ML18206A216
| ML18206A216 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| 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) | |
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
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:
- Control rod drive pumps
- Core spray pumps
- Emergency station service transformer
- Startup station service transformer
- Instrument air compressors
- Residual heat removal pumps
- Standby liquid control pumps
- Service water pumps
The inspectors noted that the action levels for availability in the maintenance rule monitoring
program were greater than the assumptions in the fire probabilistic risk assessment and
questioned whether this met the requirement in NFPA 805 to maintain the assumptions in the
engineering analysis.
Clarifications of the monitoring program requirements were being discussed between the
industry and the 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
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
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
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