ML24291A261
| ML24291A261 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/05/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Dia K Nebraska Public Power District (NPPD) |
| References | |
| IR 2024003 | |
| Download: ML24291A261 (1) | |
See also: IR 05000298/2024003
Text
November 5, 2024
Khalil Dia, Site Vice President
Nebraska Public Power District
72676 648A Avenue
P.O. Box 98
Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - INTEGRATED INSPECTION
REPORT 05000298/2024003
Dear Khalil Dia:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Cooper Nuclear Station. On October 15, 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. One Severity Level IV violation without an
associated finding is 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 also
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.
Additionally, in the preceding twelve months the NRC issued two Severity Level IV traditional
enforcement violations and one Severity Level III tradition enforcement violation associated with
impeding the regulatory process, as described in NRC Inspection Reports 05000298/2024001,
dated May 3, 2024; 05000298/2024090, dated April 1, 2024; and in this report. The NRC did
note that the identified issues appear to show a gap in the stations processes for reportability.
The Regional Administrator has authorized additional non-baseline inspection using Inspection
Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional
Enforcement Violations in the Same Area in a 12-Month Period. The objective of this inspection
is to provide assurance that the cause(s) of the traditional enforcement violations are
understood, the extent of condition and extent of cause are identified and that corrective actions
are sufficient to address the cause(s). This inspection will be scheduled when you notify the
NRC of your readiness.
K. Dia
2
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 205550001; 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,
Jeffrey E. Josey, Chief
Project Branch C
Division of Operating Reactor Safety
Docket No. 05000298
License No. DPR-46
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Josey, Jeffrey
on 11/05/24
SUNSI Review
By: WTS
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
SRI:DORS:C
RI:DORS:C
SPE:DORS:C
D:DORS
BC:DORS:C
NAME
KChambliss
GBirkemeier
WSchaup
GMiller
JJosey
DATE
10/30/24
10/30/24
10/30/24
11/04/24
11/05/24
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000298
License Number:
Report Number:
Enterprise Identifier:
I-2024-003-0010
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
Brownville, NE
Inspection Dates:
July 1, 2024, to September 30, 2024
Inspectors:
G. Birkemeier, Resident Inspector
K. Chambliss, Senior Resident Inspector
G. Kolcum, Senior Resident Inspector
Approved By:
Jeffrey E Josey, Chief
Project Branch C
Division of Operating Reactor Safety
2
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 report section: 71111.15.
List of Findings and Violations
Failure to Maintain Environmental Qualification of Process Line Connections Associated with
Safety-Related Instrumentation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation of Title 10 of the Code of Federal Regulations 50.49, Environmental
Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the
licensees failure to properly maintain environmental qualification of process line joints within
environmental qualification boundaries. Specifically, a non-qualified thread sealant was used
on instrument line joints associated with nuclear instrumentation. The licensee is required to
use qualified or to qualify thread sealants used in environmental qualification boundaries by
one of the methods as described in Title 10 of the Code of Federal Regulations 50.49.
Maintenance Affecting Performance of Safety-Related Equipment Performed without Pre-
Planned Written Procedures or Documented Instructions
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.11] -
Challenge the
Unknown
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited 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, work performed to install retention screws in
safety-related power supplies was completed without written instructions or procedures.
Failure to Make Required 10 CFR 50.72 Report
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not Applicable
Open/Closed
Not Applicable
The inspectors identified a Severity Level IV non-cited violation of Title 10 of the Code of
Federal Regulations 50.72, "Immediate Notification Requirements for Operating Nuclear
3
Power Reactors," for the licensee's failure to report to the NRC their discovery that the high-
pressure coolant injection system was inoperable due to an improperly installed pressure
switch.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
High Pressure Coolant
Injection Pressure Switch
Installation Causes
Condition that Could Have
Prevented Fulfillment of a
Safety Function and a
Condition Prohibited by
Technical Specifications
Closed
4
PLANT STATUS
Cooper Nuclear Station began the inspection period at rated thermal power. On July 19, 2024,
power was lowered to approximately 70 percent for core power management. The plant
returned to rated thermal power on July 20, 2024. On August 9, 2024, power was lowered to
approximately 70 percent for planned maintenance activities. The plant returned to rated
thermal power on August 10, 2024. On August 14, 2024, loss of a reactor recirculation pump
resulted in an unplanned power reduction to 45 percent. The plant returned to rated thermal
power on August 20, 2024. On August 20, 2024, loss of the same reactor recirculation pump
resulted in an unplanned power reduction to 45 percent. The plant returned to rated thermal
power on August 24, 2024, and commenced power coastdown. The plant continued power
coastdown to 86 percent. On September 28, 2024, power was lowered to approximately
19 percent and a manual scram was inserted to commence a scheduled refueling outage. The
unit was at 0 percent 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
71111.04 - 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 1 service water on September 20, 2024
(2)
reactor core isolation cooling on September 20, 2024
(3)
division 1 4160 Vac system on September 20, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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)
reactor building northwest quadrant, 859-foot elevation, on July 18, 2024
5
(2)
reactor building southeast quadrant, 881-foot 0-inch and 859-foot 0-inch elevations,
on August 20, 2024
(3)
reactor building southwest quadrant, 881-foot 0-inch and 859-foot 0-inch elevations,
on September 20, 2024
(4)
reactor building northeast quadrant, 881-foot 0-inch and 859-foot 0-inch elevations,
on September 20, 2024
(5)
turbine generator building electrical and instrumentation shop, non-critical switchgear
room, operating floor, 932-foot elevation, on September 20, 2024
(6)
reactor building general area, 903-foot 6-inch elevation, on September 30, 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
announced fire drill on September 30, 2024.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam administered between
June 24, 2024, and August 2, 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 quarterly downpower for core management on July 19, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated a simulator emergency preparedness
scenario on August 23, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components remain capable of performing their intended function:
(1)
control rod drive maintenance rule function CRD-PF01B at maximum number of
functional failures for performance criteria on September 27, 2024
(2)
circulating water maintenance rule function CW-SD1 exceeded reliability performance
criteria and made (a)(1) on September 27, 2024
6
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
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)
emergent risk assessment due to repeated failures of reactor recirculation pump A on
August 23, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
service water to emergency diesel generator isolation valve air operator on
August 14, 2024
(2)
high-pressure coolant injection flow indicator erratic reading on September 6, 2024
(3)
nuclear power monitoring instrument drawer configuration control on
September 25, 2024
(4)
reactor recirculation pump A spurious trip on September 30, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
reactor recirculation pump A TACH generator coupling on September 6, 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) (7 Samples)
(1)
standby liquid control post maintenance test on July 24, 2024
(2)
service water booster pump A testing following pump maintenance on
September 1, 2024
(3)
reactor core isolation cooling post testing following relay issues on
September 27, 2024
(4)
fuel pool cooling pump B repair post work testing on September 27, 2024
(5)
core spray division 1 maintenance window post work testing on September 27, 2024
(6)
core spray division 2 maintenance window post work testing and vendor
thermography on September 30, 2024
(7)
reactor recirculation pump A post work testing following spurious trip on
September 30, 2024
7
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)
main turbine stop valve closure limit switch functional test on August 12, 2024
(2)
high-pressure coolant injection turbine exhaust high-pressure functional test on
August 28, 2024
(3)
division 1 emergency diesel generator monthly surveillance run on
September 6, 2024
(4)
division 2 distribution system breaker alignment check missed Technical
Specifications Surveillance 3.8.7.1 on September 30, 2024
Inservice Testing (IST) (IP Section 03.01) (2 Samples)
(1)
reactor core isolation cooling quarterly in-service test and pump vibrations on
August 29, 2024
(2)
division 1 core spray quarterly inservice test on September 30, 2024
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
(1)
5-year vendor maintenance package for FLEX equipment on August 27, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
(1)
emergency preparedness drill on August 27, 2024
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
8
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
the site's control, review, and analysis of preventive maintenance non-conservative
frequency changes and deferred preventive maintenance for safety-related
equipment for the past 3 years on September 6, 2024
(2)
environmental qualification scoping of components that can affect the performance of
environmentally qualified instrumentation, and the use of non-qualified materials such
as Teflon inside environmentally qualified boundaries including process connection
valves on September 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program to identify potential
trends in foreign material exclusion zone maintenance controls, administrative
records, and training that might be indicative of a more significant safety issue. The
inspectors also reviewed the sites plans to control foreign material for their upcoming
refueling outage.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensees event reporting determinations to ensure it
complied with reporting requirements.
(1)
LER 05000298/2024-005-00, High Pressure Coolant Injection Pressure Switch
Installation Causes Condition that Could Have Prevented Fulfillment of a Safety
Function and a Condition Prohibited by Technical Specifications (Agencywide
Documents Access and Management System (ADAMS) Accession
No. ML24134A267). The inspection conclusions associated with this LER are
documented in this report as a Severity Level IV non-cited violation under Inspection
Results Section 71153, and as a self-revealed Green finding and associated non-
cited violation in Inspection Report 05000298/2024002 (ML24206A141). This LER is
Closed.
9
INSPECTION RESULTS
Failure to Maintain Environmental Qualification of Process Line Connections Associated with
Safety-Related Instrumentation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation of Title 10 of the Code of Federal Regulations 50.49, Environmental
Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the
licensees failure to properly maintain environmental qualification of process line joints within
environmental qualification boundaries. Specifically, a non-qualified thread sealant was used
on instrument line joints associated with nuclear instrumentation. The licensee is required to
use qualified or to qualify thread sealants used in environmental qualification boundaries by
one of the methods as described in Title 10 of the Code of Federal Regulations 50.49.
Description: During a walkdown of the plant, the inspectors identified significant use of Teflon
tape on process lines to installed instruments that are required to be environmentally qualified
in accordance with 10 CFR 50.49. Most examples identified were on pipe joints on the drain
side of Rosemount Pressure transmitters and Barton instruments, upstream of closed
isolation valves. Teflon is known to degrade when exposed to high temperatures or radiation
and is therefore not typically qualified for use in these environments.
The licensee justified the use of non-qualified sealant by defining a boundary between the EQ
and non-EQ as the point of connection, or where the process line tubing threads into an EQ
device. Additionally, the licensee stated that the electrical transmitter, electrical conduit seal
assembly, and thread sealant at the connection of the process line to the host transmitter are
the only components within the bounds of their EQ program. The licensee does not have
documentation adequately supporting the qualification of Teflon by testing or other
acceptable methods.
The inspectors reviewed the following:
IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear
Power Generating Stations," defines interface as "a junction or junctions between a Class 1E
Equipment and another equipment or device." Additionally, section 6.3.1.3, which specifies
connections used in type test procedures, states that "Equipment shall be connected in a
manner that simulates its expected installation when in actual use unless an analysis can be
performed and justified to show that the equipment's performance would not be altered by
other means of connection." Since the subject joints are located upstream of the isolation
valves, degradation of the non-qualified thread sealant, which is not present in the EQ test
configuration, caused by harsh conditions could result in leakage of the process fluid. This
leakage could result in inaccurate instrument readings, thereby inhibiting the instrument from
performing its safety function.
Cooper Procedure 14.0.6, revision 12, "Instrument Tubing, valve, fitting, and thread lubricant
guidelines," section 16.2.1, states in part "Teflon tape should not be used in connections
which come in contact with reactor system water." This guidance was made effective in 1989,
when the lack of viability of Teflon in harsh environments became known. Evaluation
10
EE 1998-0009 identifies locations in the plant where Teflon was used and recommends
replacing the thread sealant when maintenance activities disturb the affected joint.
The inspectors determined that the extent to which this guidance has been applied is not
apparent, given that work orders associated with the disturbance of the applicable joints do
not contain specific instruction on torque or thread sealant application, nor do the work orders
contain guidance advising against the use of Teflon tape referenced in station
Procedure 14.0.6. Work orders associated with replacement of transmitters do not contain
any specific guidance for disconnecting and reconnecting the instrument to process lines,
relying on the use of the licensee's generic Lead Removal and Installation Maintenance
Procedure 7.3.28.1. Additionally, Procedure 14.0.6 is an information use procedure and is not
required to be reviewed by technicians prior to each applicable job.
Therefore, the inspectors, along with subject matter experts determined that the licensee has
not demonstrated that instruments considered electric equipment important to safety satisfy
the environmental qualification requirements when Teflon tape is used as a thread sealant on
process line joint connections. As a result, the licensee has not demonstrated that these
components could be relied upon to perform the required function for the specified mission
time under design basis accident conditions.
Corrective Actions: The licensee has entered the performance deficiency into their corrective
action program and intends to determine the appropriate scope of equipment which
10 CFR 50.49 applies to.
Corrective Action References: Condition Report CR-CNS-2024-03635
Performance Assessment:
Performance Deficiency: Title 10 CFR 50.49, Environmental Qualification of Electrical
Equipment Important to Safety for Nuclear Power Plants, section (f) requires that each item
of electric equipment important to safety must be qualified by one of four methods listed in the
regulation. The inspectors determined the licensee's failure to maintain equipment required to
be environmentally qualified is reasonably in the licensee's ability to foresee and correct and
therefore a performance deficiency. This resulted in no assurance that these components
could be relied upon to perform the required function for the specified mission time under
design basis accident conditions.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance 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 licensee failed to ensure environmentally
qualified thread sealants were used on all process connections, whose failure could result in
the failure of the instrument.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using
exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined this finding to
be of very low safety significance (Green) because it was a deficiency affecting the design or
qualification of equipment, but the equipment maintained its probabilistic risk assessment
(PRA) functionality.
11
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement:
Violation: Title 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important
to Safety for Nuclear Power Plants, section (f) requires that each item of electric equipment
important to safety must be qualified by one of the following methods:
(1) testing an identical item of equipment under identical conditions or under similar
conditions with a supporting analysis to show that the equipment to be qualified is acceptable
(2) testing a similar item of equipment with a supporting analysis to show that the equipment
to be qualified is acceptable
(3) experience with identical or similar equipment under similar conditions with a supporting
analysis to show that the equipment to be qualified is acceptable
(4) analysis in combination with partial type test data that supports the analytical assumptions
and conclusions
Contrary to the above since 1989 to September 30, 2024, the licensee failed to qualify thread
sealant used on process line connections with environmentally qualified instruments by one
of the following methods:
(1) testing an identical item of equipment under identical conditions or under similar
conditions with a supporting analysis to show that the equipment to be qualified is acceptable
(2) testing a similar item of equipment with a supporting analysis to show that the equipment
to be qualified is acceptable
(3) experience with identical or similar equipment under similar conditions with a supporting
analysis to show that the equipment to be qualified is acceptable
(4) analysis in combination with partial type test data that supports the analytical assumptions
and conclusions
Specifically, the licensee has numerous safety-related transmitters, installed in multiple
systems with non-qualified thread sealant installed in process connections to environmentally
qualified instruments, which may inhibit the environmentally qualified instruments from
performing their intended function under the environmental conditions described by
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Maintenance Affecting Performance of Safety-Related Equipment Performed without Pre-
Planned Written Procedures or Documented Instructions
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.11] -
Challenge the
Unknown
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation of Technical Specifications 5.4.1.a, "Instructions, Procedures, and
Drawings," for the licensee's failure to implement maintenance that can affect the
12
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, work performed to install retention screws in
safety-related power supplies was completed without written instructions or procedures.
Description: On May 10, 2024, during surveillance testing, the licensee identified that multiple
average power range monitor (APRM) power supply drawers did not have retention screws
present in all four required mounting locations whose function is to secure the drawers to
vertical angle brackets. This configuration did not meet the seismic qualification requirements
specified by GE topical report NEDO-10678, "Seismic Qualification of Class I Electrical
Equipment," and Qualification Report QTR03P1000, section 7.4.2, "Items Mounted on the
Seismic Table," which specifies that "flanges on either side of the face of the drawer were
secured to the test fixture using four 10-32 machine screws torqued to 17 in-lbs." Spectrum
Certificate of Conformance COC03P1000 states, in part, "when the Items listed are properly
installed in accordance with the manufacturer's instructions the configuration of the
equipment will be the same as that which was successfully tested to IEEE-344-1975."
In an attempt to restore compliance, maintenance installed a single retention screw in NM-
-ES--17, the +20VDC supply for APRM C, without pre-planned procedures or work
instructions. This maintenance activity was retroactively documented in
Notification 11983996, which stated that a focus meeting directed the installation of the lone
retention screw in NM--ES--17, resulting in the power supply drawers remaining out of
compliance. Engineering was in the process of researching the seismic requirements for the
drawers when the spot maintenance was performed. After performance of spot maintenance,
a work order (WO 5546110) was then issued directing the installation of retention screws in
the remaining locations. The work order did not contain the torque requirements specified in
the qualification report.
Corrective Actions: The licensee is reviewing their process for performance of spot
maintenance activities.
Corrective Action References: Condition Report CR-CNS-2024-03670
Performance Assessment:
Performance Deficiency: Lack of written work instructions and procedures for maintenance on
safety-related equipment is in the licensee's ability to foresee, and is 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 licensee failed to prepare and distribute procedures or pre-
planned instructions directing maintenance performed on safety-related equipment.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using
exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined this finding to
be of very low safety significance (Green) because it was a deficiency affecting the design or
qualification of equipment, but the equipment maintained its PRA functionality.
13
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the
licensee discovered a condition that did not meet seismic qualification requirements and were
uncertain of design requirements. The licensee failed to question whether actions taken as
part of spot maintenance were sufficient to restore compliance.
Enforcement:
Violation: Technical Specification 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.
Contrary to the above, on May 10, 2024, the licensee failed to establish written work
instructions to address the requirements of Regulatory Guide 1.33, Appendix A, section 9,
when performing maintenance on safety-related components. Specifically, the licensee
installed retention screws on APRM power supplies using spot maintenance, without written
procedures or work instructions, and documented the activity on a non-quality record,
Notification 11983996.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation
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: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that
measures shall be established to assure that applicable regulatory requirements and the
design basis, as defined in § 50.2 and as specified in the license application, for those
structures, systems, and components to which this appendix applies are correctly translated
into specifications, drawings, procedures, and instructions. These measures shall include
provisions to assure that appropriate quality standards are specified and included in design
documents and that deviations from such standards are controlled. Contrary to the above, the
licensee did not assure that applicable regulatory requirements and the design basis, as
defined in § 50.2 and as specified in the license application, for those structures, systems,
and components to which this appendix applies are correctly translated into specifications,
drawings, procedures, and instructions nor assure that appropriate quality standards are
specified and included in design documents and that deviations from such standards are
controlled. Specifically, from approximately 2006 to May 10, 2024, the licensee failed to install
the correct number of retention screws required by a seismic qualification report for several
safety-related neutron monitoring system power supply drawers.
On May 10, 2024, during surveillance testing, an operator observed that several retention
screws were missing from each neutron monitoring power supply drawer. The power supply
drawers provide power to the APRMs and rod block monitors (RBMs) which provide input to
14
the reactor protection system (RPS). In total, eight drawers were observed to be missing at
least two screws.
The original seismic design for the neutron monitoring drawers is documented in the GE
supplied topical report NEDO-10678, "Seismic Qualification of Class I Electrical Equipment."
Per the seismic qualification report and as documented in the vendor manual, four screws are
required to meet the seismic qualification. Six drawers were missing two screws, one drawer
was missing three screws, and one drawer was missing all four screws. The licensee's failure
to assure that deviations from the seismic qualification test report were not controlled could
have potentially impacted the APRMs and RBMs ability to perform their intended safety
function during a seismic event. Per the licensee's Updated Safety Analysis Report (USAR),
section VII-2.2.7.h, "earthquake ground motions shall not impair the ability of the RPS to
initiate a reactor scram."
The licensee took action to install the correct number of screws in all drawers except for one
drawer which only was able to have three screws installed due to the need for more intrusive
maintenance. This final screw was able to be installed during the refueling outage.
Significance/Severity: Green. 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.
Corrective Action References: Condition Reports CR-CNS-2024-01817 and
Failure to Make Required 10 CFR 50.72 Report
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not
Applicable
Open/Closed
Not
Applicable
The inspectors identified a Severity Level IV non-cited violation of Title 10 of the Code of
Federal Regulations 50.72, "Immediate Notification Requirements for Operating Nuclear
Power Reactors," for the licensee's failure to report to the NRC their discovery that the high-
pressure coolant injection system was inoperable due to an improperly installed pressure
switch.
Description: On March 13, 2024, during a maintenance work window for the high-pressure
coolant injection (HPCI) system, the site replaced pressure switch HPCI-PS-2787. The as-
found values were found shifted from the bench calibration similar to the as-found values for
the pressure switch that had been replaced. Specifically, the trip setting for the pressure
switches were found at a value of 44.7 psig instead of the nominal setting of 90 psig.
The function of pressure switch HPCI-PS-2787 is to start and secure the HPCI auxiliary oil
pump which operates when the HPCI turbine oil pressure is greater than or equal to 20 psig
and secures when HPCI turbine oil pressure reaches 85 psig. Upon discovery of
HPCI-PS-2787 being out of tolerance, the site wrote two condition reports
(CR-CNS-2024-01009 and CR-CNS-2024-01035) and entered the condition into their
corrective action program. Both condition reports were coded as inoperable. The first
15
condition report captured the as-found values, and the second condition report documented
the pressure switch was initially installed inadequately in March 2023 resulting in the pressure
switch being out of calibration for 1 year. During the reportability screening for both condition
reports, the site concluded the conditions were not immediately reportable per station
Procedure 2.0.5, "Reports to NRC Operations Center," revision 60, NUREG-1022, Event
Reporting Guidelines: 10 CFR 50.72 and 50.73, or NEI 13-01, Reportable Action Levels for
Loss of Emergency Preparedness Capabilities. The site further concluded that a report would
not be required since the condition was part of a pre-planned evolution for maintenance or
surveillance testing.
However, NUREG-1022 states: "As a result, reports are not required when systems are
declared inoperable as part of a planned evolution for maintenance or surveillance testing
when done in accordance with an approved procedure and the plants TS (unless a condition
is discovered that would have resulted in the system being declared inoperable)." The site's
conclusion that a report was not required due to pre-planned maintenance activities was
incorrect since the condition discovered (HPCI pressure switch inadequately installed and out
of calibration) would have, and did, result in the HPCI system being declared inoperable.
Since HPCI is a single-train system, its inoperability also constituted a loss of safety function
which was reportable under 10 CFR 50.72(b)(3)(v)(D) as an 8-hour notification. However, the
site did not issue the 8-hour notification until March 21, 2024 (Event Notification 57041) after
the inspectors informed site leadership of the missed report.
The licensee wrote a condition report (CR-CNS-2024-01082) to document the inspectors'
concerns for a missed 10 CFR 50.72 notification. The site concluded that although site
Procedure 2.0.5 states NUREG-1022 shall be referenced when making reportability
decisions, the procedure did not have the necessary clarity for the exception for discoveries
made during maintenance activities.
Corrective Actions: The site entered the failure to make a timely notification to the NRC into
their corrective action program and have revised site Procedure 2.0.5, "Reports to NRC
Operations Center," to improve clarity on reporting requirements.
Corrective Action References: Condition Report CR-CNS-2024-01082
Performance Assessment: The inspectors determined this violation was associated with a
minor 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: Based on the NRC Enforcement Policy dated January 12, 2024, section 6.9.d.9 lists
a failure to make a required report per 10 CFR 50.72 as an example of a Severity Level IV
violation.
Violation: Title 10 CFR 50.72 requires, in part, that each nuclear power reactor licensee shall
notify the NRC Operations Center of those non-emergency events specified in paragraph (b).
Paragraph (b)(3)(v)(D) of 10 CFR 50.72 states, in part, that events or conditions that at time
of discovery could have prevented fulfillment of the safety function of systems that are
needed to mitigate the consequences of an accident be reported within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
16
Contrary to this requirement, on March 13, 2024, the licensee failed to notify the NRC
Operations Center of a condition that at the time of discovery could have prevented fulfillment
of the safety function of systems that are needed to mitigate the consequences of an accident
within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Specifically, the licensee did not notify the NRC Operations Center within
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of discovering an inadequately installed pressure switch for the single-train HPCI
system which rendered the HPCI auxiliary oil pump out of calibration and the HPCI system
inoperable. The licensee discovered the inoperable pressure switch on March 13, 2024,
during a maintenance window for the HPCI system. However, the licensee did not recognize
the reporting requirements for conditions discovered during maintenance activities until
March 21, 2024.
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 15, 2024, the inspectors presented the integrated inspection results to Khalil
Dia, Site Vice President, and other members of the licensee staff.
17
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
2024-00435, 2024-00602, 2024-02057, 2024-02687, 2024-
04005
Drawings
2006, Sheet 1
Circulating, Screen Wash & Service Water Systems
93
Drawings
2043
Flow Diagram Reactor Core Isolation Coolant and Reactor
Feed Systems
58
Drawings
3012, Sheet 3
Main Three Line Diagram
3
Procedures
2.2.67A
Reactor Core Isolation Cooling System Component
Checklist
24
Procedures
2.2.67B
Reactor Core Isolation Cooling System Instrument Valve
Checklist
4
Procedures
2.2A.SW.DIV.1
Service Water System Component Checklist (DIV 1)
21
Procedures
2.2A_4160.DIV1
4160 VAC Auxiliary Power Checklist (DIV 1)
2
Fire Plans
CNS-FP-211
Reactor Building Northeast Quadrant Elevations 881-9 and
859-9
5
Fire Plans
CNS-FP-212
Reactor Building Southeast Quadrant Elevations 881-9 and
859-9
6
Fire Plans
CNS-FP-213
Reactor Building Northwest Quadrant Elevations 881-9 and
859-9
6
Fire Plans
CNS-FP-214
Reactor Building Southwest Quadrant Elevations 881-9 and
859-9
6
Fire Plans
CNS-FP-215
Reactor Building First Floor Elevation 903-6
7
Fire Plans
CNS-FP-251
Turbine Generator Building Turbine Operating Floor
Elevation 932-6
11
Fire Plans
CNS-FP-252
Turbine Generator Building Non-Critical Switchgear Room
Elevation 932-6
4
Fire Plans
CNS-FP-253
Turbine Generator Building Electrical and Instrumentation
Shops Elevation 932-6
7
Miscellaneous
CNS-FP-9
Piping Isometric - Wet Sprinkler System Electrical trays in
NO. East Corner Reactor Building - Floor Elevation 903 6
N04
Miscellaneous
EE-01-006
Disposition of NFPA Code Compliance Deviations (Systems
in Fire Zones Requiring an IPEEE Phase 2 Screening)
6
Procedures
0-Barrier
Barrier Control Process
45
18
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-Barrier-Reactor
Reactor Building
16
Procedures
0-Barrier-Turbine
Turbine Building
12
Miscellaneous
Table 03.03-1
Examination Results
Corrective Action
Documents
CR-CNS-
2024-02716, 2024-02885, 2024-02907, 2024-03019, 2024-
03021, 2024-03103
Procedures
10.13
Control Rod Sequence and Movement Control
78
Procedures
2.0.2
Operation Logs and Reports
124
Procedures
2.0.3
Conduct of Operations
108
Procedures
2.1.10
Station Power Changes
125
Procedures
2.1.4.3
Power Reduction to <25/30%
19
Procedures
2.1.5
Reactor Scram
82
Procedures
5.7.1
Emergency Classification
73
Procedures
5.7.1.1
Emergency Classification Process
5
Procedures
5.7.6
Notification
90
Procedures
RPV Control (1-3)
24
Procedures
Secondary Containment Control (1-3)
21
Procedures
EPIPEALHOT
23
Corrective Action
Documents
CR-CNS-
2022-03389, 2022-06786, 2023-05167, 2024-00534, 2024-
01929
CRD-PF01B
Maintenance Rule Functional Basis CRD-PF01B
4
CW-SD1
Maintenance Rule Functional Basis CW-SD1
5
Miscellaneous
RR-F01
Maintenance Rule Function Basis for RR-F01, Provide Variable
Forced Circulation of Water through the Reactor Core
3
Procedures
2.2.3
165
Procedures
5.8.3
Alternate Rod Injections
18
Procedures
5.8.6
RPV Flooding Systems
41
Corrective Action
Documents
CR-CNS-
2024-03203, 2024-03232, 2024-03256, 2024-03265, 2024-
03300
Procedures
0-CNS-FAP-OP-
031
Emergent Issue Response, Risk Classification, and
Oversight Determination
3
Procedures
0-CNS-WM-104
On-Line Schedule Risk Assessment
21
Procedures
2.0.3
Conduct of Operations
108
19
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
2021-04028, 2024-01817, 2024-01866, 2024-01867, 2024-
01918, 2024-02479, 2024-03076, 2024-03100, 2024-03156,
2024-03169, 2024-03203, 2024-03229, 2024-03230, 2024-
03231, 2024-03232, 2024-03252, 2024-03256, 2024-03258,
2024-03261, 2024-03262, 2024-03265, 2024-03279, 2024-
03283, 2024-03300, 2024-03309, 2024-03401, 2024-03670
Drawings
2044
Flow Diagram - High Pressure Coolant Injection and Feed
Systems
78
Drawings
791E562, Sheet 6
Panel 9-3 Connection Diagram
17
Drawings
KSV-47-8
Diesel Generator 1 & 2 Cooling Water Schematic
28
Miscellaneous
VM-0988
Fisher Controls Composite Manual
81
Miscellaneous
VM-1345
Edgewise E4 Instruments
3
Procedures
2.4RR
Reactor Recirculation Abnormal
51
Corrective Action
Documents
CR-CNS-
2024-03203
Drawings
34A770521
0
Miscellaneous
Design Equivalent
Change DEC-
5558459
RRMG Tach Generator Coupling
0
Miscellaneous
VM-0033
Reactor Recirculation Motor Generator Sets - RRMG
50
Corrective Action
Documents
CR-CNS-
2023-03558, 2023-03635, 2023-03839, 2024-03225
0-CNS-WM-104
ON-LINE SCHEDULE RISK ASSESSMENT
21
Procedures
6.HPCI.705
HPCI Turbine High Exhaust Pressure Channel Functional Test
6
Procedures
6.1CS.101
Core Spray Test Mode Surveillance Operation (IST) (DIV 1)
36
Procedures
6.1DG.101
Diesel Generator 31 Day Operability Test (IST) (DIV 1)
97
Procedures
6.1EE.305
Distribution System Breaker Alignment (DIV 1)
6
Procedures
6.2CS.101
Core Spray Test Mode Surveillance Operation (IST) (DIV 2)
35
Procedures
6.2EE.305
Distribution System Breaker Alignment (DIV 2)
8
Procedures
7.0.14.2.2
Oil Sampling
11
Procedures
7.2.1
Fuel Pool Cooling Pump Maintenance
9
Work Orders
WO 5431213, 5441290, 5445397, 5456462, 5457168, 5457235,
5457241, 5458764, 5487692, 5487985, 5489907, 5516480,
5534477, 5553984
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-CNS-
2024-02716, 2024-02885, 2024-02907, 2024-03019, 2024-
03021, 2024-03103
Procedures
2.1.5
Reactor Scram
82
Procedures
5.7.1
Emergency Classification
73
Procedures
5.7.1.1
Emergency Classification Process
5
Procedures
5.7.6
Notification
90
Procedures
EPIPEALHOT
23
71151
Miscellaneous
Performance Indicator Documentation and Data Review
Package Operator Logs 3Q23 thru 2Q24
71151
Procedures
0-CNS-LI-114
Regulatory Performance Indicator Process
0
Corrective Action
Documents
CR-CNS-
1993-00925, 2023-00921, 2023-00975, 2023-01763, 2023-
01983, 2023-02133, 2023-02345, 2023-02464, 2023-02576,
2023-02987, 2023-03103, 2023-03921, 2023-04223, 2023-
04458, 2023-04507, 2023-04820, 2023-05033, 2023-05362,
2024-00022, 2024-00442, 2024-00443, 2024-00451, 2024-
00452, 2024-00482, 2024-00535, 2024-00561, 2024-00691,
2024-00769, 2024-00850, 2024-00867, 2024-00882, 2024-
00916, 2024-00989, 2024-01233, 2024-01355, 2024-01589,
2024-01617, 2024-01669, 2024-01703, 2024-01755, 2024-
02024, 2024-02141, 2024-02163, 2024-02179, 2024-02229,
2024-02232, 2024-02349, 2024-02369, 2024-02536, 2024-
02607, 2024-02763, 2024-02786, 2023-02823, 2024-02974,
2024-03047, 2024-03543, 2024-03643
Engineering
Evaluations
EE-1998-0009
Teflon, Survey & Evaluation of Use of Teflon at Cooper
Nuclear Station
02/1999
Miscellaneous
VM-0245
KSV16T Emergency Diesel Generator
280
Miscellaneous
VM-0769
Static-O-Ring Pressure Switches Composite Manual
20
Miscellaneous
VM-0986
Limitorque Composite Manual
34
Procedures
14.0.6
Instrument Tubing, Valve, Fitting, and Thread Lubricant
Guidelines
12
Procedures
3-CNS-DC-324
Preventative Maintenance Program
10
Procedures
3.47.31
Periodic Surveillance and Preventative Maintenance
Program
7
Procedures
9C0
21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
WO 5380075, 5418389, 5418459, 5429236, 5436439, 5450224,
5455581, 5483516, 5488109, 5502016, 5509934
Corrective Action
Documents
CR-CNS-
2024-01009, 2024-01035, 2024-01082, 2024-01140, 2024-
01234
Procedures
0-CNS-LI-108
Event Notification and Reporting
2
Procedures
0.5.OPS
Operations Review of Condition Reports/Operability
Determination