ML25128A180

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Nuclear Station - Integrated Inspection Report 05000298/2025001
ML25128A180
Person / Time
Site: Cooper 
Issue date: 05/13/2025
From: Douglas Dodson
NRC/RGN-IV/DORS/PBC
To: Dia K
Nebraska Public Power District (NPPD)
References
IR 2025001
Download: ML25128A180 (1)


Text

May 13, 2025 Khalil Dia, Site Vice President Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2025001

Dear Khalil Dia:

On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On April 7, 2025, the NRC inspectors discussed the results of this inspection with John Dent Jr., Executive Vice President and Chief Nuclear Officer, 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.

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.

K. Dia 2

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, Douglas E. Dodson II, Chief Reactor Projects 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 Dodson, Douglas on 05/13/25

ML25128A180

SUNSI Review By: DED

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available OFFICE RI:DORS/PBC SRI:DORS/PBC BC:DORS/PBC NAME GBirkemeier GKolcum DDodson SIGNATURE

/RA/

/RA/

/RA/

DATE 05/09/25 05/08/25 05/13/25

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

05000298 License Number:

DPR-46 Report Number:

05000298/2025001 Enterprise Identifier:

I-2025-001-0004 Licensee:

Nebraska Public Power District Facility:

Cooper Nuclear Station Location:

Brownville, NE Inspection Dates:

January 1, 2025, to March 31, 2025 Inspectors:

B. Baca, Health Physicist G. Birkemeier, Resident Inspector L. Carson, Senior Health Physicist N. Greene, Senior Health Physicist G. Kolcum, Senior Resident Inspector J. O'Donnell, Senior Health Physicist Approved By:

Douglas E. Dodson II, Chief Reactor Projects 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.

List of Findings and Violations Failure to Maintain Design Configuration Resulting in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2025001-01 Open/Closed

[P.1] -

Identification 71153 The inspectors reviewed a self-revealing finding of very low safety significance (Green) and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." Specifically, the licensee failed to maintain design configuration of safety-related instrumentation associated with main steam safety relief valves, which resulted in the licensee violating Technical Specification limiting condition for operation (LCO) 3.0.4, while the low-low-set (LLS) valve instrumentation was inoperable and the licensee entered the MODE of applicability for LCO 3.3.6.3.

Failure to Follow Surveillance Procedure Resulting in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2025001-02 Open/Closed

[H.12] - Avoid Complacency 71153 The inspectors reviewed a self-revealing 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 surveillance tests, procedures, and calibrations on reactor protection systems. Specifically, formal reviews of completed surveillances failed to identify equipment calibrated out of tolerance, rendering equipment inoperable.

3 Additional Tracking Items Type Issue Number Title Report Section Status LER 05000298/2024-007-00 Inoperable Pressure Switch during Mode Change Results in Operation or Condition Prohibited by Technical Specifications 71153 Closed LER 05000298/2024-006-00 Human Performance Errors Cause a Condition Prohibited by Technical Specifications and Common Cause Inoperability of Independent Reactor Protection System Channels 71153 Closed

4 PLANT STATUS Cooper Nuclear Station began the inspection period at rated thermal power. On January 26, 2025, the plant lowered power to approximately 96 percent when the leading-edge flow meter became nonfunctional. After the licensee completed surveillance testing, the leading-edge flow meter was returned to functional status and the unit was returned to rated thermal power. On February 7, 2025, power was lowered to approximately 70 percent for a planned rod pattern adjustment. The plant returned to rated thermal power on February 9, 2025.

On February 10, 2025, power was lowered to approximately 70 percent for a planned rod pattern adjustment. The plant returned to rated thermal power on February 11, 2025. On March 23, 2025, power was lowered to approximately 80 percent for the reactor feedwater pump A governor valve position deviation alarm and maintenance. The plant was returned to rated thermal power on March 24, 2025. 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 onsite 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) (3 Samples)

(1)

The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during a winter storm warning on January 6, 2025.

(2)

The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during a winter storm warning on February 11, 2025.

(3)

The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during a high wind and blizzard warning on March 4, 2025.

5 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) division 2 reactor building closed cooling water system on January 16, 2025 (2) restoration of division 2 emergency diesel generator following jacket water leak repairs on January 28, 2025 (3) restoration of division 1 emergency diesel generator following maintenance during the week of February 3, 2025 (4) reactor core isolation cooling partial system walkdown following a maintenance window on March 12, 2025 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 standby liquid control area on January 15, 2025 (2) reactor building motor generator set area on January 23, 2025 (3) reactor building refueling floor area on January 29, 2025 (4) critical switchgear 1F on February 10, 2025 (5) reactor building northwest quadrant on February 11, 2025 (6) control building basement on February 24, 2025 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 February 16, 2025.

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 the first quarter rod pattern adjustment on February 11, 2025.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1)

The inspectors observed and evaluated operations training in the simulator on March 5, 2025.

6 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 (SSCs) remain capable of performing their intended function:

(1) jacket water and lube oil leaks on the division 1 emergency diesel generator on February 3, 2025 (2) main steam isolation valve logic relays during downpower on February 8, 2025 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (6 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)

Yellow risk window for 125 Vdc A charger maintenance on January 9, 2025 (2) emergent Yellow risk window for division 2 emergency diesel generator inoperability due to jacket water leakage on January 23, 2025 (3)

Yellow risk window for division 2 residual heat removal maintenance on January 29, 2025 (4)

Yellow risk window for division 1 emergency diesel generator maintenance on February 5, 2025 (5)

Yellow risk window for reactor core isolation cooling maintenance on March 4, 2025 (6) emergent Yellow risk window for division 2 emergency diesel generator maintenance following failure to start on March 18, 2025 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) division 1 emergency diesel generator jacket water and lube oil leaks on February 3, 2025 (2) main steam isolation valve logic relays during downpower on February 8, 2025 (3) division 1 emergency diesel generator exhaust pipe measurements on February 12, 2025 (4) small leak on division 1 emergency diesel generator cooler on February 12, 2025 (5) reactor core isolation cooling air operated valve calibration found out of specification on March 18, 2025

7 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) (3 Samples)

(1) restoration of division 1 emergency diesel generator following maintenance during the week of February 3, 2025 (2) battery charger post-work testing on February 27, 2025 (3) division 2 emergency diesel generator post-maintenance testing following failure to start and replacement of trip solenoid valves on March 19, 2025 Surveillance Testing (IP Section 03.01) (3 Samples)

(1) division 2 service water booster pump operability test on February 3, 2025 (2) 24-month primary containment purge and vent valve test on February 25, 2025 (3) division 1 quarterly residual heat removal test mode surveillance operation on March 3, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) division 2 quarterly residual heat removal test mode surveillance operation on February 4, 2025 71114.06 - Drill Evaluation Required Emergency Preparedness Drill (1 Sample)

(1) emergency response organization drill on February 18, 2025 RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

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

(1) high radiation area controls during the loading of a condensate liner into the shipping cask for transportation into the public domain on March 26, 2025, using radiation work permit 2025-102, "High Integrity Container (HIC) Prep / Shipments," Revision 0 (2) radiological controls for the reactor water cleanup pump disassembly on March 25, 2025, using radiation work permit 2025-116, "RWCU Pump B Work," Revision 0 (3) respiratory protection control measures during the system breach of the reactor water cleanup system in the pump room on March 26, 2025, using radiation work permit 2025-116, "RWCU Pump B Work," Revision 0

8 71124.05 - Radiation Monitoring Instrumentation Walkdowns and Observations (IP Section 03.01) (9 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) portable ion chambers stored ready for use' (2) portable frisker located in the airlock to the reactor building (3) portable wide-range Geiger-Mueller survey instrument (tele-pole)

(4) personnel contamination monitors at the radiologically controlled area exit (5) gamma exit monitors at the radiologically controlled area exit (6) tool and equipment monitors in the multipurpose facility (7) area radiation monitors in reactor and radwaste buildings (8) elevated release point effluent monitor (9) turbine building ventilation effluent monitor Calibration and Testing Program (IP Section 03.02) (14 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1)

Eberline AMS 4, RP-10981/10987, January 17, 2024 (2)

KAMAN Effluent Monitor (reactor building), RMV-RM-40, February 14, 2024 (3)

Eberline RO-20, RP-10574, March 11, 2024 (4)

Radeco H-809-V-1, RP-10091, May 7, 2024 (5)

Mirion FastScan, FastscanEXT, May 29, 2024 (6)

General Electric Main Steam Line Radiation Monitors, RMP-RM-251A/B/C/D, August 21, 2024 (7)

General Electric Area Radiation Monitor System, RMA-RA-1 thru RMA-RA-30, September 10, 2024 (8)

Mirion RDS-32iTxSD, RP-12050, September 27, 2024 (9)

Victoreen Model 875, RMA-RM-40A/B, October 7, 2024 (10)

Merlin Gerin AMP-100, RP-10860, December 5, 2024 (11)

Ludlum Model 3, RP-11167, January 14, 2025 (12)

Canberra Chronos 11, RP-11976, January 21, 2025 (13)

Ludlum Model 177, RP-11432, March 3, 2025 (14)

MGP Tele-pole, RP-11243, March 10, 2025 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1)

Turbine Building (KAMAN) Effluent Monitor, RMV-RM-20A and 20B, W/O 5436569, February 23, 2024 (2)

Liquid Radwaste Effluent Monitor, RMP-RM-354, W/O 5438238, February 28, 2024 (3)

Elevated Release Point (KAMAN) Effluent Monitor, RMP-RM-3A and 3B, W/O 5449357, June 13, 2024

9 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walkdowns and Observations (IP Section 03.01) (5 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) elevated release point effluent monitoring system (2) liquid radwaste discharge monitoring system (3) multipurpose facility ventilation monitoring system (4) service water effluent monitoring system (SW-A and SW-B)

(5) turbine building ventilation monitoring system Sampling and Analysis (IP Section 03.02) (5 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) particulate and iodine samples for the elevated release point effluent dated March 25, 2025 (2) particulate and iodine samples for the multiple purpose facility effluent dated March 25, 2025 (3) particulate and iodine samples for the radwaste building effluent dated March 25, 2025 (4) particulate and iodine samples for the reactor building effluent dated March 25, 2025 (5) particulate and iodine samples for the turbine building effluent dated March 25, 2025 Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) fourth quarter 2024 quarterly dose evaluation for gaseous effluent (2) first quarter 2025 quarterly dose evaluation for gaseous effluent up to March 12, 2025, effluent samples Abnormal Discharges (IP Section 03.04)

There were no abnormal discharges for the inspectors to evaluate.

71124.07 - Radiological Environmental Monitoring Program Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated environmental monitoring equipment and observed the collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

10 GPI Implementation (IP Section 03.03) (1 Sample)

(1)

The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative (GPI) program to identify incomplete or discontinued program elements.

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

Transportation Radioactive Material Storage (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:

(1) radioactive material and waste stored within the radiologically controlled area and the protected area (2)

Category 2 quantities of radioactive material within the calibrators stored in the calibration lab (3) selected radioactive sealed sources within the radiologically controlled area per the Source Inventory Report Radioactive Waste System Walkdown (IP Section 03.02) (3 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) reactor water cleanup waste system (2)

AVANTech radwaste resin processing system (3) condensate waste system Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1)

Work Order 672500, 10 CFR Part 61 condensate phase separator and waste sludge tank resin waste stream analysis and characterization, dated July 12, 2024 (2)

Work Order 699028, 10 CFR Part 61 dry active waste stream analysis and characterization, dated December 30, 2024 Shipment Preparation (IP Section 03.04) (1 Sample)

(1)

The inspectors observed the preparation of radioactive shipment #25-03 of spent resin on March 26, 2025.

Shipping Records (IP Section 03.05) (5 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) 23-06, UN3321, radioactive material, low specific activity (LSA-II), fissile-excepted, Class 7, reportable quantity (RQ), dated August 8, 2023

11 (2) 23-10, UN2912, radioactive material, low specific activity (LSA-I), fissile-excepted, Class 7, RQ, dated November 14, 2023 (3) 24-01, UN3321, radioactive material, low specific activity (LSA-II), fissile-excepted, Class 7, dated March 6, 2024 (4) 24-06, UN2912, radioactive material, low specific activity (LSA-I), fissile-excepted, Class 7, dated August 28, 2024 (5)25-01A, UN3321, radioactive material, low specific activity (LSA-II), Class 7, dated January 7, 2025 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)

January 1 through December 31, 2024 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1)

January 1 through December 31, 2024 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1)

January 1 through December 31, 2024 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)

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

(1) automatic depressurization system valve testing failure and review of apparent cause analysis on March 31, 2025 71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (2 Samples)

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

(1)

LER 05000298/2024-007-00, Inoperable Pressure Switch During Mode Change Results in Operation or Condition Prohibited by Technical Specifications (ML24366A126). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71153. This LER is Closed.

12 (2)

LER 05000298/2024-006-00, Human Performance Errors Cause a Condition Prohibited by Technical Specifications and Common Cause lnoperability of Independent Reactor Protection System Channels (ML24354A318). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71153. This LER is Closed.

INSPECTION RESULTS Failure to Maintain Design Configuration Resulting in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2025001-01 Open/Closed

[P.1] -

Identification 71153 The inspectors reviewed a self-revealing finding of very low safety significance (Green) and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." Specifically, the licensee failed to maintain design configuration of safety-related instrumentation associated with main steam safety relief valves, which resulted in the licensee violating Technical Specification limiting condition for operation (LCO) 3.0.4, while the low-low-set (LLS) valve instrumentation was inoperable and the licensee entered the MODE of applicability for LCO 3.3.6.3.

==

Description:==

On November 3, 2024, at 7:53 p.m. during performance of Procedure 6.ADS.201, "ADS Manual Valve Actuation IST," Revision 14, in support of startup in MODE 1, the safety relief valve discharge pressure monitoring pressure switch, MS-PS-300B, did not actuate as expected when safety relief valve MS-RV-71B was taken to the OPEN position.

Tailpipe temperature readings immediately rose, indicating the valve was physically open as expected. A physical walkdown revealed that the stainless-steel braided flex hose connecting the safety relief valve tailpipe was disconnected, contrary to the design configuration specified in Burns and Roe Drawing 2028, "Cooper Nuclear Station Flow Diagram Reactor Building & Drywell Equipment Drain System," Revision 57, rendering MS-PS-300B and its associated functions inoperable.

During investigation of the issue, the licensee discovered a photograph taken on October 16, 2024, while the plant was in MODE 4. The photograph showed the braided hose from MS-RV-71B to MS-PS-300B was disconnected from the tailpipe. The image was taken for unrelated activities, and the subject deficiency was neither identified at the time nor during containment closeout activities or other start-up preparations.

In addition to the primary function of safety relief valve position indication, MS-PS-300B provides secondary functions associated with the LLS relief logic, which lowers operating setpoints of two safety relief valves to reduce cycling of components and stresses on downstream SSCs. The inoperability of MS-PS-300B could have prevented the arming logic for the A channel of LLS to function.

Technical Specification 3.3.6.3, Low-Low Set (LLS) Instrumentation, which is applicable in MODES 1, 2, and 3, requires LLS valve instrumentation for each Function in Table 3.3.6.3-1, to be operable. However, when the plant started up on November 2, 2024, and entered the MODE of applicability at 6:56 p.m., pressure switch MS-PS-300B for channel A LLS valve instrumentation functions was not operable. Additionally, the licensee transitioned the plant from MODE 2 to MODE 1 on November 3, 2024, at 10:29 a.m. However, the licensee failed

13 to recognize before changing MODES that the channel A LLS logic was inoperable and that the the impacted valve (safety relief valve MS-RV-71B) needed to be declared inoperable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

As a result, the licensee entered the MODE of applicability for LCO 3.3.6.3, while LLS valve instrumentation for one channel was not operable, and therefore, failed to meet LCO 3.0.4 due to entry into MODES of applicability when an LCO was not met without meeting one of the acceptable exceptions of LCO 3.0.4.

Corrective Actions: The licensee entered the condition into their corrective action program and repaired the deficient condition identified during the failed surveillance 6.ADS.201, ADS Manual Valve Isolation -IST.

Corrective Action References: CR-CNS-2024-05524 and CR-CNS-2024-05593 Performance Assessment:

Performance Deficiency: Failure to maintain design configuration of safety-related instrumentation does not meet the requirements of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." The licensee failed to ensure the braided hose from MS-RV-71B to MS-PS-300B was connected to the tailpipe, which is reasonably within the licensee's ability to foresee and correct and is therefore, a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control 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's failure to maintain control of the configuration of main steam safety relief valve instrumentation rendered a required channel of LLS unavailable and incapable of performing its technical specification required functions.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter (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.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the organization failed to recognize deviations from standards during the refueling outage and containment closeout inspections and failed to identify equipment deficiencies, which could contribute to conditions prohibited by technical specifications.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," states, in part, that for those SSCs to which this appendix applies, measures shall include provisions to assure that deviations from quality standards are controlled.

Technical Specification 3.3.6.3, Low-Low Set (LLS) Instrumentation, requires, in part that the LLS valve instrumentation for each function in Table 3.3.6.3-1 shall be operable in

14 MODES 1, 2, and 3. Condition A requires channel(s) to be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when one LLS valve is inoperable due to inoperable channel(s). Condition B requires the associated LLS valve(s) declared inoperable immediately when the required action and associated completion time of Condition A is not met.

Technical Specification 3.0, Limiting Condition for Operation (LCO) Applicability, LCO 3.0.4, requires, in part, that when an LCO is not met, entry into a MODE or other specified condition in the applicability shall only be made when LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c are met.

Contrary to the above, from November 2, 2024, to November 4, 2024, the licensee failed to include provisions to assure that deviations from quality standards were controlled.

Specifically, the braided hose from MS-RV-71B to MS-PS-300B, a safety-related component, was not maintained and controlled in the configuration specified by Burns and Roe Drawing 2028, "Cooper Nuclear Station flow diagram reactor building & drywell equipment drain system," Revision 57, a quality standard. As a result, the licensee entered the MODE of applicability for LCO 3.3.6.3, while LLS valve instrumentation for one channel was not operable, and therefore, failed to meet LCO 3.0.4 due to entry into a MODE of applicability when an LCO was not met, and neither LCO 3.0.4.a, LCO 3.0.4.b, nor LCO 3.0.4.c were met.

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

Failure to Follow Surveillance Procedure Resulting in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2025001-02 Open/Closed

[H.12] - Avoid Complacency 71153 The inspectors reviewed a self-revealing 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 surveillance tests, procedures, and calibrations on reactor protection systems. Specifically, formal reviews of completed surveillances failed to identify equipment calibrated out of tolerance, rendering equipment inoperable.

==

Description:==

On October 22, 2024, while performing underfrequency relay calibration in accordance with Procedure 6.2RPS.313, "RPS Electrical Protection Assemblies Calibration and Functional Test (Div 2)," Revision 15, the performer documented as left frequency to be low out of specification per technical specification requirements for the RPS-EPA-1B1 and RPS-EPA-1B2 electric power monitoring assemblies. The licensee marked the surveillance as passed, which was subsequently reviewed by both a Maintenance Supervisor and Control Room Supervisor, as delegated by the Shift Manager. Both reviewers failed to note the discrepancy. Reactor protection systems (RPS) division 2 was declared operable following the control room supervisor review.

On October 24, 2024, the surveillance coordinator was completing an informal review of the completed surveillance when he discovered the error. The surveillance coordinator documented the condition in CR-CNS-2024-05020 and notified the control room.

15 On October 23, 2024, at 2:05 a.m., while in MODE 5, the licensee commenced control rod timing and calibrations, causing the station to enter the MODE of applicability for Technical Specification 3.3.8.2, which requires two RPS electric power monitoring assemblies to be operable for an in-service RPS motor generator set. Since the as left frequency was low out of specification on October 22 for the two RPS electric power monitoring assemblies (RPS-EPA-1B1 and RPS-EPA-1B2), the licensee did not recognize Condition B was applicable, which requires the removal of associated in-service power supply(s) from service within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The duration of the control rod movements exceeded 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, which should have resulted in the licensee taking action in accordance with Condition Dinitiation of action to fully insert all control rods in cells containing fuel assemblies immediately.

The inspectors determined that the required reviews of surveillance testing procedures completed by a maintenance technician, maintenance supervisor, and control room supervisor, were inadequate. With the inadequate reviews and the relays being outside acceptable technical specification limits, the licensee failed to recognize that standard control rod movements (one rod at a time) in preparation for startup were not permitted. As a result, the licensee did not comply with Technical Specification 3.3.8.2.

Corrective Actions: The licensee entered the condition into their corrective action program, developed a procedure use and adherence lesson for electrical maintenance personnel, and reviewed requirements for surveillance test reviews with all licensed senior reactor operators.

Corrective Action References: CR-CNS-2024-05020 Performance Assessment:

Performance Deficiency: Failure to follow surveillance procedures associated with safety-related equipment in accordance with licensee procedures and Technical Specification 5.4.1.a, "Instructions, Procedures, and Drawings" is within the licensee's ability to foresee and prevent, and is therefore, a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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 failure to calibrate relays within the acceptable tolerance rendered two RPS electrical power monitoring assemblies inoperable.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. Using Exhibit 3 -

"Mitigating Systems Screening Questions," the inspectors determined this finding to be of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating SSC; did not represent a loss of system safety function; did not represent an actual loss of safety function of at least a single train for greater than its technical specification allowed outage time; did not represent an actual loss of safety function of one or more non-technical specification trains of equipment during shutdown designated as risk-significant 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 degrade a functional auto-isolation; did not involve an open, cold leg penetration without an adequate, large hot leg vent path; did not involve a seismic, flooding, or severe weather initiating event; and did not involve issues related to fire protection, fire brigade, fire hoses fire extinguishers, or hose stations.

16 Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, individuals did not adequately consider potential undesired consequences of their actions before performing work and implement appropriate error reduction tools while performing the surveillance and conducting required reviews of the surveillancethe Maintenance and Control Room Supervisors reviews failed to identify as left conditions that were outside of calibration tolerances.

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. Section 8 of Appendix A to Regulatory Guide 1.33, Revision 2, provides recommendations for procedures for control of measuring and testing equipment and for surveillance tests, procedures, and calibrations for systems, including RPS tests and calibrations.

The license established Procedure 6.2RPS.313, "RPS Electrical Protection Assemblies Calibration and Functional Test (Div 2)," Revision 15, to implement Regulatory Guide 1.33 requirements. Step 7.1 of Procedure 6.2RPS.313 requires that acceptance criteria include "Values recorded in shaded AS LEFT blocks on Attachment 1 within CALIBRATION TOLERANCES."

Technical Specification 3.3.8.2, Reactor Protection System (RPS) Electric Power Monitoring, requires, in part, two RPS electric power monitoring assemblies to be operable for an in-service RPS motor generator set or alternate power supply while in MODE 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies. Condition B requires inservice power supply(s) to be removed from service within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when one or both inservice power supplies have both electric power monitoring assemblies inoperable.

Condition D requires initiation of action to fully insert all insertable control rods in core cells containing one or more fuel assemblies immediately when required action and associated completion time of Condition B is not met in MODE 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies.

Contrary to the above, from October 22 to October 24, 2024, the licensee failed to ensure that acceptance criteria included "Values recorded in shaded AS LEFT blocks on within CALIBRATION TOLERANCES." Specifically, on October 22, 2024, the licensee documented as left values were out of specification per technical specification requirements for the RPS-EPA-1B1 and RPS-EPA-1B2 RPS electrical power monitoring assemblies, and reviewers failed to note the discrepancy. As a result, the division 2 RPS electrical power monitoring assemblies remained inoperable following surveillance testing, and on October 23, 2024, the licensee performed multiple control rod withdrawals from core cells containing one or more fuel assemblies, which also represented a violation of Technical Specification 3.3.8.2.

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

17 EXIT MEETINGS AND DEBRIEFS The inspectors verified that no proprietary information was retained or documented in this report.

On March 28, 2025, the inspectors presented the public radiation safety inspection results to Khalil Dia, Site Vice President, and other members of the licensee staff.

On April 7, 2025, the inspectors presented the integrated inspection results to John Dent, Jr., Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.

18 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents CR-CNS-2019-06302, 2024-01350, 2025-00260, 2025-01266, 2025-01267 Drawings 2031, Sheet 2 Flow Diagram Reactor Building - Closed Cooling Water System Cooper Nuclear Station 67 Miscellaneous DGB-1-5581972 DG2 JW LEAK Clearance Order 2.2.20.1 Diesel Generator Operations 78 71111.04 Procedures 2.2.65 Reactor Equipment Cooling Water System 69 Cooper Nuclear Station Fire Protection Pre-Fire Plan Control Building Basement Floor Elevation 882'-6" CNS-FP-213 Cooper Nuclear Station Fire Protection Pre-Fire Plan Reactor Building Northwest Quadrant 881'-9" and 859'-9 6

CNS-FP-216 Cooper Nuclear Station Fire Protection Pre-Fire Plan Rx.

Bldg. Critical Switchgear Rm. 1F Elevation 932'-6" 4

CNS-FP-220 Reactor Building Standby Liquid Control Area CNS-FP-221 Reactor MG Set Area Fire Plans CNS-FP-223 Reactor Building Refuel Floor 0-BARRIER-CONTROL Control Building 7

5.4POST-FIRE-REACTOR Reactor Building Post-Fire Operational Information 10 71111.05 Procedures TPP 207 Fire Brigade Drills and Evaluations 8

2.0.1 Plant Operations Policy 69 2.0.2 Operations Logs and Reports 124 2.0.3 Conduct of Operations 108 2.1.10 Station Power Changes 127 2.1.10 Station Power Changes 127 2.2.19 480 VAC Auxiliary Power Distribution System 66 2.2.68.1 Reactor Recirculation System Operations 97 5.3AC480 480 VAC Bus Failure 75 Procedures 5.3GRID Degraded Grid Voltage 56 71111.11Q Work Orders WO 5497856

19 Inspection Procedure Type Designation Description or Title Revision or Date 71111.12 Corrective Action Documents CR-CNS-2025-00693, 2025-00694, 2025-00744, 2025-00748 DGA-1-DG1 Protected Equipment Tagout, Week 2505 DGB-1-DG2 Protected Equipment Tagout, Failed to Start DGB-1-DG2 Protected Equipment Tagout, Week 2503 EDC1-1-EE-CHG-125A MAINT Protected Equipment Tagout, Week 2501 PRA-SA019 Probabilistic Safety Assessment System Analysis Notebook, Cooper Nuclear Station, Service Water and RHR Service Water Booster System 2

PSA-SA006 Probabilistic Safety Assessment System Analysis Notebook, Cooper Nuclear Station, Electrical Power System - AC 2

PSA-SA006 Probabilistic Safety Assessment System Analysis Notebook, Cooper Nuclear Station, Electrical Power System - AC 2

PSA-SA018 Probabilistic Safety Assessment System Analysis Notebook, Cooper Nuclear Station Reactor Core Isolation Cooling (RCIC) System RCIC-1-RCIC Protected Equipment Tagout, Week 2509 71111.13 Miscellaneous RHRB-1-RHR-SUBS-B Protected Equipment Tagout, Week 2503 0-CNS-FAP-OM-031 Emergent Issue Response, Risk Classification, and Oversight Determination 3

0-CNS-06 Site Risk Significance Standards 4

0-CNS-WM-104 On-line Risk Assessment 21 71111.13 Procedures 0-PROTECT-EQP Protected Equipment Program 64 Corrective Action Documents CR-CNS-2025-00693, 2025-00694, 2025-00744, 2025-00748, 2025-00765, 2025-00807, 2025-01266 Drawings

CC05920, 460014829 Air Operated Control Valve Flomatics Globe Valve - Socket Weld Ends 1

71111.15 Miscellaneous Vendor Manual, CNS Number 0988 Fisher 4195K Series Gauge Pressure Controller

20 Inspection Procedure Type Designation Description or Title Revision or Date Procedures 14.25.3 RCIC Auxiliary Cooling Supply Pressure Control Loop 6

Corrective Action Documents CR-CNS-2021-00623, 2024-06048 Miscellaneous BCT-2000 Battery Load Test Report 02/27/2025 2.2.20.1 Diesel Generator Operations 78 6.1PC.204 Purge and Vent Valve 24-month Test (Div1) 5 6.1RHR.101 RHR Test Mode Surveillance Operation (IST)(Div 1) 42, 43 6.2DG.101 Diesel Generator 31 day Operability Test (IST)(Div 2) 94 6.2RHR.101 RHR Test Mode Surveillance Operation (IST)(Div 2) 44 6.2SWBP.101 Division 2 Residual Heat Removal Service Water Booster Pump Flow Test and Valve Operability Test 37 Procedures 6.EE.604 125V Battery Charger Performance Test 24 71111.24 Work Orders 71111.24 WO 5433593, 5481355, 5482129, 5482148, 5488476, 5489278, 5490144, 5497887, 5502872, 5566172, 5588872 0-EP-04 Emergency Preparedness Simulator Scenario-Based Testing 0

2.4ICE River Icing 1

2.4RR Reactor Recirculation Abnormal 51 2.4RXLVL RPV Water Level Control Trouble 29 2.4VAC Loss of Condenser Vacuum 36 71114.06 Procedures 5.3EMPWR Emergency Power during Modes 1, 2, or 3 91 ALARA Plans 2025-03 RWCU Pump B Seal Repair 03/04/2025 CNS-2503-0013 CNS-RP-100 HIC Survey for ASC-200 Metal liner 03/12/2025 CNS-2503-0021 RWCU Pump Room 1B 03/24/2025 CNS-2503-0022 MPF Decon Pit 03/25/2025 CNS-2503-0023 MPF Decon Pit 03/25/2025 CNS-2503-0025 RWCU Pump Room 1B - Down Post Survey 03/25/2025 MPF 903' Decon Pit Work Area Air Sample for RWCU Pump Disassembly 03/25/2025 MPF 903' Decon Pit Work Area Air Sample for RWCU Pump B Work 03/25/2025 71124.01 Radiation Surveys MPF 903' Decon Pit General Area Air Sample for RWCU Pump B work 03/25/2025

21 Inspection Procedure Type Designation Description or Title Revision or Date MPF 903' Decon Pit Beta/Alpha Ratio Smear Count Data Sheet for RWCU Pump B Post Decon 03/25/2025 Rx 931' RWCU Pump Room 1B Beta/Alpha Ratio Smear Count Data Sheet for RWCU Pump Removal 03/24/2025 Rx 931' RWCU Pump Room 1B Work Area Air Sample for Pump Removal and Seal Repair 03/24/2025 2025-102 High Integrity Container (HIC) Prep / Shipments 0

Radiation Work Permits (RWPs) 2025-116 RWCU Pump B Work 0

Work Orders 5585974 Replace RWCU Pump B Mechanical seal 03/25/2025 044591 DMC 2000 Electronic Dosimeter Calibration Report 08/12/2024 DET03 - Charcoal Cartridge Efficiency Calibration at 1 cm 08/07/2024 DET03 - Liquid Marinelli Efficiency Calibration 07/19/2024 DET03 -

Particulate Filter Efficiency Calibration at 1 cm 08/14/2024 NCS IS-10117 Certificate of Calibration for RadCal Model 2026C 10/30/2024 RMA-RA-11 Area Radiation Monitors Calibration and Functional Test 02/11/2025 RMA-RM-40A/B Containment High Range Area Monitor Channel Calibration 09/11/2024 RMV-RM-30A/B Radwaste Building Kaman Monitor Channel Calibration 11/27/2023 RP-10615 and RP-11961 J.L. Shepherd Model 89 Calibration Range 11/20/2024 RP-10844/11189 Instrument Calibration Data Sheet:

Thermo Eberline AMS-4 01/15/2025 RP-10870 Instrument Calibration Data Sheet:

Ludlum Model 2401P 11/18/2024 RP-11271 Instrument Calibration Data Sheet:

Radeco Model HD-29A 08/29/2024 RP-11462 Instrument Calibration Data Sheet:

MGP DRM-1 06/11/2024 RP-11984 Instrument Calibration Sheet:

Mirion ARGOS-5AB 11/13/2024 71124.05 Calibration Records RP-11996 Instrument Calibration Sheet:

Mirion GEM-5 08/152024

22 Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents CR-CNS-2023-03848, 2023-04598, 2023-04599, 2023-04630, 2023-04640, 2023-05245, 2024-01778, 2024-01847, 2024-01899, 2024-01912, 2024-02394, 2024-03302, 2024-03323, 2024-03462, 2024-03475, 2024-03497, 2024-03505, 2024-03925, 2024-04117, 2024-05219, 2024-05739, 2024-05834, 2024-05904, 2024-06156, 2024-06212, 2025-00810 Corrective Action Documents Resulting from Inspection CR-CNS-2025-01626 Miscellaneous 4Q 2024 CNS System Health Report for RM (Radiation Monitors) 12/31/2024 15.ARM.302 Area Radiation Monitors Calibration and Functional Test 22 4.15 Elevated Release Point and Building KAMAN Radiation Monitoring Systems 57 6.PRM.308 Liquid Radwaste Effluent System Channel Calibration 16 6.PRM.310 ERP Kaman Monitor Channel Calibration 32 6.PRM.313 Reactor Building Kaman Monitor Channel Calibration 20 6.PRM.315 Turbine Building Kaman Monitor Channel Calibration 35 6.PRM.320 Radwaste Building Kaman Monitor Channel Calibration 32 6.PRM.322 Containment High Range Area Monitor Channel Calibration 23 6.PRM.323 High Range Containment Monitor Victoreen Model 875 Source Calibration Check 12 6.PRM.324 Main Steam Liner Process Radiation Monitor Channel Calibration Source Test, and Setpoint Determination 36 8-CNS-CY-102 Laboratory Analytical Quality Control 7

9.INST.11 Calibration/Verification of NIST Traceable Radioactive Sources 4

Procedures 9.INST.50 Geiger-Mueller (GM) Survey Meters 10 LO-2024-0044 Chemistry Laboratory Analytical Quality Assurance/Quality Control (QA/QC) Focused Self-Assessment 12/11/2024 Self-Assessments LO-2024-0164 Pre-NRC Assessment for Radiological Monitoring Instrumentation and Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transport Inspections 01/31/2025

23 Inspection Procedure Type Designation Description or Title Revision or Date QAD 2023-035 NIOS Audit 23-07, "Chemistry, Effluent and Environmental Monitoring" 11/06/2023 QAD 2024-016 NIOS Audit 24-04, "Radiological Controls" 09/11/2024 CM 5549428 Replace Detector for RMP-RM-452C 06/06/2024 CM 5555902 Replace Detector for RMP-RM-452A 07/29/2024 W/O 5483810 Containment High Range Area Monitor Functional Test 02/04/2025 W/O 5556540 Replace RMA_RE_29 Radiation Detector 03/25/2025 Work Orders W/O 5562128 Replace RMA-RE-2 Radiation Detector 11/15/2024 Corrective Action Documents CR-CNS-2022-02855, 2022-03078, 2022-03608, 2022-03626, 2022-03633, 2022-03742, 2022-03900, 2022-05300, 2022-06054, 2022-06418, 2023-00075, 2023-00571, 2023-01802, 2023-01819, 2023-02429, 2023-02606, 2023-03138, 2023-03483, 2023-03974, 2023-04471, 2023-04597, 2023-04598, 2023-04599, 2023-04630, 2023-04650, 2023-04718, 2023-04995, 2023-05011, 2023-05012, 2023-05027, 2023-05151, 2023-05335, 2024-00774, 2024-01691, 2024-01778, 2024-01847, 2024-01874, 2024-01912, 2024-01999, 2024-02217, 2024-02381, 2024-02394, 2024-02398, 2024-04676, 2024-02513, 2024-02691, 2024-02708, 2024-02709, 2024-03164, 2024-03221, 2024-03444, 2024-03614, 2024-04676, 2024-05098, 2024-05976, 2024-06277, 2025-00784, 2024-02709, 2024-03614 Corrective Action Documents Resulting from Inspection CR-CNS-2025-01604, 2025-01605 Eckert & Ziegler Analytics - Quarterly Results of Radiochemistry Cross Check Program for 2022 Eckert & Ziegler Analytics - Quarterly Results of Radiochemistry Cross Check Program for 2023 Eckert & Ziegler Analytics - 1st Quarter Results of Radiochemistry Cross Check Program for 2025 71124.06 Miscellaneous Eckert & Ziegler Analytics - Quarterly Results of Radiochemistry Cross Check Program for 2024

24 Inspection Procedure Type Designation Description or Title Revision or Date Annual CNS Land Use Census / Potable Water Use for 2023 07/10/2023 Annual CNS Land Use Census / Potable Water Use for 2024 07/10/2024 Limiting Condition of Operation Tracking Record (LCOTR)

TS22-RMP-RM-3A WATCHDOG -1, TS22-RMV-RM-20A INOP -1, TS22-RW KAMAN FOR 6.2DG.302-01, TS23-ERP NR-HR KAMANS-05, TS23-SGT-A WEEK 2315 MAINT-07, TS24-SGT-B WEEK 2424 -1, NLS2023030 Annual Radioactive Effluent Release Report for 2022 04/27/2023 NLS2024030 Annual Radioactive Effluent Release Report for 2023 04/25/2024 6.1SGT.501 SGT A Carbon Sample, Carbon Adsorber and HEPA Filter In-Place Leak Test, and Components Leak Test (Div 1) 23 6.2SGT.501 SGT B Carbon Sample, Carbon Adsorber and HEPA Filter In-Place Leak Test, and Components Leak Test (Div 2) 26 6.HV.104 Control Room Emergency Filter System Flow Test, Charcoal and HEPA Filter Leak Test, Filter DP Test, And Charcoal Sample Analysis 21 8-CNS-CY-102 Laboratory Analytical Quality Control 7

8-CNS-CY-102-01 Quality Control for Analytical Laboratory Interlab and Intralab Cross-Check Programs 1

8.8ERP Particulate and Iodine Sample Collection for ERP Effluent 22 8.8MPF Particulate and Iodine Sample Collection for MPF Building Effluent 9

8.8RW Particulate and Iodine Sample Collection for Radwaste Building Effluent 16 8.8RX Particulate and Iodine Sample Collection for Reactor Building Effluent 21 Procedures 8.8TB Particulate and Iodine Sample Collection for Turbine Building Effluent 17 NUPIC Audit Number 25248 NCS Corporation audit 10/18/2022 NUPIC Audit/Survey Number 25559 Teledyne Brown Engineering Environmental Services Audit 11/22/2024 Self-Assessments QAD 2023-035 NIOS Audit 23-07, "Chemistry, Effluent and Environmental Monitoring" 11/06/2023

25 Inspection Procedure Type Designation Description or Title Revision or Date Work Orders WO 5348812, 5353473, 5400535, 5446361, 5463966 NPPD W.O.

5418613 Meteorological Instruments 09/01/2022 NPPD W.O.

5444382 Meteorological Instruments 04/06/2023 Calibration Records NPPD W.O.

5461855 Meteorological Instruments 09/28/2023 Corrective Action Documents CR-CNS-2022-03116, 2022-03182, 2022-03183, 2023-00018, 2023-00019, 2023-00118, 2023-02108, 2023-05143, 2024-00223, 2024-00224, 2024-00923, 2024-01201, 2024-01878, 2024-02609, 2024-03913 Corrective Action Documents Resulting from Inspection CR-CNS-2025-01603, 2025-01653 CNS Groundwater Protection Plan 08/31/2008 CNS Groundwater Monitoring Wells Tritium Trends 01/01/2025 2021 CNS 2021 Annual Radioactive Effluent Release Report 04/27/2022 2021 CNS 2021 Annual Radiological Environmental Report 05/10/2022 2022 X/Q and/or D/Q Sectors Annual Offsite Dose Assessment 07/25/2022 2022 CNS 2022 Annual Radioactive Effluent Release Report 04/27/2023 2022 CNS 2022 Annual Radiological Environmental Report 05/11/2023 2022 2022 CNS Annual Land Use Census 07/18/2022 2023 X/Q and/or D/Q Sectors Annual Offsite Dose Assessment 07/23/2024 2023 CNS 2023 Annual Radioactive Effluent Release Report 04/25/2024 2023 CNS 2023 Annual Radiological Environmental Report 05/08/2024 2023 2023 CNS Annual Land Use Census 07/10/2023 2024 X/Q and/or D/Q Sectors Annual Offsite Dose Assessment 07/24/2023 2024 2024 CNS Annual Land Use Census 07/10/2024 Miscellaneous January 1, 2022 -

December 31, 2022 Meteorological Program for Cooper Nuclear Station 06/2023 71124.07 Procedures 14.MET.304 Meteorological Maintenance Procedure for New 100-Meter Tower System-A 7

26 Inspection Procedure Type Designation Description or Title Revision or Date 14.MET.305 Meteorological Maintenance Procedure for New 100-Meter Tower System-B 6

8.ENV.1 REMP Administration 10 8.ENV.2 REMP Sampling 8

8.ENV.4 REMP Air Pump Calibration 1

8.ENV.5 Annual Review of Broadleaf Vegetation Sample Locations Procedure 1

9.RADOP.113 Response to Contaminated Leaks and Spills 0

ODAM Offsite Dose Assessment Manual 09/18/2024 LO 2024-0082 Radiological Environmental Monitoring Program (REMP)

Self-Assessment 01/30/2025 NUPIC Audit 23-01 Radiological Environmental Monitoring Program (REMP)

Environmental, Area, QAQC, and ISFSI TLDs processing for Environmental Monitoring Programs 05/23/2023 NUPIC Audit/Survey Number: 25559 NUPIC Audit: Teledyne Brown 11/22/2024 Self-Assessments QAD 2023-035 NIOS Audit 23-07: Chemistry, Effluent and Environmental Monitoring 11/06/2023 Corrective Action Documents CR-CNS-2023-03833, 2023-03880, 2023-03977, 2023-03978, 2023-03997, 2023-04589, 2023-05081, 2023-05234, 2023-05308, 2024-00101, 2024-00187, 2024-00582, 2024-00937, 2024-00947, 2024-01805, 2024-02784, 2024-02812, 2024-03330, 2024-04126, 2024-06235 Corrective Action Documents Resulting from Inspection CR-CNS-2025-01646, 2025-01647, 2025-01662, 2025-01663 Engineering Changes LBDCR 2023-012 Implementation of the Process Control Program with the new AVANTech Radwaste Resin Processing System at Cooper Nuclear Station 09/14/2023 Radioactive Source Inventory and Leak Test Record 12/18/2024 71124.08 Miscellaneous USAR, Chapter IX - Radioactive Waste Systems 03/21/2013

27 Inspection Procedure Type Designation Description or Title Revision or Date USAR, Chapter XIII - Process Control Program 31 Offsite Radioactive Material Storage Inventory 02/25/2025 Cooper Nuclear Station Process Control Program 04/17/2024 USAR Change Request 2023-0004, IX-3, Radioactive Waste Systems; XIII, Conduct of Operations - Process Control Program 09/14/2023 CNS-RP-504 Radioactive Source Inventory and Leak Test Record -

Disposal of LS85 01/11/2025 CNS-RP-602 2023 Radioactive Material Shipment Log 2023 CNS-RP-602 2024 Radioactive Material Shipment Log 2024 CNS-RP-602 2025 Radioactive Material Shipment Log 2025 NLS2024003 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector 01/15/2024 NLS2024030 Cooper Nuclear Station Annual Radioactive Effluent Release Report - Table 3 Shipments 04/25/2024 2.5.1.6 Radwaste Low Conductivity Liquid Waste Sample Tank Fluid Transfer 48 2.5.4.5 AVANTech Dewatering System 0

59.RW.10 Physical Protection of Category 1 Quantities of Radioactive Material in Transit 9

9.NISP-RP-04 Radiation Protection Posting and Labeling 5

9.RADOP.10 Radioactive Sources Control and Accountability 23 9.RW.1 Radioactive Shipments 42 9.RW.7 Waste Stream Sampling 22 9.RW.9 Filling Containers with Waste/Radioactive Material 18 Procedures Security Procedure 2.16 Radioactive Materials Security 4

CNS-2411-0105 Spent Fuel Pool 11/26/2024 CNS-2412-0006 Rad Material Storage Building 12/05/2024 CNS-2502-0033 Low Level Rad Pad 02/25/2025 Radiation Surveys CNS-2503-0013 Shipment 25-03 ASC-200 Metal Liner 03/12/2025 Radiation Protection Program Annual Report 2023 Self-Assessments LO-2024-0164 Radiological Monitoring Instrumentation and Radioactive 01/31/2025

28 Inspection Procedure Type Designation Description or Title Revision or Date Solid Waste Processing and Radioactive Material Handling, Storage, and Transport QAD 2024-016 NIOS Audit 24-04, Radiological Controls 09/11/2024 23-06 UN3321, Radioactive material, LSA-II, Fissile-excepted, Class 7, RQ 08/08/2023 23-10 UN2912, Radioactive material, LSA-I, Fissile-excepted, Class 7, RQ 11/14/2023 23-12 UN2912, Radioactive material, LSA-I, Fissile-excepted, Class 7 12/12/2023 24-01 UN3321, Radioactive material, LSA-II, Fissile-excepted, Class 7 03/06/2024 24-05 UN2912, Radioactive material, LSA-I, Fissile-excepted, Class 7 06/04/2024 24-06 UN2912, Radioactive material, LSA-I, Fissile-excepted, Class 7 08/28/2024 25-01A UN3321, Radioactive material, LSA-II, Class 7 01/07/2025 Shipping Records 25-03 UN3321, Radioactive material, LSA-II, Fissile-excepted, Class 7 03/26/2025 672500 10 CFR 61 Analysis - Condensate Phase Separator Tank 'A' Condensate/Waste Sludge Tank Resin 07/12/2024 Work Orders 699028 10 CFR 61 Analysis - Dry Active Waste Smears RE-33 12/30/2024 71152A Corrective Action Documents CR-CNS-2022-06220, 2024-05593, 2024-05524 71153 Corrective Action Documents CR-CNS-2024-05524