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#REDIRECT [[IR 05000298/2018002]]
{{Adams
| number = ML18206A216
| issue date = 07/25/2018
| title = Cooper Nuclear Station - NRC Integrated Inspection Report 05000298/2018002
| author name = Kozal J W
| author affiliation = NRC/RGN-IV/DRP/RPB-C
| addressee name = Dent J
| addressee affiliation = Nebraska Public Power District (NPPD)
| docket = 05000298
| license number = DPR-046
| contact person = Kozal J W
| document report number = IR 2018002
| document type = Inspection Report, Letter
| page count = 27
}}
See also: [[followed by::IR 05000298/2018002]]
 
=Text=
{{#Wiki_filter:July 25, 2018
  Mr. John Dent, Jr.
Vice President
-Nuclear and CNO
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
P.O. Box 98
Brownville, NE  68321
  SUBJECT: COOPER NUCLEAR STATION
- NRC INTEGRATED
INSPECTION REPORT 05000 298/2018002  Dear Mr. Dent:  On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station
.  On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. K. Dia, Acting Vice President
-Nuclear and CNO, and other members of your staff.  The results of this inspection are documented in the enclosed report.
  NRC inspectors documented three findings of very low safety significance (Green) in this report.  All of these findings involved violations
of NRC requirements
.  The NRC is treating these violation s as non-cited violations (NCVs) consistent with Section
2.3.2.a of the Enforcement Policy.  If you contest the violations or significance of these NCVs, 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 the 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 the Cooper Nuclear Station.
       
J. Dent Jr. 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 10
CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.
"  Sincerely,  /RA/  Jason W. Kozal , Chief Project Branch C Division of Reactor Projects
  Docket No. 50
-298 License No. DPR-46  Enclosure: 
Inspection Report
05000298/2018002
w/ Attachment:
1. Documents Reviewed
2. NRC Request for Information
   
  Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
  Docket Number:
05000298  License Number:
DPR-46  Report Number:
05000298/2018002  Enterprise Identifier:
I-2018-002-0003  Licensee: Nebraska Public Power District
  Facility: Cooper Nuclear Station
  Location: Brownville, Nebraska
  Inspection Dates:
April 1, 2018
to June 30, 2018
  Inspectors:
M. Tobin, Acting Senior Resident Inspector
R. Kumana, Acting Senior Resident Inspector
R. Deese, Senior Reactor Analyst
J. Mateychick, Senior Reactor Inspector
W. Sifre, Senior Reactor Inspector
C. Young, Senior Project Engineer
M. Stafford, Resident Inspector
  Approved By:
J. Kozal, Chief, Project Branch C
  Division of Reactor Projects
   
  2  SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Cooper Nuclear Station in accordance with the Reactor Oversight Process.  The Reactor Oversight Process is the NRC's program for
overseeing the safe operation of commercial nuclear power reactors.  Refer to https://www.nrc.gov/reactors/operating/oversight.html
for more information.  NRC and self
-revealed violations and additional items are summarized in the tables below.
  List of Findings and Violations
Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid
Cornerstone
Significance
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002
-01 Closed [H.3] - Human Performance, Change Management
71111.05XT
- Fire Protection
- NFPA 805 (Triennial)
The inspectors identified a Green non-cited violation of License Condition
2.C.(4), "Fire Protection," for the failure to establish an appropriate monitoring program in accordance with Section 2.6 of the National Fire Protection Association (NFPA) Standard
805, "Performance
-Based Standard for Fire Protection for Light
-Water Reactor Electric Generating Plants."  Specifically, the licensee failed to set the action level for the availability of some plant components to ensure that the assumptions in the engineering analysis remained valid.
  Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone
Significance
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management
71111.18 - Plant Modifications
The inspectors identified a Green non
-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure
2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified
in Engineering Evaluation NEDC 92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision 3C2.  As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13
hours for completion of manual actions rather than the bounding 5.8
-hour allowance described in NEDC
92-064. 
  3  Failure to Maintain Adequate Work Instructions for Traversing In
-Core Probe System Limit Switches Cornerstone
Significance
Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000298/2018002
-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion
A self-revealed, Green non-cited violation of Technical Specification 5.4, "Procedures," was identified when the licensee failed to maintain Procedure
14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in
-core probe system
in-shield limit switches.  As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves
.  Additional Tracking Items
Type Issue number
Title Report Section Status URI 05000298/2016008
-01 Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid 71111.05 XT Closed LER 05000298/2017
-005-00 Traversing In
-core Probe
In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
71153 Closed   
  4  PLANT STATUS
The unit began the inspection period at rated thermal power.  On May 30, 2018, the unit was shut down for repairs to the drywell fan co
il units.  The unit was returned to rated thermal power
on June 11, 2018 , and remained at or near 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 plant status activities described in IMC 2515 , Appendix D, "Plant Status
," and conducted routine reviews using IP
71152, "Problem Identification and Resolution."
  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
Summer Readiness
(1 Sample) The inspectors evaluated summer readiness of offsite and alternate alternating current
(AC) power systems
on May 11, 2018.  External Flooding
(1 Sample) The inspectors evaluated readiness to cope with external flooding on May 17, 2018.  71111.04-Equipment Alignment
Partial Walkdown
(3 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
  (1) Reactor core isolation cooling during high pressure coolant injection work window
on April 18, 2018 (2) Shutdown cooling
A while B in service on June 1, 2018 (3) Control building ventilation for service water
booster system
on May 11, 2018 Complete Walkdown
(1 Sample) The inspectors evaluated system configurations during a complete walkdown of the high pressure coolant injection full system alignment
o n June 28, 2018. 
  5  71111.05Q-Fire Protection
Quarterly Inspection
(5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:  (1) Intake building and service water pump room
on April 5, 2018 (2) Reactor core isolation cooling and core spray
A area on April 18, 2018 (3) 125/250 Vdc battery and switchgear room on May 23, 2018 (4) Supplemental diesel generator on May
29, 2018 (5) Cable spreading room on June 28, 2018
  71111.05XT
-Fire Protection
- NFPA 805 (Triennial)
The inspectors reviewed the licensee's actions to address the issue identified in
Unresolved Item (URI)
05000298/2016008
-01 from May 7, 2018, to June 5, 2018.  This URI is now closed.  71111.06-Flood Protection Measures
Internal Flooding
(1 Sample) The inspectors evaluated internal flooding mitigation protections in the high pressure coolant injection room
on June 26, 2018
.  71111.11-Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification
(1 Sample) The inspectors observed and evaluated operator training during a licensed operator requalification simulator scenario focusing on an anticipated transient without a scram on May 18, 2018.  Operator Performance
(1 Sample) The inspectors observed and evaluated operator performance during a downpower for a forced outage associated with fan coil unit maintenance
on May 29, 2018.  71111.12-Maintenance Effectiveness
Routine Maintenance Effectiveness
(2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
  (1) Service water
booster system
room cooler
on May 11 , 2018 (2) Traversing in
-core probe on May 11 , 2018 
  6  71111.13-Maintenance Risk Assessments and Emergent Work Control
(5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities:
  (1) High pressure coolant injection
maintenance window
on April 19, 2018 (2) Service water
booster system
room cooler risk evaluation on May 11 , 2018 (3) Service water pump
D work week on May
17, 2018 (4) Emergent drywell fan coil unit
D work on May 18, 2018 (5) Emergent downpower due to drywell fan coil unit A on May 26, 2018  71111.15-Operability Determinations and Functionality Assessments
(4 Samples) The inspectors evaluated the following operability determinations and functionality assessments:
  (1) Emergency diesel generator
2 jacket water temperature issue on April
25, 2018 (2) Service water
booster system
pipe below minimum wall thickness on May
1, 2018 (3) Fan coil unit functionality
on June 22, 2018 (4) High pressure coolant injection operability with room floor drains clogged, extending limiting condition for operation time on June
25, 2018 71111.18-Plant Modifications (2 Samples) The inspectors evaluated the following temporary or permanent modifications:
(1) Service water
booster system
room fan coil unit manual actions on May
11 , 2018 (2) Service water booster pump oil reservoirs on May
11, 2018  71111.19-Post Maintenance Testing
(4 Samples) The inspectors evaluated the following post maintenance
tests:  (1) HPCI-MO-15 following packing replacement on March
15, 2018 (2) High pressure coolant injection pump test following maintenance window on April 20 2018 (3) Service water
pump C on May 3, 2018 (4) Reactor recirculation pump
B relay replacement on June 21, 2018 71111.20-Refueling and Other Outage Activities
(1 Sample) The inspectors evaluated fan coil D forced outage activities
from May 30, 2018 to June 11, 2018. 
  7  71111.22-Surveillance Testing
The inspectors evaluated the following surveillance tests:
  Routine (3 Samples) (1) Service water pump
D surveillance test on May 29, 2018 (2) Division 1 reactor recirculation flow unit channel calibration on June 7, 2018 (3) Operator rounds on June 15, 2018  In-service (1 Sample) (1) Core spray subsystem
A quarterly inservice surveillance test on May 1, 2018  71114.06-Drill Evaluation
Emergency Planning Drill
(1 Sample) The inspectors evaluated a full team drill
on May 22, 2018.  OTHER ACTIVITIES
- BASELINE 71151-Performance Indicator Verification
(3 Samples) The inspectors
verified licensee performance
indicators
submittals
listed below:  (1) MS05:  Safety System Functional Failures (SSFFs) (April 1, 2017 - March 31, 2018) (1 Sample) (2) BI01:  Reactor Coolant System (RCS) Specific Activity
(April 1, 2017 - March 31, 2018) (1 Sample) (3) BI02:  RCS Leak Rate
(April 1, 2017 - March 31, 2018) (1 Sample)  71152-Problem Identification and Resolution
Semiannual Trend Review
(1 Sample) The inspectors reviewed the licensee's corrective action program for trends that might be indicative of a more significant safety issue.
  Annual Follow
-up of Selected Issue s (1 Sample) The inspectors reviewed the licensee's implementation of its corrective acti
on program related to
the following issues:
  (1) Emergency diesel generator damper failures on May 11, 2018 
  8  71153-Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 Sample) The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
:  (1) Licensee Event Report (LER
) 05000 298/201 7-005-00, Traversing In
-core Probe
In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
(ADAMS Accession No.
ML17236A166), on May 11 , 2018.    INSPECTION RESULTS
Observation
71152 - Problem Identification
and Resolution
The inspectors identified a potential adverse trend involving the sizing of bolts associated with emergency diesel generator components.  The inspectors determined that the licensee documented multiple instances where they discovered incorrect bolting on various components of the emergency diesel generators.  The inspectors determined that in all cases reviewed, the licensee had determined that the bolts used in the plant were greater than the length required by design, had adequate thread engagement
to ensure they maintained their safety function, and did not adversely impact the ability of the emergency diesel generators to perform their function.  The inspectors determined that the licensee had identified these issues through focused observation of the system design requirements and had implemented appropriate corrective actions.
  Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid
Cornerstone
Significance
Cross-cutting Aspect Report Section Mitigating Systems
Green NCV 05000298/2018002
-01 Closed [H.3] - Human Performance, Change Management
71111.05XT
- Fire Protection
- NFPA 805 (Triennial)
The inspectors identified a Green non
-cited violation of License Condition
2.C.(4), "Fire Protection," for the failure to establish an appropriate monitoring program in accordance with Section 2.6 of the National Fire Protection Association (NFPA) Standard
805, "Performance
-Based Standard for Fire Protection for Light
-Water Reactor Electric Generating Plants."  Specifically, the licensee failed to set the action level for the availability of some plant components to ensure that the assumptions in the engineering analysis remained valid.
Description
:  During the NRC triennial fire protection inspection in 2016 (see NRC Inspection Report 05000298/2016008
(Agencywide Documents Access and Managem
ent System (ADAMS) Accession No.
ML16270A561)), the inspectors reviewed the licensee's implementation of the monitoring program required in Section
2.6 of NFPA Standard
805, "Performance
-Based Standard for Fire Protection for Light
-Water Reactor Electric Generating Plants."  NFPA
805 requires the following in Section
2.6: 
  9  Monitoring.  A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained
, and to assess the performance of the fire protection program in meeting the performance criteria.  Monitoring shall ensure that the assumptions in the engineering analysis remain valid.
  The inspectors reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, "National Fire Protection Association (NFPA)
805 Monitoring Program," Revision
0, to ensure that the licensee's program properly implemented the requirements of NFPA
805, Section
2.6.  The inspectors also reviewed Engineering Report ER-2015-002, "National Fire Protection Association (NFPA)
805 Fire Protection Monitoring Program," Revision 2.  The inspectors observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule (10 CFR 50.65) monitoring program.  These components included the:  Control rod drive pumps
  Core spray pumps
  Emergency diesel generators
  Emergency station service transformer
  Startup station service transformer
  High pressure core spray pump
  Instrument air compressors
  Residual heat removal pumps
  Standby liquid control pumps
  Service water pumps
  The inspectors noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment and questioned whether this met the requirement in NFPA
805 to maintain the assumptions in the engineering analysis.
  Clarifications of the monitoring program requirements were being discussed between the industry and the NRC's Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question
10-0059, "National Fire Protection Association (NFPA) 805 Monitoring."  With the further clarification pending, the inspectors documented the issue as Unresolved Item
05000298/2016008
-01, "Possible
Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid."  The discussions failed to provide any additional guidance
; therefore, the inspectors are addressing this issue based on the information contained in
Frequently Asked Question
10-0059, "National Fire Protection Association (NFPA)
805 Monitoring," Revision
5.  Corrective Action (s):  The inspectors concluded that the issue did not present an immediate safety concern based on the licensee performing a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule.  This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire
probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability.  The increase in core damage frequency was determined to not exceed 1.0E
-6/year. 
  10  Corrective Action Reference
(s):  Condition Report
CR-CNS-2016-05109 Performance Assessment
:  Performance Deficiency:  The failure to adequately monitor unavailability of the plant components to ensure that the assumptions in the engineering analysis remained valid was a performance deficiency.
  Screening:  The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern.  Specifically, the performance deficiency could adversely affect the acceptable level of availability of the components which are used to respond to fire initiating events, in that the action levels for availability in the monitoring program were greater than the assumptions in the fire probabilistic risk assessment.
  This finding affects the Mitigating Systems Cornerstone.
  Significance:  The inspectors assessed the significance of the finding using
NRC Inspection Manual Chapter
0609, "Significance Determination Process," Attachment
4, "Initial Characterization of Findings," dated October 7, 2016, as requiring significance determination per Manual Chapter
0609, Appendix
F, "Fire Protection Significance Determination Process," dated May 2, 2018, because the finding affected the ability to reach and maintain safe shutdown conditions in case of a fire.
The inspectors categorized the finding as a post
-fire safe shutdown finding with a high degradation rating.  The high degradation rating was made using Manual Chapter
0609, Appendix
F, Attachment
2, "Degradation Rating Guidance," dated May 2, 2018, because the finding was not a minor procedural deficiency that was able to be compensated by operators.  Using
step 1.4.7 of Attachment
1 of Appendix
F, the finding was screened as a Green finding of very low safety significance in
Question 1.4.7-C because the fire finding did not adversely affect the ability to reach and maintain hot shutdown/hot standby, or safe and stable conditions using the credited safe shutdown success path.
  Cross-cutting Aspect:  This finding had a cross
-cutting aspect associated with change management within the human performance area since the leaders failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.  Specifically, the inspectors determined that the licensee
did not use the process that was in place to ensure that the appropriate fire risk assessment monitoring action levels were incorporated into the maintenance rule program and monitored
[H.3]. Enforcement
:  Violation:  License Condition
2.C.(4), "Fire Protection," states, in part, "Nebraska Public Power District shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10
CFR 50.48(a) and 10
CFR 50.48(c), as specified in the license amendment request
, dated April
24, 2012 , (and supplements
dated July
12, 2012, January 14, 2013, February
12, 2013, March
13, 2013, June
13, 2013, December
12, 2013, January 17, 2014, February
18, 2014, and April
11, 2014), and as approved in the safety evaluation dated Apr
il 29, 2014."  The approved fire protection program is a risk
-informed performance
-based program in accordance with NFPA
805, "Performance
-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
," which is incorporated by reference into
10 CFR 50.48(c).  NFPA
805, Section
2.6, "Monitoring," states that, "Monitoring shall ensure that the assumptions in the engineering analysis remain valid."
 
  11  Contrary to the above, from April 29, 2014, to June 5 , 2018, the licensee failed to appropriately monitor plant equipment to ensure that the assumptions in the NFPA
805 engineering analysis remained valid.  Specifically, the licensee's monitoring program did not
monitor the availability of the
control rod drive pumps, core spray pumps, emergency diesel generators, emergency station service transformer, startup station service transformer, high pressure core spray pump, instrument air compressors, residual heat removal pumps, standby liquid control pumps, and service water pumps to ensure that it was no lower than the fire probabilistic risk assessment assumptions.
  Disposition:
  This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
  The disposition of this finding and associated violation closes Unresolved Item 05000298/2016008
-01.  Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone
Significance
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management
71111.18 - Plant Modifications
The inspectors identified a Green non
-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure
2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC 92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision 3C2.  As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13
hours for completion of manual actions rather than the bounding 5.8
-hour allowance described in NEDC
92-064. Description
:  On October
13, 2017, during routine maintenance activities for the service water booster pump (SWBP) fan coil unit (FCU), FC
-C-1A, the licensee discovered a 5
-10 gallon per minute (gpm) leak in the cooling coil.  The licensee was using high pressure demineralize
d water to flush the FCU when the leak initiated, and operations personnel took action to isolate the coil.  The fan coil unit is used to cool the SWBP room, which contains all four SWBPs, when power is lost to the site and nonessential ventilation is automatically
isolated from the room.  The SWBPs provide service water to the residual heat removal (RHR) heat exchange
rs during accident and shutdown cooling conditions.  The operations crew determined that the SWBPs remained operable because Updated Safety Analysis
Report (USAR)
, Section X-10.3.5.4 , states that although the fan coil unit can be used to keep the room cool during an accident, "acceptable room temperatures can be maintained for a single RHR service water booster pump without forced ventilation through operator action to reduce the room heat load and establishment of a natural ventilation flowpath."  The operations crew also determined that these manual actions, which included rigging and removing three equipment hatches and opening three control building doors, were directed by Alarm Procedure
2.3_R-1, "Panel R
- Annunciator R
-1 ," Revision 18.  The inspectors reviewed Calculation NEDC
92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision
3C2, and Calculation NEDC
92-063, "Maximum SWBP Room Temperatures w/ No Cooling From Control Bldg HVAC," Revision
1.  These heat
-up 
  12  calculations served as the basis for acceptability of the manual ventilation actions described in Alarm Procedure
2.3_R-1.  NEDC 92-064 concluded that the required maximum design temperature for the SWBP room was 131
degrees Fahrenheit
(F).  The calculation also concluded that with the FCU unavailable, once the SWBP room high temperature alarm was triggered at 120
degrees F, the control room staff would enter Alarm Procedure
2.3_R-1, and station personnel would have a limited amount of time to establish a natural ventilation path and secure excess heat loads in the room before operability of all four SWBPs was lost.  The calculation determined that if two SWBPs were in service, station personnel would have 5.8 hours to establish a ventilation path, secure all lighting, de
-energize all instrument air compressors, secure all instrument air dryers, and secure all but one SWBP.  The calculation also determined that
station personnel would have 13
hours to perform the same actions if only one SWBP was in service during an accident scenario.  The inspectors also noted that emergency operating procedures directed control room staff to "operate all available suppression pool cooling" during accident conditions, which made operation of two SWBPs a very likely scenario during an accident.
  The inspectors also reviewed Alarm Procedure
2.3_R-1, Revision
17 , and 50.59 Evaluation
2013-04, "RHR SWBP FCU 50.59 Inadequate for USAR Change LCR
93-10," Revision 0.  Evaluation
2013-04 sought to prove through simulation that the associated manual actions could be completed within the limiting 5.8
hours that would be available during an event.  This evaluation concluded that the activities could be completed in less than
5 hours, and deemed the actions acceptable.
Upon review of Alarm Procedure
2.3_R-1, the inspectors discovered that step
1.3 of the procedure provided directions to secure heat loads in the room and establish natural ventilation through manual actions.  However, prior to
step 1.3, a procedure note stated, "NEDC
92-064 assumes that step
1.3 is complete within
13 hours of receiving RHR SWBP ROOM high temperature alarm."  The inspectors determined that this procedure should have included the bounding timeline of 5.8
hours, as
described by NEDC
92-064, rather than the timeline of 13
hours that was based on the
nonconservative
assumption that only one SWBP would be in service.  The inspectors challenged the licensee on the procedure timelines, and the licensee initiated Condition Report CR-CNS-2017-07601 and performed the associated procedure changes to make the correction on December 21, 2017.  The inspectors concluded that, prior to December
21, 2017, the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified
in Engineering Evaluation NEDC
92-064.  In addition, prior to 2015, the procedure failed to contain any timeline restrictions, despite NEDC
92-064 concluding that time critical manual ventilation actions were required to ensure operability of all four service water booster pumps.  The inspectors found that a May
2015 procedure change introduced the nonconservative 13
-hour timeline into Alarm Procedure
2.3_R-1.  Corrective Action(s):  The licensee implemented a revision to Alarm Procedure
2.3_R-1 to include the correct manual action required timelines.  Corrective Action Reference(s):  Condition Report
CR-CNS-2017-07601 Performance Assessment
:  Performance Deficiency:  The licensee's failure to provide adequate guidance for restoring room cooling in Alarm Procedure
2.3_R-1 was a performance deficiency.
 
  13  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 (i.e., core damage).
  Significance:  The inspectors assessed the significance of the finding using Inspection Manual Chapt
er 0609, Appendix
A, "The Significance Determination Process for Finding
s At-Power."  Using Exhibit
2, "Mitigating Systems Screening Questions," the finding was screened as having very low safety significance (Green) because the finding was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety
-significant nontechnical specification train.
  Cross-cutting Aspect:  The inspectors determined that the finding had a cross
-cutting aspect in the area of
human performance associated with change management , because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.  Specifically, the licensee failed to ensure that the appropriate and correct changes were made when updating the procedure. [H.3]
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 Appendix
A of Regulatory Guide
1.33, Revision
2.  Section
5 of Appendix
A to Regulatory Guide 1.33, Revision
2, requires, "Procedures for Abnormal, Offnormal, or Alarm Conditions."  The licensee established Alarm Procedure
2.3_R-1, "Panel R
- Annunciator R
-1," Revision 17, to meet the Regulatory Guide
1.33 requirement
.  Contrary to the above, prior to December
21, 2017, the licensee failed to maintain adequate written procedures
for abnormal, offnormal, or alarm conditions.
  Specifically, the licensee failed to maintain Alarm Procedure
2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC
92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision
3C2.  Disposition:  This violation is being treated as a
n on-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
             
  14  Failure to Maintain Adequate Work Instructions for Traversing In
-Core Probe System Limit Switches Cornerstone
Significance
Cross-cutting Aspect Report Section Barrier Integrity
Green NCV 05000298/2018002
-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion
A self-revealed, Green, non
-cited violation of Technical Specification 5.4, "Procedures," was identified when t
he licensee failed to maintain Procedure
14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in
-core probe system
in-shield limit switches.  As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves
. Description
:  On June 21, 2017, during operation of the traversing in
-core probe (TIP) system, the C probe failed to stop at the correct "in
-shield" position during withdrawal of the probe from the core.  The probe is designed to stop when the limit switch is activated.  While the limit switch is not activated, the associated containment isolation ball valve is blocked from automatic and manual operation.  The licensee declared the valve inoperable.  Subsequently, on June 22, 2017, the D probe failed to stop at the "in
-shield" position during withdrawal.  The licensee declared the D containment isolation ball valve inoperable.  The licensee determined that the cause of the failures was that the limit switches had become loose due to inadequate mounting of the switches to the chamber shields.  The design drawing for the system indicated that the switches were to be mounted using bolts and washers, but the licensee identified that some mounting bolts did not have washers installed.
  The switches had been removed and reinstalled during performance of Procedure
14.2.14 , "TIP Chamber Shield Maintenance," Revision 12 , as part of the maintenance of the system.  The procedures did not specify the method for reinstalling the switches.  The licensee found that the vendor drawing specified the use of washers.
  Corrective Action(s):
  The licensee implemented a revision to Procedure
14.2.14 to include a description of the vendor specified mounting configuration and a requirement to apply a minimum torque to the bolts.
  Corrective Action Reference(s):  Condition Report
CR-CNS-2017-0003 9 Performance Assessment
:  Performance Deficiency:  The licensee's failure to provide adequate guidance for maintenance on the TIP system was 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 Barrier Integrity
Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and
containment) protect the public from radionuclide releases caused by accidents or events
.  Significance:  The inspectors assessed the significance of the finding using Inspection Manual Chapter
0609, Appendix
A, "The Significance Determination Process for Finding s 
  15  At-Power."  Using Exhibit
3 , "Barrier Integrity
Screening Questions," the finding was screened as having very low safety significance (Green) because the finding
did not represent an actual open pathway in the physical integrity of reactor containment (valves, airlocks, etc.), containment isolation system (logic and instrumentation), and heat removal components, and did not involve hydrogen igniters
.  Cross-cutting Aspect:  No cross-cutting aspect was assigned
to this finding
because the inspectors determined that since the last revision of the procedure was more than three years ago, the finding did not reflect present licensee performance.
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 Appendix
A of Regulatory Guide 1.33, Revision
2.  Appendix
A to Regulatory Guide
1.33, Revision 2, Section 9, "Procedures for Performing Maintenance ," requires, in part, that maintenance that can affect the performance
of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings
appropriate to the circumstances.
  The licensee established Procedure
14.2.14, "TIP Chamber Shield Maintenance," Revision
12, to meet the Regulatory Guide
1.33 requirement
.  Contrary to the above, prior to July
5 , 2017, the licensee failed to
establish adequate written procedures appropriate to the circumstances for performing maintenance that can affect the performance of safety related equipment.  Specifically, the licensee failed to provide instructions appropriate to the circumstances for Procedure
14.2.4, "TIP Chamber Shield
Maintenance
."  Disposition:
  This violation is being treated as a
n on-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
  The disposition of this finding and associated violation closes Licensee Event Report (LER) 05000298/2017
-005-00, Traversing In
-core Probe In
-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
(ADAMS Accession No.
ML17236A166).
  EXIT MEETIN
GS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report
.  On July 12, 2018, the inspector presented the
quarterly resident inspector
inspection results to Mr. K. Dia , Acting Vice President
-Nuclear and CNO, and other members of the licensee staff.
   
  Attachment
1 DOCUMENTS REVIEWED
71111.01-Adverse Weather Protection
Miscellaneous Documents
Number Title Revision  Interface Operating Agreement between Nebraska Public Power District Operations Business Unit and Nebraska Public Power District Nuclear Power Group Business Unit
9 NC43456 Cooper 161
kV Substation One
-Line Switching Diagram
13 NC66688 Cooper 345
kV Substation One
-Line Switching Diagram
23  Procedures
Number Title Revision 0-CNS-52 Control of Switchyard and Transformer Yard Activities at
CNS 32  Work Orders
5196728      71111.04-Equipment Alignment
Miscellaneous Documents
Number Title Revision 2040 Flow Diagram Residual Heat Removal System
N82 2043 Flow Diagram Reactor Core Isolation Coolant and Reactor Feed Systems
56 2044 Flow Diagram High Pressure Coolant Injection and Reactor Feed Systems
75  Procedures
Number Title Revision 2.2.33A High Pressure Coolant Injection System Component Checklist 30 2.2.33B High Pressure Coolant Injection System Instrument Valve Checklist 8 2.2.67A Reactor Core Isolation Cooling System Component Checklist 22 
  A1-2  Procedures
Number Title Revision 2.2A.RHR.DIV1
Residual Heat Removal System Component Checklist (Div 1) 9 2.2A.RHR.DIVSDC
Residual Heat Removal System Component Checklist (Div SDC) 3  Condition Reports (CR
-CNS-) 2018-03339    71111.05-Fire Protection Quarterly
Drawings CNS-FP-211 CNS-FP-227 CNS-FP-256 CNS-FP-379  Procedures
Number Title Revision 0-BARRIER-CONTROL Control Building
7 0-BARRIER-MAPS Barrier Maps
9 0-BARRIER-MISC Miscellaneous Buildings
5 0-BARRIER-REACTOR Reactor Building
13 6.FP.305 Halon 1301 Service Water Pump Room Fire Suppression Surveillance Checks
15  Condition Reports (CR
-CNS-) 2018-02059 2018-02067    71111.06 - Flood Protection Measures
Procedures
Number Title Revision 6.HPCI.103
HPCI IS and 92 Day Test Mode
55 0-Barrier Flooding Barriers
24 
  A1-3  Procedures
Number Title Revision 2.2.33A High Pressure Coolant Injection System Component Checklist 30  Condition Reports (CR
-CNS-) 2018-02403    71111.11-Licensed Operator Requalification Program and Licensed Operator Performance
Miscellaneous Documents
Number Title Revision SKL05151245
CRD Pump Trip, Drifting Rods, ATWS, Loss of Level Indication, EOP 7B RPV Flooding
3  Procedures
Number Title Revision 2.1.4 Normal Shutdown
160 2.2.28.1 Feedwater System Operation
95  Condition Reports (CR
-CNS-) 2018-03326    71111.12-Maintenance Effectiveness
Miscellaneous Documents
Number Title Revision  Maintenance Rule Function HV
-F02 Performance Criteria Basis 4 11414213 Notification
  Condition Reports (CR
-CNS-) 2016-02434 2016-08539 2017-00039 2017-06120  Work Orders
5166424 5214101     
  A1-4  71111.13-Maintenance Risk Assessments and Emergent Work Control
Miscellaneous Documents
Number Title Revision/Date  D Drywell Fan Coil Unit Operational Decision Making Issue
0  Drywell Fan Coil Unit
D Failure, Week
1819 Protected Equipment Program Tracking Form
May 11, 2018
  HPCI Remain in Service List
  HPCI Window, Week 1816 Protected Equipment Program Tracking Form
April 16, 2018
Calc NEDC 89
-1234 Review of EAS Calculation
4 Calc NEDC 91
-253G Limiting Conditions Analysis for 18" Tricentric Valves
0  Procedures
Number Title Revision 0-CNS-WM-104A On-Line Fire Risk Management Actions
4 2.1.4 Normal Shutdown
160 2.2.71 Service Water System
123 6.2EE.602 Div 2 125V/250V Station Battery 92 Day Check
6 6.2SW.101 Service Water Surveillance Operation (Div
2) (IST) 53  Condition Reports (CR
-CNS-) 2018-02373 2018-02375 2018-02377 2018-02378 2018-02380 2012-06509    Work Orders
5134630      71111.15-Operability Determinations and Functionality Assessments
Procedures
Number Title Revision 2.1.11.1 Turbine Building Data
167 2.2.20 Standby AC Power System (Diesel Generator)
99 
  A1-5  Procedures
Number Title Revision 14.17.4 DG-2 System Instrument Calibration
25 6.HPCI.103
HPCI IS and 92 Day Test Mode
55 0-Barrier Flooding Barriers
24 2.2.33A High Pressure Coolant Injection System Component Checklist 30  Condition Reports (CR
-CNS-) 2 018-02364 2018-02413 2018-02426 2018-02427 2018-02492 2018-03294 2018-03341 2018-03365 2018-03388 2018-2403    Work Orders
5169626 5244135    71111.18-Plant Modifications
Miscellaneous Documents
Number Title Revision EC 6040480
SWBP Oil Sight Glasses and Reservoir
- and ECNs 1
- 5 0 ER 2017-036 Seismic Test Report for Oil
-Rite Constant Level Oiler
0  Condition Reports (CR
-CNS-) 2018-02091 2018-02148 2018-02412 2018-02565  71111.19-Post Maintenance Testing
Miscellaneous Documents
Number Title Revision NEDC 10-027 Drywell MOV Backseat Limits
1 NEDC 95-003 Determination of Allowable Operating Parameters for CNS MOV Program MOVs
32 730E197BB Sheet 3 Elementary Diagram Variable Speed Recirc Pump and MG Set 19 730E197BB Sheet 8 Elementary Diagram Variable Speed Recirc Pump and MG Set  28 
  A1-6  Procedures
Number Title Revision 6.HPCI.201
HPCI Valve Operability Test (IST)
26 6.1SW.101 Service Water Surveillance Operation (Div
1)(IST) 52  Work Orders
5077619 5122033 5233022 5249662    71111.22-Surveillance Testing
Miscellaneous Documents
Number Title Revision Calc NEDC 89
-1234 Review of EAS Calculation
4 Calc NEDC 91
-253G Limiting Conditions Analysis for 18" Tricentric Valves
0  Procedures
Number Title Revision 2.1.11.2 Reactor Building Data
68 2.2.71 Service Water System
123 6.1CS.101 Core Spray Test Mode Surveillance Operation (IST) (Div
1) 30 6.1RR.302 Reactor Recirculation Flow Unit Channel Calibration (Div
1) 38 6.2SW.101 Service Water Surveillance Operation (IST) (Div
2) 53  Condition Reports (CR
-CNS-) 2018-03674    Work Orders
5134630 5147404    71151-Performance Indicator Verification
Miscellaneous Documents
Number Title Revision/Date  Operations Instruction 17, Daily Report
47 
  A1-7  Miscellaneous Documents
Number Title Revision/Date  RCS Activity PI Data January 2017
- March 2018
  RCS Leakage PI Data
January 2017
- March 2018
NEI 99-02 Regulatory Assessment Performance Indicator Guideline
7  Procedures
Number Title Revision 6.LOG.601 Daily Surveillance Log
- Modes 1, 2, and 3
1 32  Condition Reports (CR
-CNS-) 2018-02134 2018-02571 2018-02592 2018-02657 2018-02679 2018-02700 2018-02860  71153-Follow-up of Events and Notices of Enforcement Discretion
Miscellaneous Documents
Number Title Date 846D931 Chamber Shield
February 4, 1966  Procedures
Number Title Revision 14.2.14 TIP Chamber Shield Maintenance
12  Condition Reports (CR
-CNS-) 2017-00039 2017-03764 2017-03790 2017-03982  Work Orders
5175552       
  Attachment
2 NRC Request
for Information
  System: High Pressure Coolant Injection
  CD Date Requested by:  April 2, 2018
  Date Range of Document Request
: March 31, 2016
- Current  Please provide the following documents
:    1. Copies of all root and apparent cause evaluations performed on this system.
    2. Summary list of all condition reports written on this system, sorted by CR classification
  3. List of all surveillances performed on this system, sortable by component if possible.
  4. Provide copies of the three most recently completed quarterly surveillances
  5. List of all corrective maintenance work orders, with description of work, performed on this
system  6. Provide a list of control room deficiencies associated with this system
  7. Copies of ODMI's, OWA/OWB's, prompt operability evaluations, and standing orders associated with this system
  8. Summarized list of all Maintenance Rule equipment issues evaluated for the system (including their conclusions and their CR number); copies of each MRule evaluation for the system (MRFF and a(1) evaluations
- regardless of their result); and any MRule Basis Document(s) for the system
  9. List of all work orders, with description of work, planned for this system within the next year  10. Provide a list and description of overdue PM's, deferred PM's, and PM change requests for this system
  11. System design calculations
  12. Provide fire impairments associated with this system
  13. Provide copies of any QA audits or self
-assessments associated with this system
  14. Copies of vendor manuals, drawings (P&ID's), and system training manuals
  15. System health reports and system engineering logs for this system
 
  A2-2  16. List and description of temporary modifications; completed ECs (within the requested date range); and planned ECs (within the next year) associated with this system
  17. Schedule of activities (Fragnet) for the planned AOT for HPCI scheduled for the work week
of 1 816.   
 
 
  ML18206A216
  SUNSI Review
By:  JWK/rdr  Non-Sensitive  Sensitive Publicly Available
  Non-Publicly Available
Keyword: NRC-002 OFFICE ASRI:DRP/C
ASRI:DRP/C
RI:DRP/C BC:DRS/EB1
BC:DRS/EB2
BC:DRS/OB NAME MTobin RKumana MStafford TFarnholtz
JDrake VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 7/11/2018 7/12/2018 7/12/2018 7/16/2018 7/16/2018 7/12/2018 OFFICE BC:DRS/PSB2
TL:DRS/IPAT
SPE:DRP/C BC:DRP/C  NAME HGepford GGeorge CYoung JKozal  SIGNATURE /RA/ /RA/ /RA/ /RA/  DATE 7/12/2018 7/12/2018 7/10/2018 7/25/2018
}}

Revision as of 19:40, 19 January 2019

Cooper Nuclear Station - NRC Integrated Inspection Report 05000298/2018002
ML18206A216
Person / Time
Site: Cooper Entergy icon.png
Issue date: 07/25/2018
From: Kozal J W
NRC/RGN-IV/DRP/RPB-C
To: Dent J
Nebraska Public Power District (NPPD)
Kozal J W
References
IR 2018002
Download: ML18206A216 (27)
v • d • e


See also: IR 05000298/2018002

Text

July 25, 2018

Mr. John Dent, Jr.

Vice President

-Nuclear and CNO

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

P.O. Box 98

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION

- NRC INTEGRATED

INSPECTION REPORT 05000 298/2018002 Dear Mr. Dent: On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station

. On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. K. Dia, Acting Vice President

-Nuclear and CNO, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented three findings of very low safety significance (Green) in this report. All of these findings involved violations

of NRC requirements

. The NRC is treating these violation s as non-cited violations (NCVs) consistent with Section

2.3.2.a of the Enforcement Policy. If you contest the violations or significance of these NCVs, 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 the 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 the Cooper Nuclear Station.

J. Dent Jr. 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 10

CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.

" Sincerely, /RA/ Jason W. Kozal , Chief Project Branch C Division of Reactor Projects

Docket No. 50

-298 License No. DPR-46 Enclosure:

Inspection Report 05000298/2018002

w/ Attachment:

1. Documents Reviewed

2. NRC Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000298 License Number:

DPR-46 Report Number:

05000298/2018002 Enterprise Identifier:

I-2018-002-0003 Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: Brownville, Nebraska

Inspection Dates:

April 1, 2018

to June 30, 2018

Inspectors:

M. Tobin, Acting Senior Resident Inspector

R. Kumana, Acting Senior Resident Inspector

R. Deese, Senior Reactor Analyst

J. Mateychick, Senior Reactor Inspector

W. Sifre, Senior Reactor Inspector

C. Young, Senior Project Engineer

M. Stafford, Resident Inspector

Approved By:

J. Kozal, Chief, Project Branch C

Division of Reactor Projects

2 SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for

overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html

for more information. NRC and self

-revealed violations and additional items are summarized in the tables below.

List of Findings and Violations

Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid

Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002

-01 Closed [H.3] - Human Performance, Change Management

71111.05XT

- Fire Protection

- NFPA 805 (Triennial)

The inspectors identified a Green non-cited violation of License Condition

2.C.(4), "Fire Protection," for the failure to establish an appropriate monitoring program in accordance with Section 2.6 of the National Fire Protection Association (NFPA) Standard

805, "Performance

-Based Standard for Fire Protection for Light

-Water Reactor Electric Generating Plants." Specifically, the licensee failed to set the action level for the availability of some plant components to ensure that the assumptions in the engineering analysis remained valid.

Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management

71111.18 - Plant Modifications

The inspectors identified a Green non

-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure

2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified

in Engineering Evaluation NEDC 92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision 3C2. As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13

hours for completion of manual actions rather than the bounding 5.8

-hour allowance described in NEDC

92-064.

3 Failure to Maintain Adequate Work Instructions for Traversing In

-Core Probe System Limit Switches Cornerstone

Significance

Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000298/2018002

-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion

A self-revealed, Green non-cited violation of Technical Specification 5.4, "Procedures," was identified when the licensee failed to maintain Procedure

14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in

-core probe system

in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves

. Additional Tracking Items

Type Issue number

Title Report Section Status URI 05000298/2016008

-01 Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid 71111.05 XT Closed LER 05000298/2017

-005-00 Traversing In

-core Probe

In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications

71153 Closed

4 PLANT STATUS

The unit began the inspection period at rated thermal power. On May 30, 2018, the unit was shut down for repairs to the drywell fan co

il units. The unit was returned to rated thermal power

on June 11, 2018 , and remained at or near 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 plant status activities described in IMC 2515 , Appendix D, "Plant Status

," and conducted routine reviews using IP

71152, "Problem Identification and Resolution."

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

Summer Readiness

(1 Sample) The inspectors evaluated summer readiness of offsite and alternate alternating current

(AC) power systems

on May 11, 2018. External Flooding

(1 Sample) The inspectors evaluated readiness to cope with external flooding on May 17, 2018. 71111.04-Equipment Alignment

Partial Walkdown

(3 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Reactor core isolation cooling during high pressure coolant injection work window

on April 18, 2018 (2) Shutdown cooling

A while B in service on June 1, 2018 (3) Control building ventilation for service water

booster system

on May 11, 2018 Complete Walkdown

(1 Sample) The inspectors evaluated system configurations during a complete walkdown of the high pressure coolant injection full system alignment

o n June 28, 2018.

5 71111.05Q-Fire Protection

Quarterly Inspection

(5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas: (1) Intake building and service water pump room

on April 5, 2018 (2) Reactor core isolation cooling and core spray

A area on April 18, 2018 (3) 125/250 Vdc battery and switchgear room on May 23, 2018 (4) Supplemental diesel generator on May

29, 2018 (5) Cable spreading room on June 28, 2018

71111.05XT

-Fire Protection

- NFPA 805 (Triennial)

The inspectors reviewed the licensee's actions to address the issue identified in

Unresolved Item (URI)

05000298/2016008

-01 from May 7, 2018, to June 5, 2018. This URI is now closed. 71111.06-Flood Protection Measures

Internal Flooding

(1 Sample) The inspectors evaluated internal flooding mitigation protections in the high pressure coolant injection room

on June 26, 2018

. 71111.11-Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification

(1 Sample) The inspectors observed and evaluated operator training during a licensed operator requalification simulator scenario focusing on an anticipated transient without a scram on May 18, 2018. Operator Performance

(1 Sample) The inspectors observed and evaluated operator performance during a downpower for a forced outage associated with fan coil unit maintenance

on May 29, 2018. 71111.12-Maintenance Effectiveness

Routine Maintenance Effectiveness

(2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Service water

booster system

room cooler

on May 11 , 2018 (2) Traversing in

-core probe on May 11 , 2018

6 71111.13-Maintenance Risk Assessments and Emergent Work Control

(5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) High pressure coolant injection

maintenance window

on April 19, 2018 (2) Service water

booster system

room cooler risk evaluation on May 11 , 2018 (3) Service water pump

D work week on May

17, 2018 (4) Emergent drywell fan coil unit

D work on May 18, 2018 (5) Emergent downpower due to drywell fan coil unit A on May 26, 2018 71111.15-Operability Determinations and Functionality Assessments

(4 Samples) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Emergency diesel generator

2 jacket water temperature issue on April

25, 2018 (2) Service water

booster system

pipe below minimum wall thickness on May

1, 2018 (3) Fan coil unit functionality

on June 22, 2018 (4) High pressure coolant injection operability with room floor drains clogged, extending limiting condition for operation time on June

25, 2018 71111.18-Plant Modifications (2 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) Service water

booster system

room fan coil unit manual actions on May

11 , 2018 (2) Service water booster pump oil reservoirs on May

11, 2018 71111.19-Post Maintenance Testing

(4 Samples) The inspectors evaluated the following post maintenance

tests: (1) HPCI-MO-15 following packing replacement on March

15, 2018 (2) High pressure coolant injection pump test following maintenance window on April 20 2018 (3) Service water

pump C on May 3, 2018 (4) Reactor recirculation pump

B relay replacement on June 21, 2018 71111.20-Refueling and Other Outage Activities

(1 Sample) The inspectors evaluated fan coil D forced outage activities

from May 30, 2018 to June 11, 2018.

7 71111.22-Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples) (1) Service water pump

D surveillance test on May 29, 2018 (2) Division 1 reactor recirculation flow unit channel calibration on June 7, 2018 (3) Operator rounds on June 15, 2018 In-service (1 Sample) (1) Core spray subsystem

A quarterly inservice surveillance test on May 1, 2018 71114.06-Drill Evaluation

Emergency Planning Drill

(1 Sample) The inspectors evaluated a full team drill

on May 22, 2018. OTHER ACTIVITIES

- BASELINE 71151-Performance Indicator Verification

(3 Samples) The inspectors

verified licensee performance

indicators

submittals

listed below: (1) MS05: Safety System Functional Failures (SSFFs) (April 1, 2017 - March 31, 2018) (1 Sample) (2) BI01: Reactor Coolant System (RCS) Specific Activity

(April 1, 2017 - March 31, 2018) (1 Sample) (3) BI02: RCS Leak Rate

(April 1, 2017 - March 31, 2018) (1 Sample) 71152-Problem Identification and Resolution

Semiannual Trend Review

(1 Sample) The inspectors reviewed the licensee's corrective action program for trends that might be indicative of a more significant safety issue.

Annual Follow

-up of Selected Issue s (1 Sample) The inspectors reviewed the licensee's implementation of its corrective acti

on program related to

the following issues:

(1) Emergency diesel generator damper failures on May 11, 2018

8 71153-Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 Sample) The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx

(1) Licensee Event Report (LER

) 05000 298/201 7-005-00, Traversing In

-core Probe

In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications

(ADAMS Accession No.

ML17236A166), on May 11 , 2018. INSPECTION RESULTS

Observation

71152 - Problem Identification

and Resolution

The inspectors identified a potential adverse trend involving the sizing of bolts associated with emergency diesel generator components. The inspectors determined that the licensee documented multiple instances where they discovered incorrect bolting on various components of the emergency diesel generators. The inspectors determined that in all cases reviewed, the licensee had determined that the bolts used in the plant were greater than the length required by design, had adequate thread engagement

to ensure they maintained their safety function, and did not adversely impact the ability of the emergency diesel generators to perform their function. The inspectors determined that the licensee had identified these issues through focused observation of the system design requirements and had implemented appropriate corrective actions.

Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid

Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000298/2018002

-01 Closed [H.3] - Human Performance, Change Management

71111.05XT

- Fire Protection

- NFPA 805 (Triennial)

The inspectors identified a Green non

-cited violation of License Condition

2.C.(4), "Fire Protection," for the failure to establish an appropriate monitoring program in accordance with Section 2.6 of the National Fire Protection Association (NFPA) Standard

805, "Performance

-Based Standard for Fire Protection for Light

-Water Reactor Electric Generating Plants." Specifically, the licensee failed to set the action level for the availability of some plant components to ensure that the assumptions in the engineering analysis remained valid.

Description

During the NRC triennial fire protection inspection in 2016 (see NRC Inspection Report 05000298/2016008

(Agencywide Documents Access and Managem

ent System (ADAMS) Accession No.

ML16270A561)), the inspectors reviewed the licensee's implementation of the monitoring program required in Section

2.6 of NFPA Standard

805, "Performance

-Based Standard for Fire Protection for Light

-Water Reactor Electric Generating Plants." NFPA

805 requires the following in Section

2.6:

9 Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained

, and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid.

The inspectors reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, "National Fire Protection Association (NFPA)

805 Monitoring Program," Revision

0, to ensure that the licensee's program properly implemented the requirements of NFPA

805, Section

2.6. The inspectors also reviewed Engineering Report ER-2015-002, "National Fire Protection Association (NFPA)

805 Fire Protection Monitoring Program," Revision 2. The inspectors observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule (10 CFR 50.65) monitoring program. These components included the: Control rod drive pumps

Core spray pumps

Emergency diesel generators

Emergency station service transformer

Startup station service transformer

High pressure core spray pump

Instrument air compressors

Residual heat removal pumps

Standby liquid control pumps

Service water pumps

The inspectors noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment and questioned whether this met the requirement in NFPA

805 to maintain the assumptions in the engineering analysis.

Clarifications of the monitoring program requirements were being discussed between the industry and the NRC's Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question

10-0059, "National Fire Protection Association (NFPA) 805 Monitoring." With the further clarification pending, the inspectors documented the issue as Unresolved Item

05000298/2016008

-01, "Possible

Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid." The discussions failed to provide any additional guidance

therefore, the inspectors are addressing this issue based on the information contained in

Frequently Asked Question

10-0059, "National Fire Protection Association (NFPA)

805 Monitoring," Revision

5. Corrective Action (s): The inspectors concluded that the issue did not present an immediate safety concern based on the licensee performing a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire

probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. The increase in core damage frequency was determined to not exceed 1.0E

-6/year.

10 Corrective Action Reference

(s): Condition Report

CR-CNS-2016-05109 Performance Assessment

Performance Deficiency: The failure to adequately monitor unavailability of the plant components to ensure that the assumptions in the engineering analysis remained valid was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the performance deficiency could adversely affect the acceptable level of availability of the components which are used to respond to fire initiating events, in that the action levels for availability in the monitoring program were greater than the assumptions in the fire probabilistic risk assessment.

This finding affects the Mitigating Systems Cornerstone.

Significance: The inspectors assessed the significance of the finding using

NRC Inspection Manual Chapter 0609, "Significance Determination Process," Attachment

4, "Initial Characterization of Findings," dated October 7, 2016, as requiring significance determination per Manual Chapter

0609, Appendix

F, "Fire Protection Significance Determination Process," dated May 2, 2018, because the finding affected the ability to reach and maintain safe shutdown conditions in case of a fire.

The inspectors categorized the finding as a post

-fire safe shutdown finding with a high degradation rating. The high degradation rating was made using Manual Chapter

0609, Appendix

F, Attachment

2, "Degradation Rating Guidance," dated May 2, 2018, because the finding was not a minor procedural deficiency that was able to be compensated by operators. Using

step 1.4.7 of Attachment

1 of Appendix

F, the finding was screened as a Green finding of very low safety significance in

Question 1.4.7-C because the fire finding did not adversely affect the ability to reach and maintain hot shutdown/hot standby, or safe and stable conditions using the credited safe shutdown success path.

Cross-cutting Aspect: This finding had a cross

-cutting aspect associated with change management within the human performance area since the leaders failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the inspectors determined that the licensee

did not use the process that was in place to ensure that the appropriate fire risk assessment monitoring action levels were incorporated into the maintenance rule program and monitored

[H.3]. Enforcement

Violation: License Condition

2.C.(4), "Fire Protection," states, in part, "Nebraska Public Power District shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10

CFR 50.48(a) and 10

CFR 50.48(c), as specified in the license amendment request

, dated April

24, 2012 , (and supplements

dated July

12, 2012, January 14, 2013, February

12, 2013, March

13, 2013, June

13, 2013, December

12, 2013, January 17, 2014, February

18, 2014, and April

11, 2014), and as approved in the safety evaluation dated Apr

il 29, 2014." The approved fire protection program is a risk

-informed performance

-based program in accordance with NFPA

805, "Performance

-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition

," which is incorporated by reference into

10 CFR 50.48(c). NFPA

805, Section

2.6, "Monitoring," states that, "Monitoring shall ensure that the assumptions in the engineering analysis remain valid."

11 Contrary to the above, from April 29, 2014, to June 5 , 2018, the licensee failed to appropriately monitor plant equipment to ensure that the assumptions in the NFPA

805 engineering analysis remained valid. Specifically, the licensee's monitoring program did not

monitor the availability of the

control rod drive pumps, core spray pumps, emergency diesel generators, emergency station service transformer, startup station service transformer, high pressure core spray pump, instrument air compressors, residual heat removal pumps, standby liquid control pumps, and service water pumps to ensure that it was no lower than the fire probabilistic risk assessment assumptions.

Disposition:

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

The disposition of this finding and associated violation closes Unresolved Item 05000298/2016008

-01. Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone

Significance

Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management

71111.18 - Plant Modifications

The inspectors identified a Green non

-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure

2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC 92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision 3C2. As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13

hours for completion of manual actions rather than the bounding 5.8

-hour allowance described in NEDC

92-064. Description

On October

13, 2017, during routine maintenance activities for the service water booster pump (SWBP) fan coil unit (FCU), FC

-C-1A, the licensee discovered a 5

-10 gallon per minute (gpm) leak in the cooling coil. The licensee was using high pressure demineralize

d water to flush the FCU when the leak initiated, and operations personnel took action to isolate the coil. The fan coil unit is used to cool the SWBP room, which contains all four SWBPs, when power is lost to the site and nonessential ventilation is automatically

isolated from the room. The SWBPs provide service water to the residual heat removal (RHR) heat exchange

rs during accident and shutdown cooling conditions. The operations crew determined that the SWBPs remained operable because Updated Safety Analysis

Report (USAR)

, Section X-10.3.5.4 , states that although the fan coil unit can be used to keep the room cool during an accident, "acceptable room temperatures can be maintained for a single RHR service water booster pump without forced ventilation through operator action to reduce the room heat load and establishment of a natural ventilation flowpath." The operations crew also determined that these manual actions, which included rigging and removing three equipment hatches and opening three control building doors, were directed by Alarm Procedure

2.3_R-1, "Panel R

- Annunciator R

-1 ," Revision 18. The inspectors reviewed Calculation NEDC

92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision

3C2, and Calculation NEDC

92-063, "Maximum SWBP Room Temperatures w/ No Cooling From Control Bldg HVAC," Revision

1. These heat

-up

12 calculations served as the basis for acceptability of the manual ventilation actions described in Alarm Procedure

2.3_R-1. NEDC 92-064 concluded that the required maximum design temperature for the SWBP room was 131

degrees Fahrenheit

(F). The calculation also concluded that with the FCU unavailable, once the SWBP room high temperature alarm was triggered at 120

degrees F, the control room staff would enter Alarm Procedure

2.3_R-1, and station personnel would have a limited amount of time to establish a natural ventilation path and secure excess heat loads in the room before operability of all four SWBPs was lost. The calculation determined that if two SWBPs were in service, station personnel would have 5.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to establish a ventilation path, secure all lighting, de

-energize all instrument air compressors, secure all instrument air dryers, and secure all but one SWBP. The calculation also determined that

station personnel would have 13

hours to perform the same actions if only one SWBP was in service during an accident scenario. The inspectors also noted that emergency operating procedures directed control room staff to "operate all available suppression pool cooling" during accident conditions, which made operation of two SWBPs a very likely scenario during an accident.

The inspectors also reviewed Alarm Procedure

2.3_R-1, Revision

17 , and 50.59 Evaluation

2013-04, "RHR SWBP FCU 50.59 Inadequate for USAR Change LCR

93-10," Revision 0. Evaluation

2013-04 sought to prove through simulation that the associated manual actions could be completed within the limiting 5.8

hours that would be available during an event. This evaluation concluded that the activities could be completed in less than

5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and deemed the actions acceptable.

Upon review of Alarm Procedure

2.3_R-1, the inspectors discovered that step

1.3 of the procedure provided directions to secure heat loads in the room and establish natural ventilation through manual actions. However, prior to

step 1.3, a procedure note stated, "NEDC

92-064 assumes that step

1.3 is complete within

13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> of receiving RHR SWBP ROOM high temperature alarm." The inspectors determined that this procedure should have included the bounding timeline of 5.8

hours, as

described by NEDC

92-064, rather than the timeline of 13

hours that was based on the

nonconservative

assumption that only one SWBP would be in service. The inspectors challenged the licensee on the procedure timelines, and the licensee initiated Condition Report CR-CNS-2017-07601 and performed the associated procedure changes to make the correction on December 21, 2017. The inspectors concluded that, prior to December

21, 2017, the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified

in Engineering Evaluation NEDC

92-064. In addition, prior to 2015, the procedure failed to contain any timeline restrictions, despite NEDC

92-064 concluding that time critical manual ventilation actions were required to ensure operability of all four service water booster pumps. The inspectors found that a May

2015 procedure change introduced the nonconservative 13

-hour timeline into Alarm Procedure

2.3_R-1. Corrective Action(s): The licensee implemented a revision to Alarm Procedure

2.3_R-1 to include the correct manual action required timelines. Corrective Action Reference(s): Condition Report

CR-CNS-2017-07601 Performance Assessment

Performance Deficiency: The licensee's failure to provide adequate guidance for restoring room cooling in Alarm Procedure

2.3_R-1 was a performance deficiency.

13 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 (i.e., core damage).

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapt

er 0609, Appendix

A, "The Significance Determination Process for Finding

s At-Power." Using Exhibit

2, "Mitigating Systems Screening Questions," the finding was screened as having very low safety significance (Green) because the finding was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety

-significant nontechnical specification train.

Cross-cutting Aspect: The inspectors determined that the finding had a cross

-cutting aspect in the area of

human performance associated with change management , because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee failed to ensure that the appropriate and correct changes were made when updating the procedure. [H.3]

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 Appendix

A of Regulatory Guide

1.33, Revision

2. Section

5 of Appendix

A to Regulatory Guide 1.33, Revision

2, requires, "Procedures for Abnormal, Offnormal, or Alarm Conditions." The licensee established Alarm Procedure

2.3_R-1, "Panel R

- Annunciator R

-1," Revision 17, to meet the Regulatory Guide

1.33 requirement

. Contrary to the above, prior to December

21, 2017, the licensee failed to maintain adequate written procedures

for abnormal, offnormal, or alarm conditions.

Specifically, the licensee failed to maintain Alarm Procedure

2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC

92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision

3C2. Disposition: This violation is being treated as a

n on-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

14 Failure to Maintain Adequate Work Instructions for Traversing In

-Core Probe System Limit Switches Cornerstone

Significance

Cross-cutting Aspect Report Section Barrier Integrity

Green NCV 05000298/2018002

-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion

A self-revealed, Green, non

-cited violation of Technical Specification 5.4, "Procedures," was identified when t

he licensee failed to maintain Procedure

14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in

-core probe system

in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves

. Description

On June 21, 2017, during operation of the traversing in

-core probe (TIP) system, the C probe failed to stop at the correct "in

-shield" position during withdrawal of the probe from the core. The probe is designed to stop when the limit switch is activated. While the limit switch is not activated, the associated containment isolation ball valve is blocked from automatic and manual operation. The licensee declared the valve inoperable. Subsequently, on June 22, 2017, the D probe failed to stop at the "in

-shield" position during withdrawal. The licensee declared the D containment isolation ball valve inoperable. The licensee determined that the cause of the failures was that the limit switches had become loose due to inadequate mounting of the switches to the chamber shields. The design drawing for the system indicated that the switches were to be mounted using bolts and washers, but the licensee identified that some mounting bolts did not have washers installed.

The switches had been removed and reinstalled during performance of Procedure

14.2.14 , "TIP Chamber Shield Maintenance," Revision 12 , as part of the maintenance of the system. The procedures did not specify the method for reinstalling the switches. The licensee found that the vendor drawing specified the use of washers.

Corrective Action(s):

The licensee implemented a revision to Procedure

14.2.14 to include a description of the vendor specified mounting configuration and a requirement to apply a minimum torque to the bolts.

Corrective Action Reference(s): Condition Report

CR-CNS-2017-0003 9 Performance Assessment

Performance Deficiency: The licensee's failure to provide adequate guidance for maintenance on the TIP system was 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 Barrier Integrity

Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and

containment) protect the public from radionuclide releases caused by accidents or events

. Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix

A, "The Significance Determination Process for Finding s

15 At-Power." Using Exhibit

3 , "Barrier Integrity

Screening Questions," the finding was screened as having very low safety significance (Green) because the finding

did not represent an actual open pathway in the physical integrity of reactor containment (valves, airlocks, etc.), containment isolation system (logic and instrumentation), and heat removal components, and did not involve hydrogen igniters

. Cross-cutting Aspect: No cross-cutting aspect was assigned

to this finding

because the inspectors determined that since the last revision of the procedure was more than three years ago, the finding did not reflect present licensee performance.

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 Appendix

A of Regulatory Guide 1.33, Revision

2. Appendix

A to Regulatory Guide

1.33, Revision 2, Section 9, "Procedures for Performing Maintenance ," requires, in part, that maintenance that can affect the performance

of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings

appropriate to the circumstances.

The licensee established Procedure

14.2.14, "TIP Chamber Shield Maintenance," Revision

12, to meet the Regulatory Guide

1.33 requirement

. Contrary to the above, prior to July

5 , 2017, the licensee failed to

establish adequate written procedures appropriate to the circumstances for performing maintenance that can affect the performance of safety related equipment. Specifically, the licensee failed to provide instructions appropriate to the circumstances for Procedure

14.2.4, "TIP Chamber Shield

Maintenance

." Disposition:

This violation is being treated as a

n on-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this finding and associated violation closes Licensee Event Report (LER) 05000298/2017

-005-00, Traversing In

-core Probe In

-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications

(ADAMS Accession No.

ML17236A166).

EXIT MEETIN

GS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report

. On July 12, 2018, the inspector presented the

quarterly resident inspector

inspection results to Mr. K. Dia , Acting Vice President

-Nuclear and CNO, and other members of the licensee staff.

Attachment

1 DOCUMENTS REVIEWED

71111.01-Adverse Weather Protection

Miscellaneous Documents

Number Title Revision Interface Operating Agreement between Nebraska Public Power District Operations Business Unit and Nebraska Public Power District Nuclear Power Group Business Unit

9 NC43456 Cooper 161

kV Substation One

-Line Switching Diagram

13 NC66688 Cooper 345

kV Substation One

-Line Switching Diagram

23 Procedures

Number Title Revision 0-CNS-52 Control of Switchyard and Transformer Yard Activities at

CNS 32 Work Orders

5196728 71111.04-Equipment Alignment

Miscellaneous Documents

Number Title Revision 2040 Flow Diagram Residual Heat Removal System

N82 2043 Flow Diagram Reactor Core Isolation Coolant and Reactor Feed Systems

56 2044 Flow Diagram High Pressure Coolant Injection and Reactor Feed Systems

75 Procedures

Number Title Revision 2.2.33A High Pressure Coolant Injection System Component Checklist 30 2.2.33B High Pressure Coolant Injection System Instrument Valve Checklist 8 2.2.67A Reactor Core Isolation Cooling System Component Checklist 22

A1-2 Procedures

Number Title Revision 2.2A.RHR.DIV1

Residual Heat Removal System Component Checklist (Div 1) 9 2.2A.RHR.DIVSDC

Residual Heat Removal System Component Checklist (Div SDC) 3 Condition Reports (CR

-CNS-) 2018-03339 71111.05-Fire Protection Quarterly

Drawings CNS-FP-211 CNS-FP-227 CNS-FP-256 CNS-FP-379 Procedures

Number Title Revision 0-BARRIER-CONTROL Control Building

7 0-BARRIER-MAPS Barrier Maps

9 0-BARRIER-MISC Miscellaneous Buildings

5 0-BARRIER-REACTOR Reactor Building

13 6.FP.305 Halon 1301 Service Water Pump Room Fire Suppression Surveillance Checks

15 Condition Reports (CR

-CNS-) 2018-02059 2018-02067 71111.06 - Flood Protection Measures

Procedures

Number Title Revision 6.HPCI.103

HPCI IS and 92 Day Test Mode

55 0-Barrier Flooding Barriers

24

A1-3 Procedures

Number Title Revision 2.2.33A High Pressure Coolant Injection System Component Checklist 30 Condition Reports (CR

-CNS-) 2018-02403 71111.11-Licensed Operator Requalification Program and Licensed Operator Performance

Miscellaneous Documents

Number Title Revision SKL05151245

CRD Pump Trip, Drifting Rods, ATWS, Loss of Level Indication, EOP 7B RPV Flooding

3 Procedures

Number Title Revision 2.1.4 Normal Shutdown

160 2.2.28.1 Feedwater System Operation

95 Condition Reports (CR

-CNS-) 2018-03326 71111.12-Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision Maintenance Rule Function HV

-F02 Performance Criteria Basis 4 11414213 Notification

Condition Reports (CR

-CNS-) 2016-02434 2016-08539 2017-00039 2017-06120 Work Orders

5166424 5214101

A1-4 71111.13-Maintenance Risk Assessments and Emergent Work Control

Miscellaneous Documents

Number Title Revision/Date D Drywell Fan Coil Unit Operational Decision Making Issue

0 Drywell Fan Coil Unit

D Failure, Week

1819 Protected Equipment Program Tracking Form

May 11, 2018

HPCI Remain in Service List

HPCI Window, Week 1816 Protected Equipment Program Tracking Form

April 16, 2018

Calc NEDC 89

-1234 Review of EAS Calculation

4 Calc NEDC 91

-253G Limiting Conditions Analysis for 18" Tricentric Valves

0 Procedures

Number Title Revision 0-CNS-WM-104A On-Line Fire Risk Management Actions

4 2.1.4 Normal Shutdown

160 2.2.71 Service Water System

123 6.2EE.602 Div 2 125V/250V Station Battery 92 Day Check

6 6.2SW.101 Service Water Surveillance Operation (Div

2) (IST) 53 Condition Reports (CR

-CNS-) 2018-02373 2018-02375 2018-02377 2018-02378 2018-02380 2012-06509 Work Orders

5134630 71111.15-Operability Determinations and Functionality Assessments

Procedures

Number Title Revision 2.1.11.1 Turbine Building Data

167 2.2.20 Standby AC Power System (Diesel Generator)

99

A1-5 Procedures

Number Title Revision 14.17.4 DG-2 System Instrument Calibration

25 6.HPCI.103

HPCI IS and 92 Day Test Mode

55 0-Barrier Flooding Barriers

24 2.2.33A High Pressure Coolant Injection System Component Checklist 30 Condition Reports (CR

-CNS-) 2 018-02364 2018-02413 2018-02426 2018-02427 2018-02492 2018-03294 2018-03341 2018-03365 2018-03388 2018-2403 Work Orders

5169626 5244135 71111.18-Plant Modifications

Miscellaneous Documents

Number Title Revision EC 6040480

SWBP Oil Sight Glasses and Reservoir

- and ECNs 1

- 5 0 ER 2017-036 Seismic Test Report for Oil

-Rite Constant Level Oiler

0 Condition Reports (CR

-CNS-) 2018-02091 2018-02148 2018-02412 2018-02565 71111.19-Post Maintenance Testing

Miscellaneous Documents

Number Title Revision NEDC 10-027 Drywell MOV Backseat Limits

1 NEDC 95-003 Determination of Allowable Operating Parameters for CNS MOV Program MOVs

32 730E197BB Sheet 3 Elementary Diagram Variable Speed Recirc Pump and MG Set 19 730E197BB Sheet 8 Elementary Diagram Variable Speed Recirc Pump and MG Set 28

A1-6 Procedures

Number Title Revision 6.HPCI.201

HPCI Valve Operability Test (IST)

26 6.1SW.101 Service Water Surveillance Operation (Div

1)(IST) 52 Work Orders

5077619 5122033 5233022 5249662 71111.22-Surveillance Testing

Miscellaneous Documents

Number Title Revision Calc NEDC 89

-1234 Review of EAS Calculation

4 Calc NEDC 91

-253G Limiting Conditions Analysis for 18" Tricentric Valves

0 Procedures

Number Title Revision 2.1.11.2 Reactor Building Data

68 2.2.71 Service Water System

123 6.1CS.101 Core Spray Test Mode Surveillance Operation (IST) (Div

1) 30 6.1RR.302 Reactor Recirculation Flow Unit Channel Calibration (Div

1) 38 6.2SW.101 Service Water Surveillance Operation (IST) (Div

2) 53 Condition Reports (CR

-CNS-) 2018-03674 Work Orders

5134630 5147404 71151-Performance Indicator Verification

Miscellaneous Documents

Number Title Revision/Date Operations Instruction 17, Daily Report

47

A1-7 Miscellaneous Documents

Number Title Revision/Date RCS Activity PI Data January 2017

- March 2018

RCS Leakage PI Data

January 2017

- March 2018

NEI 99-02 Regulatory Assessment Performance Indicator Guideline

7 Procedures

Number Title Revision 6.LOG.601 Daily Surveillance Log

- Modes 1, 2, and 3

1 32 Condition Reports (CR

-CNS-) 2018-02134 2018-02571 2018-02592 2018-02657 2018-02679 2018-02700 2018-02860 71153-Follow-up of Events and Notices of Enforcement Discretion

Miscellaneous Documents

Number Title Date 846D931 Chamber Shield

February 4, 1966 Procedures

Number Title Revision 14.2.14 TIP Chamber Shield Maintenance

12 Condition Reports (CR

-CNS-) 2017-00039 2017-03764 2017-03790 2017-03982 Work Orders

5175552

Attachment

2 NRC Request

for Information

System: High Pressure Coolant Injection

CD Date Requested by: April 2, 2018

Date Range of Document Request

March 31, 2016

- Current Please provide the following documents

1. Copies of all root and apparent cause evaluations performed on this system.

2. Summary list of all condition reports written on this system, sorted by CR classification

3. List of all surveillances performed on this system, sortable by component if possible.

4. Provide copies of the three most recently completed quarterly surveillances

5. List of all corrective maintenance work orders, with description of work, performed on this

system 6. Provide a list of control room deficiencies associated with this system

7. Copies of ODMI's, OWA/OWB's, prompt operability evaluations, and standing orders associated with this system

8. Summarized list of all Maintenance Rule equipment issues evaluated for the system (including their conclusions and their CR number); copies of each MRule evaluation for the system (MRFF and a(1) evaluations

- regardless of their result); and any MRule Basis Document(s) for the system

9. List of all work orders, with description of work, planned for this system within the next year 10. Provide a list and description of overdue PM's, deferred PM's, and PM change requests for this system

11. System design calculations

12. Provide fire impairments associated with this system

13. Provide copies of any QA audits or self

-assessments associated with this system

14. Copies of vendor manuals, drawings (P&ID's), and system training manuals

15. System health reports and system engineering logs for this system

A2-2 16. List and description of temporary modifications; completed ECs (within the requested date range); and planned ECs (within the next year) associated with this system

17. Schedule of activities (Fragnet) for the planned AOT for HPCI scheduled for the work week

of 1 816.

ML18206A216

SUNSI Review

By: JWK/rdr Non-Sensitive Sensitive Publicly Available

Non-Publicly Available

Keyword: NRC-002 OFFICE ASRI:DRP/C

ASRI:DRP/C

RI:DRP/C BC:DRS/EB1

BC:DRS/EB2

BC:DRS/OB NAME MTobin RKumana MStafford TFarnholtz

JDrake VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 7/11/2018 7/12/2018 7/12/2018 7/16/2018 7/16/2018 7/12/2018 OFFICE BC:DRS/PSB2

TL:DRS/IPAT

SPE:DRP/C BC:DRP/C NAME HGepford GGeorge CYoung JKozal SIGNATURE /RA/ /RA/ /RA/ /RA/ DATE 7/12/2018 7/12/2018 7/10/2018 7/25/2018

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