IR 05000298/2024001
| ML24121A143 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/03/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Dia K Nebraska Public Power District (NPPD) |
| References | |
| EA-24-029 IR 2024001 | |
| Download: ML24121A143 (26) | |
Text
May 03, 2024
SUBJECT:
COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2024001
Dear Khalil Dia:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On April 18, 2024, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.
In addition, the NRC determined that a violation of Title 10 of the Code of Federal Regulations (10 CFR) 21.21(d)(1) occurred. The violation involved the failure to report a defect associated with a substantial safety hazard for a service water booster pump seal. This violation was considered for escalated enforcement at Severity Level III per the NRC Enforcement Policy.
However, in reviewing the specific circumstances of this violation (i.e., the NRC resident staff was aware of the issue; there was little to no impact to the inspection process/regulatory process; the seals were only supplied to Cooper Nuclear Station and no other licensees; and your staff entered the issue into the corrective action program and submitted the 10 CFR Part 21 report) the NRC determined that it is more appropriately categorized as a Severity Level IV violation. Since the violation was entered into the corrective action program, corrected by your staff, not repetitive, and not willful, it is being treated as an NCV, consistent with section 2.3.2 of the NRC 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor 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:
Report Number:
Enterprise Identifier:
I-2024-001-0004
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, NE
Inspection Dates:
January 1, 2024, to March 31, 2024
Inspectors:
G. Birkemeier, Resident Inspector
K. Chambliss, Senior Resident Inspector
W. Schaup, Senior Project Engineer
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch C
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Cooper Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Incorporate Vendor Instructions Resulting in Residual Heat Removal Service Water Booster Pump Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2024001-01 Open/Closed
[H.14] -
Conservative Bias 71111.15 The inspectors are documenting a self-revealed finding of very low safety significance (Green)and an associated non-citied violation of Technical Specifications 5.4.1.a, "Instructions,
Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the work instructions for the rebuilding of residual heat removal service water booster pumps failed to incorporate vendor instructions directing the installation of the outboard thrust bearing.
Failure to Incorporate Vendor Instructions Resulting in Turbine Stop Valve Limit Switch Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2024001-02 Open/Closed
[H.5] - Work Management 71111.15 The inspectors are documenting a self-revealed finding of very low safety significance (Green)and an associated non-citied violation of Technical Specification 5.4.1.a, "Instructions,
Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment. Specifically, the work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor manual that would have prevented a failure of the limit switches.
Failure to Report Deviation of a Basic Component Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2024001-03 Open/Closed EA-24-029 Not Applicable 71153 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(d)(1) for the licensee's failure to properly evaluate the reportability of a deviation in a basic component. As a result, the licensee failed to report a deviation identified on September 14, 2022, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000298/2023-002-00 Secondary Containment Differential Pressure Perturbation Exceeds Technical Specifications 71153 Closed LER 05000298/2024-001-00 Inoperable Turbine Stop Valve Limit Switch Causes Condition Prohibited by Technical Specifications 71153 Closed LER 05000298/2024-002-00 Technical Specifications Prohibited Condition for Inoperable Service Water Booster Pump 71153 Closed
PLANT STATUS
Cooper Nuclear Station began the inspection period at rated thermal power. On January 3, 2024, power was lowered to approximately 60 percent for maintenance activities.
The plant returned to rated thermal power on January 4, 2024. On March 1, 2024, power was lowered to approximately 65 percent for a planned rod pattern adjustment. The plant returned to rated thermal power on March 2, 2024. The unit remained at rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk
-significant systems from impending severe weather due to multiple winter weather warnings and low river levels on March 1, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)division 2 standby liquid control on February 12, 2024 (2)division 2 residual heat removal on March 13, 2024 (3)division 2 reactor equipment cooling on March 29, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 battery and switchgear rooms, 903-foot 6-inch elevation, on February 6, 2024 (2)cable expansion room on March 11, 2024 (3)intake structure, 903-foot 6-inch elevation, on March 13, 2024 (4)division 1 emergency diesel generator room, 917-foot 6-inch and 903-foot 6-inch elevations, on March 13, 2024 (5)control building basement on March 22, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on March 25, 2024.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the reactor building southwest quadrant and high-pressure coolant injection room on March 21, 2024.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)division 1 emergency diesel generator lube oil and jacket water heat exchangers on February 23, 2024
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a quarterly down power for core management on February 28, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulator emergency preparedness scenario on February 12, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)reactor building heating, ventilation, and air conditioning maintenance hatch (a)(1)evaluation on March 14, 2024 (2)reactor protector system function RPS-F01A (a)(1) evaluation due to limit switch failure causing an unplanned power reduction on March 29, 2024 (3)emergency diesel generator heating, ventilation, and air conditioning maintenance hatch (a)(1) evaluation on March 29, 2024
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)risk assessment and management during emergency diesel generator 1 maintenance window on February 5, 2024 (2)emergent work due to unplanned inoperability of residual heat removal service water booster pump B on February 7, 2024 (3)planned Yellow online risk during residual heat removal division 2 outlet valve and emergency diesel generator division 2 maintenance window on February 22, 2024 (4)emergent work due to unplanned inoperability of 250 Vdc batteries on February 28, 2023 (5)emergent work due to potential through-wall leakage of high-pressure coolant injection piping on March 1, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)residual heat removal service water booster pump B high vibrations on February 9, 2024 (2)low temperatures inside 125 Vdc battery rooms on February 15, 2024 (3)emergency diesel fuel oil transfer pump auto-start on March 20, 2024 (4)main turbine generator stop valve limit switch loose linkages on March 29, 2024 (5)division 2 service water heat exchanger outlet valve stem galling on March 29, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)emergency diesel generator heating and ventilation hatch door modification on March 28, 2024 (2)division 1 250 Vdc battery temporary jumper installation due to second faulty cell on March 28, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
(1)division 2 residual heat removal maintenance window post-work testing on February 9, 2024 (2)residual heat removal service water booster pump B emergency maintenance and restoration testing on February 9, 2024 (3)division 1 250 Vdc battery with jumper installed on March 25, 2024 (4)residual heat exchanger B outlet valve post-maintenance testing on March 27, 2024 (5)reactor equipment cooling motor-operated valve REC-MO-695 post-work testing on March 27, 2024
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)emergency diesel generator B operability test with isolation switches in isolate on February 16, 2024 (2)main turbine stop valve closure limit switch functional test on March 6, 2024 (3)division 2 residual heat removal service water booster pump flow test and valve operability test on March 27, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)main steam isolation valve operability in-service test on March 27, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
(1)emergency preparedness drill on February 29,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) January 1, 2023, through December 31, 2023
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) January 1, 2023, through December 31, 2023
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) January 1, 2023, through December 31, 2023
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) January 1, 2023, through December 31, 2023
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) January 1, 2023, through December 31, 2023
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)work package development and work control deficiencies on February 7, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in secondary containment tracking and control room response that might be indicative of a more significant safety issue.
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 05000298/2023-002-00, Secondary Containment Differential Pressure Perturbation Exceeds Technical Specifications (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23355A120). The inspection conclusions associated with this LER are documented in Inspection Report 05000298/2023004 (ML24038A256) under Inspection Results section 71111.15. This LER is Closed.
- (2) LER 05000298/2024-001-00, Inoperable Turbine Stop Valve Limit Switch Causes Condition Prohibited by Technical Specifications (ML24064A252). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71111.15. This LER is Closed.
- (3) LER 05000298/2024-002-00, Technical Specifications Prohibited Condition for Inoperable Service Water Booster Pump (ML24064A255). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71111.15. This LER is Closed.
INSPECTION RESULTS
Failure to Incorporate Vendor Instructions Resulting in Residual Heat Removal Service Water Booster Pump Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2024001-01 Open/Closed
[H.14] -
Conservative Bias 71111.15 The inspectors are documenting a self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specifications 5.4.1.a, "Instructions, Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the work instructions for the rebuilding of residual heat removal service water booster pumps failed to incorporate vendor instructions directing the installation of the outboard thrust bearing.
Description:
In January 2018, the licensee removed A residual heat removal (RHR) service water booster pump (SWBP) for replacement. The pump was subsequently rebuilt from November 2020 to June 2022, including replacement of the pump's shaft and bearings. The pump was reinstalled into the SWBP-D location and passed all post-maintenance testing. On August 27, 2022, the outboard bearing high temperature warning alarm was received while the pump was supporting service water chemical injection, and the licensee declared the pump inoperable. This licensee entered this condition into their corrective action program as condition report CR-CNS-2022-03653. Following repairs to the inboard and outboard bearings, the licensee returned SWBP-D to service after completing post-maintenance testing following a pump run of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
In December 2023, the licensee performed a reportability audit of previous evaluations of adverse conditions to determine if new evidence related to these evaluations could result in a reportable condition. In January 2024, a review of condition report CR-CNS-2022-03653 identified a question related to the past operability of SWBP-D. The licensee captured this question on the past operability condition of SWBP-D as condition report CR-CNS-2023-05194 with corrective action to perform a thorough engineering evaluation related to the outboard bearing high temperature. The evaluation determined SWBP-D would not have been capable of performing for its 30-day mission time and the licensee exceeded the limiting condition for operation (LCO) action statement completion time for technical specifications (TS) 3.7.1, which requires two RHR SWBP subsystems, including two SWBP per subsystem to be operable in Modes 1 through 3. The condition of one inoperable SWBP (Condition A) requires restoration of the pump to operable within 30 days. Initially, the licensee declared the pump inoperable from when the high temperature alarm was received on August 27, 2022. The pump was declared operable following repairs on September 1, 2022.
The evaluation determined the high temperature warning alarm was a result of maintenance technicians overtightening the outboard bearing. Based on this information the licensee determined the pump was inoperable since July 27, 2022, when TS 3.7.1 LCO action statement A was entered for the pump replacement. This amount of time resulted in SWBP-D being inoperable for 36 days, exceeding the 30-day action statement to restore the pump to operable. Additionally, not satisfying this action would have resulted in entering condition C, which requires the plant to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The SWBP-B was rebuilt using station Procedure 7.2.14, "RHR SWBP Overhaul and Replacement," revision 46. The station procedure did not contain the manufacturer's instructions for installation of the service water booster pump thrust bearing. The vendor manual contains detailed instruction for tightening the thrust bearing locknut to prevent overheating between the pump shaft, the bearings, and the thrust bearing locknut. The work package developed from station procedure 7.2.14 instead relied on skill of craft to complete the SWBP-D rebuild vice incorporating all required vendor instructions.
Corrective Actions: The station entered the condition into its corrective action program as condition report CR-CNS-2023-03653 and CR-CNS-2024-00463. The licensee submitted a licensee event report to the NRC to document the condition prohibited by technical specifications. Additionally, the licensee has since instituted a policy that all work packages developed for work on safety-related equipment must incorporate all relevant vendor instructions, refer to all relevant engineering calculations, and incorporate all relevant industry operating experience.
Corrective Action References: condition reports CR-CNS-2022-03653, CR-CNS-2023-05194, and CR-CNS-2024-00463
Performance Assessment:
Performance Deficiency: NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The inspectors determined that the licensees work instructions for the rebuild of RHR SWBP-D failed to incorporate instructions from the vendor that would have prevented a failure of the pump and was therefore a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure for rebuilding RHR SWBP-D failed to incorporate vendor instructions resulting in the pump being declared inoperable.
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 this finding is of very low safety significance (Green) because the finding did not represent a deficiency affecting design or qualification of a mitigating structure, system, or component; did not involve the loss of a single-train technical specification (TS)system longer than its TS allowed outage time; did not represent the loss of probabilistic risk assessment (PRA) function one train of a multi-train system for greater than its TS allowed outage time; did not represent the loss of PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; did not represent the loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and did not represent the loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.
Additionally, the finding did not involve external events mitigating systems, the reactor protection system, fire brigade, or flexible coping strategies.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee relied upon skill of the craft and non-specific instructions to perform work on safety-related equipment. The licensee's failure to incorporate vendor instructions for maintenance on safety-related equipment demonstrated a lack of awareness for the risk involved and a lack of forethought for the potential to impact the operability of mitigating systems.
Enforcement:
Violation: Technical specification section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978.
NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Maintenance Procedure 7.2.14, "RHR SWBP Overhaul and Replacement," dated April 20, 2022, was a quality document that the licensee used to perform replacement of the outboard thrust bearing on SWBP-D.
Technical specification 3.7.1.a LCO requires two RHR SWBP subsystems, including two RHR SWBPs per subsystem, to be operable in Modes 1 through 3.
Contrary to the above, in July 2022, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, appendix A, section 9. Specifically, maintenance procedure 7.2.14 did not incorporate vendor guidance specifying torque requirements for the outboard thrust bearing. As a result, the outboard thrust bearing was over-tightened, and subsequently, while being placed in service on August 27, 2022, the RHR SWBP-D outboard bearing high temperature was high out of tolerance, rendering the pump inoperable. Because of this the RHR service water LCO was not met between July 29, 2022, and September 1, 2022.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Incorporate Vendor Instructions Resulting in Turbine Stop Valve Limit Switch Failure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2024001-02 Open/Closed
[H.5] - Work Management 71111.15 The inspectors are documenting a self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specification 5.4.1.a, "Instructions, Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment. Specifically, the work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor manual that would have prevented a failure of the limit switches.
Description:
On August 19, 2023, November 18, 2023, and January 3, 2024, safety-related limit switch A1 (NAMCO series EA740) for main turbine stop valve SV1 failed to actuate during performance of surveillance Procedure 6.RPS.302, Main Turbine Stop Valve Closure and Steam Valve Functional Test, revision 65. This surveillance ensures the reactor protection system limit switches associated with the turbine stop valve actuate upon a turbine stop valve closure. The limit switches are relied upon to initiate an automatic reactor scram upon closure of both turbine stop valves.
In both the August 2023 and November 2023 surveillance failures, the failures were initially attributed to operator action failures and the steps associated with limit switch A1 were reperformed. Limit switch A1 successfully actuated during the reperformance both times.
Following the November 2023 surveillance, Cooper Nuclear Station engineers determined that grease hardening could be a potential cause of the initial failure of limit switch A1 to actuate during the August 2023 and November 2023 surveillances. The licensee initiated corrective actions to increase the frequency of performing surveillance 6.RPS.302 from 13 weeks to 6 weeks. Additionally, prior to the performance of the surveillance on January 3, 2024, the licensee implemented a contingency whereby if a limit switch failed to actuate, the site would lower reactor power to 60 percent and replace the limit switch.
On January 3, 2024, after limit switch A1 again failed to actuate, the site lowered reactor power to 60 percent and replaced limit switches A1 and A2. Limit switch A2 was replaced despite passing the surveillance because limit switch A2 was in the same procurement batch as A1. The removed limit switches were sent to a lab for analysis to determine the cause of the failures.
The vendor manual for NAMCO series EA740 limit switches, Maintenance & Surveillance Instructions for EA740 Limit Switches, revision C (dated May 15, 1991), contains detailed instructions for ensuring the linkage is tightened correctly to the input shaft cam and ensuring proper alignment of components to prevent failure of the limit switch.
During the installation and post-work testing of the limit switches in November 2022, the work instructions for the installation failed to incorporate vendor installation details nor the did the work instructions contain guidance to verify proper alignment. The work package instructions for the installation of the limit switches utilized CNS Procedure 7.3.28.1, "Lead Removal/Installation and Lug Installation," revision 33. This procedure is a generic, high-level procedure that does not incorporate component-specific or vendor-specific guidance. As part of the licensees reportability process it was determined that the A1 limit switch was inoperable from August 19, 2023, to January 4, 2024.
Cooper Nuclear Station technical specification 3.3.1.1, table 3.3.1.1-1 states that when reactor power is greater than or equal 29.5 percent, two channels per trip system are required for the turbine stop valve closure reactor protection system. Condition A of technical specification 3.3.1.1 requires placing a channel in trip if a channel is inoperable. Since limit switch A1 was inoperable, this LCO was applicable. If the required action for condition A is not met, condition D requires entering condition E immediately per table 3.3.1.1-1.
Condition E requires reducing thermal power to less than 29.5 percent power. However, the station did not perform the actions of technical specifications 3.3.1.1, conditions A, D, or E within the required time frames. This represented a condition prohibited by technical specifications. As a result, the station submitted a licensee event report to the NRC to document the condition.
Based upon the above information the inspectors determined the following:
Contrary to technical specification 5.4.1.a and Regulatory Guide 1.33, the site did not properly utilize vendor manual guidance for developing work instructions for the installation of turbine stop valve limit switches, a safety-related component, which led to the failure of limit switch A1 for a period of time prohibited by technical specification 3.3.1.1.
Corrective Actions: The station entered the condition into its corrective action program as condition report CR-CNS-2024-00019. Additionally, the site reinstalled limit switches A1 and A2 using the vendor detailed instructions and reperformed the surveillance as post-work testing to ensure operability of the reactor protection system components. The vendor detailed instructions were also permanently incorporated into the work instructions for further installation practices. The B1 and B2 limit switches associated with turbine stop valve 2 are scheduled to be replaced during the fall 2024 refueling outage.
Corrective Action References: condition report CR-CNS-2024-00019
Performance Assessment:
Performance Deficiency: NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that "maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The inspectors determined that the licensees work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor that would have prevented a failure of the limit switches and was therefore a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure for installing the turbine stop valve limit switches failed to incorporate vendor instructions resulting in repeated failure of the A1 limit switch.
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 the finding did affect a single RPS trip signal to initiate a reactor scram and did not affect the function of other redundant trips or diverse methods of reactor shutdown.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the site's utilization of a generic procedure without incorporating vendor-specific guidance was representative of the site's failure to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority.
Enforcement:
Violation: Technical specification section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978.
NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Technical specification 3.3.1.1.a and 3.3.1.1.b LCO requires two reactor protection system instrumentation channels in each turbine stop valve closure scram to be operable while rated thermal power is greater than or equal to 29.5 percent.
Contrary to the above, on November 10, 2022, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, appendix A, section 9. Specially, the licensee failed to implement vendor-developed installation guidance for the turbine stop valve limit switches that specified steps for tightening the linkage to the cam shaft and aligning the actuator leading to the limit switch failing to actuate. Because of this the reactor protection system instrumentation LCO for the turbine stop valve closure scram was not met between August 19, 2023, and January 4, 2024.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Report Deviation of a Basic Component Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2024001-03 Open/Closed EA-24-029 Not Applicable 71153 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(d)(1) for the licensee's failure to properly evaluate the reportability of a deviation in a basic component. As a result, the licensee failed to report a deviation identified on September 14, 2022, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected.
Description:
On August 27, 2022, a three-drop per minute oil leak was observed from the inboard bearing of RHR SWBP-D during a planned service water chemical injection. During the same run, SWBP-D was declared inoperable due to high outboard bearing temperature.
On September 20, 2022, while repairing SWBP-D, the licensee identified a difference in the inboard bearing cover plates labyrinth seal when compared to a spare. This defect affected the oil drain path and resulted in the three-drop per minute leakage. The licensee contacted Flowserve, the original equipment manufacturer, who determined a drawing error was introduced in 2012. The pump cover was fabricated in accordance with the drawing error resulting in oil leakage past the labyrinth seal along the pump shaft. The vendor provided information to restore the covers to the correct configuration.
On October 19, 2022, the licensee approved a 10 CFR Part 21(Part 21) discovery and reportability evaluation in accordance with station Procedure 0-CNS-LI-108-01, "10 CFR 21 Evaluations and Reporting," revision 2, which is derived from guidance in NEI-14-09, "Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance,"
revision 1. The evaluation incorrectly concluded this defect was not reportable as the defect would not create a substantial safety hazard if it were to remain uncorrected. The licensee's basis for not reporting the condition stated the pump could have operated consecutively for 10 days without operator action and that procedural guidance to take operator action by checking oil every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would maintain the operational status of the pump for the 30-day mission time and prevent a substantial safety hazard.
The vendor completed their own internal Part 21 evaluation, NPO-NNF-07, "Formal Evaluation of Deviation for Impact to Safety," revision 00, and submitted the results to the licensee on January 18, 2023. The vendor's evaluation stated the defect would result in a depletion of the 1-gallon oil reservoir within 10.5 days causing the inboard bearing to overheat. This would likely result in the pump rotor seizing, thus challenging the 30-day mission time of the pump. Additionally, the vendor asserted the defect is considered a potential safety hazard and confirmed they had only supplied the defective component to Cooper Nuclear Station. The licensee maintained their original position that the defect did not create a substantial safety hazard due to compensatory measures and the defect was not reportable.
On February 15, 2024, the inspectors reviewed the Part 21 evaluation and questioned the licensee's basis for determining this deviation would not create a substantial safety hazard and questioned the reportability of the defect. The licensee credited a compensatory measure to add oil, directed by station Procedure 2.2.70, "RHR Service Water Booster Pump System,"
revision 96, which would prevent the manifestation of a substantial safety hazard.
The inspectors determined the compensatory action was a correction to the defect and was not a disqualifier to submit notification to the NRC pursuant to 10 CFR 21.21(a)(1),notification of failure to comply or existence of a defect and its evaluation, which states in part, "evaluate deviations and failures to comply to identify defects and failures to comply associated with substantial safety hazards as soon as practicable, in order to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected."
The inspectors concluded the licensee should have submitted the Part 21 notification within two days following receipt of information regarding the defect from Flowserve as specified in 10 CFR 21.21(d)(3)(i).
Corrective Actions: The station entered the condition and the concerns raised by the resident inspectors into its corrective action program. The affected bearing housing covers were replaced or scheduled to be replaced, and the vendor will rework the affected bearing house covers and ensure the covers are machined correctly. Additionally, the licensee submitted the Part 21 notification (Event Number 57001) on March 1, 2024.
Corrective Action References: condition reports CR-CNS-2024-00463 and CR-CNS-2024-00693
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the failure to make a timely Part 21 report was contrary to licensee procedure 0-CNS-LI-108-01 and was a performance deficiency. This performance deficiency was minor because the inspectors answered No to all three screening questions in appendix B of IMC 0612.
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 noncompliance.
Severity: This performance deficiency was evaluated in accordance with the Enforcement Manual and determined to be a Severity Level IV NCV because
- (a) there was little to no impact to the inspection process/regulatory process,
- (b) the seals were only supplied to Cooper Nuclear Station and no other licensees,
- (c) the licensee entered the issue into the corrective action program and issued a Part 21 report to the NRC,
- (d) the licensee only requires one SWBP to meet mission requirements, and
- (e) the failure to report a defect did not have any impact on the function of any systems, structures, or components at Cooper Nuclear Station, so it would constitute a minor violation on the Reactor Oversight Process path of IMC 0612, appendix B.
Violation: Title 10 CFR 21.21(d)(1) requires, in part, that a responsible officer subject to the regulations of 10 CFR Part 21 must notify the Commission when he or she obtains information reasonably indicating a failure to comply or a defect affecting a basic component.
Contrary to the above, from October 27, 2022, to March 1, 2024, the licensee, subject to the regulations of 10 CFR Part 21, failed to notify the Commission after obtaining information reasonably indicating a failure to comply or a defect affecting a basic component. Specifically, on August 27, 2022, the licensee identified a three-drop per minute oil leak on RHR SWBP-D caused by a machining defect that resulted in the pump being inoperable and then failed to notify the Commission within 60 days after discovery of a defect associated with a substantial safety hazard evaluation described in 10 CFR 21.21(a)(1).
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 April 18, 2024, the inspectors presented the integrated inspection results to Khalil Dia, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
24-00063, 2024-00067, 2024-00075, 2024-00077, 2024-
00080, 2024-00081, 2024-00082, 2024-00098, 2024-00120,
24-00125, 2024-00126, 2024-00127, 2024-00129, 2024-
00161, 2024-00275
Procedures
5.1WEATHER
Operation During Weather Watches and Warnings
Procedures
5.2SW
Service Water Casualties
Corrective Action
Documents
CR-CNS-
23-03071, 2023-03196, 2023-03696, 2023-05100, 2024-
00337, 2024-00454, 2024-00752, 2024-00758, 2024-00759,
24-00968, 2024-00969, 2024-00989
Drawings
DWG 2031,
Sheet 1
Flow Diagram Reactor Building Closed Cooling Water
System
Drawings
DWG 2045,
Sheet 2
Flow Diagram Standby Liquid Control System
Procedures
2.2.70
RHR Service Water Booster Pump System
Procedures
2.2.74A
Standby Liquid Control System Component Checklist
Procedures
2.2A.REC.DIV0
Reactor Equipment Cooling Water System Non-Divisional
Component Checklist
Procedures
2.2A.REC.DIV2
Reactor Equipment Cooling Water System Component
Checklist (DIV 2)
Procedures
2.2A.REC.DIV3
Reactor Equipment Cooling Water System Common
Divisional Component Checklist
Procedures
5.2REC
Loss of REC
Procedures
6.SLC.101
SLC Pump Operability Test
Corrective Action
Documents
CR-CNS-
24-00041, 2024-00675, 2024-00958
Fire Plans
CNS-FP-228
Cooper Nuclear Station Fire Protection Pre-Fire Plan Control
Building Battery/SWGR RMS 1B Elevation 903 6
Fire Plans
CNS-FP-234
Fire Protection Pre-Fire Plan Office Building Cable
Expansion Room Elevation 918-6
Fire Plans
CNS-FP-236
Fire Protection Pre-Fire Plan Diesel Generator Building
DG#1 Elevations 917-6 and 903-6
Fire Plans
CNS-FP-256
Fire Protection Pre-Fire Plan Intake Structure Elevation 903-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-BARRIER-
REACTOR
Reactor Building
Procedures
0.23
Fire Protection Plan
Procedures
2.2.30
Fire Protection System
Procedures
3.6.1
Fire Barrier Control
Procedures
5.1INCIDENT
Site Emergency Incident
Procedures
5.4Fire-S/D
Fire Induced Shutdown from Outside Control Room
Procedures
6.FP.204
Fire Door Examination
Corrective Action
Documents
CR-CNS-
2013-04701
Miscellaneous
NEDC 09-102
Internal Flooding - HELB, MELB, and Feedwater Line Break
Drawings
DWG KSV47-
9NP
Jacket Water Schematic
Miscellaneous
CR-CNS-
24-00015, 2024-00445, 2024-00470, 2024-00472, 2024-
00477, 2024-00488
Miscellaneous
VM-1778
ITT/American Heat Exchangers Composite Manual
Procedures
3.34
Heat Exchanger Program Implementation
Corrective Action
Documents
CR-CNS-
23-04939
Procedures
10.13
Control Rod Sequence and Movement Control
Procedures
2.0.3
Conduct of Operations
107
Procedures
2.1.10
Station Power Changes
24
Procedures
2.1.5
Reactor Scram
Procedures
2.2.17
Emergency Station Transformer
Procedures
2.4PC
Primary Containment Control
Procedures
4.2
Procedures
5.1QUAKE
Procedures
5.7.1
Emergency Classification
Procedures
5.8.3
Alternate Rod Insertion Methods
Procedures
RPV Control (1-3)
Procedures
RPV Pressure/Reactor Power (Failure to Scram)
Procedures
RPV Level (Failure to Scram)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
22-02184, 2023-04582, 2023-04902, 2023-05221, 2024-
00019, 2024-00071
Miscellaneous
CR-CNS-2023-
04902
Maintenance Rule (a)(1) Evaluation and Action Plan
Miscellaneous
DGHV-PF04
Maintenance Rule Function DGHV-PF04 Performance
Criteria Basis
Miscellaneous
HV-F03
Maintenance Rule Function HV-F03 Performance Criteria
Basis
Miscellaneous
RPS-F01A
Maintenance Rule Function RPS-F01A Performance Criteria
Basis
Procedures
3-CNS-DC-203
Procedures
3-CNS-DC-204
Maintenance Rule Scope and Basis
Procedures
3-CNS-DC-205
Maintenance Rule Monitoring
Procedures
3-CNS-DC-206
Maintenance Rule (a)(1) Process
Procedures
3-CNS-DC-324
Preventative Maintenance Program
Miscellaneous
DGA-1-DG1,
Week 2405
Protected Equipment Tagout
Miscellaneous
EDC1-1-EE-BAT-
250(1A) INOP
Protected Equipment Tagout
Miscellaneous
HPCI-1-HPCI
ISOLATION
Protected Equipment Tagout
Miscellaneous
HPCI-1-HPCI-TP-
S57-STEAM
LEAK
Clearance Orders
Miscellaneous
RHWB-1-
5480050 SWBP
D
Clearance Orders
Miscellaneous
RHWB-1-
5480579 SW-P-
BPB REBUILD
Clearance Orders
Miscellaneous
RHWB-1-SW-
MO89B, WK 2407
Protected Equipment Tagout
Procedures
0-BARRIER-
REACTOR
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-CNS-WM-104
On-Line Schedule Risk Assessment
Procedures
0-PROTECT-
EQP
Protected Equipment Program
Procedures
2.0.2
Operation Logs and Reports
24
Procedures
2.0.3
Conduct of Operations
107
Procedures
6.2SWBP.101
RHR Service Water Booster Pump Flow Test and Valve
Operability Test (DIV 2)
Procedures
6.EE.601
25V/250V Station and Diesel Fire Pump Battery 7 Day
Check
Work Orders
WO 5432848, 5480050, 5480579
Corrective Action
Documents
CR-CNS-
2006-08170, 2020-00340, 2023-02794, 2023-03794, 2023-
04939, 2023-05071, 2024-00019, 2024-00029, 2024-00033,
24-00037, 2024-00183, 2024-00260, 2024-00441, 2024-
00463, 2024-00617, 2024-00665, 2024-00643, 2024-00643-
CA-001, 2024-00686, 2024-00696, 2024-00700
Drawings
3040, Sheet 9
Cooper Nuclear Station Control Elementary Diagrams
Drawings
3045, Sheet 14
Control Elementary Diagrams
Miscellaneous
VM-1034
NAMCO Composite Limit Switch & Connector Manual
Miscellaneous
VM-1459
Drag Velocity Control Element Model 103190 AND 709791
Procedures
6.RPS.302
Main Turbine Stop Valve Closure and Steam Valve
Functional Test
Procedures
6.RPS.303
Turbine Stop Valve Closure Channel Calibration
Procedures
7.2.70
Valve Packing Maintenance
Procedures
7.3.28.1
Lead Removal/Installation and Lug Installation
Work Orders
WO 282573, 5381769, 5382651, 5408016, 5417964, 5433573,
5443952, 5462978, 5524979
Calculations
NEDC 87-131A
250VDC Division 1 Load and Voltage Study
14C6
Calculations
NEDC 91-044
Cable Resistance Calculation for 125VDC and 250 VDC
Buses and Loads
5C5
Corrective Action
Documents
CR-CNS-
23-04770, 2023-04773, 2023-05221, 2024-00909
Drawings
SWG E150,
Sheet 14
Relay Settings for Battery Chargers & RPS MG Set Relays
N13
Miscellaneous
DEC-5521738
Diesel Generator Intake HVAC Hatch Securing Screws
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Maintenance Plan
Miscellaneous
TCC-5501351
Temporary Configuration Change
(Field
Change
Revision 2)
Miscellaneous
VM-1188
25 & 250 Volt Batteries & Chargers
Procedures
2.1.12
Control Room Data
149
Procedures
3-CNS-DC-141
Design Inputs
Procedures
3-EN-DC-115
Engineering Change Process
3C6
Procedures
6.1EE.602
DIV 1 125V/250V Station Battery 92 Day Check
Procedures
6.EE.601
25V/250V Station and Diesel Fire Pump Battery 7 Day
Check
Procedures
6.EE.609
25V/250V Station Battery Intercell Connection Testing
Corrective Action
Documents
CR-CNS-
24-00260, 2024-00261
Miscellaneous
VM-0144
RHR Service Water Booster Pumps and Motors
Procedures
6.1EE.602
DIV 1 125V/250V Station Battery 92 Day Check
Procedures
6.2DG.104
Diesel Operability Test with Isolation Switches in Isolate
(DIV 2)
Procedures
6.2SWBP.101
RHR Service Water Booster Pump Flow Test and Valve
Operability Test (DIV 2)
Procedures
6.EE.609
25V/250V Station Battery Intercell Connection Testing
Procedures
6.MISC.401
Position Indicator Inservice Testing (IST)
Procedures
6.MS.201
Main Steam Isolation Valve Operability Test (IST)
Procedures
6.RPS.302,
Section 5
Main Turbine Stop Valve Closure and Steam Valve
Functional Test, Turbine Stop Valve Limit Switch Manual
Actuation
Procedures
6.SWBP.201
SW-MO-89A/B Full Stroke Operability (IST)
Procedures
7.3.28.1
Lead Removal/Installation and Lug Installation
Procedures
7.5.12
SMB-0 Through SMB-4 MOV Refurbishment
Procedures
7.5.8
Limitorque Mechanical/Electrical Examination
Work Orders
WO 5339776, 5381769, 5433573, 5434209, 5436535, 5437844,
5437845, 5479861, 5479879, 5479881, 5480054, 5480103,
5480244, 5489851, 5536537, 5537525,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Cooper Nuclear
Station
Qualification Drill
Emergency Preparedness Drill
71151
Corrective Action
Documents
CR-CNS-
24-01006, 2023-04337
71151
Miscellaneous
MSPI Derivation Reports 1Q23 thru 4Q23
71151
Miscellaneous
Operator Logs 1Q23 thru 4Q23
71151
Procedures
0-CNS-LI-114
Regulatory Performed Indicator Process
Corrective Action
Documents
CR-CNS-
22-06623, 2022-06878, 2023-00982, 2023-02574, 2023-
277, 2023-04455, 2024-00019, 2024-00260, 2024-00658,
24-00769, 2024-01035, 2024-01098
Procedures
EN-MS-S-013-
MULTI
System Engineering Work Planning and Prioritization
6C0
Corrective Action
Documents
CR-CNS-
21-00194, 2023-04582, 2024-01036,
Procedures
2.2.47
HVAC Reactor Building System
67, 68
Procedures
3-CNS-DC-112
Engineering Change Request and Project Initiation Process
Corrective Action
Documents
CR-CNS-
22-02184, 2022-03653, 2023-04582, 2023-04584, 2023-
04770, 2023-04775, 2023-04902, 2023-04939, 2023-05071,
23-05221, 2024-00019, 2024-00319, 2024-00325, 2024-
00463, 2024-00498, 2024-00655, 2024-00693, 2024-05194
Miscellaneous
VM-1034
NAMCO Composite Limit Switch & Connector Manual
Procedures
6.2SWBP.101
RHR Service Water Booster Pump Flow Test and Valve
Operability Test (DIV 2)
Procedures
6.RPS.302
Main Turbine Stop Valve Closure and Steam Valve
Functional Test
Procedures
6.RPS.303
Turbine Stop Valve Closure Channel Calibration
Work Orders
WO 27796, 5433802, 5460250, 5520987