6, 2022, the inspectors presented the inservice inspection results to John Dent, Site Vice President and Chief Nuclear Officer, and other members of the licensee staff.

On October 20, 2022, the inspectors presented the radiation safety inspection results to John Dent, Site Vice President and Chief Nuclear Officer, and other members of the licensee staff.

On January 5, 2023, the inspectors presented the integrated inspection results to John Dent, Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action CR-CNS- 2022-03769, 2022-06441

Documents

Procedures 0-CNS-FAP-WM- Seasonal Reliability 0

016

Work Orders WO 5361887

71111.04 Corrective Action CR-CNS- 2022-04525

Documents

Drawings CNS-FP-216 Rx Bldg. Critical Switchgear Rm. 1F Elevation 932-6 4

CNS-FP-217 Rx Bldg. Critical Switchgear Rm 1G Elevation 932-6 4

DWG-2044 High Pressure Coolant Injection and Reactor Feed Systems 77

Procedures 0.7.1 Control of Combustibles 42

2.2.33 High Pressure Coolant Injection System 91

2.2.33A High Pressure Coolant Injection System Component Checklist 33A

2.2.33B High Pressure Coolant Injection System Instrument Valve 9

Checklist

2.2A 4160.Div0 4160 VAC Non-Divisional Auxiliary Power Checklist 2

2.2A 4160.Div2 4160 VAC Auxiliary Power Checklist 2

71111.05 Fire Plans CNS-FP-218 Reactor Building - Second Floor Elevation 931-6 11

CNS-FP-222 Reactor Building Standby Gas Treatment Room Elevation 5

976

CNS-FP-224 Control Building Basement Floor Elevation 882-6 5

Procedures 0.7.1 Fire Zone Combustible Control Zone Levels 42

71111.06 Drawings DWG-944E689, Elementary Diagram (MOD) Low-Low Set 14

Sheet 1

Miscellaneous NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line Break 3

Procedures 0-BARRIER- Control Building 7

CONTROL

7.0.11 Flood Control Barriers 33

71111.08G Calculations NPD037.0200 NEDC 92-213, Local Penetration Area Pitting Acceptance 2

Criteria

Corrective Action CR-CNS- 2016-07398, 2018-06748, 2018-07303, 2018-07312, 2019-

Documents 00495, 2020-00914, 2020-04557, 2020-04620, 2020-04659,

Inspection Type Designation Description or Title Revision or

Procedure Date

20-04773, 2020-04807, 2020-04816, 2020-04858, 2020-

04914, 2020-04917, 2020-04964, 2020-04967, 2020-05076,

21-00857, 2022-00368, 2022-01655, 2022-01662,

Corrective Action CR-CNS- 2022-04405, 2022-04409, 2022-04430, 2022-04436, 2022-

Documents 04484, 2022-04645,

Resulting from

Inspection

Miscellaneous INR CNS RE32 IVVl-22-07 Surveillance Specimen Holder 10/14/2022

300° Indication Notification Report

Review of Structural Integrity Calculations 1400334.301 & 03/08/2018

1400334.302 for Code Case N-702 Relief Request

NLS2006051 Revision of Relief Request PR-02 06/15/2006

Cooper Nuclear Station, Docket No. 50-298, DPR-46

NLS2018012 Response to Nuclear Regulatory Commission Request for 03/14/2018

Additional Information for Relief Request RI5-03

Cooper Nuclear Station, Docket No. 50-298, License No.

DPR-46

NLS2018025 10 CFR 50.55a Relief Request RI5-03 Supplement Cooper 04/26/2018

Nuclear Station, Docket No. 50-298, DPR-46

NLS2019034 10 CFR 50.55a Relief Request RP5-02 and RI5-02, 06/28/2019

Revision 2

Cooper Nuclear Station, Docket No. 50-298, License No.

DPR-46

NLS20I707l 10 CFR 50.55a Relief Requests for Fifth Ten-Year Inservice 08/17/2017

Inspection Interval

Cooper Nuclear Station, Docket No. 50-298, License No.

DPR-46

SAP Notification 1189108

Procedures 20.A.100 Winter Radiographic Examinations of Welds General Requirements 1

1983

20.A.100-1986 Radiographic Examinations of Welds 0

20.A.131 Winter Radiographic Examinations of Welds 0

1983

20.F.071-1969 Radiographic Examinations of Welds 0

Inspection Type Designation Description or Title Revision or

Procedure Date

20.F.111-1972 Radiographic Examinations of Welds 0

2.A.100-1989 Ultrasonic Examination of Welds other than Pipe General 0

Requirements

2.A.101-1983 Ultrasonic Examination of Welds General Requirements 0

2.A.101-1989 Ultrasonic Examination of Pipe Welds General Requirements 0

2.A.131-1983 Ultrasonic Examination of Welds 0

2.A.700-1989A Ultrasonic Thickness Measurements 0

2.F.071-1970 Ultrasonic Examination of Welds 0

6.MISC.502 ASME CLASS 1 SYSTEM LEAKAGE TEST 57

7.7.10.2 P1-B Welding Procedure Specification 7

7.7.10.41 P1-P4_PWHT_ Welding Procedure Specification 4

7.7.10.41.1 P4-P1BG Welding Procedure Specification 2

7.7.10.41.2 P4-P1B Welding Procedure Specification 2

7.7.10.41.3 P4-P1B Welding Procedure Specification 0

7.7.10.44 P4-B Welding Procedure Specification 3

7.7.10.52 P5A-B Welding Procedure Specification 3

7.7.10.52.1 P5A-B _PWHT_ Welding Procedure Specification 0

7.7.10.6 P1-BG Welding Procedure Specification 5

7.7.10.7 P1-BG_CVN_ Welding Procedure Specification 6

7.7.11.1 AWS D1.1 Welding Procedure Specification 3

7.7.3.1 General Welding Standard for ASME And ANSI Code 7

Applications

7.7.3.2 General Welding Standard for Structural Steel CNS-GWS - 3

AWS D1.1

7.7.5.1 Welding Material Care, Storage, And Control Procedure CNS- 10

WFMC

7.7.6.1 Post-Weld Heat Treatment Procedure 2

GEH-PDI-UT-5 Ultrasonic examination of Studs 12.1

GEH-TP-110 Procedure for the Operation and Maintenance of the 3

Specimen Holder Installation and Removal Tooling

MT.CNS.1224 Magnetic Particle Examination 0

PT.CNS.1224 Liquid Penetrant Examination 1

QCP-9.1.6-CNS Visual Examination of Class MC Metal Containment 2

Inspection Type Designation Description or Title Revision or

Procedure Date

Components

Work Orders WO 5166166, 5288946, 5291972, 5292110, 5393362, 5463897

71111.11Q Corrective Action CR-CNS- 2022-06110, 2022-06114, 2022-06120, 2022-06121

Documents

Procedures 10.13 Control Rod Sequence and Movement Control 78

2.0.2 Operations Logs and Reports 123

2.1.1 Startup Procedure 203

2.1.4 Normal Shutdown 179

2.2.15 Startup Transformer 68

2.2.17 Emergency Station Service Transformer 77

6.REACT.603 Shutdown Margin, Evaluation 14

71111.12 Corrective Action CR-CNS- 2018-07259, 2020-05383, 2020-05430, 2020-05934, 2020-

Documents 06397, 2022-04914

Drawings DWG 2010, Flow Diagram Instrument Air Reactor Building 99

Sheet 2

Miscellaneous VM-0658 Conoflow Valves and Controls 17

VM-1030 Model 8SAA052 Valve Actuator 6

Procedures 12.1 CNS QC Program Description 30

2.5 CNS QC Functions 47

14.19.3.15 Pneumatic Instrument and Control Maintenance (Conoflow 2

GFH45XT1782G)

6.PC.312 PC-243AV/244AV Accumulator Functional Test 8

Work Orders WO 5316815, 5317501, 5369098, 5377352, 5403127, 5408577

71111.13 Miscellaneous Shutdown Safety Contingency Plan RE32-015, ESST & SDG

UNAVAILABLE - YELLOW WINDOW

Clearance Order EE-1-RE32 ESST-1 GROUNDS

Clearance Order EE-1-RE32 ESST-2 START WORK

Protected EE-1-EEST RE32 and EE-1-EEST RE32 - A

Equipment

Protected RHRB-1-RE32 RHR B SDC - D

Equipment

Protected RHRA-1-RE32 RHR SDC A PUMP

Equipment

Inspection Type Designation Description or Title Revision or

Procedure Date

Protected FPC-1-72HR to 200F (SW-P-C OOS)

Equipment

Procedures 0-CNS-52 Control of Switchyard and Transformer Activities at CNS 36

0-CNS-WM-102 Work Implementation and Closeout 17

3.3SAFE Safety Assessment 21

6.1DG.302 Undervoltage Logic Functional, Load Shedding, and 98

Sequential Loading Test (DIV 1)

6.2EE.306 4160V Bus 1G Undervoltage Relay Channel Functional Test 7

(DIV 2)

6.MISC.502 ASME Class 1 System Leakage Test 58

6.RCS.601 Technical Specification Monitoring of RCS Heatup/Cooldown 26

Rate

Work Orders WO 5403127

71111.15 Corrective Action CR-CNS- 2022-04203, 2022-04914, 2022-04933, 2022-05293, 2022-

Documents 05294, 2022-05296

Drawings DWG-2030, Fuel Pool Cooling and Clean-Up System 21

Sheet 1

DWG-2030, Fuel Pool Cooling and Clean-Up System 17

Sheet 2

DWG-2033, Low Conductivity (Equipment Drains) Processing 21

Sheet 1

DWG-2033, Low Conductivity (Equipment Drains) Processing 16

Sheet 3

DWG-3251, 4160V Switchgear Connection Wiring Diagram 27

Sheet 10

Work Orders WO 5403127

71111.18 Calculations NEDC 93-104 Emergency Transformer Permissive Relay CCN 8C1

Drawings 3010, Sheet 1 Vital One Line Diagram 85

Miscellaneous Change 4kV Breaker Auxiliary Switch Removal

Evaluation

Document CED

24460

Design Equivalent Replacement of 3/4 IN Crane Model 3605-XU Gate Valve in 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Change Package CRD System

DEC-4936133

Design Equivalent EOP PTM 97-100 Switches 0

Change Package

DEC-5229496

Engineering Emergency Station Service Transformer Replacement

Change Document

6039780

Procedures 5.8 Emergency Operating Procedures (EOPs) 48

5.9SAMG Severe Accident Management Guidance 16

71111.19 Corrective Action CR-CNS- 2012-09909, 2022-04194, 2022-04401, 2022-04559, 2022-

Documents 04746, 2022-04959, 2022-05046, 2022-05057, 2022-05068,

22-05072, 2022-05075, 2022-05088, 2022-05108, 2022-

05109, 2022-05111, 2022-05119, 2022-05159, 2022-05195,

22-05345, 2022-05777, 2022-05869, 2022-05914, 2022-

05958

Miscellaneous VM-0056 194X400G17 & 194X400G28 Source Range Monitor - SRM 11

VM-0227 Cast Steel Valves 75

VM-0633 Reactor Protection Electrical Protection Assembly 10

VM-2166 4160 Volt Vacuum Circuit Breakers Type GEH - 4.16KV 5

Procedures 2.2.17 Emergency Station Service Transformer 77

2.2.18.1 4160V Auxiliary Power Distribution System 6

6.1MISC.503 31 Day Venting of ECCS and RCIC Injection/Spray 10

Subsystem, Piping (DIV 1)

6.1PC.204 PC Purge and Vent Valve 24 Month Test (DIV 1) (IST) 4

6.1RHR.201 RHR Power Operated Valve Operability Test (IST) (DIV 1) 35

6.2CS.401 CS-MOV-MO12B And CS-CV-19CV Pressure Isolation Valve 13

Leak Rate Test (IST)

6.EE.610 Off-Site AC Power Alignment 48

6.MISC.401 Position Indicator Inservice Testing (IST) 22

6.PC.522 Standby Nitrogen Injection and PC Purge and Vent System 22

Local Leak Rate Tests

6.RCIC.201 RCIC Power Operated Valve Operability Test (IST) 32

6.RHR.301 RHR Initiation and Containment Spray Logic System 28

Inspection Type Designation Description or Title Revision or

Procedure Date

Functional Test

6.SRM.302 SRM Channel Functional Test (Reactor Not In Run With 19

Shorting Link Switches Closed) (DIV 2)

7.3.24.3 General Electric Type HEA (86) Relay Testing 9

Work Orders WO 4685506, 5370802, 5381522, 5382324, 5382375, 5382638,

5382733, 5382737, 5382738, 5387485, 5387662, 5387664,

5393872, 5395665, 5403084, 5403127, 5467634, 5467636

71111.20 Corrective Action CR-CNS- 2022-04559, 2022-04746, 2022-04914, 2022-04959, 2022-

Documents 05046, 2022-05057, 2022-05068, 2022-05072, 2022-05075,

22-05108, 2022-05109, 2022-05111, 2022-05119, 2022-

05136, 2022-05157, 2022-05158, 2022-05162, 2022-05190,

22-05330, 2022-05335, 2022-05345, 2022-05431, 2022-

05433, 2022-05470, 2022-05481, 2022-05490, 2022-05499,

22-05659, 2022-05695, 2022-06267

Miscellaneous Clearance Order EE-1-RE32 ESST-1 GROUNDS

Clearance Order EE-1-RE32 ESST-2 START WORK

Clearance Order EE-1-RE32 ESST-3 MODS POST FLD UP

Clearance Order EDC2-1-RE32 5392329 250V BATT REPL -

CNS Cycle 32 Core Operating Limits Report 0

CNS Cycle 33 Core Operating Limits Report 0

MFN 15-007 Safety Limit Minimum Critical Power Ratio 02/05/2015

Methodology, Global Nuclear Fuel

Procedures 0-CNS-52 Control of Switchyard and Transformer Activities at CNS 36

0-CNS-WM-102 Work Implementation and Closeout 17

0.50.5 Outage Shutdown-Safety 43

10.13 Control Rod Sequence and Movement Control 78

2.0.10 Primary Containment Access Control 36

2.1.1 Startup Procedure 203

2.1.1.1 Plant Startup Review and Authorization 29

2.1.1.2 Technical Specifications Pre-startup Checks 44

2.1.10 Station Power Changes 122

2.1.13 System Activity Coordination During Outages 41

2.1.20.2 Cycle Specific Fuel Transfer and Alternate Cooling Guideline 23

Inspection Type Designation Description or Title Revision or

Procedure Date

2.1.4 Normal Shutdown 179

2.1.6 Primary Containment Access Preparation and Closeout 21

Activities

2.2.17 Emergency Station Service Transformer 77

2.2.18.2 4160V Breaker Operations 9

2.2.22 Vital Instrument Power System 86

2.2.38.2 Portable Heating System 18

2.2.69.2 RHR System Shutdown Operations 112

2.2A_4160.DIV0 4160 VAC Non-Divisional Auxiliary Power Checklist 2

2.2A_4160.DIV2 4160 VAC Auxiliary Power Checklist (DIV 2) 2

2.4FPC Fuel Pool Cooling Trouble 40

2.4SDC Shutdown Cooling Abnormal 18

3.3SAFE Safety Assessment 21

5.10FLEX.11 Spent Fuel Pool Supply Flex Operations 5

5.3ALT- Alternate Core Cooling Mitigating Strategies 64

STRATEGY

5.8.23 Decay Heat Removal Methods 2

6.SC.603 Technical Specification Verification of Secondary 11

Containment Manual Valves and Blind Flanges

7.4DISASSEMBLY Reactor Vessel Disassembly 22

7.4REASSEMBLY Reactor Vessel Reassembly 22

7.6.1 Reactor Building Crane Operation 28

EOP-8D Decay Heat Removal (5.D) 1

Work Orders WO 5367049, 5381823, 5382320, 5382742,

71111.22 Corrective Action CR-CNS- 2022-05193

Documents

Procedures 6.1SRM.302 SRM Channel Functional Test (Reactor Not In Run With 19

Shorting Link Switches Closed) (DIV 1)

6.2RHR.201 RHR Power Operated Valve Operability Test (IST) (DIV 2) 37

6.MISC.401 Position Indicator Inservice Testing (IST) 22

6.SDG.101 SDG Test Mode Surveillance Operation 10

Work Orders WO 5382394, 5382698, 5403127

71124.01 Corrective Action CR-CNS- 2021-05122, 2022-00464, 2022-00687, 2022-00723, 2022-

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 00796, 2022-00903, 2022-01222, 2022-01669, 2022-01810,

22-01904, 2022-01960, 2022-02173, 2022-02326, 2022-

2437, 2022-02577, 2022-02971, 2022-03087

Corrective Action CR-CNS- 2022-05206, 2022-05205

Documents

Resulting from

Inspection

Miscellaneous Surveillance TIP Ball Shear Valve Assembly Maintenance 10/17/2022

5382615

Procedures 6.TIP.601 TIP Ball and Shear Valve Assembly Maintenance 13

8.ENN-RP-102 Radiological Control 3

9.ALARA.1 Dosimetry Administration 48

9.ALARA.5 ALARA Planning and Controls 27

9.EN-RP-100 Radiation Worker Expectations 19

9.EN-RP-110 ALARA Program 12

9.EN-RP-122 Alpha Monitoring 6

9.EN-RP-123 Radiological Controls for Highly Radioactive Objects 4

9.NISP-RP-02 Radiation and Contamination Surveys 2

9.NISP-RP-04 Radiation Protection Posting and Labeling 1

9.NISP-RP-05 Access Control for Radiologically Controlled Areas 1

9.RADOP.1 Radiation Protection at CNS 15

9.RADOP.2 Radiation Safety Standards and Limits 19

Radiation Surveys CNS-2210-0048 Drywell 901-foot Radiation Survey 10/17/2022

CNS-2210-0063 Drywell 901-foot Radiation Survey 10/17/2022

CNS-2210-0072 Reactor Building, 903-foot traveling in-core probe room 10/17/2022

survey

CNS-2210-0211 Steam Tunnel Radiation Survey 10/20/2022

CNS-2210-0258 Steam Tunnel Radiation Survey 10/20/2022

Radiation Work 2022-537 Miscellaneous Maintenance, Electrical, I/C, and Support in 00

Permits (RWPs) SWP areas22-545 Reactor Disassembly and Reassembly 00

22-559 MSIV Repairs 00

Self-Assessments Radiation Protection Program Annual Report (2021)

Inspection Type Designation Description or Title Revision or

Procedure Date

QAD 2022-0018 NIOS Audi 22-04, "Radiological Controls" 08/19/2022

Work Orders 5465386 Dryer Separator Strongback 10/18/2022

5465451 Repair MS-AOV-AO86A 10/20/2022

71124.03 Corrective Action CR-CNS- 2021-05145, 2021-05866, 2022-00401, 2022-00735, 2022-

Documents 01102, 2022-02961, 2022-03021, 2022-03147, 2022-03298,

22-03606, 2022-03608, 2022-03626, 2022-03633

Corrective Action CR-CNS- 2022-05174, 2022-05204

Documents

Resulting from

Inspection

Drawings 2019, Sheet 1, As Flow Diagram: Main Control Room, Cable Room, and 07/16/2015

Built 454003607 Computer Room Heating Ventilating and Air Conditioning

DGM-1381 Bauer Compressors, Inc., Unicus III / 4 Stage Compressor 05/12/2015

Miscellaneous ALARA TEDE Worksheet: 2022-05/Refuel Floor - 10/19/2022

Troubleshoot Moisture Separator Strongback

ALARA TEDE Worksheet: Non-package - Disposal of diakont 09/27/2022

hydrolazer hose from RE31

ALARA TEDE Worksheet: WO 5434851 - Repair/Replace 08/18/2022

FPC-FDEM-A Filters

SCBA Qualification Records 10/19/2022

441301-0 Laboratory Report - Compressed Air/Gas Quality Testing 03/09/2022

445796-0 Laboratory Report - Compressed Air/Gas Quality Testing 05/04/2022

5353473 Cooper Nuclear Station Maintenance Order: Replace Carbon 04/25/2022

Adsorbers on Standby Gas Treatment Unit B

CNS RP-136 Air Sample Assay: Reactor, 1001-foot elevation, top of shield 10/18/2022

blocks, dryer strongback repair

CNS RP-402 Cooper Nuclear Station Self-Contained Breathing Apparatus 2022

(SCBA) Functionals

CNS RP-402 Cooper Nuclear Station Self-Contained Breathing Apparatus 2021

(SCBA) Functionals

CNS RP-410 Cooper Nuclear Station Respirator Inspection 2021

CNS RP-410 Cooper Nuclear Station Respirator Inspection 2022

Contract NCS Corporation - Control Room Envelope In-Leakage 2022

200003562 Testing at Cooper Nuclear Station

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures 15.HV.102 TSC Emergency Ventilation Charcoal and HEPA Filter Leak 10

Test, Fan Capacity Test, and Charcoal Sampling

6.1SGT.501 SGT A Carbon Sample, Carbon Adsorber and HEPA Filter In- 18

Place Leak Test, and Components Leak Test (DIV 1)

6.2SGT.501 SGT B Carbon Sample, Carbon Adsorber and HEPA Filter In- 23

Place Leak Test, and Components Leak Test (DIV 1)

6.HV.104 Control Room Emergency Filter System Flow Test, Charcoal 19

and HEPA Filter Leak Test, Filter DP Test, and Charcoal

Sample Analysis

9.RESP.1 Respiratory Protection Program 19

9.RESP.2 Self-Contained Breathing Apparatus 29

9.RESP.5 Air Quality Monitoring 7

Radiation Surveys CNS RP-136 Steam Tunnel Radiation Air Sample Assay 10/20/2022

CNS RP-138 Beta/Alpha Radiation Smear Count Data Sheet 10/20/2022

CNS-2210-0226 Dryer Separator Strongback removed to replace two cylinders 10/15/2022

Radiation Work 2022-545 Reactor Disassembly and Reassembly 00

Permits (RWPs) 2022-549 Cavity Decon 00

Self-Assessments Radiation Protection Program Annual Report (2021) 05/12/2022

CNS RP-416 Nebraska Public Power District Cooper Nuclear Station 09/28/2021

Annual Respiratory Program Evaluation

QAD-2022-0018 NIOS Audit 22-04, "Radiological Controls" 08/19/2022

Work Orders 5299028 Control Room Emergency Filter System Flow Test, Charcoal 05/13/2021

and HEPA Filter Leak Test, Filter DP Test, and Charcoal

Sample Analysis

5301534 SGT A Carbon Sample, Carbon Adsorber and HEPA Filter In- 05/11/2021

Place Leak Test, and Components Leak Test (DIV 1)

5315890 TSC Emergency Ventilation Charcoal and HEPA Filter Leak 05/10/2021

Test, Fan Capacity Test, and Charcoal Sampling

5348812 SGT B Carbon Sample, Carbon Adsorber and HEPA Filter In- 08/25/2022

Place Leak Test, and Components Leak Test (DIV 1)

5353473 Replace Carbon Adsorbers, Standby Gas Treatment Unit B 08/25/2022

5419302 TSC Emergency Ventilation Charcoal and HEPA Filter Leak 09/12/2022

Test, Fan Capacity Test, and Charcoal Sampling

71124.06 Corrective Action CR-CNS- 2021-00019, 2022-04111, 2022-04112

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

Miscellaneous 2021 Radioactive Effluent Release Report 04/30/2022

Cooper Nuclear Station Offsite Dose Assessment Manual 04/01/2020

71124.08 Shipping Records22-10E UN2912, Radioactive Material, LSA-I, fissile-excepted, 7 10/19/2022

71151 Procedures 0-EN-LI-114 Performance Indicator Process 17C0

Self-Assessments NRC PI Occupation Exposure Control Effectiveness 07/01/2022

71152A Corrective Action CR-CNS- 2008-04200, 2010-02444, 2014-02718, 2015-02021, 2016-

Documents 02281, 2016-02753, 2017-03915, 2017-03917, 2017-03936,

2018-04652, 2018-07207, 2019-00630, 2019-00631, 2022-

00163, 2022-05579, 2022-05709, 2022-06139, 2022-06143,

22-06147, 2022-06154, 2022-06186, 2022-06442

Drawings DWG E501, Integrated Control Circuit Diagram HPCI-MOV-MO19 HPCI 2

Sheet 34A Injection Valve

DWG E501, Integrated Control Circuit Diagram HPCI-MOV-MO19 HPCI 3

Sheet 34A Injection Valve

Miscellaneous Design Change HPCI LOV Relay Removal 0

5319938

USAR VIII, Standby A-C Power Source

Section 5.0

Procedures 2.2.74 Standby Liquid Control System 58

6.HPCI.313 HPCI (</ 165 PSIG) Beginning of Cycle Test 39

6.HPCI.313 HPCI (</ 165 PSIG) Beginning of Cycle Test 40

Work Orders WO 4859646, 5002443

71153 Corrective Action CR-CNS- 2022-06139, 2022-06143

Documents

Drawings DWG E501, Integrated Control Circuit Diagram HPCI-MOV-MO19 HPCI 3

Sheet 34A Injection Valve

DWG E501, Integrated Control Circuit Diagram HPCI-MOV-MO19 HPCI 2

Sheet 34A Injection Valve

Miscellaneous Drawing Change HPCI LOV Relay Removal 0

5319938

Procedures 6.HPCI.313 HPCI (<=165 PSIG) Beginning of Cycle Test 39, 40

30