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{{#Wiki_filter:July 25, 2018
{{#Wiki_filter:July 25, 2018
  Mr. John Dent, Jr.
Mr. John Dent, Jr.
Vice President
Vice President-Nuclear and CNO
-Nuclear and CNO
Nebraska Public Power District
Nebraska Public Power District
Cooper Nuclear Station
Cooper Nuclear Station
72676 648A Avenue
72676 648A Avenue
P.O. Box 98
P.O. Box 98
Brownville, NE 68321
Brownville, NE 68321
SUBJECT:       COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT
  SUBJECT: COOPER NUCLEAR STATION
                05000298/2018002
- NRC INTEGRATED
Dear Mr. Dent:
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 June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
. On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. K. Dia, Acting Vice President
your Cooper Nuclear Station. On July 12, 2018, the NRC inspectors discussed the results of
-Nuclear and CNO, and other members of your staff. The results of this inspection are documented in the enclosed report.
this inspection with Mr. K. Dia, Acting Vice President-Nuclear and CNO, and other members of
  NRC inspectors documented three findings of very low safety significance (Green) in this report. All of these findings involved violations
your staff. The results of this inspection are documented in the enclosed report.
of NRC requirements
NRC inspectors documented three findings of very low safety significance (Green) in this report.
. The NRC is treating these violation s as non-cited violations (NCVs) consistent with Section
All of these findings involved violations of NRC requirements. The NRC is treating these
2.3.2.a of the Enforcement Policy. If you contest the violations or significance of these NCVs, you should provide a response within  
violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement
30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Policy.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
If you contest the violations or significance of these NCVs, you should provide a response within
Regional Administrator, Region
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
IV; the Director, Office of Enforcement; and the NRC resident inspector at the Cooper Nuclear Station
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
.  If you disagree with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the
a cross-cutting aspect assignment in this report, you should provide a response within 30
NRC resident inspector at the Cooper Nuclear Station.
days of the date of this inspection report, with the basis for your disagreement, to the U.S.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
response within 30 days of the date of this inspection report, with the basis for your
Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station.
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
J. Dent Jr. 2   This letter, its enclosure, and your response (if any) will be made available for public inspection
NRC resident inspector at the Cooper Nuclear Station.
and copying at http://www.nrc.gov/reading
 
-rm/adams.html
J. Dent Jr.                                       2
and at the NRC Public Document Room in accordance with 10
This letter, its enclosure, and your response (if any) will be made available for public inspection
CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
"  Sincerely,   /RA/ Jason W. Kozal , Chief Project Branch C Division of Reactor Projects
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
  Docket No. 50
Withholding.
-298 License No. DPR-46 Enclosure:
                                                Sincerely,
Inspection Report
                                                /RA/
05000298/2018002
                                                Jason W. Kozal, Chief
w/ Attachment:
                                                Project Branch C
1. Documents Reviewed
                                                Division of Reactor Projects
2. NRC Request for Information
Docket No. 50-298
   
License No. DPR-46
  Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Enclosure:
Inspection Report
Inspection Report 05000298/2018002
  Docket Number:  
w/ Attachment:
05000298  License Number:
1. Documents Reviewed
DPR-46   Report Number:
2. NRC Request for Information
05000298/2018002   Enterprise Identifier:
 
I-2018-002-0003   Licensee: Nebraska Public Power District
                          U.S. NUCLEAR REGULATORY COMMISSION
  Facility: Cooper Nuclear Station
                                        Inspection Report
  Location: Brownville, Nebraska
Docket Number:         05000298
  Inspection Dates:
License Number:       DPR-46
April 1, 2018
Report Number:         05000298/2018002
to June 30, 2018
Enterprise Identifier: I-2018-002-0003
  Inspectors:
Licensee:             Nebraska Public Power District
M. Tobin, Acting Senior Resident Inspector
Facility:             Cooper Nuclear Station
R. Kumana, Acting Senior Resident Inspector
Location:             Brownville, Nebraska
R. Deese, Senior Reactor Analyst
Inspection Dates:     April 1, 2018 to June 30, 2018
J. Mateychick, Senior Reactor Inspector
Inspectors:           M. Tobin, Acting Senior Resident Inspector
W. Sifre, Senior Reactor Inspector
                      R. Kumana, Acting Senior Resident Inspector
C. Young, Senior Project Engineer
                      R. Deese, Senior Reactor Analyst
M. Stafford, Resident Inspector
                      J. Mateychick, Senior Reactor Inspector
  Approved By:
                      W. Sifre, Senior Reactor Inspector
J. Kozal, Chief, Project Branch C
                      C. Young, Senior Project Engineer
  Division of Reactor Projects
                      M. Stafford, Resident Inspector
   
Approved By:           J. Kozal, Chief, Project Branch C
  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  
                      Division of Reactor Projects
overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html
                                                                  Enclosure
for more information. NRC and self
 
-revealed violations and additional items are summarized in the tables below.
                                              SUMMARY
  List of Findings and Violations
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid
performance by conducting an integrated inspection at Cooper Nuclear Station in accordance
Cornerstone
with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
Significance
overseeing the safe operation of commercial nuclear power reactors. Refer to
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-
-01 Closed [H.3] - Human Performance, Change Management
revealed violations and additional items are summarized in the tables below.
71111.05XT
                                  List of Findings and Violations
- Fire Protection
  Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the
- NFPA 805 (Triennial)
  Engineering Analysis Remain Valid
The inspectors identified a Green non-cited violation of License Condition
  Cornerstone       Significance                                     Cross-cutting     Report
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
                                                                      Aspect             Section
805, "Performance
  Mitigating         Green                                             [H.3] - Human 71111.05XT
-Based Standard for Fire Protection for Light
  Systems            NCV 05000298/2018002-01                          Performance,      - Fire
-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.
                    Closed                                            Change            Protection -
   Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone
                                                                      Management        NFPA 805
Significance
                                                                                          (Triennial)
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management
  The inspectors identified a Green non-cited violation of License Condition 2.C.(4), Fire
71111.18 - Plant Modifications
  Protection, for the failure to establish an appropriate monitoring program in accordance with
The inspectors identified a Green non
  Section 2.6 of the National Fire Protection Association (NFPA) Standard 805, Performance-
-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure
  Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants.
2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified
  Specifically, the licensee failed to set the action level for the availability of some plant
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
  components to ensure that the assumptions in the engineering analysis remained valid.
hours for completion of manual actions rather than the bounding 5.8
   Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual
-hour allowance described in NEDC
  Actions
92-064.  
  Cornerstone       Significance                                     Cross-cutting     Report
  3  Failure to Maintain Adequate Work Instructions for Traversing In
                                                                      Aspect            Section
-Core Probe System Limit Switches Cornerstone
  Mitigating         Green                                             [H.3] - Human 71111.18 -
Significance
  Systems            NCV 05000298/2018002-02                          Performance,      Plant
Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000298/2018002
                    Closed                                            Change            Modifications
-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion
                                                                      Management
A self-revealed, Green non-cited violation of Technical Specification 5.4, "Procedures," was identified when the licensee failed to maintain Procedure
  The inspectors identified a Green non-cited violation of Technical Specification 5.4,
14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in
  Procedures, when the licensee failed to maintain Procedure 2.3_R-1 with the bounding time
-core probe system  
  restrictions for required manual ventilation actions identified in Engineering Evaluation
in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves
  NEDC 92-064, Transient Temperature Rise in SWBP Room After Loss of Cooling,
.  Additional Tracking Items
  Revision 3C2. As a result, the licensee relied on procedure guidance that contained an
Type Issue number
  incorrect, less restrictive allowance of 13 hours for completion of manual actions rather than
Title Report Section Status URI 05000298/2016008
  the bounding 5.8-hour allowance described in NEDC 92-064.
-01 Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid 71111.05 XT Closed LER 05000298/2017
                                                  2
-005-00 Traversing In
 
-core Probe  
Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit
In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
Switches
71153 Closed   
Cornerstone       Significance                                   Cross-cutting       Report
  4  PLANT STATUS
                                                                  Aspect             Section
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
Barrier           Green                                           None                71153 -
il units. The unit was returned to rated thermal power  
Integrity        NCV 05000298/2018002-03                                             Follow-up of
on June 11, 2018 , and remained at or near rated thermal power for the remainder of the inspection period.
                  Closed                                                              Events and
  INSPECTION SCOPES
                                                                                      Notices of
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
                                                                                      Enforcement
-rm/doc-collections/insp
                                                                                      Discretion
-manual/inspection
A self-revealed, Green non-cited violation of Technical Specification 5.4, Procedures, was
-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)
identified when the licensee failed to maintain Procedure 14.2.14, TIP Chamber Shield
2515, "Light
Maintenance, with adequate instructions for reinstalling the traversing in-core probe system
-Water Reactor Inspection Program - Operations Phase."  The inspectors performed plant status activities described in IMC 2515 , Appendix D, "Plant Status
in-shield limit switches. As a result, the licensee experienced multiple failures of the shield
," and conducted routine reviews using IP
limit switches resulting in inoperable primary containment isolation valves.
71152, "Problem Identification and Resolution."
                                  Additional Tracking Items
  The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance  
Type     Issue number               Title                             Report         Status
                                                                      Section
URI       05000298/2016008-01       Possible Failure to Ensure that   71111.05XT      Closed
                                    the Assumptions in the
                                    Engineering Analysis Remain
                                    Valid
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
                                                3
 
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 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.
with Commission rules and regulations, license conditions, site procedures, and standards.
  REACTOR SAFETY
REACTOR SAFETY
71111.01-Adverse Weather Protection
71111.01Adverse Weather Protection
Summer Readiness
    Summer Readiness (1 Sample)
(1 Sample) The inspectors evaluated summer readiness of offsite and alternate alternating current
    The inspectors evaluated summer readiness of offsite and alternate alternating current (AC)
(AC) power systems
    power systems on May 11, 2018.
on May 11, 2018. External Flooding
    External Flooding (1 Sample)
(1 Sample) The inspectors evaluated readiness to cope with external flooding on May 17, 2018. 71111.04-Equipment Alignment
    The inspectors evaluated readiness to cope with external flooding on May 17, 2018.
Partial Walkdown
71111.04Equipment Alignment
(3 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
    Partial Walkdown (3 Samples)
  (1) Reactor core isolation cooling during high pressure coolant injection work window
    The inspectors evaluated system configurations during partial walkdowns of the following
on April 18, 2018 (2) Shutdown cooling
    systems/trains:
A while B in service on June 1, 2018 (3) Control building ventilation for service water
    (1) Reactor core isolation cooling during high pressure coolant injection work window on
booster system
        April 18, 2018
on May 11, 2018 Complete Walkdown
    (2) Shutdown cooling A while B in service on June 1, 2018
(1 Sample) The inspectors evaluated system configurations during a complete walkdown of the high pressure coolant injection full system alignment  
    (3) Control building ventilation for service water booster system on May 11, 2018
o n June 28, 2018.
    Complete Walkdown (1 Sample)
  5  71111.05Q-Fire Protection
    The inspectors evaluated system configurations during a complete walkdown of the high
Quarterly Inspection
    pressure coolant injection full system alignment on June 28, 2018.
(5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas: (1) Intake building and service water pump room
                                                  4
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
71111.05QFire Protection
29, 2018 (5) Cable spreading room on June 28, 2018
  Quarterly Inspection (5 Samples)
  71111.05XT
  The inspectors evaluated fire protection program implementation in the following selected
-Fire Protection
  areas:
- NFPA 805 (Triennial)
  (1) Intake building and service water pump room on April 5, 2018
The inspectors reviewed the licensee's actions to address the issue identified in  
  (2) Reactor core isolation cooling and core spray A area on April 18, 2018
Unresolved Item (URI)
  (3) 125/250 Vdc battery and switchgear room on May 23, 2018
05000298/2016008
  (4) Supplemental diesel generator on May 29, 2018
-01 from May 7, 2018, to June 5, 2018. This URI is now closed. 71111.06-Flood Protection Measures
  (5) Cable spreading room on June 28, 2018
Internal Flooding
71111.05XTFire Protection - NFPA 805 (Triennial)
(1 Sample) The inspectors evaluated internal flooding mitigation protections in the high pressure coolant injection room
  The inspectors reviewed the licensees actions to address the issue identified in Unresolved
on June 26, 2018
  Item (URI) 05000298/2016008-01 from May 7, 2018, to June 5, 2018. This URI is now
.  71111.11-Licensed Operator Requalification Program and Licensed Operator Performance
  closed.
Operator Requalification
71111.06Flood Protection Measures
(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
  Internal Flooding (1 Sample)
(1 Sample) The inspectors observed and evaluated operator performance during a downpower for a forced outage associated with fan coil unit maintenance
  The inspectors evaluated internal flooding mitigation protections in the high pressure coolant
on May 29, 2018. 71111.12-Maintenance Effectiveness
  injection room on June 26, 2018.
Routine Maintenance Effectiveness
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
(2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
  Operator Requalification (1 Sample)
  (1) Service water
  The inspectors observed and evaluated operator training during a licensed operator
booster system
  requalification simulator scenario focusing on an anticipated transient without a scram on
room cooler
  May 18, 2018.
on May 11 , 2018 (2) Traversing in
  Operator Performance (1 Sample)
-core probe on May 11 , 2018  
  The inspectors observed and evaluated operator performance during a downpower for a
  6  71111.13-Maintenance Risk Assessments and Emergent Work Control
  forced outage associated with fan coil unit maintenance on May 29, 2018.
(5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities:
71111.12Maintenance Effectiveness
  (1) High pressure coolant injection
  Routine Maintenance Effectiveness (2 Samples)
maintenance window  
  The inspectors evaluated the effectiveness of routine maintenance activities associated
on April 19, 2018 (2) Service water
  with the following equipment and/or safety significant functions:
booster system
  (1) Service water booster system room cooler on May 11, 2018
room cooler risk evaluation on May 11 , 2018 (3) Service water pump
  (2) Traversing in-core probe on May 11, 2018
D work week on May
                                                5
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
71111.13Maintenance Risk Assessments and Emergent Work Control (5 Samples)
(4 Samples) The inspectors evaluated the following operability determinations and functionality assessments:
  The inspectors evaluated the risk assessments for the following planned and emergent
  (1) Emergency diesel generator
  work activities:
2 jacket water temperature issue on April
  (1) High pressure coolant injection maintenance window on April 19, 2018
25, 2018 (2) Service water
  (2) Service water booster system room cooler risk evaluation on May 11, 2018
booster system
  (3) Service water pump D work week on May 17, 2018
pipe below minimum wall thickness on May
  (4) Emergent drywell fan coil unit D work on May 18, 2018
1, 2018 (3) Fan coil unit functionality
  (5) Emergent downpower due to drywell fan coil unit A on May 26, 2018
on June 22, 2018 (4) High pressure coolant injection operability with room floor drains clogged, extending limiting condition for operation time on June
71111.15Operability Determinations and Functionality Assessments (4 Samples)
25, 2018 71111.18-Plant Modifications (2 Samples) The inspectors evaluated the following temporary or permanent modifications:
  The inspectors evaluated the following operability determinations and functionality
(1) Service water
  assessments:
booster system
  (1) Emergency diesel generator 2 jacket water temperature issue on April 25, 2018
room fan coil unit manual actions on May
  (2) Service water booster system pipe below minimum wall thickness on May 1, 2018
11 , 2018 (2) Service water booster pump oil reservoirs on May
  (3) Fan coil unit functionality on June 22, 2018
11, 2018 71111.19-Post Maintenance Testing
  (4) High pressure coolant injection operability with room floor drains clogged, extending
(4 Samples) The inspectors evaluated the following post maintenance
      limiting condition for operation time on June 25, 2018
tests: (1) HPCI-MO-15 following packing replacement on March
71111.18Plant Modifications (2 Samples)
15, 2018 (2) High pressure coolant injection pump test following maintenance window on April 20 2018 (3) Service water
  The inspectors evaluated the following temporary or permanent modifications:
pump C on May 3, 2018 (4) Reactor recirculation pump
  (1) Service water booster system room fan coil unit manual actions on May 11, 2018
B relay replacement on June 21, 2018 71111.20-Refueling and Other Outage Activities
  (2) Service water booster pump oil reservoirs on May 11, 2018
(1 Sample) The inspectors evaluated fan coil D forced outage activities
71111.19Post Maintenance Testing (4 Samples)
from May 30, 2018 to June 11, 2018.  
  The inspectors evaluated the following post maintenance tests:
  7  71111.22-Surveillance Testing
  (1) HPCI-MO-15 following packing replacement on March 15, 2018
The inspectors evaluated the following surveillance tests:
  (2) High pressure coolant injection pump test following maintenance window on
  Routine (3 Samples) (1) Service water pump
      April 20 2018
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
  (3) Service water pump C on May 3, 2018
A quarterly inservice surveillance test on May 1, 2018 71114.06-Drill Evaluation
  (4) Reactor recirculation pump B relay replacement on June 21, 2018
Emergency Planning Drill
71111.20Refueling and Other Outage Activities (1 Sample)
(1 Sample) The inspectors evaluated a full team drill  
  The inspectors evaluated fan coil D forced outage activities from May 30, 2018 to
on May 22, 2018. OTHER ACTIVITIES  
  June 11, 2018.
- BASELINE 71151-Performance Indicator Verification
                                                6
(3 Samples) The inspectors
 
verified licensee performance
71111.22Surveillance Testing
indicators
  The inspectors evaluated the following surveillance tests:
submittals
  Routine (3 Samples)
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
  (1) Service water pump D surveillance test on May 29, 2018
(April 1, 2017 - March 31, 2018) (1 Sample) (3) BI02: RCS Leak Rate
  (2) Division 1 reactor recirculation flow unit channel calibration on June 7, 2018
(April 1, 2017 - March 31, 2018) (1 Sample) 71152-Problem Identification and Resolution
  (3) Operator rounds on June 15, 2018
Semiannual Trend Review
  In-service (1 Sample)
(1 Sample) The inspectors reviewed the licensee's corrective action program for trends that might be indicative of a more significant safety issue.
  (1) Core spray subsystem A quarterly inservice surveillance test on May 1, 2018
  Annual Follow
71114.06Drill Evaluation
-up of Selected Issue s (1 Sample) The inspectors reviewed the licensee's implementation of its corrective acti
  Emergency Planning Drill (1 Sample)
on program related to
  The inspectors evaluated a full team drill on May 22, 2018.
the following issues:
OTHER ACTIVITIES - BASELINE
  (1) Emergency diesel generator damper failures on May 11, 2018  
71151Performance Indicator Verification (3 Samples)
  8  71153-Follow-up of Events and Notices of Enforcement Discretion
  The inspectors verified licensee performance indicators submittals listed below:
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) MS05: Safety System Functional Failures (SSFFs) (April 1, 2017 - March 31, 2018)
:  (1) Licensee Event Report (LER
  (1 Sample)
) 05000 298/201 7-005-00, Traversing In
  (2) BI01: Reactor Coolant System (RCS) Specific Activity (April 1, 2017 - March 31, 2018)
-core Probe  
  (1 Sample)
In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
  (3) BI02: RCS Leak Rate (April 1, 2017 - March 31, 2018) (1 Sample)
(ADAMS Accession No.
71152Problem Identification and Resolution
ML17236A166), on May 11 , 2018.   INSPECTION RESULTS
  Semiannual Trend Review (1 Sample)
Observation
  The inspectors reviewed the licensees corrective action program for trends that might be
71152 - Problem Identification  
  indicative of a more significant safety issue.
and Resolution
  Annual Follow-up of Selected Issues (1 Sample)
  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
  The inspectors reviewed the licensees implementation of its corrective action program
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.
  related to the following issues:
  Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid
  (1) Emergency diesel generator damper failures on May 11, 2018
  Cornerstone
                                                  7
Significance
 
Cross-cutting Aspect Report Section Mitigating Systems
71153Follow-up of Events and Notices of Enforcement Discretion
Green NCV 05000298/2018002
    Licensee Event Reports (1 Sample)
-01 Closed [H.3] - Human Performance, Change Management
    The inspectors evaluated the following licensee event reports which can be accessed at
71111.05XT
    https://lersearch.inl.gov/LERSearchCriteria.aspx:
- Fire Protection
    (1) Licensee Event Report (LER) 05000298/2017-005-00, Traversing In-core Probe
- NFPA 805 (Triennial)
        In-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of
  The inspectors identified a Green non
        Independent Trains or Channels and Condition Prohibited by Technical Specifications
-cited violation of License Condition
        (ADAMS Accession No. ML17236A166), on May 11, 2018.
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
INSPECTION RESULTS
805, "Performance
                                    Observation                                           71152 -
-Based Standard for Fire Protection for Light
                                                                                          Problem
-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.
                                                                                        Identification
  Description
                                                                                              and
: During the NRC triennial fire protection inspection in 2016 (see NRC Inspection Report 05000298/2016008
                                                                                          Resolution
(Agencywide Documents Access and Managem
  The inspectors identified a potential adverse trend involving the sizing of bolts associated with
ent System (ADAMS) Accession No.
emergency diesel generator components. The inspectors determined that the licensee
ML16270A561)), the inspectors reviewed the licensee's implementation of the monitoring program required in Section
documented multiple instances where they discovered incorrect bolting on various
2.6 of NFPA Standard
components of the emergency diesel generators. The inspectors determined that in all cases
  805, "Performance
reviewed, the licensee had determined that the bolts used in the plant were greater than the
-Based Standard for Fire Protection for Light
length required by design, had adequate thread engagement to ensure they maintained their
-Water Reactor Electric Generating Plants."  NFPA
safety function, and did not adversely impact the ability of the emergency diesel generators to
805 requires the following in Section
perform their function. The inspectors determined that the licensee had identified these
2.6:
issues through focused observation of the system design requirements and had implemented
  9  Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained
appropriate corrective actions.
, 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.
Failure to Set Performance Monitoring Action Levels to Ensure that the Assumptions in the
  The inspectors reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, "National Fire Protection Association (NFPA)
Engineering Analysis Remain Valid
805 Monitoring Program," Revision
  Cornerstone           Significance                               Cross-cutting       Report
0, to ensure that the licensee's program properly implemented the requirements of NFPA
                                                                    Aspect             Section
805, Section
Mitigating Systems Green                                           [H.3] - Human       71111.05XT
2.6. The inspectors also reviewed Engineering Report ER-2015-002, "National Fire Protection Association (NFPA)
                        NCV 05000298/2018002-01                    Performance,        - Fire
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
                        Closed                                      Change              Protection -
  Core spray pumps
                                                                    Management          NFPA 805
  Emergency diesel generators
                                                                                        (Triennial)
  Emergency station service transformer
  The inspectors identified a Green non-cited violation of License Condition 2.C.(4), Fire
  Startup station service transformer
Protection, for the failure to establish an appropriate monitoring program in accordance with
  High pressure core spray pump
Section 2.6 of the National Fire Protection Association (NFPA) Standard 805, Performance-
  Instrument air compressors
Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants.
  Residual heat removal pumps
  Specifically, the licensee failed to set the action level for the availability of some plant
  Standby liquid control pumps
components to ensure that the assumptions in the engineering analysis remained valid.
  Service water pumps
  Description: During the NRC triennial fire protection inspection in 2016 (see NRC Inspection
  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
Report 05000298/2016008 (Agencywide Documents Access and Management System
805 to maintain the assumptions in the engineering analysis.
(ADAMS) Accession No. ML16270A561)), the inspectors reviewed the licensees
  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
implementation of the monitoring program required in Section 2.6 of NFPA Standard 805,
10-0059, "National Fire Protection Association (NFPA) 805 Monitoring."  With the further clarification pending, the inspectors documented the issue as Unresolved Item
  Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating
05000298/2016008
Plants. NFPA 805 requires the following in Section 2.6:
-01, "Possible
                                                  8
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
    Monitoring. A monitoring program shall be established to ensure that the
Frequently Asked Question
    availability and reliability of the fire protection systems and features are
10-0059, "National Fire Protection Association (NFPA)
    maintained, and to assess the performance of the fire protection program in
805 Monitoring," Revision
    meeting the performance criteria. Monitoring shall ensure that the assumptions in
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
    the engineering analysis remain valid.
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
The inspectors reviewed selected samples of equipment monitored by the licensee using
-6/year.  
Procedure 3-CNS-DC-357, National Fire Protection Association (NFPA) 805 Monitoring
  10  Corrective Action Reference
Program, Revision 0, to ensure that the licensees program properly implemented the
(s): Condition Report  
requirements of NFPA 805, Section 2.6. The inspectors also reviewed Engineering
CR-CNS-2016-05109 Performance Assessment
Report ER-2015-002, National Fire Protection Association (NFPA) 805 Fire Protection
:  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.
Monitoring Program, Revision 2. The inspectors observed that for components used in the
  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.
fire probabilistic risk assessment, the unavailability time for those components was monitored
  This finding affects the Mitigating Systems Cornerstone.
using the existing maintenance rule (10 CFR 50.65) monitoring program. These components
  Significance: The inspectors assessed the significance of the finding using
included the:
NRC Inspection Manual Chapter
            *    Control rod drive pumps
0609, "Significance Determination Process," Attachment
            *    Core spray pumps
4, "Initial Characterization of Findings," dated October 7, 2016, as requiring significance determination per Manual Chapter
            *    Emergency diesel generators
0609, Appendix
            *    Emergency station service transformer
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.  
            *    Startup station service transformer
The inspectors categorized the finding as a post
            *    High pressure core spray pump
-fire safe shutdown finding with a high degradation rating. The high degradation rating was made using Manual Chapter
            *    Instrument air compressors
0609, Appendix
            *    Residual heat removal pumps
F, Attachment
            *    Standby liquid control pumps
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  
            *    Service water pumps
step 1.4.7 of Attachment
The inspectors noted that the action levels for availability in the maintenance rule monitoring
1 of Appendix
program were greater than the assumptions in the fire probabilistic risk assessment and
F, the finding was screened as a Green finding of very low safety significance in  
questioned whether this met the requirement in NFPA 805 to maintain the assumptions in the
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.
engineering analysis.
  Cross-cutting Aspect: This finding had a cross
Clarifications of the monitoring program requirements were being discussed between the
-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
industry and the NRCs Office of Nuclear Reactor Regulation during periodic public meetings
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
which discussed Frequently Asked Question 10-0059, National Fire Protection Association
[H.3]. Enforcement
(NFPA) 805 Monitoring. With the further clarification pending, the inspectors documented
:  Violation: License Condition
the issue as Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the
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
Assumptions in the Engineering Analysis Remain Valid. The discussions failed to provide
CFR 50.48(a) and 10
any additional guidance; therefore, the inspectors are addressing this issue based on the
CFR 50.48(c), as specified in the license amendment request
information contained in Frequently Asked Question 10-0059, National Fire Protection
, dated April
Association (NFPA) 805 Monitoring, Revision 5.
24, 2012 , (and supplements
Corrective Action(s): The inspectors concluded that the issue did not present an immediate
dated July
safety concern based on the licensee performing a sensitivity analysis to determine the
12, 2012, January 14, 2013, February
significance of monitoring at a higher level of unavailability via the maintenance rule. This
12, 2013, March
analysis determined an increase in core damage frequency for the additional unavailability
13, 2013, June
time that could be accrued above the assumption for availability in the fire probabilistic risk
13, 2013, December
assessment and up to the maintenance rule monitoring value for unavailability. The increase
12, 2013, January 17, 2014, February
in core damage frequency was determined to not exceed 1.0E-6/year.
18, 2014, and April
                                                    9
11, 2014), and as approved in the safety evaluation dated Apr
 
il 29, 2014."  The approved fire protection program is a risk
Corrective Action Reference(s): Condition Report CR-CNS-2016-05109
-informed performance
Performance Assessment:
-based program in accordance with NFPA
Performance Deficiency: The failure to adequately monitor unavailability of the plant
805, "Performance
components to ensure that the assumptions in the engineering analysis remained valid was a
-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
performance deficiency.
," which is incorporated by reference into  
Screening: The inspectors determined the performance deficiency was more than minor
10 CFR 50.48(c). NFPA
because if left uncorrected, it would have the potential to lead to a more significant safety
805, Section
concern. Specifically, the performance deficiency could adversely affect the acceptable level
2.6, "Monitoring," states that, "Monitoring shall ensure that the assumptions in the engineering analysis remain valid."
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
  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
the fire probabilistic risk assessment. This finding affects the Mitigating Systems
805 engineering analysis remained valid. Specifically, the licensee's monitoring program did not
Cornerstone.
monitor the availability of the  
Significance: The inspectors assessed the significance of the finding using NRC Inspection
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.
Manual Chapter 0609, Significance Determination Process, Attachment 4, Initial
  Disposition:
Characterization of Findings, dated October 7, 2016, as requiring significance determination
  This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
per Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process,
  The disposition of this finding and associated violation closes Unresolved Item 05000298/2016008
dated May 2, 2018, because the finding affected the ability to reach and maintain safe
-01. Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions Cornerstone
shutdown conditions in case of a fire. The inspectors categorized the finding as a post-fire
Significance
safe shutdown finding with a high degradation rating. The high degradation rating was made
Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000298/2018002-02 Closed [H.3] - Human Performance, Change Management
using Manual Chapter 0609, Appendix F, Attachment 2, Degradation Rating Guidance,
71111.18 - Plant Modifications
dated May 2, 2018, because the finding was not a minor procedural deficiency that was able
The inspectors identified a Green non
to be compensated by operators. Using step 1.4.7 of Attachment 1 of Appendix F, the finding
-cited violation of Technical Specification 5.4, "Procedures," when the licensee failed to maintain Procedure
was screened as a Green finding of very low safety significance in Question 1.4.7-C because
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
the fire finding did not adversely affect the ability to reach and maintain hot shutdown/hot
hours for completion of manual actions rather than the bounding 5.8
standby, or safe and stable conditions using the credited safe shutdown success path.
-hour allowance described in NEDC
Cross-cutting Aspect: This finding had a cross-cutting aspect associated with change
92-064. Description
management within the human performance area since the leaders failed to use a systematic
: On October
process for evaluating and implementing change so that nuclear safety remains the overriding
13, 2017, during routine maintenance activities for the service water booster pump (SWBP) fan coil unit (FCU), FC
priority. Specifically, the inspectors determined that the licensee did not use the process that
-C-1A, the licensee discovered a 5
was in place to ensure that the appropriate fire risk assessment monitoring action levels were
-10 gallon per minute (gpm) leak in the cooling coil. The licensee was using high pressure demineralize
incorporated into the maintenance rule program and monitored [H.3].
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
Enforcement:
isolated from the room. The SWBPs provide service water to the residual heat removal (RHR) heat exchange
Violation: License Condition 2.C.(4), Fire Protection, states, in part, Nebraska Public Power
rs during accident and shutdown cooling conditions. The operations crew determined that the SWBPs remained operable because Updated Safety Analysis  
District shall implement and maintain in effect all provisions of the approved fire protection
Report (USAR)
program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license
, 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
amendment request, dated April 24, 2012, (and supplements dated July 12, 2012,
2.3_R-1, "Panel R  
January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013,
- Annunciator R
January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety
-1 ," Revision 18. The inspectors reviewed Calculation NEDC
evaluation dated April 29, 2014.
92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision
The approved fire protection program is a risk-informed performance-based program in
3C2, and Calculation NEDC
accordance with NFPA 805, Performance-Based Standard for Fire Protection for Light Water
92-063, "Maximum SWBP Room Temperatures w/ No Cooling From Control Bldg HVAC," Revision
Reactor Electric Generating Plants, 2001 Edition, which is incorporated by reference into
1. These heat
10 CFR 50.48(c). NFPA 805, Section 2.6, Monitoring, states that, Monitoring shall ensure
-up
that the assumptions in the engineering analysis remain valid.
  12  calculations served as the basis for acceptability of the manual ventilation actions described in Alarm Procedure
                                                  10
2.3_R-1. NEDC 92-064 concluded that the required maximum design temperature for the SWBP room was 131
 
degrees Fahrenheit
Contrary to the above, from April 29, 2014, to June 5, 2018, the licensee failed to
(F). The calculation also concluded that with the FCU unavailable, once the SWBP room high temperature alarm was triggered at 120
appropriately monitor plant equipment to ensure that the assumptions in the NFPA 805
degrees F, the control room staff would enter Alarm Procedure
engineering analysis remained valid. Specifically, the licensees monitoring program did not
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
monitor the availability of the control rod drive pumps, core spray pumps, emergency diesel
-energize all instrument air compressors, secure all instrument air dryers, and secure all but one SWBP. The calculation also determined that  
generators, emergency station service transformer, startup station service transformer, high
station personnel would have 13
pressure core spray pump, instrument air compressors, residual heat removal pumps,
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.
standby liquid control pumps, and service water pumps to ensure that it was no lower than
  The inspectors also reviewed Alarm Procedure
the fire probabilistic risk assessment assumptions.
2.3_R-1, Revision
Disposition: This violation is being treated as a non-cited violation, consistent with
17 , and 50.59 Evaluation
Section 2.3.2 of the Enforcement Policy.
2013-04, "RHR SWBP FCU 50.59 Inadequate for USAR Change LCR
The disposition of this finding and associated violation closes Unresolved
93-10," Revision 0. Evaluation
Item 05000298/2016008-01.
2013-04 sought to prove through simulation that the associated manual actions could be completed within the limiting 5.8
Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual
hours that would be available during an event. This evaluation concluded that the activities could be completed in less than  
Actions
5 hours, and deemed the actions acceptable.  
Cornerstone             Significance                               Cross-cutting   Report
Upon review of Alarm Procedure
                                                                  Aspect           Section
2.3_R-1, the inspectors discovered that step
Mitigating             Green                                     [H.3] - Human   71111.18 -
1.3 of the procedure provided directions to secure heat loads in the room and establish natural ventilation through manual actions. However, prior to  
Systems                NCV 05000298/2018002-02                    Performance,    Plant
step 1.3, a procedure note stated, "NEDC
                        Closed                                    Change          Modifications
92-064 assumes that step
                                                                  Management
1.3 is complete within  
The inspectors identified a Green non-cited violation of Technical Specification 5.4,
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
Procedures, when the licensee failed to maintain Procedure 2.3_R-1 with the bounding time
hours, as  
restrictions for required manual ventilation actions identified in Engineering Evaluation
described by NEDC
NEDC 92-064, Transient Temperature Rise in SWBP Room After Loss of Cooling,
92-064, rather than the timeline of 13
Revision 3C2. As a result, the licensee relied on procedure guidance that contained an
hours that was based on the  
incorrect, less restrictive allowance of 13 hours for completion of manual actions rather than
nonconservative
the bounding 5.8-hour allowance described in NEDC 92-064.
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
Description: On October 13, 2017, during routine maintenance activities for the service water
21, 2017, the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified
booster pump (SWBP) fan coil unit (FCU), FC-C-1A, the licensee discovered a 5-10 gallon
in Engineering Evaluation NEDC
per minute (gpm) leak in the cooling coil. The licensee was using high pressure
92-064. In addition, prior to 2015, the procedure failed to contain any timeline restrictions, despite NEDC
demineralized water to flush the FCU when the leak initiated, and operations personnel took
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
action to isolate the coil. The fan coil unit is used to cool the SWBP room, which contains all
2015 procedure change introduced the nonconservative 13
four SWBPs, when power is lost to the site and nonessential ventilation is automatically
-hour timeline into Alarm Procedure
isolated from the room. The SWBPs provide service water to the residual heat removal
2.3_R-1. Corrective Action(s): The licensee implemented a revision to Alarm Procedure
(RHR) heat exchangers during accident and shutdown cooling conditions. The operations
2.3_R-1 to include the correct manual action required timelines. Corrective Action Reference(s): Condition Report  
crew determined that the SWBPs remained operable because Updated Safety Analysis
CR-CNS-2017-07601 Performance Assessment
Report (USAR), Section X-10.3.5.4, states that although the fan coil unit can be used to keep
:  Performance Deficiency: The licensee's failure to provide adequate guidance for restoring room cooling in Alarm Procedure
the room cool during an accident, acceptable room temperatures can be maintained for a
2.3_R-1 was a performance deficiency.
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
  13  Screening: The inspectors determined the performance deficiency was more than minor because it was associated with
operations crew also determined that these manual actions, which included rigging and
the procedure quality attribute of the  
removing three equipment hatches and opening three control building doors, were directed by
Mitigating  
Alarm Procedure 2.3_R-1, Panel R - Annunciator R-1, Revision 18.
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).
The inspectors reviewed Calculation NEDC 92-064, Transient Temperature Rise in SWBP
  Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapt
Room After Loss of Cooling, Revision 3C2, and Calculation NEDC 92-063, Maximum SWBP
er 0609, Appendix
Room Temperatures w/ No Cooling From Control Bldg HVAC, Revision 1. These heat-up
A, "The Significance Determination Process for Finding
                                                  11
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
calculations served as the basis for acceptability of the manual ventilation actions described
-significant nontechnical specification train.
in Alarm Procedure 2.3_R-1. NEDC 92-064 concluded that the required maximum design
  Cross-cutting Aspect: The inspectors determined that the finding had a cross
temperature for the SWBP room was 131 degrees Fahrenheit (F). The calculation also
-cutting aspect in the area of  
concluded that with the FCU unavailable, once the SWBP room high temperature alarm was
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]
triggered at 120 degrees F, the control room staff would enter Alarm Procedure 2.3_R-1, and
Enforcement
station personnel would have a limited amount of time to establish a natural ventilation path
:  Violation: Technical Specification
and secure excess heat loads in the room before operability of all four SWBPs was lost. The
5.4.1.a, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix
calculation determined that if two SWBPs were in service, station personnel would have
A of Regulatory Guide
5.8 hours to establish a ventilation path, secure all lighting, de-energize all instrument air
1.33, Revision
compressors, secure all instrument air dryers, and secure all but one SWBP. The calculation
2. Section
also determined that station personnel would have 13 hours to perform the same actions if
5 of Appendix
only one SWBP was in service during an accident scenario. The inspectors also noted that
A to Regulatory Guide 1.33, Revision
emergency operating procedures directed control room staff to operate all available
2, requires, "Procedures for Abnormal, Offnormal, or Alarm Conditions."  The licensee established Alarm Procedure
suppression pool cooling during accident conditions, which made operation of two SWBPs a
2.3_R-1, "Panel R  
very likely scenario during an accident.
- Annunciator R
The inspectors also reviewed Alarm Procedure 2.3_R-1, Revision 17, and 50.59
-1," Revision 17, to meet the Regulatory Guide
Evaluation 2013-04, RHR SWBP FCU 50.59 Inadequate for USAR Change LCR 93-10,
1.33 requirement
Revision 0. Evaluation 2013-04 sought to prove through simulation that the associated
.  Contrary to the above, prior to December
manual actions could be completed within the limiting 5.8 hours that would be available
21, 2017, the licensee failed to maintain adequate written procedures
during an event. This evaluation concluded that the activities could be completed in less than
for abnormal, offnormal, or alarm conditions.
5 hours, and deemed the actions acceptable. Upon review of Alarm Procedure 2.3_R-1, the
  Specifically, the licensee failed to maintain Alarm Procedure
inspectors discovered that step 1.3 of the procedure provided directions to secure heat loads
2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC
in the room and establish natural ventilation through manual actions. However, prior to
92-064, "Transient Temperature Rise in SWBP Room After Loss of Cooling," Revision
step 1.3, a procedure note stated, NEDC 92-064 assumes that step 1.3 is complete within
3C2. Disposition: This violation is being treated as a
13 hours of receiving RHR SWBP ROOM high temperature alarm. The inspectors
n on-cited violation, consistent with  
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 licensees failure to provide adequate guidance for restoring
room cooling in Alarm Procedure 2.3_R-1 was a performance deficiency.
                                                12
 
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.
Section 2.3.2 of the Enforcement Policy.
             
                                                  13
  14  Failure to Maintain Adequate Work Instructions for Traversing In
 
-Core Probe System Limit Switches Cornerstone
Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit
Significance
Switches
Cross-cutting Aspect Report Section Barrier Integrity
Cornerstone             Significance                             Cross-cutting     Report
Green NCV 05000298/2018002
                                                                  Aspect             Section
-03 Closed None 71153 - Follow-up of Events and Notices of Enforcement Discretion
Barrier Integrity       Green                                    None              71153 -
A self-revealed, Green, non
                        NCV 05000298/2018002-03                                     Follow-up of
-cited violation of Technical Specification 5.4, "Procedures," was identified when t
                        Closed                                                      Events and
he licensee failed to maintain Procedure
                                                                                    Notices of
14.2.14, "TIP Chamber Shield Maintenance," with adequate instructions for reinstalling the traversing in
                                                                                    Enforcement
-core probe system  
                                                                                    Discretion
in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves
A self-revealed, Green, non-cited violation of Technical Specification 5.4, Procedures, was
. Description
identified when the licensee failed to maintain Procedure 14.2.14, TIP Chamber Shield
: On June 21, 2017, during operation of the traversing in
Maintenance, with adequate instructions for reinstalling the traversing in-core probe system
-core probe (TIP) system, the C probe failed to stop at the correct "in
in-shield limit switches. As a result, the licensee experienced multiple failures of the shield
-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
limit switches resulting in inoperable primary containment isolation valves.
-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.
Description: On June 21, 2017, during operation of the traversing in-core probe (TIP) system,
  The switches had been removed and reinstalled during performance of Procedure
the C probe failed to stop at the correct in-shield position during withdrawal of the probe
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.
from the core. The probe is designed to stop when the limit switch is activated. While the
  Corrective Action(s):
limit switch is not activated, the associated containment isolation ball valve is blocked from
  The licensee implemented a revision to Procedure
automatic and manual operation. The licensee declared the valve inoperable. Subsequently,
14.2.14 to include a description of the vendor specified mounting configuration and a requirement to apply a minimum torque to the bolts.
on June 22, 2017, the D probe failed to stop at the in-shield position during withdrawal. The
  Corrective Action Reference(s): Condition Report  
licensee declared the D containment isolation ball valve inoperable. The licensee determined
CR-CNS-2017-0003 9 Performance Assessment
that the cause of the failures was that the limit switches had become loose due to inadequate
:  Performance Deficiency: The licensee's failure to provide adequate guidance for maintenance on the TIP system was a performance deficiency.
mounting of the switches to the chamber shields. The design drawing for the system
  Screening: The inspectors determined the performance deficiency was more than minor  
indicated that the switches were to be mounted using bolts and washers, but the licensee
because it was associated with
identified that some mounting bolts did not have washers installed.
the procedure quality attribute of the Barrier Integrity
The switches had been removed and reinstalled during performance of Procedure 14.2.14,
Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and  
TIP Chamber Shield Maintenance, Revision 12, as part of the maintenance of the system.
containment) protect the public from radionuclide releases caused by accidents or events
The procedures did not specify the method for reinstalling the switches. The licensee found
.  Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter
that the vendor drawing specified the use of washers.
0609, Appendix
Corrective Action(s): The licensee implemented a revision to Procedure 14.2.14 to include a
A, "The Significance Determination Process for Finding s 
description of the vendor specified mounting configuration and a requirement to apply a
  15 At-Power."  Using Exhibit
minimum torque to the bolts.
3 , "Barrier Integrity
Corrective Action Reference(s): Condition Report CR-CNS-2017-00039
Screening Questions," the finding was screened as having very low safety significance (Green) because the finding
Performance Assessment:
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
Performance Deficiency: The licensees failure to provide adequate guidance for
. Cross-cutting Aspect: No cross-cutting aspect was assigned
maintenance on the TIP system was a performance deficiency.
to this finding
Screening: The inspectors determined the performance deficiency was more than minor
  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.
because it was associated with the procedure quality attribute of the Barrier Integrity
  Enforcement
Cornerstone and adversely affected the cornerstone objective to provide reasonable
: Violation: Technical Specification
assurance that physical design barriers (fuel cladding, reactor coolant system, and
5.4.1.a, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix
containment) protect the public from radionuclide releases caused by accidents or events.
A of Regulatory Guide 1.33, Revision
Significance: The inspectors assessed the significance of the finding using Inspection
2. Appendix
Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings
A to Regulatory Guide
                                                14
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
  At-Power. Using Exhibit 3, Barrier Integrity Screening Questions, the finding was screened
appropriate to the circumstances.
as having very low safety significance (Green) because the finding did not represent an actual
  The licensee established Procedure
open pathway in the physical integrity of reactor containment (valves, airlocks, etc.),
14.2.14, "TIP Chamber Shield Maintenance," Revision
containment isolation system (logic and instrumentation), and heat removal components, and
12, to meet the Regulatory Guide
did not involve hydrogen igniters.
1.33 requirement
  Cross-cutting Aspect: No cross-cutting aspect was assigned to this finding because the
. Contrary to the above, prior to July
  inspectors determined that since the last revision of the procedure was more than three years
5 , 2017, the licensee failed to
ago, the finding did not reflect present licensee performance.
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
  Enforcement:
14.2.4, "TIP Chamber Shield  
  Violation: Technical Specification 5.4.1.a, requires, in part, that written procedures shall be
Maintenance
established, implemented, and maintained covering the applicable procedures recommended
." Disposition:
in Appendix A of Regulatory Guide 1.33, Revision 2. Appendix A to Regulatory Guide 1.33,
  This violation is being treated as a
Revision 2, Section 9, Procedures for Performing Maintenance, requires, in part, that
n on-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
maintenance that can affect the performance of safety-related equipment should be properly
  The disposition of this finding and associated violation closes Licensee Event Report (LER) 05000298/2017
pre-planned and performed in accordance with written procedures, documented instructions,
-005-00, Traversing In
or drawings appropriate to the circumstances. The licensee established Procedure 14.2.14,
-core Probe In
TIP Chamber Shield Maintenance, Revision 12, to meet the Regulatory Guide 1.33
-shield Limit Switch Mounting Failure Results in Common Cause Inoperability of Independent Trains or Channels and Condition Prohibited by Technical Specifications
requirement.
(ADAMS Accession No.
  Contrary to the above, prior to July 5, 2017, the licensee failed to establish adequate written
ML17236A166).
procedures appropriate to the circumstances for performing maintenance that can affect the
  EXIT MEETIN
performance of safety related equipment. Specifically, the licensee failed to provide
GS AND DEBRIEFS
instructions appropriate to the circumstances for Procedure 14.2.4, TIP Chamber Shield
The inspectors verified no proprietary information was retained or documented in this report
Maintenance.
.  On July 12, 2018, the inspector presented the
  Disposition: This violation is being treated as a non-cited violation, consistent with
quarterly resident inspector
Section 2.3.2 of the Enforcement Policy.
inspection results to Mr. K. Dia , Acting Vice President
The disposition of this finding and associated violation closes Licensee Event Report
-Nuclear and CNO, and other members of the licensee staff.
(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
  Attachment
Condition Prohibited by Technical Specifications (ADAMS Accession No. ML17236A166).
1 DOCUMENTS REVIEWED
EXIT MEETINGS AND DEBRIEFS
71111.01-Adverse Weather Protection
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.
                                                15
 
DOCUMENTS REVIEWED
71111.01Adverse Weather Protection
  Miscellaneous Documents
  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
  Number           Title                                                     Revision
  9 NC43456 Cooper 161
                  Interface Operating Agreement between Nebraska Public     9
kV Substation One
                  Power District Operations Business Unit and Nebraska
-Line Switching Diagram
                  Public Power District Nuclear Power Group Business Unit
  13 NC66688 Cooper 345
  NC43456         Cooper 161 kV Substation One-Line Switching Diagram       13
kV Substation One
  NC66688         Cooper 345 kV Substation One-Line Switching Diagram       23
-Line Switching Diagram
  Procedures
23 Procedures
  Number           Title                                                     Revision
  Number Title Revision 0-CNS-52 Control of Switchyard and Transformer Yard Activities at  
0-CNS-52         Control of Switchyard and Transformer Yard Activities at 32
CNS 32 Work Orders
                  CNS
  5196728     71111.04-Equipment Alignment
  Work Orders
  5196728
71111.04Equipment Alignment
  Miscellaneous Documents
  Miscellaneous Documents
  Number Title Revision 2040 Flow Diagram Residual Heat Removal System
  Number           Title                                                     Revision
  N82 2043 Flow Diagram Reactor Core Isolation Coolant and Reactor Feed Systems
2040             Flow Diagram Residual Heat Removal System                 N82
  56 2044 Flow Diagram High Pressure Coolant Injection and Reactor Feed Systems
  2043             Flow Diagram Reactor Core Isolation Coolant and Reactor   56
  75 Procedures
                  Feed Systems
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 
  2044             Flow Diagram High Pressure Coolant Injection and Reactor  75
  A1-2  Procedures
                  Feed Systems
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
  Procedures
  Number Title Revision 6.HPCI.103
  Number             Title                                                   Revision
HPCI IS and 92 Day Test Mode
2.2.33A            High Pressure Coolant Injection System Component        30
  55 0-Barrier Flooding Barriers
                    Checklist
24
2.2.33B            High Pressure Coolant Injection System Instrument Valve 8
  A1-3 Procedures
                    Checklist
  Number Title Revision 2.2.33A High Pressure Coolant Injection System Component Checklist 30 Condition Reports (CR
2.2.67A            Reactor Core Isolation Cooling System Component        22
-CNS-) 2018-02403     71111.11-Licensed Operator Requalification Program and Licensed Operator Performance
                    Checklist
                                                                              Attachment 1
 
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
                                          A1-2
 
  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
  Miscellaneous Documents
  Number Title Revision SKL05151245
  Number           Title                                                   Revision
  CRD Pump Trip, Drifting Rods, ATWS, Loss of Level Indication, EOP 7B RPV Flooding
  SKL05151245      CRD Pump Trip, Drifting Rods, ATWS, Loss of Level       3
3 Procedures
                  Indication, EOP 7B RPV Flooding
  Number Title Revision 2.1.4 Normal Shutdown
  Procedures
  160 2.2.28.1 Feedwater System Operation
  Number           Title                                                   Revision
95 Condition Reports (CR
2.1.4             Normal Shutdown                                         160
-CNS-) 2018-03326     71111.12-Maintenance Effectiveness
  2.2.28.1         Feedwater System Operation                               95
  Condition Reports (CR-CNS-)
2018-03326
71111.12Maintenance Effectiveness
  Miscellaneous Documents
  Miscellaneous Documents
  Number Title Revision Maintenance Rule Function HV
  Number           Title                                                   Revision
-F02 Performance Criteria Basis 4 11414213 Notification
                  Maintenance Rule Function HV-F02 Performance Criteria   4
  Condition Reports (CR
                  Basis
-CNS-) 2016-02434 2016-08539 2017-00039 2017-06120  Work Orders
11414213         Notification
  5166424 5214101    
Condition Reports (CR-CNS-)
  A1-4  71111.13-Maintenance Risk Assessments and Emergent Work Control
2016-02434             2016-08539             2017-00039           2017-06120
  Work Orders
  5166424           5214101
                                            A1-3
 
71111.13Maintenance Risk Assessments and Emergent Work Control
  Miscellaneous Documents
  Miscellaneous Documents
  Number Title Revision/Date D Drywell Fan Coil Unit Operational Decision Making Issue
  Number           Title                                                         Revision/Date
0  Drywell Fan Coil Unit
                  D Drywell Fan Coil Unit Operational Decision Making Issue     0
D Failure, Week
                  Drywell Fan Coil Unit D Failure, Week 1819 Protected         May 11, 2018
1819 Protected Equipment Program Tracking Form
                  Equipment Program Tracking Form
May 11, 2018
                  HPCI Remain in Service List
  HPCI Remain in Service List
                  HPCI Window, Week 1816 Protected Equipment Program           April 16, 2018
  HPCI Window, Week 1816 Protected Equipment Program Tracking Form
                  Tracking Form
April 16, 2018
  Calc NEDC 89-     Review of EAS Calculation                                     4
  Calc NEDC 89
1234
-1234 Review of EAS Calculation
  Calc NEDC 91-     Limiting Conditions Analysis for 18 Tricentric Valves       0
  4 Calc NEDC 91
  253G
-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
  Procedures
  Number Title Revision 2.1.11.1 Turbine Building Data
  Number           Title                                                         Revision
  167 2.2.20 Standby AC Power System (Diesel Generator)
0-CNS-WM-        On-Line Fire Risk Management Actions                          4
99
104A
  A1-5 Procedures
2.1.4            Normal Shutdown                                              160
  Number Title Revision 14.17.4 DG-2 System Instrument Calibration
2.2.71            Service Water System                                          123
  25 6.HPCI.103
6.2EE.602        Div 2 125V/250V Station Battery 92 Day Check                  6
HPCI IS and 92 Day Test Mode
6.2SW.101        Service Water Surveillance Operation (Div 2) (IST)            53
  55 0-Barrier Flooding Barriers
Condition Reports (CR-CNS-)
  24 2.2.33A High Pressure Coolant Injection System Component Checklist 30 Condition Reports (CR
2018-02373              2018-02375              2018-02377              2018-02378
-CNS-) 2 018-02364 2018-02413 2018-02426 2018-02427 2018-02492 2018-03294 2018-03341 2018-03365 2018-03388 2018-2403   Work Orders
2018-02380              2012-06509
  5169626 5244135     71111.18-Plant Modifications
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
                                            A1-4
 
  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
  Miscellaneous Documents
  Number Title Revision EC 6040480
  Number           Title                                                       Revision
SWBP Oil Sight Glasses and Reservoir  
EC 6040480       SWBP Oil Sight Glasses and Reservoir - and ECNs 1- 5         0
- and ECNs 1
ER 2017-036       Seismic Test Report for Oil-Rite Constant Level Oiler       0
- 5 0 ER 2017-036 Seismic Test Report for Oil
  Condition Reports (CR-CNS-)
-Rite Constant Level Oiler
2018-02091             2018-02148             2018-02412             2018-02565
0 Condition Reports (CR
71111.19Post Maintenance Testing
-CNS-) 2018-02091 2018-02148 2018-02412 2018-02565 71111.19-Post Maintenance Testing
  Miscellaneous Documents
  Miscellaneous Documents
  Number Title Revision NEDC 10-027 Drywell MOV Backseat Limits
  Number           Title                                                       Revision
  1 NEDC 95-003 Determination of Allowable Operating Parameters for CNS MOV Program MOVs
NEDC 10-027       Drywell MOV Backseat Limits                                 1
  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   
  NEDC 95-003       Determination of Allowable Operating Parameters for CNS     32
  A1-6  Procedures
                  MOV Program MOVs
  Number Title Revision 6.HPCI.201
  730E197BB         Elementary Diagram Variable Speed Recirc Pump and MG         19
HPCI Valve Operability Test (IST)
Sheet 3          Set
  26 6.1SW.101 Service Water Surveillance Operation (Div
730E197BB         Elementary Diagram Variable Speed Recirc Pump and MG         28
1)(IST) 52  Work Orders
  Sheet 8          Set
  5077619 5122033 5233022 5249662   71111.22-Surveillance Testing
                                            A1-5
 
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
  Miscellaneous Documents
  Number Title Revision Calc NEDC 89
  Number           Title                                                       Revision
-1234 Review of EAS Calculation
Calc NEDC 89-     Review of EAS Calculation                                   4
  4 Calc NEDC 91
1234
-253G Limiting Conditions Analysis for 18" Tricentric Valves
  Calc NEDC 91-     Limiting Conditions Analysis for 18 Tricentric Valves     0
  0 Procedures
  253G
  Number Title Revision 2.1.11.2 Reactor Building Data
  Procedures
  68 2.2.71 Service Water System
  Number           Title                                                       Revision
  123 6.1CS.101 Core Spray Test Mode Surveillance Operation (IST) (Div
2.1.11.2         Reactor Building Data                                       68
1) 30 6.1RR.302 Reactor Recirculation Flow Unit Channel Calibration (Div
  2.2.71           Service Water System                                       123
1) 38 6.2SW.101 Service Water Surveillance Operation (IST) (Div
  6.1CS.101         Core Spray Test Mode Surveillance Operation (IST) (Div 1)   30
2) 53  Condition Reports (CR
6.1RR.302         Reactor Recirculation Flow Unit Channel Calibration (Div 1) 38
-CNS-) 2018-03674     Work Orders
6.2SW.101         Service Water Surveillance Operation (IST) (Div 2)         53
  5134630 5147404     71151-Performance Indicator Verification
  Condition Reports (CR-CNS-)
2018-03674
Work Orders
  5134630           5147404
71151Performance Indicator Verification
  Miscellaneous Documents
  Miscellaneous Documents
  Number Title Revision/Date Operations Instruction 17, Daily Report
  Number           Title                                                       Revision/Date
47
                  Operations Instruction 17, Daily Report                     47
  A1-7  Miscellaneous Documents
                                            A1-6
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
  Miscellaneous Documents
  Number Title Date 846D931 Chamber Shield
  Number           Title                                                   Revision/Date
February 4, 1966  Procedures
                  RCS Activity PI Data                                    January 2017
  Number Title Revision 14.2.14 TIP Chamber Shield Maintenance
                                                                            - March 2018
12 Condition Reports (CR
                  RCS Leakage PI Data                                      January 2017
-CNS-) 2017-00039 2017-03764 2017-03790 2017-03982  Work Orders
                                                                            - March 2018
  5175552      
NEI 99-02        Regulatory Assessment Performance Indicator Guideline    7
  Attachment
Procedures
2 NRC Request
Number            Title                                                    Revision
for Information
6.LOG.601        Daily Surveillance Log - Modes 1, 2, and 3              132
  System: High Pressure Coolant Injection
Condition Reports (CR-CNS-)
  CD Date Requested by: April 2, 2018
2018-02134              2018-02571            2018-02592          2018-02657
  Date Range of Document Request
2018-02679              2018-02700            2018-02860
: March 31, 2016
71153Follow-up of Events and Notices of Enforcement Discretion
- Current Please provide the following documents
Miscellaneous Documents
:    1. Copies of all root and apparent cause evaluations performed on this system.
Number            Title                                                    Date
    2. Summary list of all condition reports written on this system, sorted by CR classification
846D931           Chamber Shield                                           February 4,
  3. List of all surveillances performed on this system, sortable by component if possible.
                                                                            1966
  4. Provide copies of the three most recently completed quarterly surveillances
  Procedures
  5. List of all corrective maintenance work orders, with description of work, performed on this
  Number           Title                                                   Revision
system   6. Provide a list of control room deficiencies associated with this system
14.2.14           TIP Chamber Shield Maintenance                           12
  7. Copies of ODMI's, OWA/OWB's, prompt operability evaluations, and standing orders associated with this system
  Condition Reports (CR-CNS-)
  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  
2017-00039             2017-03764             2017-03790           2017-03982
- regardless of their result); and any MRule Basis Document(s) for the system
  Work Orders
  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
  5175552
  11. System design calculations  
                                            A1-7
  12. Provide fire impairments associated with this system
 
  13. Provide copies of any QA audits or self
                          NRC Request for Information
-assessments associated with this system
System: High Pressure Coolant Injection
  14. Copies of vendor manuals, drawings (P&ID's), and system training manuals
CD Date Requested by: April 2, 2018
  15. System health reports and system engineering logs for this system
Date Range of Document Request: March 31, 2016 - Current
 
Please provide the following documents:
  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
1. Copies of all root and apparent cause evaluations performed on this system.
  17. Schedule of activities (Fragnet) for the planned AOT for HPCI scheduled for the work week
2. Summary list of all condition reports written on this system, sorted by CR classification
of 1 816.  
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
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&IDs), and system training manuals
15. System health reports and system engineering logs for this system
                                                                                      Attachment 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 1816.
                                                A2-2




  ML18206A216
  ML18206A216
  SUNSI Review
  SUNSI Review           Non-Sensitive            Publicly Available          Keyword:
  By: JWK/rdr Non-Sensitive  Sensitive Publicly Available
  By: JWK/rdr               Sensitive                 Non-Publicly Available     NRC-002
  Non-Publicly Available
OFFICE       ASRI:DRP/C ASRI:DRP/C       RI:DRP/C BC:DRS/EB1       BC:DRS/EB2   BC:DRS/OB
Keyword: NRC-002 OFFICE ASRI:DRP/C
NAME           MTobin   RKumana         MStafford TFarnholtz         JDrake      VGaddy
ASRI:DRP/C
  SIGNATURE         /RA/       /RA/           /RA/       /RA/             /RA/       /RA/
RI:DRP/C BC:DRS/EB1
DATE           7/11/2018 7/12/2018       7/12/2018   7/16/2018       7/16/2018   7/12/2018
BC:DRS/EB2
OFFICE       BC:DRS/PSB2 TL:DRS/IPAT     SPE:DRP/C   BC:DRP/C
BC:DRS/OB NAME MTobin RKumana MStafford TFarnholtz
NAME           HGepford   GGeorge         CYoung       JKozal
  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
SIGNATURE         /RA/       /RA/           /RA/       /RA/
TL:DRS/IPAT
DATE           7/12/2018 7/12/2018       7/10/2018   7/25/2018
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
}}
}}

Latest revision as of 20:47, 20 October 2019

NRC Integrated Inspection Report 05000298/2018002
ML18206A216
Person / Time
Site: Cooper Entergy icon.png
Issue date: 07/25/2018
From: Jason Kozal
NRC/RGN-IV/DRP/RPB-C
To: Dent J
Nebraska Public Power District (NPPD)
Kozal J
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

05000298/2018002

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

violations 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

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 Set Performance Monitoring Action Levels to Ensure that the Assumptions in the

Engineering Analysis Remain Valid

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.3] - Human 71111.05XT

Systems NCV 05000298/2018002-01 Performance, - Fire

Closed Change Protection -

Management 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 Report

Aspect Section

Mitigating Green [H.3] - Human 71111.18 -

Systems NCV 05000298/2018002-02 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.

2

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 05000298/2018002-03 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

URI 05000298/2016008-01 Possible Failure to Ensure that 71111.05XT Closed

the Assumptions in the

Engineering Analysis Remain

Valid

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

3

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 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

71111.01Adverse 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.

71111.04Equipment 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 on June 28, 2018.

4

71111.05QFire 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

71111.05XTFire Protection - NFPA 805 (Triennial)

The inspectors reviewed the licensees 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.

71111.06Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the high pressure coolant

injection room on June 26, 2018.

71111.11Licensed 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.

71111.12Maintenance 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

5

71111.13Maintenance 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

71111.15Operability 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

71111.18Plant 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

71111.19Post 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

71111.20Refueling and Other Outage Activities (1 Sample)

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

June 11, 2018.

6

71111.22Surveillance 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

71114.06Drill Evaluation

Emergency Planning Drill (1 Sample)

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

OTHER ACTIVITIES - BASELINE

71151Performance 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)

71152Problem Identification and Resolution

Semiannual Trend Review (1 Sample)

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

7

71153Follow-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) 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 Set Performance Monitoring Action Levels to Ensure that the Assumptions in the

Engineering Analysis Remain Valid

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Systems Green [H.3] - Human 71111.05XT

NCV 05000298/2018002-01 Performance, - Fire

Closed Change Protection -

Management 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 Management System

(ADAMS) Accession No. ML16270A561)), the inspectors reviewed the licensees

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:

8

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 licensees 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:

  • Emergency station service transformer
  • Startup station service transformer
  • Instrument air compressors

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 NRCs 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.

9

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 April 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.

10

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 licensees 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 Report

Aspect Section

Mitigating Green [H.3] - Human 71111.18 -

Systems NCV 05000298/2018002-02 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 gallon

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

11

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.

12

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.

13

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 05000298/2018002-03 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

14

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 CNO, and other members of the licensee staff.

15

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

Attachment 1

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

A1-2

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

A1-3

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

1234

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

A1-4

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

A1-5

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

1234

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

A1-6

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

A1-7

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

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&IDs), and system training manuals

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

Attachment 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 1816.

A2-2

ML18206A216

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: JWK/rdr Sensitive Non-Publicly Available 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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