IR 05000298/2025403
| ML25153A593 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/11/2025 |
| From: | Jesse Rollins NRC/RGN-IV/DRSS/PSB |
| To: | Dia K Nebraska Public Power District (NPPD) |
| References | |
| IR 2025403 | |
| Download: ML25153A593 (1) | |
Text
June 11, 2025
SUBJECT:
COOPER NUCLEAR STATION - SECURITY BASELINE INSPECTION REPORT 05000298/2025403
Dear Khalil Dia:
On May 10, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On May 27, 2025, 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.
One Severity Level IV violation without an associated finding 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. No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; 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, Jesse M. Rollins, Chief Physical Security Branch Division of Radiological Safety & Security Signed by Rollins, Jesse on 06/11/25 Docket No. 05000298 License No. DPR-46
Enclosure:
As stated
Inspection Report
Docket Number:
05000298
License Number:
Report Number:
Enterprise Identifier:
I-2025-403-0002
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, NE
Inspection Dates:
May 5, 2025, to May 10, 2025
Inspectors:
J. Allen, Physical Security Inspector
R. Lanfear, Physical Security Inspector
M. Stafford, Senior Resident Inspector
Approved By:
Jesse M. Rollins, Chief
Physical Security Branch
Division of Radiological Safety & Security
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Cooper Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Ensure That the Arrival and Presence of an NRC Inspector is Not Announced Unless Specifically Requested Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2025403-01 Open/Closed Not Applicable 71130.05 The inspectors identified a Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.70(b)(4) associated with the licensees failure to ensure the arrival and presence of an NRC inspector is not announced or otherwise communicated by its employees without a specific request by the NRC inspector. Specifically, during an NRC security inspection at the facility, a security officer alerted other security officers inside of a security post that an NRC inspector was coming. This adversely impacts the NRCs ability to perform its regulatory oversight function.
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) 2201, Security Inspection Program for Commercial Nuclear Power Reactors. 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.
SAFEGUARDS
71130.05 - Protective Strategy Evaluation
The inspectors evaluated the licensee's protective strategy through completion of the following
procedure elements: Protective Strategy Evaluation
- (1) Tier I: All Requirements Tier II: 17 Requirements (02.05a., 02.06a., c., f.-n., 02.07a.-e.)
Tier III: All Requirements
- (2) Performance Evaluation Program: The inspectors observed the licensees annual force-on-force exercise on May 9, 2025.
71130.14 - Review of Power Reactor Target Sets
The inspectors evaluated the Security Target Set Program. The following elements were evaluated:
Review of Power Reactor Target Sets
- (1) All Requirements (03.01 - 03.05)
INSPECTION RESULTS
Failure to Ensure That the Arrival and Presence of an NRC Inspector is Not Announced Unless Specifically Requested Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2025403-01 Open/Closed Not Applicable 71130.05 The inspectors identified a Severity Level IV NCV of 10 CFR 50.70(b)(4) associated with the licensees failure to ensure the arrival and presence of an NRC inspector is not announced or otherwise communicated by its employees without a specific request by the NRC inspector.
Specifically, during an NRC security inspection at the facility, a security officer alerted other security officers inside of a security post that an NRC inspector was coming. This adversely impacts the NRCs ability to perform its regulatory oversight function.
Description:
On May 6, 2025, while conducting a security baseline inspection at the Cooper Nuclear Station, an NRC security inspector was conducting checks of security posts inside the protected area. While the inspector was interviewing security officers and checking equipment inside of a security post, the door to that security post abruptly swung open and another security officer announced to everyone in the room that the NRC was coming. The security officer quickly recognized that his actions may not have been appropriate and self-reported the incident to security management at the site. Announcing the presence or arrival of an NRC inspector onsite impedes the NRCs ability to perform its regulatory oversight function.
Corrective Actions: When notified of the event, the licensee escorted the security officer offsite, placed their unescorted access on hold, conducted an investigation, and took personnel actions that the licensee deemed appropriate. The licensee also entered the incident into its corrective action program for review and notified its entire security organization about the incident, reinforcing its expectation that site personnel will not announce the NRCs presence onsite without NRC approval.
Corrective Action References: CR-CNS-2025-02232
Performance Assessment:
The inspectors determined this violation was associated with a minor Reactor Oversight Process (ROP) 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 using traditional enforcement to adequately deter non-compliance.
Severity: This issue was determined to be a Severity Level IV violation in accordance with the NRCs Enforcement Policy. The severity of the violation is consistent with NRC Enforcement Policy Section 2.2.2.d., which states that Severity Level IV violations are those that are less serious, but are of more than minor concern, that resulted in no or relatively inappreciable potential safety or security consequences.
Violation: 10 CFR 50.70(b)(4) requires that the licensee or construction permit holder (nuclear power reactor only) shall ensure that the arrival and presence of an NRC inspector, who has been properly authorized facility access as described in paragraph (b)(3) of this section, is not announced or otherwise communicated by its employees or contractors to other persons at the facility unless specifically requested by the NRC inspector.
Contrary to the above, on May 6, 2025, the licensee failed to ensure that the arrival and presence of an NRC inspector, who was properly authorized facility access as described in 10 CFR 50.70(b)(3), was not announced or otherwise communicated by its employees to other persons at the facility unless specifically requested by the NRC inspector. Specifically, without approval from the NRC inspector, a security officer informed other security officers onsite that an NRC inspector was in the area conducting inspection activities and was moving toward their location.
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 May 27, 2025, the inspectors presented the security baseline inspection results to Khalil Dia, Site Vice President, and other members of the licensee staff.
- On May 9, 2025, the inspectors presented a debrief of the inspection activities to Jeremy Allen, Security Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-2024-
00960, CR-CNS-
24-02833, CR-
CR-CNS-2025-
01994, CR-CNS-
25-01842, CR-
CR-CNS-2025-
2184
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-2025-
222, CR-CNS-
25-02232, CR-
CR-CNS-2025-
264, CR-CNS-
25-02273, CR-
CR-CNS-2025-
2317, CR-CNS-
25-06057
Miscellaneous
Training
Presentation
Force on Force Drill / Exercise Controller / Evaluator Training
0-SE-JPM-4.20
Mock Adversary Force Training
Cooper Nuclear
Station Physical
Security Plan
11/30/2023
Security
Procedure 2.13
Security Team Training and Exercises
Security
Procedure 2.14
Compensatory Measure
Procedures
Security
CAS/SAS Duties
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedure 2.3
Security
Procedure 2.4
Patrol Duties
Self-Assessments
QAD-2025-024
Security Programs
05/21/2025
Corrective Action
Documents
CR-CNS-2025-
242
Security Self-Assessment
01/15/2025
Corrective Action
Documents
Resulting from
Inspection
CR-CNS-2025-
242, CR-CNS-
25-02243, CR-
CR-CNS-2025-
248
Miscellaneous
Cooper Nuclear
Station Target
Sets
Target Sets
0-CNS-WM-106
Planning
0-SEC-
INTERFACE
Safety/Security Interface Screen
5.5SECURITY
Security
IP-ENG-001
Standard Design Process
Procedures
Security
Procedure 2.15
Development and Maintenance of Critical Target Sets
2