IR 05000298/2018003

NRC Integrated Inspection Report 05000298/2018003

ML18304A484
Person / Time
Site:	Cooper
Issue date:	10/31/2018
From:	Jason Kozal NRC/RGN-IV/DRP
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2018003
Download: ML18304A484 (34)

Text

ber 31, 2018

SUBJECT:

COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000298/2018003

Dear Mr. Dent:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. On October 17, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

One of these findings involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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, or a finding not associated with a regulatory requirement 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. 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 05000298/2018003 w/Attachment: Documents Reviewed

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s): 05000298 License Number(s): DPR-46 Report Number(s): 05000298/2018003 Enterprise Identifier: I-2018-003-0003 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, Nebraska Inspection Dates: July 1, 2018 to September 30, 2018 Inspectors: P. Vossmar, Senior Resident Inspector M. Tobin, Acting Senior Resident Inspector M. Stafford, Resident Inspector J. Ambrosini, Senior Emergency Preparedness Inspector, R-I R. Azua, Senior Reactor Inspector W. Cullum, Reactor Engineer P. Elkmann, Senior Emergency Preparedness Inspector D. Johnson, Senior Emergency Preparedness Specialist, NSIR J. Kirkland, Senior Operations Engineer C. Stott, Reactor Engineer Approved By: Jason W. 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 findings and violations are summarized in the tables below.

List of Findings and Violations Failure to Provide Complete and Accurate Information in a License Amendment Request Cornerstone Significance Cross-cutting Inspection Aspect Procedure Not Severity Level IV Not 71114.01 -

Applicable NCV 05000298/2018003-01 Applicable Exercise Closed Evaluation The inspectors identified that the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that was not accurate.

Failure to Perform Process Applicability Determination Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.5 - Work 71152 -

Systems NCV 05000298/2018003-02 Management Problem Closed Identification and Resolution The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the licensees failure to follow Administrative Procedure 0.9, Tagout,

Revision 88, for performing a monthly audit and Process Applicability Determination.

Specifically, the inspectors noted that a clearance order on the safety-related residual heat removal service water booster pump room fan coil unit was hanging for greater than 90 days with no Process Applicability Determination performed, which resulted in the power switch for the fan coil unit being unintentionally tagged out of its normal configuration for almost 2 years.

Failure to Provide Adequate Lubrication for Drywell Fan Coil Units Cornerstone Significance Cross-cutting Inspection Aspect Procedure Initiating Green H.5 - Work 71152 -

Events FIN 05000298/2018003-03 Management Problem Closed Identification and Resolution The inspectors reviewed a Green, self-revealed finding for the licensees failure to implement Work Order 5060136 during maintenance on the drywell fan coil units. Specifically, on October 26, 2016, during bearing replacement work on drywell fan coil, unit D, maintenance personnel failed to properly reinstall auto-lubricator injection connectors after removing the interferences per the work order instructions. This error resulted in the failure of fan coil, unit D, due to inadequate bearing lubrication and ultimately led to a downpower and reactor shutdown.

PLANT STATUS

Cooper Nuclear Station began the inspection period at rated thermal power. On August 24, 2018, the plant commenced power coast down and on September 29, 2018, the licensee shut the plant down for Refueling Outage

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

71111.04Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Protected area fire protection distribution on July 27, 2018

(2) Startup station service transformer during emergency station service transformer bus replacement on August 9, 2018

(3) Core spray B following maintenance on August 15, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the residual heat removal system on September 14, 2018.

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Standby gas treatment room, Fire Area RB-V, Zone 5B, on August 6, 2018

(2) Reactor building southeast quad, Fire Area RB-B, Zones 1B and 1G, on August 15, 2018

(3) Optimum water chemistry building, Fire Area YD, Zone 26, on August 24, 2018

(4) Reactor building northeast 903 foot level, Fire Area RB-FN, Zone 2A-1, on September 11, 2018

(5) Reactor building northwest 903 foot level, Fire Area RB-CF, Zones 2A-2 and 2B, on

September 11, 2018 Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance on March 30, 2018, and August 23, 2018.

71111.06Flood Protection Measures Cables

The inspectors evaluated cable submergence protection in:

(1) Manhole 6A on July 18, 2018

71111.07Heat Sink Performance Heat Sink (Triennial)

The inspectors evaluated exchanger/sink performance on the following components from August 20, 2018, to August 23, 2018:

(1) Residual heat removal heat exchanger B, cooled by service water, Section 02.02b

(2) Reactor equipment cooling heat exchanger B, cooled by service water, Section 02.02b

(3) Emergency diesel generator 1 jacket water heat exchanger, cooled by service water, Section 02.02b

(4) Emergency diesel generator 1 intercooler A, cooled by service water, Section 02.02b

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated training scenarios in the simulator on

===August 28, 2018.

Operator Performance (1 Sample)===

The inspectors observed and evaluated plant shutdown for Refueling Outage 30 on

===September 29, 2018.

Operator Exams (1 Sample)===

The inspectors reviewed and evaluated requalification examination results on August 15, 2018.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

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

(1) Drywell fan coil Unit A on August 24, 2018

(2) Core spray system on September 28, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) New fuel receipt inspections on July, 27, 2018

(2) Emergency station service transformer replacement on August 10, 2018

(3) Core spray B valve maintenance on August 15, 2018

(4) Residual heat removal A maintenance window on September 5, 2018

(5) Reactor recirculation M-G set A generator brushes arcing on September 13, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Reactor core flow indication issues on July 24, 2018

(2) Mechanical remote operating station hardened vent control structure design discrepancy on August 3, 2018

(3) Residual heat removal service water 18-inch pipe elbow found below bounding 20-inch pipe minimum thickness requirement on September 11, 2018

(4) Residual heat removal service water B pipe SW-E-10-2851-3 found below minimum wall thickness on September 28, 2018

(5) Residual heat removal service water B pipe SW-E-8-2851-3 found below minimum wall thickness on September 28, 2018

(6) Residual heat removal service water B pipe SW-E-7-2851-7 found below minimum wall thickness on September 28, 2018

71111.18Plant Modifications

The inspectors evaluated the following temporary modification:

(1) Voltage regulator temporary modification to address manual controller failure on August 16, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Core spray A following maintenance on August 1, 2018

(2) Emergency diesel generator compressor 2B replacement on August 10, 2018

(3) Phase 1 of planned emergency station service transformer bus replacement on August 10, 2018

(4) Emergency station service transformer bus corona and moisture repairs on August 10, 2018

(5) Core spray B following maintenance on August 15, 2018

===71111.20Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Refueling Outage 30 activities from September 29, 2018, to September 30, 2018. The inspectors completed inspection procedure Sections 03.01.a and 03.01.c.1.

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine ===

(1) Alternate rod insertion instrumentation and control surveillance on July 5, 2018

(2) Emergency diesel generator 2 monthly surveillance run on September 11, 2018

(3) High pressure coolant injection steam line low pressure logic system functional test on

September 29, 2018 In-service (1 Sample)

(1) Standby liquid control pump operability test and discharge check valve radiography on September 27, 2018

71114.01Exercise Evaluation

The inspectors evaluated the biennial emergency plan exercise conducted July 31, 2018.

The exercise simulated a fire in the reactor building, a failure on the turbine requiring a manual reactor scram followed by a failure of the reactor protection system to bring the reactor to shutdown (anticipated transients without scram), failures preventing emergency response personnel access to the reactor building, multiple failures of safety relief valves to operate when required, and a pipe break on the high pressure core injection line with a failure of the inboard isolation valve to close. A filtered and monitored radiological release was simulated to occur from the ruptured pipe through the reactor building standby gas treatment system. A wind shift after the General Emergency required the emergency response personnel to develop a second protective action recommendation. The inspectors discussed exercise performance with staff at Federal Emergency Management Agency (FEMA) Region VII.

71114.08Exercise Evaluation - Scenario Review

The inspectors reviewed and evaluated the proposed scenario for the July 31, 2018, biennial emergency plan exercise on June 21, 2018. The inspectors discussed the proposed scenario with staff at FEMA Region VII.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) IE04: Unplanned Scrams with Complications (USwC) Sample (07/01/2017-06/30/2018)

(2) EP01: Drill/Exercise Performance (DEP) Sample (04/01/2017-06/30/2018)

(3) EP02: Emergency Response Organization (ERO) Drill Participation Sample (04/01/2017-06/30/2018)

(4) EP03: Alert And Notification System (ANS) Reliability Sample (04/01/2017-06/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends in station human performance and risk recognition that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (2 Samples)

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

(1) Drywell fan coil unit bearing failures on September 14, 2018

(2) Service water booster pump fan coil unit tagged out for an extended period on September 21,

INSPECTION RESULTS

Failure to Provide Complete and Accurate Information in a License Amendment Request Cornerstone Significance Cross-cutting Inspection Aspect Procedure Not Applicable Severity Level IV Not Applicable

71114.01 - NCV 5000298/2018003-01 Exercise Closed

Evaluation The inspectors identified that the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that was not accurate.

Description:

The NRC approved an emergency action level (EAL) scheme on February 23, 2010, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML100080231), which included changes to emergency action levels AU1.2 and AA1.2. The Unusual Event threshold was 2 times the calculated alarm value for a liquid release, the Alert threshold was 200 times the calculated alarm value. Liquid release alarm setpoints are variable and calculated using methods detailed in the licensees Offsite Dose Assessment Manual. The maximum permissible alarm value was 0.099 µCi/ml on the liquid radwaste effluent monitor, with the maximum instrument range being 0.100 µCi/ml.

The licensee identified on October 26, 2010, that there were no controls in place to ensure that two times and two hundred times the calculated alarm value could be read on the liquid radwaste effluent monitor. Therefore, the licensee could not ensure that emergency action levels AU1.2 and AA1.2 would be accurately implemented when conditions warranted for any specific release package. This was documented in Condition Report CR-CNS-2010-07974.

The inspectors reviewed the licensees license amendment request dated February 26, 2009 (ADAMS Accession No. ML090700408), and the licensees response to a request for additional information dated September 24, 2009 (ADAMS Accession No. ML092750402) to determine whether the conditions identified in the corrective action program existed at the time the licensee requested the license amendment and whether the request correctly described the instrument responses. The inspectors determined that the licensee was requested to affirm in the request for additional information that all instruments referenced in the license amendment request were capable of measuring the parameter values provided in the proposed emergency action levels. The licensee responded on September 24, 2009, that all instruments were capable of measuring the values proposed in the emergency action levels, including the radiation monitors.

Corrective Action: The licensee made a change to the emergency action levels in 2010 to add upscale high on the liquid effluent radiation monitor as an initiating condition. In 2017 the licensee removed upscale high as a condition of AU1.2 to restore the differentiation between classifications. The inspectors reviewed the licensees current emergency action levels and determined the emergency action levels can be implemented. There is no immediate safety concern pending the licensees long-term corrective action to implement a new emergency action level scheme based on Nuclear Energy Institute (NEI) 99-02, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6.

Corrective Action References: Condition Reports CR-CNS-2010-07974, CR-CNS-2016-04791, CR-CNS-2017-01508, CR-CNS-2017-04468, and CR-CNS-2018-04662

Performance Assessment:

The inspectors determined this violation was associated with a reactor oversight program performance deficiency of minor significance. Specifically, it was determined that the licensee failed to maintain the effectiveness of the emergency plan, but it was a minor performance deficiency due to the continued effectiveness of the EAL despite the error.

Enforcement:

Severity: The Reactor Oversight Process (ROP) significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance.

Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. This issue was determined to be a Severity Level IV violation using the NRC Enforcement Policy dated May 15, 2018, Section 2.3.11, Inaccurate and Incomplete Information, and Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report.

The Enforcement Policy, Section 6.9(c)(1), provides that a violation is characterized as Severity Level III if the accurate information would have caused the NRC to reconsider a regulatory position or undertake substantial further inquiry. There are no corresponding Severity Level IV examples. Through discussion with the Office of Nuclear Security and Incident Response (NSIR), it was determined that had the accurate information been provided (or had the NRC known the information was inaccurate), the NRC license reviewer would have used the request for additional information (RAI) process to address the license amendment request. Specifically, the licensee would have been required to revise their proposed emergency action levels so they could be implemented before the emergency action scheme change was approved. Because the RAI is a routine NRC process, it was concluded that the failure to provide accurate information to the NRC would not have caused the NRC to undertake substantial further inquiry, and the violation was appropriately characterized as Severity Level IV.

Violation: Section 50.9(a) of 10 CFR states, in part, that information provided by a licensee shall be complete and accurate in all material respects.

Contrary to the above, on February 26, 2009, and September 24, 2009, information was provided to the Commission by the licensee that was not complete and accurate in all material respects. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that were not correct. The information was material to the NRCs decision whether to approve a license amendment request. The NRC approved a license amendment for an emergency action level scheme on February 23, 2010, which included emergency action levels which could not be implemented; the approval of those emergency action levels was based on the incorrect submission provided by the licensee.

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

Failure to Perform Process Applicability Determination Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Systems Green H.5 - Work

71152 - NCV 05000298/2018003-02 Management Problem Closed

Identification and Resolution The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow Administrative Procedure 0.9, Tagout, Revision 88, for performing a monthly audit and Process Applicability Determination.

Specifically, the inspectors noted that a clearance order on the safety-related residual heat removal service water booster pump room fan coil unit was hanging for greater than 90 days with no Process Applicability Determination performed, which resulted in the power switch for the fan coil unit being unintentionally tagged out of its normal configuration for almost 2 years.

Description:

In April 2018, inspectors identified a tag, on the safety-related residual heat removal (RHR) service water booster pump (SWBP) room fan coil unit (FCU), which maintained the power switch for the FCU OFF, out of its normal position. This safety-related FCU supports operation of more than one RHR SWBP in the event that normal control building ventilation is lost during an emergency. The FCU had recently been repaired and the licensee informed the inspectors that it had been returned to service. Upon further investigation, the inspectors noted that the tag had been present since July 2016, nearly 2 years. The inspectors also noted that the clearance order (CO) for the Tagout did not have a Process Applicability Determination (PAD) performed. The PAD would have helped the operators recognize the off-normal position of this power switch and would have identified any compensatory measures for the condition. Ultimately the licensee returned the power switch to the normal position, returning the RHR SWBP room FCU to service.

The inspectors reviewed the history associated with this CO. In 2016, the licensee created a work order (WO), WO 5140788, to remove an obsolete, abandoned cooling tower. This cooling tower, a standby to control building ventilation, had been used to cool the RHR SWBP room. The licensee had abandoned this cooling tower in place in 2005. In July of that year, the licensee identified damage to the fan motor associated with this cooling tower.

A subsequent work order, WO 5143045, was created to remove the damaged fan motor, which posed a safety risk, until the obsolete cooling tower could be fully removed. The licensee had to establish a CO in order to remove the fan motor. The CO was established on July 29, 2016. As part of the Tagout process, operations correctly identified this CO as requiring a PAD. The PAD was required because the CO tagged the safety-related RHR SWBP room FCU out of its normal position. On July 31, 2016, a revision to the CO was created and established. This revised CO was not marked as requiring a PAD, and the initial CO was removed. On August 3, 2016, the work to remove the damaged fan motor was completed; however, the CO remained in place to support abandoning the obsolete cooling tower per WO 5140788.

On September 22, 2016, the licensee conducted a monthly Tagout Audit, which included the tag on the RHR SWBP room FCU. As part of the audit process, the licensee incorrectly marked the CO as not requiring a PAD because the work was intended to support abandoning equipment. This was incorrect because the power switch for the safety-related FCU was not being abandoned and was maintained in an off-normal position. WO 5143045, to remove the damaged fan motor, was closed out and marked as complete on October 3, 2016. In January 2017, WO 5140788, to abandon the cooling tower, was placed in a Reschedule status, to be completed at some point in the future. The CO to support this removal was still in place and no subsequent Tagout Audits would identify the need for a PAD.

On October 13, 2017, the licensee identified leakage from the service water portion of the RHR SWBP room FCU. The service water leak was repaired on April 5, 2018. Upon completing work and clearing the tags used to repair the leak, the licensee informed the inspectors that the fan coil unit had been restored to service. A few days later, the inspectors questioned the status of the RHR SWBP room FCU. It was at this time that inspectors noticed the power switch for the FCU was still tagged in the off-normal, OFF position. The inspectors noted that the licensee was surprised to learn of the remaining tag. With the switch positioned to OFF, the FCU would not run if called upon, and only one of four RHR SWBPs could be used in the event of an emergency. These questions led the licensee to revise the CO to remove the tag from the RHR SWBP room FCU. In total, the FCU was inadvertently tagged out from July 29, 2016, until May 8, 2018.

Corrective Action: The licensee revised the clearance order in order to remove the tag from the safety-related RHR SWBP room FCU, thereby returning the fan coil unit to service.

Corrective Action Reference: Condition Report CR-CNS-2018-05472

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to follow Administrative Procedure 0.9 for performing a monthly audit and Process Applicability Determination was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the configuration control 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. Specifically, the failure to follow Administrative Procedure 0.9 resulted in a missed opportunity to identify that the RHR SWBP FCU power switch had been inadvertently left tagged out of its normal position. In this configuration, the licensee was limited to only being able to run one RHR SWBP at a time, thereby adversely impacting the cornerstone objective.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors determined that this finding was of very low safety significance (Green) because the finding:

(1) was not a deficiency affecting the design or qualification of a mitigating system, structure, or component;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out of service for greater than its technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-cutting Aspect: This finding had a human performance cross-cutting aspect associated with work management, in that the licensee failed to implement a process of planning, controlling, and executing work, resulting in the safety-related RHR SWBP room FCU remaining inadvertently tagged out for an extended period of time.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Section 1.c of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for Equipment Control including configuration control activities such as locking and tagging. The licensee established Administrative Procedure 0.9, Tagout, Revision 88, to meet this requirement.

Procedure 0.9, Step 22.1.2 requires, in part, that a monthly audit shall ensure an action is issued to the operations department to complete a Process Applicability Determination for components that are greater than 45 days but less than 90 days that result in a change in normal plant configuration.

Contrary to the above, on September 22, 2016, the licensee failed to ensure that the monthly audit issued an action to the operations department to complete a Process Applicability Determination (PAD) for components that were greater than 45 days but less than 90 days that resulted in a change in normal plant configuration. Specifically, the licensee failed to complete a PAD for a clearance order that changed the normal plant configuration of the safety-related RHR SWBP room FCU power switch from ON to OFF.

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

Failure to Provide Adequate Lubrication for Drywell Fan Coil Units Cornerstone Significance Cross-cutting Inspection Aspect Procedure Initiating Events Green H.5 - Work

71152 - FIN 05000298/2018003-03 Management Problem Closed

Identification and Resolution The inspectors reviewed a self-revealed finding for the licensees failure to implement Work Order 5060136 during maintenance on the drywell fan coil units. Specifically, on October 26, 2016, during bearing replacement work on drywell fan coil, unit D, maintenance personnel failed to properly reinstall auto-lubricator injection connectors after removing the interferences per the work order instructions. This error resulted in the failure of drywell fan coil, unit D, due to inadequate bearing lubrication, and ultimately led to a downpower and reactor shutdown.

Description:

On May 11, 2018, operations personnel secured drywell fan coil unit (DWFCU) D after they observed indications of fan failure. Subsequently, on May 26, 2018, DWFCU A also failed and needed to be secured. The licensee lowered power by approximately 5 percent in order to maintain drywell temperature below the 150 degree Fahrenheit technical specification limit. As a result of the challenge to drywell temperature limits, the licensee shut the plant down in order to repair the DWFCUs. Upon inspection, the licensee discovered that bearings associated with the D and A DWFCUs had catastrophically failed due to improper lubrication, and both fans had sustained damage related to these failures. Further investigation revealed the auto-lubricator device that ensured bearing lubrication during the cycle had been installed in the wrong port on the bearing housing of DWFCU D. As a result, these bearings did not receive any of the relubrication that was required throughout the operating cycle. In addition, bearings with tighter tolerances than what was dictated by design specifications had been installed in all four DWFCUs as a result of an unrecognized vendor material supply issue. The licensee concluded that both of these issues led to the DWFCU bearing failures.

The inspectors reviewed work orders (WOs) associated with the work that took place during the 2016 refueling outage that replaced bearings on all four DWFCUs. The inspectors found that WO 5060136 provided instructions to remove interferences (bearing lubricator, accelerometer, and thermos couple cables) as required for inboard and outboard bearing replacement. An additional step instructed workers to reinstall the removed interferences.

The inspectors concluded that these steps were not performed properly in accordance with licensee guidance on control of in-process material, and that the bearing auto-lubricators should have been restored to connect to the same bearing housing port that they had been removed from, as directed by the WO. The inspectors also concluded that the WO should have contained more detailed instructions to ensure that the auto-lubricator was reinstalled properly, that photos or drawings should have been attached to the work order to aid in worker identification of the as-found configuration, and that the workers failed to recognize that they had lost traceability control of the bearing lubricators and should have terminated execution of the work until traceability could be restored.

Corrective Actions: The licensee repaired and replaced damaged portions of all affected drywell fan coil units; revised the associated maintenance plans to include auto-lubricator installation instructions; and initiated an engineering change to address necessary improvements to the lubrication systems for the fan coil unit bearings.

Corrective Action Reference: Condition Report CR-CNS-2018-03245

Performance Assessment:

Performance Deficiency: The licensees failure to ensure that the drywell fan cooling units were provided with adequate lubrication was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Initiating Events Cornerstone to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the issue resulted in a downpower and reactor shutdown due to challenging technical specification drywell temperature limits.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, and determined that the finding had very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with work management, because the licensee failed to ensure that the organization implemented a process of planning and executing work activities to assure that the DWFCU auto-lubricators were connected to the correct bearing housing ports.

Enforcement:

The inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

On June 7, 2018, as part of the biennial emergency preparedness inspection, the inspectors discussed the proposed exercise scenario with Mr. T. Morgan, Branch Chief, Technological Hazards Branch, FEMA Region VII, and other FEMA regional staff.

On June 21, 2018, as part of the biennial emergency preparedness inspection, the inspectors discussed the proposed exercise scenario with Mr. J. Stough, Manager, Emergency Preparedness, and other licensee staff.

On August 2, 2018, as part of the biennial emergency preparedness inspection, the inspectors discussed exercise performance with Mr. T. Morgan, Branch Chief, Technological Hazards Branch, FEMA Region VII, and other FEMA regional staff.

On September 10, 2018, the inspectors presented the biennial emergency preparedness exercise and performance indicator inspection results to Mr. J. Dent, Jr., Site Vice President and Chief Nuclear Officer, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On October 12, 2018, the inspectors discussed the significance of the biennial emergency preparedness exercise and performance indicator inspection findings with Mr. J. Shaw, Manager, Licensing, and other members of the licensee staff. The licensee acknowledged the issues presented.

On August 15, 2018, the inspector presented the annual licensed operator requalification inspection results to Mr. J. Florence, Superintendent, Simulator and Training Support, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On August 23, 2018, the inspectors presented the heat sink performance inspection results to Mr. J. Kalamaja, General Manager Plant Operations, and other members of the licensee staff.

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On October 17, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. J. Dent, Jr., Site Vice President and Chief Nuclear Officer, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

71111.04 - Equipment Alignment

Condition Reports (CR-CNS-)

2017-00553 2018-01015 2018-04816

Drawings

Number Title Revision

2016, Sheet 7 Fire Protection System Site Plan 12

2045 Flow Diagram - Core Spray System N58

Miscellaneous Documents

Number Title Revision/Date

Protected Equipment Tracking Form - ESST August 6,

Week 1832 2018

CNS-2040, Sheet 2 Flow Diagram RHR Sys B

CNS-FP-352 Yard Fire Protection N02

DCD-13 RHR Design Control Document February 14,

2018

Procedures

Number Title Revision

2.1.11.3 Radwaste/Augmented Radwaste Building Data 103

2.2.15A Startup Transformer Component Checklist 8

2.2.30A Fire Protection System Component Checklist 32

2.2.69 Residual Heat Removal System 101

2.2A.CS.DIV2 Core Spray Component Checklist 3

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

(DIV 1)

2.2B.CS.DIV2 Core Spray System Instrument Valve Checklist 0

2.2B.RHR.DIV2 Residual Heat Removal System Component Checklist 12

(DIV 2)

Work Orders

218034

71111.05 - Fire Protection

Condition Reports (CR-CNS-)

2018-01888 2018-04015 2018-04068

Miscellaneous Documents

Number Title Revision

Fire Brigade Scenario #5 4

0-BARRIER-MAPS Barrier Maps 9

CNS-FP-212 Reactor Building Southeast Quadrant AB/05

CNS-FP-222 Reactor Building Standby Gas Treatment Room AB/04

CNS-FP-242 Turbine Building Basement South AB/05

CNS-FP-247 Turbine Building - Bus Duct Area AB/07

CNS-FP-268 Transformer Yard N05

CNS-FP-343 OWC Gas Generator Bldg N05

EE-01-006 Disposition of NFPA Code Compliance Deviations 54

(Systems in Fire Zones Requiring an IPEEE Phase 2

Screening)

NEDC 10-080 Fundamental Fire Protection Program and Design 3

Element Review EPM Report R1906-002-001

NEDC 11-104 Fire Safety Analysis for Fire Area RB-V EPM 4

Report R1906-008-RBV

TPP 207, Fire Drill Report 5

Procedures

Number Title Revision

0.7.1 Control of Combustibles 40

0-BARRIER-MISC Miscellaneous Buildings 5

3.6.1 Fire Barrier Control 21

71111.06 - Flood Protection Measures

Condition Reports (CR-CNS-)

2018-04041 2018-04052 2018-04083 2018-04119

2018-04135 2018-04178 2018-04240 2018-04275

2018-04817 2018-04898

Miscellaneous Documents

Number Title Revision

CNS-EE-16 Underground Electrical Layout 23

FDN-F02 Maintenance Rule Function FDN-F02 Performance 5

Criteria Basis Document

Notifications

11515173 11515267 11515943 11516865

11517491 11518668 11520057 11520617

11534368

Procedures

Number Title Revision

2.3_S-1 Panel S - Annunciator S-1 29

71111.07 - Heat Sink Performance

Calculations

Number Title Revision

NEDC 00-095A EQ Normal Temperature, Relative Humidity, Pressure 5

and Radiation

NEDC 00-095C High Energy Line Break/Loss of Coolant Accident 1

Inside Containment

NEDC 00-095D HELB EQ - RB Pressure / Temperature Response 1

NEDC 00-095E CNS Reactor Building Post-LOCA Heating Analysis 3

NEDC 00-095G Development of Methodology and Applications to Allow 2

the Reduction of Beta TID to Equipment in the CNS

EQ Program

NEDC 11-140 Review of ZNE Calculation 11-198 Rev. 1 Cooper 1

Nuclear Station Service Water System Analysis

NEDC 12-019 SW Post-LOCA Flow Test Revised Acceptance 1

Criteria

NEDC 91-239 DGLO/DGJW/DG Intercooler Heat Exchanger 5

Evaluation

NEDC 92-034 Water Hammer Analysis of Service Water System 3, 3C1, 3C2

NEDC 93-050 RHR Quad Temperature With Hatches Removed 4

Calculations

Number Title Revision

NEDC 93-184 RHR Heat Exchangers Thermal Performance and 3

Tube Plugging Margin

NEDC 94-021 REC-HX-A and REC-HX-B Maximum Allowable 7

Accident Case Fouling

NEDC 97-085 RHR Quad Heatup Rate After a Loss of Cooling With 9

Two Pump Operation

NEDC 97-087 Acceptance Criteria for HPCI Room Cooler and 4

Reactor Building Quad Coolers

Condition Reports (CR-CNS-)

2016-04984 2018-04932 2018-04946

Design Basis Documents

Number Title Date

DG1 Diesel Generator (DG) - Design Criteria Document January 14,

2016

DGb Appendix B - Component Design Information January 14,

2016

REC1 Reactor Equipment Cooling System Design Criteria December 3,

Document 2014

RECb Appendix B Component Design Information May 20, 2016

RHR1 Residual Heat Removal System Design Criteria April 4, 2016

Document

RHRb Appendix B Component Design Information February 14,

2018

SW1 Service Water and Residual Heat Removal Service January 18,

Water Booster System Design Criteria Document 2016

SWb Appendix B Component Design Information June 2, 2017

Drawings

Number Title Revision

2006 SH 1 Flow Diagram Circulating, Screen Wash and Service 90

Water Systems

2006 SH 3 Flow Diagram Circulating, Screen Wash and Service 56

Water Systems

Drawings

Number Title Revision

2006 SH 4 Flow Diagram Circulating, Screen Wash and Service 60

Water Systems

2031 SH 2 Flow Diagram Reactor Building Closed Cooling Water 65

System

2036 SH 1 Flow Diagram Reactor Building Service Water System 4

2040 SH 2 Flow Diagram Residual Heat Removal SYS Loop B 19

KSV-47-8 Diesel Generator 1 & 2 Cooling Water Schematic N27

KSV-47-9-NP Jacket Water Schematic 08

KSV-91-10-NP Intercooler Piping (16-Cyl. Eng.) N02

Miscellaneous Documents

Number Title Revision/Date

RHR HX B Thermal performance test January 18,

2016

RHR HX B Thermal performance test January 17,

2018

REC HX B Thermal Performance Test February 23,

2018

REC HX B Thermal Performance Test April 25,

2018

REC HX TEMA June 17,

1968

RHR HX TEMA October 6,

1993

6.SW.102 Service Water System - Post-LOCA Flow Verification October 25,

(Division 1) 2014

6.SW.102 Service Water System - Post-LOCA Flow Verification October 18,

(Division 1) 2016

6.SW.102 Service Water System - Post-LOCA Flow Verification October 12,

(Division 2) 2014

6.SW.102 Service Water System - Post-LOCA Flow Verification November 3,

(Division 2) 2016

AE-5498 Procurement Drawing for EDG LO Heat Exchanger March 27,

1970

AE-5499 Procurement Drawing for EDG JW Heat Exchanger February 27,

1970

Miscellaneous Documents

Number Title Revision/Date

CNSS907024 Response to Generic Letter 89-13 January 29,

1990

Conco Job #26066 Eddy Current Report for NPPD Cooper Nuclear February

Station Unit 1 DGJW-HX-JW1 and DGLO-HX-LO1 2018

LO 2015-0224-009 Flow Accelerated / Microbiologically Influenced 1

Corrosion Programs Focused Self-Assessment Report

VM-1778 ITT / American Heat Exchangers Composite Manual 4

Procedures

Number Title Revision

2.3 DG1 Panel DG-1 - Annunciator DG-1 21

7.0.8.1 System Leakage Testing 25

7.2.42.3 Heat Exchanger Tube Plugging 18

Work Orders

4718578 4848585 4911606 4953685

4953686 5040446 5055085 5057836

5069818 5115446 5164181 5201942

234301

71111.11 - License Operator Requalification Program

Condition Reports (CR-CNS-)

2018-05727 2018-05730 2018-05735

Miscellaneous Documents

Number Title Revision/Date

Annual Requalification Results Summary August 15,

2018

IPTE RE30 Infrequently Performed Test or Evolution Brief for 0

Refueling Outage 30 Shutdown

RMP-30-027 Refueling Outage 30 Reactor Shutdown Reactivity September

Management Plan 20, 2018

SKL0560126 Ops Quick HIT #22 0

Miscellaneous Documents

Number Title Revision/Date

SKL05151333 DEH Malfunction-RFP B Trip and RRMG B Jordan 0

Failure

Procedures

Number Title Revision

2.1.4 Normal Shutdown 164

2.1.5 Reactor Scram 75

2.1.10 Station Power Changes 115

2.4RR Reactor Recirculation Abnormal 43

2.4RXPWR Reactor Power Anomalies 9

2.4TEC TEC Abnormal 29

6.RCS.601 Technical Specification Monitoring of RCS 24

Heatup/Cooldown Rate

10.9 Control Rod Scram Time Evaluation 69

71111.12 - Maintenance Effectiveness

Condition Reports (CR-CNS-)

2017-04681 2017-05664 2018-01188 2018-02869

2018-03244 2018-03245 2018-03260 2018-04693

2018-04901 2018-05421 2018-05438 2018-05845

Miscellaneous Documents

Number Title Revision/Date

Maintenance Rule Functional Failure Evaluations for 2004 through

HV-F09 2018

22, Sheet 3 Primary Containment Cooling & Nitrogen Inerting 4

System

CNS-HV-39 Reactor Building Drywell Cooling Developed Flow 1

Diagram w/ Measurement & Damper Locations

CS-PF01A Maintenance Rule Function, Performance Criteria 3

Basis

CS-PF01B Maintenance Rule Function, Performance Criteria 3

Basis

Miscellaneous Documents

Number Title Revision/Date

CS-SD1 Maintenance Rule Function, Performance Criteria 3

Basis

ECCS-F01 Maintenance Rule Function, Performance Criteria 1

Basis

HV-F09 Maintenance Rule Function, Performance Criteria 3

Basis

NEDC 89-1439 Drywell Air Cooling System Upgrade Air Flow 3

Derivation

Notifications

11390131 11406486 11462355 11536478

Procedures

Number Title Revision

2.2.40 Drywell Cooling System 31

2A1271AC Drywell Cooling System 0

3-EN-DC-204 Maintenance Rule Scope and Basis 3C1

3-EN-DC-205 Maintenance Rule Monitoring 5C1

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Condition Reports (CR-CNS-)

2018-04523 2018-04645 2018-05231 2018-05374

2018-05381 2018-05382 2018-05383

Miscellaneous Documents

Number Title Date

Protected Equipment Posting for ESST Week 1832 August 5,

2018

Protected Equipment Posting for Week 1833 CS B August 13,

Window 2018

Protected Equipment Posting for Week 1836 RHR A September 3,

Window 2018

GEK 45920A GE Systems manual for RRMG October 1992

Procedures

Number Title Revision

0-CNS-WM-104 On-line Schedule Risk Assessment 7

0-CNS-WM-104A On-line Fire Risk Management Actions 4

0-PROTECT-EQP Protected Equipment Program 42

2.0.3.1 Operational Strategy Guidance Process 1

6.REFUEL.307 Refueling Bridge Interlocks Test Prior to Working in 11

Spent Fuel Pool

10.23 Movement of New Fuel for Inspection 57

10.23.1 New Fuel Inspection and Channeling 1

OSGD-2018-05383 RRMG A Brushes Arcing 0

Work Orders

5101201 5101209 5112943 5167376

5170157 5171983 5208105

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports (CR-CNS-)

2016-04472 2016-05558 2018-04121 2018-04213

2018-04358 2018-05164 2018-05403 2018-05439

2018-05470 2018-05489

Drawings

Number Title Revision

2851-1 18 SW-1 Class IV P - Reactor Bldg 11

791E250 Jet Pump Instrument System Elementary Diagram 15

Miscellaneous Documents

Number Title Revision/Date

Significant changes from the 2008 to the 2011 edition Winter 2013

of ACI 318 Article from Precast Concrete Institute

(PCI) Journal

ECR 11516867

Miscellaneous Documents

Number Title Revision/Date

N-513-4 ASME Code Case Evaluation Criteria for Temporary 0

Acceptance of Flaws in Moderate Energy Class 2 or 3

Piping,Section XI, Division 1

NEDC 15-025 Mechanical ROS Civil/Structural Design for the 1

Hardened Containment Vent System Project

PBD-FAC Flow Accelerated Corrosion Program Basis Document 0

PBD-MIC Microbiologically Influenced Corrosion Program Basis 1

Document

Procedures

Number Title Revision

0.5.OPS Operations Review of Condition Reports/Operability 61

Determination

3.10 Flow Accelerated Corrosion (FAC) and 16

Microbiologically Influenced Corrosion (MIC) Program

Implementation

Work Orders

5065112 5223979

71111.18 - Plant Modifications

Condition Reports (CR-CNS-)

2018-04564

Miscellaneous Documents

Number Title Revision

DEC-5260125 Design Equivalent Change Package - TG VRG Track 0

and Hold

ODMI 2018-04564 Main Generator Voltage Regulator Control 0

Procedures

Number Title Revision

2.1.11.1 Turbine Building Data 168

2.2.14 22KV Electrical System 86

2.2.77 Turbine Generator 118

Procedures

Number Title Revision

2.3_C-3 Annunciator C-3 Procedure 53

2.4GEN-H2 Generator or Hydrogen Abnormal 32

5.3GRID Degraded Grid Voltage 49

Work Orders

260097 5260098

71111.19 - Post Maintenance Testing

Condition Reports (CR-CNS-)

2018-04448 2018-04471 2018-04719 2018-04723

2018-04743 2018-04744 2018-04757

Drawings

Number Title Revision

2077 Flow Diagram - Diesel Gen Bldg Service Water, N78

Starting Air, Fuel Oil, Sump System & Roof Drains

5759-D001, Sheet 2 5kV 2000A 3P 3W Bus Replacement Layout 4

and 3

Procedures

Number Title Revision

6.MISC.401 Position Indicator Inservice Testing (IST) 19

6.1CS.101 Core Spray Test Mode Surveillance Operation 31

6.1CS.201 Reference Leg Injection Flow Verification and IST 11

Check Valve Testing

6.2CS.101 Core Spray Test Mode Surveillance Operation 29

(IST)(DIV 2)

6.2CS.201 CS Motor Operated Valve Operability Test (IST)(DIV 2) 21

6.2DG.105 Diesel Generator Starting Air Compressor Operability 25

7.3.20.3 Motor Analysis 18

7.3.41 Examination, Repair, and High Pot Testing of 16

Non-Segregated Buses and Associated Equipment

7.3.51 Electrical Meter Calibration Check 15

Work Orders

5101202 5141231 5143101 5147405

5179896 5186076 5207476 5207547

208602 5208853 5208933 5208935

209259 5209261 5218034 7210044

71111.22 - Surveillance Testing

Condition Reports (CR-CNS-)

2017-06021 2018-05356 2018-05368 2018-05625

2018-05723

Drawings

Number Title Revision

945E632 ARI/ATWS Recirculation Pump Trip N02

Procedures

Number Title Revision

6.HPCI.308 HPCI Auto Isolation Logic Steam Line Low Pressure 7

Logic System Functional Test (Reactor Pressure

Greater Than or Equal to 150 PSIG)

6.SLC.101 SLC Pump Operability Test 25

6.1ARI.301 ARI/ATWS/RPT Low-Low and PCIS Low-Low-Low 13

Reactor Water Level Channel Calibration Test

6.2DG.101 Diesel Generator 31 Day Operability Test (IST)(DIV 2) 84

9.EN-RP-150 Radiography and X-Ray Testing 7

Work Orders

5149721

71114.01 - Exercise Evaluation

Condition Reports (CR-CNS-)

2016-04501 2016-04591 2016-04791 2016-04933

2016-04934 2016-05311 2016-05390 2017-01631

2017-03021 2017-03929 2017-03998 2017-04422

2017-04466 2017-04468 2017-04696 2017-04854

Condition Reports (CR-CNS-)

2017-04874 2017-05029 2017-05037 2017-05039

2017-06824 2018-00539 2018-00747 2018-01319

2018-02631 2018-02845 2018-02873 2018-03033

2018-03080 2018-03142 2018-03157 2018-03283

Miscellaneous Documents

Title Revision/Date

Cooper Nuclear Station Emergency Plan 71

Evaluation Report for the Exercise conducted December 20, 2016 January 19,

2017

Evaluation Report for the Exercise conducted March 28, 2017 April 7, 2017

Evaluation Report for the Exercise conducted May 16, 2017 May 24, 2017

Evaluation Report for the Exercise conducted August 15, 2017 August 23,

2017

Evaluation Report for the Exercise conducted October 17, 2017 October 25,

2017

Evaluation Report for the Exercise conducted January 30, 2018 February 14,

2018

Evaluation Report for the Exercises conducted in August and September 2016 September

15, 2016

Evaluation Report for the August through November 2017 Mini-Drills November 29,

2017

Evaluation Report for the Notification of Unusual Event declared September 2, September 8,

2016 2016

Evaluation Report for the Notification of Unusual Event declared on November November 17,

11, 2017 2017

Procedures

Number Title Date

0-CNS-LI-102 Corrective Action Process, Revision 8 August 23,

2017

5.7.1 Emergency Classification, Revision 60 April 12,

2018

5.7.2 Emergency Director EPIP, Revision 36 February 28,

2018

Procedures

Number Title Date

5.7.6 Notification, Revision 73 December

18, 2017

5.7.7 Activation of the TSC, Revision 39 November 3,

2016

5.7.8 Activation of the OSC, Revision 27 March 28,

2016

5.7.9 Activation of the EOF, Revision 36 November 3,

2016

5.7.12 Emergency Radiation Exposure Control, Revision 17 March 14,

2018

5.7.14 Stable Iodine Thyroid Blocking, Revision 22 October 14,

2017

5.7.15 OSC Team Dispatch, Revision 22 April 25,

2018

5.7.20 Protective Action Recommendations, Revision 29 March 22,

2017

5.7.23 Activation of the Joint Information Center, Revision 17 February 3,

2016

71151 - Performance Indicator Verification

Condition Reports (CR-CNS-)

2017-01203 2017-01805 2017-01857 2017-01858

2017-02185 2017-02895 2017-02937 2017-03256

2017-05026 2017-05889 2018-00160 2018-00650

2018-02306 2018-03157 2018-04184

Miscellaneous Documents

Number Title Revision/Date

PI Documentation and Data Review Form, Scrams July 2018

with Complications, Reporting Period

EPDG 2 Attachment G-1: Emergency Preparedness 25

Performance Indicator Guide

NEI 99-02 Regulatory Assessment Performance Indicator 7

Guideline

Procedures

Number Title Revision/Date

5.7.1 Emergency Classification 59, 60

5.7.6 Notification 72, 73

5.7.20 Protective Action Recommendations 29

5.7.27 Alert and Notification System, Revision 19 December 12,

2017

5.7.27.2 False Activation of Alert and Notification System, December 12,

Revision 9 2017

71152 - Problem Identification and Resolution

Condition Reports (CR-CNS-)

2017-07513 2018-02363 2018-02869 2018-03180

2018-03245 2018-03251 2018-03261 2018-03265

2018-03268 2018-03294 2018-04415 2018-04629

2018-04816 2018-04827 2018-04865 2018-04938

2018-05022 2018-05054 2018-05058 2018-05170

2018-05272 2018-05307 2018-05320 2018-05472

Miscellaneous Documents

Number Title Revision

22, Sheet 3 Primary Containment Cooling & Nitrogen Inerting 4

System

2016-0060-008 Work Tracker

CNS-HV-39 Reactor Building Drywell Cooling Developed Flow 1

Diagram w/ Measurement & Damper Locations

Procedures

Number Title Revision

0.47 Control of In-Process Material 16

0.9 Tagout 88, 94

0-EN-LI-100 Process Applicability Determination 18C2

2.1.11.3 Radwaste/Augmented Radwaste Building Data - 103

Modes 1, 2, and 3

2.2.38A HVAC Control Building System Component Checklist 6

Procedures

Number Title Revision

2.2.40 Drywell Cooling System 31

Work Orders

4440167 4503202 4503487 5060133

5060134 5060135 5060136 5140788

5143045 5214101 5247353 5247354

ML18304A484

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

By: JWK Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/C ASRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB

NAME PVoss MTobin MStafford TFarnholtz GWerner VGaddy

SIGNATURE PJV MCT MHS TRF GEW vgg

DATE 10/26/2018 10/29/2018 10/26/2018 10/26/2018 10/26/2018 10/26/18

OFFICE BC:DRS/PSB2 ATL:DRS/IPAT SPE:DRP/C BC:DRP/C

NAME HGepford GMiller DProulx JKozal

SIGNATURE HJG GBM DLP JWK

DATE 10/26/18 10/29/18 10/29/18 10/31/2018