IR 05000298/2018002

Errata - Cooper Nuclear Station - NRC Integrated Inspection Report 05000298/2018002

ML18233A581
Person / Time
Site:	Cooper
Issue date:	08/21/2018
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2018002
Download: ML18233A581 (24)

Text

ust 21, 2018

SUBJECT:

ERRATA - COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000298/2018002

Dear Mr. Dent:

Based on the review of the NRC memorandum, dated August 7, 2018, Close-Out of National Fire Protection Association Frequently Asked Question 10-0059 on National Fire Protection Association Standard 805 Monitoring, (Agencywide Document Management System (ADAMS)

Accession No. ML18208A454), the NRC has decided to retract NCV 05000298/2018002-01, Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid, that was contained in NRC Inspection Report No.

05000298/2018002, dated July 25, 2018 (ADAMS Accession No. ML18206A216). In the memorandum, the NRC found that the guidance contained in Frequently Asked Question 10-0059 related to use of the Maintenance Rule unavailability, versus the lower fire probabilistic risk assessment assumptions, was acceptable along with the inclusion of NRC staff comments contained within the memorandum. As a result, the NRC will reopen Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid, and will perform an inspection at a later date to determine if you are in compliance with the guidance contained in Frequently Asked Question 10-0059.

The NRC has reissued the report in its entirety to remove the associated violation and closure of the unresolved item that were contained in the report sections: Summary, Additional Tracking Items, Reactor Safety 71111.05XTFire Protection - NFPA 805 (Triennial), and Other Activities - Baseline 71153Follow-up of Events and Notices of Enforcement Discretion.

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

NRC inspectors documented two findings of very low safety significance (Green) in this report.

These findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

J. Dent, Jr. 2 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.

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/ Attachments:

1. Documents Reviewed 2. NRC Request for Information

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 Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed violations and additional items are summarized in the tables below.

List of Findings and Violations Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.3] - Human 71111.18 -

Systems NCV 05000298/2018002-01 Performance, Plant Closed Change Modifications Management 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for completion of manual actions rather than the bounding 5.8-hour allowance described in NEDC 92-064.

Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit Switches Cornerstone Significance Cross-cutting Report Aspect Section Barrier Green None 71153 -

Integrity NCV 05000298/2018002-02 Follow-up of Closed 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 Status Section LER 05000298/2017-005-00 Traversing In-core Probe 71153 Closed In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications

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 coil 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 Web site 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

71111.01Adverse Weather Protection Summer Readiness

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.

===71111.04Equipment Alignment Partial Walkdown

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 on June 28, 2018.

71111.05QFire Protection Quarterly Inspection

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

71111.06Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections in the high pressure coolant injection room on June 26, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

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.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

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

71111.13Maintenance Risk Assessments and Emergent Work Control

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

71111.15Operability Determinations and Functionality Assessments

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

71111.18Plant Modifications

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

71111.19Post Maintenance Testing

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

71111.20Refueling and Other Outage Activities

The inspectors evaluated fan coil D forced outage activities from May 30, 2018 to June 11, 2018.

===71111.22Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine ===

(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

===71114.06Drill Evaluation Emergency Planning Drill

The inspectors evaluated a full team drill on May 22, 2018.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

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)===

===71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (1 Sample)===

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

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

71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) 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), 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 Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.3] - Human

71111.18 - Systems

NCV 05000298/2018002-01 Performance, Plant Closed Change Modifications Management 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 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 gallons per minute (gpm) leak in the cooling coil. The licensee was using high pressure demineralized 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 exchangers 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 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 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, as described by NEDC 92-064, rather than the timeline of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 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 licensees failure to provide adequate guidance for restoring room cooling in Alarm Procedure 2.3_R-1 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 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 Chapter 0609, Appendix A, The Significance Determination Process for Findings 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 non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit Switches Cornerstone Significance Cross-cutting Report Aspect Section Barrier Integrity Green None 71153 -

NCV 05000298/2018002-02 Follow-up of Closed 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.

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-2017-00039

Performance Assessment:

Performance Deficiency: The licensees 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 Findings 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 non-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 MEETINGS 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 Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01Adverse Weather Protection

Miscellaneous Documents

Number Title Revision

Interface Operating Agreement between Nebraska Public 9

Power District Operations Business Unit and Nebraska

Public Power District Nuclear Power Group Business Unit

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 32

CNS

Work Orders

5196728

71111.04Equipment Alignment

Miscellaneous Documents

Number Title Revision

2040 Flow Diagram Residual Heat Removal System N82

2043 Flow Diagram Reactor Core Isolation Coolant and Reactor 56

Feed Systems

2044 Flow Diagram High Pressure Coolant Injection and Reactor 75

Feed Systems

Procedures

Number Title Revision

2.2.33A High Pressure Coolant Injection System Component 30

Checklist

2.2.33B High Pressure Coolant Injection System Instrument Valve 8

Checklist

2.2.67A Reactor Core Isolation Cooling System Component 22

Checklist

Procedures

Number Title Revision

2.2A.RHR.DIV1 Residual Heat Removal System Component Checklist 9

(Div 1)

2.2A.RHR.DIVSDC Residual Heat Removal System Component Checklist 3

(Div SDC)

Condition Reports (CR-CNS-)

2018-03339

71111.05Fire Protection Quarterly

Drawings

CNS-FP-211 CNS-FP-227 CNS-FP-256 CNS-FP-379

Procedures

Number Title Revision

0-BARRIER- Control Building 7

CONTROL

0-BARRIER- Barrier Maps 9

MAPS

0-BARRIER- Miscellaneous Buildings 5

MISC

0-BARRIER- Reactor Building 13

REACTOR

6.FP.305 Halon 1301 Service Water Pump Room Fire Suppression 15

Surveillance Checks

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

Procedures

Number Title Revision

2.2.33A High Pressure Coolant Injection System Component 30

Checklist

Condition Reports (CR-CNS-)

2018-02403

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Miscellaneous Documents

Number Title Revision

SKL05151245 CRD Pump Trip, Drifting Rods, ATWS, Loss of Level 3

Indication, EOP 7B RPV Flooding

Procedures

Number Title Revision

2.1.4 Normal Shutdown 160

2.2.28.1 Feedwater System Operation 95

Condition Reports (CR-CNS-)

2018-03326

71111.12Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision

Maintenance Rule Function HV-F02 Performance Criteria 4

Basis

11414213 Notification

Condition Reports (CR-CNS-)

2016-02434 2016-08539 2017-00039 2017-06120

Work Orders

5166424 5214101

71111.13Maintenance 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 May 11, 2018

Equipment Program Tracking Form

HPCI Remain in Service List

HPCI Window, Week 1816 Protected Equipment Program April 16, 2018

Tracking Form

Calc NEDC 89- Review of EAS Calculation 4

234

Calc NEDC 91- Limiting Conditions Analysis for 18 Tricentric Valves 0

253G

Procedures

Number Title Revision

0-CNS-WM- On-Line Fire Risk Management Actions 4

104A

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

71111.15Operability 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

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 30

Checklist

Condition Reports (CR-CNS-)

2018-02364 2018-02413 2018-02426 2018-02427

2018-02492 2018-03294 2018-03341 2018-03365

2018-03388 2018-2403

Work Orders

5169626 5244135

71111.18Plant 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

71111.19Post 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 32

MOV Program MOVs

730E197BB Elementary Diagram Variable Speed Recirc Pump and MG 19

Sheet 3 Set

730E197BB Elementary Diagram Variable Speed Recirc Pump and MG 28

Sheet 8 Set

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

71111.22Surveillance Testing

Miscellaneous Documents

Number Title Revision

Calc NEDC 89- Review of EAS Calculation 4

234

Calc NEDC 91- Limiting Conditions Analysis for 18 Tricentric Valves 0

253G

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

71151Performance Indicator Verification

Miscellaneous Documents

Number Title Revision/Date

Operations Instruction 17, Daily Report 47

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 3 132

Condition Reports (CR-CNS-)

2018-02134 2018-02571 2018-02592 2018-02657

2018-02679 2018-02700 2018-02860

71153Follow-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

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 ODMIs, OWA/OWBs, 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 PMs, deferred PMs, and PM change requests for

this system

11. System design calculations

2. 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&IDs), and system training manuals

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

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 1816.

ML18233A581

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: GWerner Yes No Publicly Available Sensitive NRC-002

OFFICE BC:DRS/EB2 BC;DRP/C

NAME GWerner JKozal

SIGNATURE /RA/ /RA/

DATE 8/17/18 8/21/18