IR 05000298/2025010
| ML25121A266 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/06/2025 |
| From: | Ramirez-Munoz F NRC/RGN-IV/DORS/PBC |
| To: | Dia K Nebraska Public Power District (NPPD) |
| References | |
| IR 2025010 | |
| Download: ML25121A266 (1) | |
Text
May 06, 2025
SUBJECT:
COOPER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2025010
Dear Khalil Dia:
On April 17, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Cooper Nuclear Station and discussed the results of this inspection with John Dent, Executive Vice President and Chief Nuclear Officer, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
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 Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Frances C. Ramirez Munoz, Acting Team Lead Inspection Programs & Assessment Team Division of Operating Reactor Safety Docket No. 05000298 License No. DPR-46
Enclosure:
As stated
Inspection Report
Docket Number:
05000298
License Number:
Report Number:
Enterprise Identifier:
I-2025-010-0010
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, NE
Inspection Dates:
March 30 to April 17, 2025
Inspectors:
G. Birkemeier, Resident Inspector
C. Henderson, Senior Resident Inspector
G. Pick, Senior Reactor Inspector
S. Thapa, Reactor Inspector
Approved By:
Frances C. Ramirez Munoz, Acting Team Lead
Inspection Programs & Assessment Team
Division of Operating 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
Type Issue Number Title Report Section Status LER 05000298/2024-003-01 High Pressure Coolant Injection Steam Leak Causes Condition that Could Have Prevented Fulfillment of a Safety Function and a Condition Prohibited by Technical Specifications 71153 Closed
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review the high pressure coolant injection. The corrective actions for the following non-cited violations, minor violations, and findings were evaluated as part of the assessment, NCVs:
===2024401-02, 2024004-05, 2024004-04, 2024003-03, 2024003-02, 2024002 05, 2024002-04, 2024002-03, 2024002 02, 2024002-01, 2024001-03, 2024001-02, 2024001-01, 2023401-01, 2023010-01, 2023004-03, 2023004-02, 2023004 01, 2023002-02, and 2023002-01.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through 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.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)===
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 2024-003-01, High Pressure Coolant Injection Steam Leak Causes Condition that Could Have Prevented Fulfillment of a Safety Function and a Condition Prohibited by Technical Specifications, (ADAMS Accession No. ML25051A147). The inspectors reviewed the updated LER submittal. The previous LER submittal was reviewed in Inspection Report 05000298/2024002 with an associated Green, non-cited violation, NCV 05000298/2024002-04, (ML24206A141). This LER is closed.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Assessment:
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of problem identification, problem prioritization and evaluation, and corrective actions adequately supported nuclear safety.
Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensees 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.
The inspectors identified two observations in the area associated with condition report classification and root cause evaluation:
- Procedure 0-CNS-LI-102, Corrective Action Process, revision 18, attachment 1, Condition Report Classification Guidance, provides examples to assist with determining the level of consequence of conditions adverse to quality described in condition reports. One example of a High Consequence Issue is a condition causing an increase in core damage frequency = 1E-6/year or large early release frequency =
1E-7/year. However, the licensee lacks sufficient guidance to ensure probabilistic risk assessment insights are implemented in their condition report classification process.
The licensee entered this observation into their correction action program as Condition Report CR-CNS-2025-01974.
- The root cause evaluation for the high pressure coolant injection through-wall steam leak documented in Condition Report CR-CNS-2024-00768 failed to address the condition of the steam traps internal valve, which may have contributed to steam leaking past the trap, which resulted in the liquid droplet impingement of the pipe wall.
Specifically, a work order associated with steam trap maintenance in 2012 identified the internal valve was steam cut away but fails to clarify whether personnel replaced the component. Documentation for the historical performance of the preventative maintenance lacked details about the condition of the steam trap valve. The evaluation does not provide sufficient detail to understand the state of the steam trap internal valve, the deficiencies' impact on steam trap performance, nor does any record of the noted deficiency exist in the corrective action program. The licensee was able to provide the inspectors information associated with work order classification that required personnel to replace the high pressure drain valve internals and provided the action to revise Procedure 7.2.62.2, Yarway Model 515 BSWR Steam Trap Maintenance, to add a step to initiate a condition report and verify discrepancies are resolved. The licensee entered this observation into their corrective action program as Condition Report CR-CNS-2025-01972.
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 high pressure coolant injection 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 these systems that were not already being addressed by the station's monitoring and corrective action programs.
Assessment 71152B Self-Assessment and Audits:
The team reviewed a sample of Cooper Nuclear Station departmental self-assessments to assess whether performance trends were regularly identified and effectively addressed. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.
Assessment 71152B Operating Experience:
The team reviewed a variety of sources of operating experience including 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups. The team determined that Cooper Nuclear Station staff 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.
Assessment 71152B Safety-Conscious Work Environment:
The team conducted safety-conscious work environment (SCWE) interviews with 44 employees from four different disciplines that included maintenance, engineering, operations, and security. The purpose of these interviews was
- (1) to evaluate the willingness of the licensees 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 licensees SCWE. The team also observed interactions between employees during plant meetings. The team interviewed the Employee Concerns Program Manager and reviewed the results of the latest safety culture surveys and a sample of case files that may relate to SCWE.
The team found that the licensee had a SCWE where individuals felt free to raise concerns without fear of retaliation. Most expressed positive experiences after raising issues to their supervisors and after documenting issues in condition reports, and all individuals indicated that they would not hesitate to raise safety concerns, through at least one of the several means available at the station.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified that no proprietary information was retained or documented in this report.
- On April 17, 2025, the inspectors presented the biennial problem identification and resolution inspection results to John Dent, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NEDC 09-044
MOV Stroke Time Effects Due to Diesel Frequency Variation
NEDC 20-017
Diesel Generator Room Temperature with Failure of CO2
Pressure Relief Dampers
Calculations
NEDC 23-018
Operability Calculation for Effects of Open HV Hatch on DG
Room Temperature
Corrective Action
Documents
CR-CNS-20YY-
NNNNN
2019-01277, 2022-03653, 2022-05293, 2022-05294,
22-05296, 2022-03656, 2022-03654, 2023-00436,
23-00454, 2023-01170, 2023-02274, 2023-02322,
23-02947, 2023-03409, 2023-03439, 2023-03473,
23-03497, 2023-03525, 2023-04559, 2023-04428,
23-02880, 2023-02793, 2023-02792, 2023-02698,
23-04775, 2023-04584, 2023-05194, 2023-05285,
23-04627, 2023-03679, 2023-03794, 2023-04939,
23-05227, 2023-02280, 2023-02332, 2023-04770,
23-03688, 2023-01066, 2023-01057, 2023-01034,
23-04582, 2024-01216, 2024-01082, 2024-01817,
24-01832, 2024-04192, 2024-00260, 2024-05323,
24-01035, 2024-01822, 2024-00655, 2024-00050,
24-00085, 2024-00463, 2024-03670, 2024-05660,
24-00286, 2024-00482, 2024-00561, 2024-00756,
24-01098, 2024-01135, 2024-01232, 2024-02230,
24-02385, 2024-02828, 2024-02861, 2024-02858,
24-02859, 2024-02860, 2024-02862, 2024-02863,
24-02864, 2024-03492, 2024-00019, 2024-05524
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-20YY-
NNNNN
25-01763, 2025-01771, 2025-01934, 2025-01971,
25-01972, 2025-01974, 2025-01975, 2025-01976,
25-01978
B&R 2020
Cooper Nuclear Station Flow Diagram Reactor Building
Heating and Ventilation
Drawings
B&R 2024 Sheet
Flow Diagram HVAC Misc. Service Building
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
B&R 2037
Cooper Nuclear Station Flow Diagram H&V Standby Gas
Treatment and Off Gas Filters
B&R 2040 Sheet
Cooper Nuclear Station Flow Diagram Residual Heat
Removal System
B&R 2040 Sheet
Cooper Nuclear Station Flow Diagram Residual Heat
Removal System Loop B
B&R 2044
High Pressure Coolant Injection and Reactor Feed Systems
DC 5547470
Turbine Stop Valve Limit Switches
DEC 5521738
Diesel Generator Intake HVAC Hatch Securing Screws
DEC 5535032
Additional Closure for Reactor Building Secondary
Containment Duct Exhaust Hatches
DEC 5545806
HVAC Hatch Redundant Restraints
DEC 5546702
Neutron Monitoring System Power Supply Mounting Screw
Replacement
Engineering
Changes
TE 10690879
Changes in SW-P-BP Materials of Construction
Cooper Nuclear Station 2024 Nuclear Safety Culture
Assessment
Cooper NSCA 2022 Nuclear Safety Culture Assessment
22
2A1382BA
Audit 23-01
Security Program
04/10/2023
Audit 23-02
Fire Protection
05/10/2023
Audit 23-04
Maintenance
07/17/2023
Audit 23-08
Fitness-for-Duty
11/28/2023
Audit 23-09
Training
2/28/2023
Audit 24-01
Engineering
03/27/2024
Audit 24-02
Corrective Action Program
06/17/2024
Audit 24-03
Technical Specifications and Operations
08/12/2024
LO-2022-0179
USA Work Management Self-Assessment 2023
LO-2023-0140
Adverse Trend Configuration Management (CR-CNS-2023-
01423)
LO-2023-0236
Response to NRC Question
Miscellaneous
LO-2024-0046
Pre PI&R NRC Inspection Self-Assessment
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LO-2024-0090
24 Site Excellence Plan
LO-2024-0157
Resolution of the 2024 Nuclear Safety Culture Assessment
Results and Actions
LO-2024-0163
24 Nuclear Safety Culture Assessment Weakness
LO-20YY-XXXX-
XXX
23-0005-003, 2023-0010-025, 2023-0010-029,
23-0010-033, 2023-0010-051, 2023-0010-062,
23-0015-011, 2023-0092-005, 2023-0093-001,
24-0007-096, 2024-0007-119, 2024-0007-120,
24-0007-122, 2024-0007-125, 2024-0007-129,
24-0133-001
VM 1034
NAMCO Composite Limit Switch and Connector Manual
VM 144
Service Water Booster Pumps
VN 1549
Lambda Power Supply and Rack Adapters Composite
Material
08/27/2024
WT-2020-0013-
019
Preventive Maintenance Program Department: EFIN
WT-2023-0002-
2
Determine correct position for valve
WT-20YY-XXXX-
XXX
2019-0034-009, 2023-0015-011, 2023-0015-072,
23-0031-062, 2023-0031-099, 2023-0031-112,
23-0043-006, 2024-0004-001, 2024-0013-018
0-Barrier-MISC
Miscellaneous Buildings
0-Barrier-Reactor
Reactor Building
0-CNS-FAP-LI-
001
Performance Improvement Review Group (PRG) Process
0-CNS-HU-102
Human Performance Traps and Tools
0-CNS-LI-102
Corrective Action Process
0-CNS-LI-108--01
CFR 21 Evaluations and Reporting
0-CNS-LI-118
Cause Evaluation Process
0-CNS-LI-121
Trending and Performance Review Process
0-CNS-QV-136
Nuclear Safety Culture Monitoring
0-CNS-WM-002
Critical Evolutions
0-CNS-WM-100
Work Order Generation, Screening, and Classification
Procedures
0-CNS-WM-102
Work Implementation and Closeout
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0-CNS-WM-104
On-Line Schedule Risk Assessment
0-EN-DC-105
Configuration Management
4C0
0.1.NUC.Safety
Nuclear Safety and Management Expectations
0.26
Surveillance Program
0.31
Equipment Status Control
101
0.4
Procedure Change Process
0.40
Work Control Program
0.48.1
Differing Professional Opinion Resolution Process
14.2.1.1
APRM, LPRM, RBM, and Flow Unit Power Supply
Calibration and Examination (Div 1)
2.2.47
HVAC Reactor Building
2.4HVAC
Building Ventilation Abnormal
3-CNS-DC-112
Engineering Change Request and Project Initiation Process
3-CNS-DC-141
Design Inputs
3-CNS-DC-203
3-CNS-DC-204
Maintenance Rule Scope and Basis
3-CNS-DC-205
Maintenance Rule Monitoring
3-CNS-DC-206
Maintenance Rule (a)(1) Process
3-CNS-DC-207
Maintenance Rule Periodic Assessment
3-CNS-DC-324
Preventative Maintenance Program
3-EN-DC-115
Engineering Change Process
6.1APRM.305
ARPM System (Flow Bias and Startup) Channel Calibration
(Div 1)
6.1RBM.302
RBM Channel Calibration (Div 1)
6.1RHR.201
RHR Power Operated Valve Operability Test (IST) (Div 1)
6.2HV.602
Air Flow Test of Fan Coil Unit HV-DG-1D (Div 2)
6.2RHR.201
RHR Power Operated Valve Operability Test (IST) (Div 2)
6.RPS.302
Main Turbine Stop Valve Closure and Steam Valve
Functional Test
6.RPS.303
Turbine Stop Valve Closure Channel Calibration
7.0.1.7
Troubleshooting Plant Equipment
7.0.4
Conduct of Maintenance
7.0.5
CNS Post-Maintenance Testing
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
7.2.14
RHR SWBP Overhaul and Replacement
7.3.25.1
NAMCO EA740 Series Limit Switch Maintenance
IP-ENG-001
Standard Design Process
1C0
JA-PI-03
OE Screening and Publishing
Work Orders
WO 5408016, 5425553, 5462978, 5483368, 5517702, 5520987,
21737, 5521738, 5529935, 5546110, 5546699, 5551156,
5552524