IR 05000298/2021012

Biennial Problem Identification and Resolution Inspection Report 05000298/2021012

ML21203A207
Person / Time
Site:	Cooper
Issue date:	07/27/2021
From:	Ami Agrawal Division of Reactor Safety IV
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2021012
Download: ML21203A207 (14)

Text

SUBJECT:

COOPER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2021012

Dear Mr. Dent,

Jr.:

On July 1, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Cooper Nuclear Station. On July 1, 2021 the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection.

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 July 27, 2021

J. Dent, Jr.

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number:

05000298

License Number:

DPR-46

Report Number:

05000298/2021012

Enterprise Identifier:

I-2021-012-0018

Licensee:

Nebraska Public Power District

Facility:

Cooper Nuclear Station

Location:

Brownville, NE

Inspection Dates:

June 14, 2021 to July 01, 2021

Inspectors:

R. Azua, Senior Reactor Inspector

B. Correll, Senior Reactor Inspector

J. Mateychick, Senior Reactor Inspector

J. Melfi, Project Engineer

A. Siwy, Senior Resident Inspector

Approved By:

Ami N. Agrawal, Insp Prgms & Assessment Team Leader

Insp Pgms & Assessment Team

Division of Reactor Safety

SUMMARY

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

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the residual heat removal system.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.

Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Cooper Nuclear Station developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants residual heat removal system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Entergy fleet notifications, NRC generic communications, and publications from various industry groups such as the Nuclear Energy Institute (NEI) and Electric Power Research Institute (EPRI). The team determined that the Cooper Nuclear Station is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received. However, the team identified that the licensee does not have a procedure to provide guidance for the Security group to monitor for operating experience. The team identified that the licensee did not incorporate guidance similar to Entergy procedure EN-OE-221 "Security Organization, Standards & Expectations," with respect to monitoring for operating experience, when implementing the 0-CNS-OE-100 "Operating Experience Program." The 0-CNS-OE-100 procedure does not apply to the Security organization, but no procedure is provided to the Security organization for conducting operating experience reviews. However, the team did not identify any missed opportunities with respect to security operating experience during this inspection. The licensee captured this observation and will evaluate it in condition report CR-CNS-2021-03053.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also/ reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process. Audits were very detailed, thorough, and identified issues.

Assessment 71152B Safety-Conscious Work Environment: The team interviewed twenty individuals in six group interviews. The purpose of these interviews was

(1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a Condition Report or by another method,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Instrumentation and Controls organization, and the Security organization. Overall, the Cooper Nuclear Station has an adequate Safety-Conscious Work Environment.

Willingness to Raise Nuclear Safety Issues: In the assessed focus groups, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available. Overall, the team concluded that the Cooper Nuclear Station maintains a healthy SCWE.

Employee Concerns Program: The team looked at Cooper Nuclear Station's Employee Concerns Program (ECP). The team interviewed the ECP manager and an on-site representative and discussed the electronic ECP program and the Lighthouse program, for a sample of ECP cases. The team independently reviewed two ECPs investigative packages. The team provided some observations to the licensee concerning the ECP program for their awareness. Overall, the team did not identify any concerns with the program.

EXIT MEETINGS AND DEBRIEFS

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

On July 1, 2021, the inspectors presented the biennial problem identification and resolution inspection results to John Dent, Jr. and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Calculations

NEDC 19-009

Operability Calculation for an Auxiliary Steam Line Break in G

Critical Switchgear Room

71152B

Corrective Action

Documents

CR-CNS-

2015-03519, 2016-04922, 2016-05082, 2016-06050, 2016-07645,

2017-00324, 2017-00553, 2017-01504, 2017-01505, 2017-01507,

2017-01510, 2017-01519, 2017-01520, 2017-01534, 2017-02326,

2017-02933, 2017-03247, 2017-03248, 2017-04162, 2017-06326,

2017-04564, 2018-00394, 2018-00397, 2018-00435, 2018-05169,

2018-06295, 2018-06420, 2018-07341, 2019-00860, 2019-01161,

2019-01166, 2019-01167, 2019-01335, 2019-01336, 2019-01337,

2019-01338, 2019-01340, 2019-01341, 2019-01361, 2019-01402,

2019-01403, 2019-03147, 2019-03192, 2019-03360, 2019-03631,

2019-03672, 2019-03729, 2019-03802, 2019-03936, 2019-03936,

2019-03940, 2019-03962, 2019-03971, 2019-04194, 2019-04209,

2019-04222, 2019-04317, 2019-04336, 2019-04572, 2019-04573,

2019-04683, 2019-04898, 2019-04945, 2019-04960, 2019-04980,

2019-05210, 2019-05331, 2019-05388, 2019-05528, 2019-05576,

2019-05617, 2019-05619, 2019-05620, 2019-05637, 2019-05638,

2019-05682, 2019-05795, 2019-05870, 2019-05967, 2019-06008,

2019-06064, 2019-06064, 2019-06159, 2019-06278, 2019-06302,

2019-06302, 2019-06322, 2019-06323, 2019-06484, 2019-06521,

20-00181, 2020-00181, 2020-00324, 2020-00446, 2020-00457,

20-00504, 2020-00612, 2020-00721, 2020-00722, 2020-00739,

20-00743, 2020-00747, 2020-00756, 2020-00978, 2020-01249,

20-01383, 2020-01458, 2020-01473, 2020-01532, 2020-01534,

20-01572, 2020-01573, 2020-01618, 2020-01621, 2020-01690,

20-01702, 2020-01703, 2020-01848, 2020-01929, 2020-01990,

20-02046, 2020-02433, 2020-02582, 2020-02757, 2020-02902,

20-03015, 2020-03402, 2020-03522, 2020-03525, 2020-03861,

20-03861, 2020-03862, 2020-04175, 2020-04392, 2020-04511,

20-04533, 2020-04814, 2020-04902, 2020-04924, 2020-04934,

20-04953, 2020-04953, 2020-05313, 2020-05580, 2020-05668,

20-06042, 2020-06058, 2020-06278, 2021-00187, 2021-00211,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21-00857, 2021-00923, 2021-01022, 2021-01210, 2021-01212,

21-01214, 2021-01216, 2021-01252, 2021-01253, 2021-01254,

21-01255, 2021-01256, 2021-01257, 2021-01262, 2021-01263,

21-01281, 2021-01282, 2021-01299, 2021-01456, 2021-02100

71152B

Corrective Action

Documents

Resulting from

Inspection

CR-CNS-

21-02959, 2021-03008, 2021-03015, 2021-03017, 2021-03053

71152B

Drawings

CNS-BLDG.-133

Cooper Nuclear Station Penetration Drawing North Wall - 2F 881

'-9" Reactor Bldg

10/05/2020

71152B

Engineering

Changes

EC 20-014

New SW Operational Requirement to Prevent Discharge Canal

Sediment Blockage

71152B

Engineering

Changes

ECR 11692576

RHR-MOV-MO31A Overtorque Evaluation

71152B

Engineering

Evaluations

ER-2015-037

RCIC Governor Control Systems Qualification Report

71152B

Miscellaneous

Operational Focus Meeting Agenda

71152B

Miscellaneous

Refueling Outage RE31 Regulatory Affairs & Compliance (RA&C)

Startup Review and Report

10/22/2020

71152B

Miscellaneous

CED

6012122

RHR Steam Condensing Mode Piping Isolation

06/12/2003

71152B

Miscellaneous

Engineering

Report

ER 2020-003 2019 Maintenance Rule Structural Monitoring

Report

71152B

Miscellaneous

Engineering

Report 2020-004

Evaluation of December 2019 Service Water Blockage

71152B

Miscellaneous

INPO 19-002

Clearance and Tagging

71152B

Miscellaneous

Licensee Event

Report

2016-007-00, Isolation of Shutdown Cooling due to Relay

Maintenance Results in a Loss of Safety Function

2/19/2016

71152B

Miscellaneous

LO 2020-0047-

008, 014, 024

71152B

Miscellaneous

Meeting

Condition Report Screening Committee

6/14/2021

71152B

Miscellaneous

ML20085H006

Cooper Nuclear Station - NRC Inspection Report 05000298/2020010

71152B

Miscellaneous

Operations

Instruction #17

Daily Report

3/18/21

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Miscellaneous

RCR

2002-

0796

Review of IN 2002-15 Hydrogen Combustion Events in Foreign

BWRs

06/06/2002

71152B

Miscellaneous

Standing Order

2019-10

Use of Skill of the Craft is prohibited for all normal plant activities.

Procedure in hand is required when performing any activity in the

plant.

8/8/2019

71152B

Miscellaneous

System Health

Report

RHR System

Dec-19

71152B

Miscellaneous

System Health

Report

RHR System

June - 20

71152B

Miscellaneous

System Health

Report

RHR System

April -21

71152B

Miscellaneous

System Health

Report

RHR System

Jan-21

71152B

Miscellaneous

System Health

Report

RHR System

Nov-20

71152B

Miscellaneous

System Health

Report

RHR System

Mar-20

71152B

Miscellaneous

Training Manual

COR002-23-03, Residual Heat Removal

71152B

Miscellaneous

Training Manual

COR002-27-03 - Service Water

71152B

Miscellaneous

Training Manual

ESP00005027 -ESO System Training

71152B

Miscellaneous

Vendor Manual

VM-1012, PRESRAY CORP, Reactor Building Doors R101 AND

R102 (proprietary)

10/25/2020

71152B

Miscellaneous

WT 2019-0040-

210

Perform a thorough review of Operations Skill of the Craft

database which includes re-screening of all activities for

applicability.

71152B

Procedures

0-CNS-FAP-LI-

001

Performance Improvement Review Group (PRG) Process

71152B

Procedures

0-CNS-LI-102

Corrective Action Process

07/29/2020

71152B

Procedures

0-CNS-LI-104

Self-assessment and Benchmark Process

71152B

Procedures

0-CNS-LI-118

Cause Evaluation Process

71152B

Procedures

0-CNS-LI-121

Trending and Performance Review Process

71152B

Procedures

0-CNS-OE-100

Operating Experience Program

2/03/2021

71152B

Procedures

0-CNS-WM-100

Work Order Generation, Screening, and Classification

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Procedures

0-EBS-NOT

SAP Notifications

71152B

Procedures

0-EN-EP-306

Drills and Exercises

10C1

71152B

Procedures

0-EN-HU-106

Procedure and Work Instruction Use and Adherence

3C2

71152B

Procedures

0.4ENTERGY

Entergy Procedure Processing

10/30/2019

71152B

Procedures

0.5OPS

Operations Review of Condition Reports/Operability

Determination

01/13/2021

71152B

Procedures

15.RCIC.311

RCIC Control System Calibration Test

71152B

Procedures

3-EN-DC-147

Engineering Reports

5C1

71152B

Procedures

3-EN-DC-150

Condition Monitoring of Maintenance Rule Structures

6C4

71152B

Procedures

3-EN-DC-306

Acceptance of Commercial-Grade Items/Services in Safety-

Related Applications

5C1

71152B

Procedures

6.RCIC.102

RCIC IST and 92 Day Test

71152B

Procedures

Administrative

Procedure 0-

Barrier

Barrier Control Process

71152B

Procedures

Administrative

Procedure 0-

CNS-MA-123

Identification and Trending of Rework

71152B

Procedures

Administrative

Procedure 0-

CNS-OE-100

Operating Experience Program

71152B

Procedures

Administrative

Procedure 0.10

Operating Experience Program

10/11/12

71152B

Procedures

Administrative

Procedure 0.23

CNS Fire Protection Plan

71152B

Procedures

EN-NS-221

Security Organization, Standards & Expectations

013

71152B

Procedures

EN-OE-100

Operating Experience Program

71152B

Procedures

Engineering

Procedure 3.21

Fabrication of Replacement Parts

71152B

Procedures

Engineering

Procedure 3.31

MOV Overthrust/Overtorque Evaluation

71152B

Procedures

Engineering

Procedure 3.33

Motor Operated Valve Program

71152B

Procedures

Engineering

Limitorque Actuator Configuration Control

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedure 3.33.6

71152B

Procedures

Engineering

Procedure 3.6.1

Fire Barrier Control

71152B

Procedures

Maintenance

Procedure

14.HV.301

HV Moore 353 Controller Configuration Download and Calibration

Check

71152B

Procedures

Maintenance

Procedure

7.2.78.2

Pipe Penetration Seal Installation Using Gasket Placement

71152B

Procedures

Maintenance

Procedure 7.5.3

MOV Diagnostics

71152B

Procedures

System

Operating

Procedure 2.2.20

Standby AC Power System (Diesel Generator)

111

71152B

Procedures

System

Operating

Procedure 2.2.47

HVAC Reactor Building

71152B

Procedures

System

Operating

Procedure

2.2.65.1

REC Operations

71152B

Procedures

System

Operating

Procedure 2.2.71

Service Water System

131

71152B

Radiation Work

Permits (RWPs)

LO 2019-0202

Occupational ALARA Planning and Controls" (IP-71124.02) and

"Occupational Dose Assessment" (IP-71124.04)

1/24/2020

71152B

Self-

Assessments

LO 2019-00129-

001

Work Control Self-Assessment

10/31/2019

71152B

Self-

Assessments

LO 2019-0124-

004

Cycle 31 Road to Excellence Priority 1.1 - Nuclear Safety,

Operations Management and Leadership, IER 17-5

recommendations and IER L3 19-005 self-assessment

71152B

Self-

Assessments

LO 2019-0176-

001

2019 Cooper Crew Performance Evaluation

71152B

Self-

LO 2020-0034-

Operation Error Pre-Cursor SOER 10-2 Screen

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Assessments

001

71152B

Self-

Assessments

LO 2020-0034-

010

Tagging Focused Self-Assessment

71152B

Self-

Assessments

LO 2020-0117-

001

Cooper Nuclear Station Operations Training Effectiveness Review

71152B

Self-

Assessments

LO 2020-0126

Pre PI&R NRC Inspection Self-Assessment

71152B

Self-

Assessments

LO-2019-0201

20 Inservice Inspection Program Self-Assessment

7/01/2020

71152B

Self-

Assessments

LO-2020-0095-

20

Analysis on Worker Protection Issues

11/17/2020

71152B

Self-

Assessments

QA Audit 19-04

Maintenance

07/11/2019

71152B

Self-

Assessments

QA Audit 19-07

Chemistry, Effluent and Environmental Monitoring

10/07/2019

71152B

Self-

Assessments

QA Audit 20-02

Corrective Action Program

05/20/2020

71152B

Self-

Assessments

QA Audit 20-04

Radiological Controls

08/19/2020

71152B

Work Orders

219342,

5319879,

5336962

71152B

Work Orders

5306957

(NRC Identified) Fire Seal Discrepancy

0