ML25153A593

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Nuclear Station - Security Baseline Inspection Report 05000298/2025403
ML25153A593
Person / Time
Site: Cooper 
Issue date: 06/11/2025
From: Jesse Rollins
NRC/RGN-IV/DRSS/PSB
To: Dia K
Nebraska Public Power District (NPPD)
References
IR 2025403
Download: ML25153A593 (1)


Text

June 11, 2025 Khalil Dia, Site Vice President Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - SECURITY BASELINE INSPECTION REPORT 05000298/2025403

Dear Khalil Dia:

On May 10, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On May 27, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. No NRC-identified or self-revealing findings were identified during this inspection.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; and the NRC Resident Inspector at Cooper Nuclear Station.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jesse M. Rollins, Chief Physical Security Branch Division of Radiological Safety & Security Signed by Rollins, Jesse on 06/11/25

K. Dia 2

Docket No. 05000298 License No. DPR-46

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML25153A593

SUNSI Review By: JMA

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available OFFICE PSI:DRSS/PSB PSI:DRSS/PSB SRI:DORS/RPB2 BC:DRSS/PSB NAME RLanfear JAllen MStafford JRollins SIGNATURE

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DATE 06/02/25 06/02/25 06/03/25 06/11/25

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

05000298 License Number:

DPR-46 Report Number:

05000298/2025403 Enterprise Identifier:

I-2025-403-0002 Licensee:

Nebraska Public Power District Facility:

Cooper Nuclear Station Location:

Brownville, NE Inspection Dates:

May 5, 2025, to May 10, 2025 Inspectors:

J. Allen, Physical Security Inspector R. Lanfear, Physical Security Inspector M. Stafford, Senior Resident Inspector Approved By:

Jesse M. Rollins, Chief Physical Security Branch Division of Radiological Safety & Security

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Cooper Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Ensure That the Arrival and Presence of an NRC Inspector is Not Announced Unless Specifically Requested Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2025403-01 Open/Closed Not Applicable 71130.05 The inspectors identified a Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.70(b)(4) associated with the licensees failure to ensure the arrival and presence of an NRC inspector is not announced or otherwise communicated by its employees without a specific request by the NRC inspector. Specifically, during an NRC security inspection at the facility, a security officer alerted other security officers inside of a security post that an NRC inspector was coming. This adversely impacts the NRCs ability to perform its regulatory oversight function.

Additional Tracking Items None.

3 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2201, Security Inspection Program for Commercial Nuclear Power Reactors. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFEGUARDS 71130.05 - Protective Strategy Evaluation The inspectors evaluated the licensee's protective strategy through completion of the following procedure elements:

Protective Strategy Evaluation (2 Samples)

(1)

Tier I: All Requirements Tier II: 17 Requirements (02.05a., 02.06a., c., f.-n., 02.07a.-e.)

Tier III: All Requirements (2)

Performance Evaluation Program: The inspectors observed the licensees annual force-on-force exercise on May 9, 2025.

71130.14 - Review of Power Reactor Target Sets The inspectors evaluated the Security Target Set Program. The following elements were evaluated:

Review of Power Reactor Target Sets (1 Sample)

(1)

All Requirements (03.01 - 03.05)

INSPECTION RESULTS Failure to Ensure That the Arrival and Presence of an NRC Inspector is Not Announced Unless Specifically Requested Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000298/2025403-01 Open/Closed Not Applicable 71130.05 The inspectors identified a Severity Level IV NCV of 10 CFR 50.70(b)(4) associated with the licensees failure to ensure the arrival and presence of an NRC inspector is not announced or otherwise communicated by its employees without a specific request by the NRC inspector.

Specifically, during an NRC security inspection at the facility, a security officer alerted other

4 security officers inside of a security post that an NRC inspector was coming. This adversely impacts the NRCs ability to perform its regulatory oversight function.

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Description:==

On May 6, 2025, while conducting a security baseline inspection at the Cooper Nuclear Station, an NRC security inspector was conducting checks of security posts inside the protected area. While the inspector was interviewing security officers and checking equipment inside of a security post, the door to that security post abruptly swung open and another security officer announced to everyone in the room that the NRC was coming. The security officer quickly recognized that his actions may not have been appropriate and self-reported the incident to security management at the site. Announcing the presence or arrival of an NRC inspector onsite impedes the NRCs ability to perform its regulatory oversight function.

Corrective Actions: When notified of the event, the licensee escorted the security officer offsite, placed their unescorted access on hold, conducted an investigation, and took personnel actions that the licensee deemed appropriate. The licensee also entered the incident into its corrective action program for review and notified its entire security organization about the incident, reinforcing its expectation that site personnel will not announce the NRCs presence onsite without NRC approval.

Corrective Action References: CR-CNS-2025-02232 Performance Assessment: The inspectors determined this violation was associated with a minor Reactor Oversight Process (ROP) performance deficiency.

Enforcement: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement to adequately deter non-compliance.

Severity: This issue was determined to be a Severity Level IV violation in accordance with the NRCs Enforcement Policy. The severity of the violation is consistent with NRC Enforcement Policy Section 2.2.2.d., which states that Severity Level IV violations are those that are less serious, but are of more than minor concern, that resulted in no or relatively inappreciable potential safety or security consequences.

Violation: 10 CFR 50.70(b)(4) requires that the licensee or construction permit holder (nuclear power reactor only) shall ensure that the arrival and presence of an NRC inspector, who has been properly authorized facility access as described in paragraph (b)(3) of this section, is not announced or otherwise communicated by its employees or contractors to other persons at the facility unless specifically requested by the NRC inspector.

Contrary to the above, on May 6, 2025, the licensee failed to ensure that the arrival and presence of an NRC inspector, who was properly authorized facility access as described in 10 CFR 50.70(b)(3), was not announced or otherwise communicated by its employees to other persons at the facility unless specifically requested by the NRC inspector. Specifically, without approval from the NRC inspector, a security officer informed other security officers onsite that an NRC inspector was in the area conducting inspection activities and was moving toward their location.

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

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

On May 27, 2025, the inspectors presented the security baseline inspection results to Khalil Dia, Site Vice President, and other members of the licensee staff.

On May 9, 2025, the inspectors presented a debrief of the inspection activities to Jeremy Allen, Security Manager, and other members of the licensee staff.

6 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents CR-CNS-2024-00960, CR-CNS-2024-02833, CR-CNS-2024-01528, CR-CNS-2025-01994, CR-CNS-2025-01842, CR-CNS-2025-01888, CR-CNS-2025-02184 Corrective Action Documents Resulting from Inspection CR-CNS-2025-02222, CR-CNS-2025-02232, CR-CNS-2025-02260, CR-CNS-2025-02264, CR-CNS-2025-02273, CR-CNS-2025-02275, CR-CNS-2025-02317, CR-CNS-2025-06057 Miscellaneous Training Presentation Force on Force Drill / Exercise Controller / Evaluator Training 0-SE-JPM-4.20 Mock Adversary Force Training 2

Cooper Nuclear Station Physical Security Plan 11/30/2023 Security Procedure 2.13 Security Team Training and Exercises 38 Security Procedure 2.14 Compensatory Measure 60 71130.05 Procedures Security CAS/SAS Duties 59

7 Inspection Procedure Type Designation Description or Title Revision or Date Procedure 2.3 Security Procedure 2.4 Patrol Duties 50 Self-Assessments QAD-2025-024 Security Programs 05/21/2025 Corrective Action Documents CR-CNS-2025-00242 Security Self-Assessment 01/15/2025 Corrective Action Documents Resulting from Inspection CR-CNS-2025-02242, CR-CNS-2025-02243, CR-CNS-2025-02246, CR-CNS-2025-02248 Miscellaneous Cooper Nuclear Station Target Sets Target Sets 21 0-CNS-WM-106 Planning 2

0-SEC-INTERFACE Safety/Security Interface Screen 10 5.5SECURITY Security 44 IP-ENG-001 Standard Design Process 1

71130.14 Procedures Security Procedure 2.15 Development and Maintenance of Critical Target Sets 12