IR 05000298/2024001

Integrated Inspection Report 05000298/2024001

ML24121A143
Person / Time
Site:	Cooper
Issue date:	05/03/2024
From:	Jeffrey Josey NRC/RGN-IV/DORS/PBC
To:	Dia K Nebraska Public Power District (NPPD)
References
EA-24-029 IR 2024001
Download: ML24121A143 (26)

Text

May 03, 2024

SUBJECT:

COOPER NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000298/2024001

Dear Khalil Dia:

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station. On April 18, 2024, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

In addition, the NRC determined that a violation of Title 10 of the Code of Federal Regulations (10 CFR) 21.21(d)(1) occurred. The violation involved the failure to report a defect associated with a substantial safety hazard for a service water booster pump seal. This violation was considered for escalated enforcement at Severity Level III per the NRC Enforcement Policy.

However, in reviewing the specific circumstances of this violation (i.e., the NRC resident staff was aware of the issue; there was little to no impact to the inspection process/regulatory process; the seals were only supplied to Cooper Nuclear Station and no other licensees; and your staff entered the issue into the corrective action program and submitted the 10 CFR Part 21 report) the NRC determined that it is more appropriately categorized as a Severity Level IV violation. Since the violation was entered into the corrective action program, corrected by your staff, not repetitive, and not willful, it is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, 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 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 Cooper Nuclear Station.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number: 05000298

License Number: DPR-46

Report Number: 05000298/2024001

Licensee: Nebraska Public Power District

Facility: Cooper Nuclear Station

Location: Brownville, NE

Inspection Dates: January 1, 2024, to March 31, 2024

Inspectors: G. Birkemeier, Resident Inspector K. Chambliss, Senior Resident Inspector W. Schaup, Senior Project Engineer

Approved By: Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety

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.

List of Findings and Violations

Failure to Incorporate Vendor Instructions Resulting in Residual Heat Removal Service Water Booster Pump Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.15 Systems NCV 05000298/2024001-01 Conservative Open/Closed Bias The inspectors are documenting a self-revealed finding of very low safety significance (Green)and an associated non-citied violation of Technical Specifications 5.4.1.a, "Instructions,

Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the work instructions for the rebuilding of residual heat removal service water booster pumps failed to incorporate vendor instructions directing the installation of the outboard thrust bearing.

Failure to Incorporate Vendor Instructions Resulting in Turbine Stop Valve Limit Switch Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000298/2024001-02 Management Open/Closed The inspectors are documenting a self-revealed finding of very low safety significance (Green)and an associated non-citied violation of Technical Specification 5.4.1.a, "Instructions,

Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment. Specifically, the work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor manual that would have prevented a failure of the limit switches.

Failure to Report Deviation of a Basic Component Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000298/2024001-03 Open/Closed EA-24-029 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(d)(1) for the licensee's failure to properly evaluate the reportability of a deviation in a basic component. As a result, the licensee failed to report a deviation identified on September 14, 2022, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000298/2023-002-00 Secondary Containment 71153 Closed Differential Pressure Perturbation Exceeds Technical Specifications LER 05000298/2024-001-00 Inoperable Turbine Stop 71153 Closed Valve Limit Switch Causes Condition Prohibited by Technical Specifications LER 05000298/2024-002-00 Technical Specifications 71153 Closed Prohibited Condition for Inoperable Service Water Booster Pump

PLANT STATUS

Cooper Nuclear Station began the inspection period at rated thermal power. On January 3, 2024, power was lowered to approximately 60 percent for maintenance activities.

The plant returned to rated thermal power on January 4, 2024. On March 1, 2024, power was lowered to approximately 65 percent for a planned rod pattern adjustment. The plant returned to rated thermal power on March 2, 2024. The unit remained at 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk

-significant systems from impending severe weather due to multiple winter weather warnings and low river levels on March 1, 2023.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) division 2 standby liquid control on February 12, 2024

(2) division 2 residual heat removal on March 13, 2024

(3) division 2 reactor equipment cooling on March 29, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) control building battery and switchgear rooms, 903-foot 6-inch elevation, on February 6, 2024

(2) cable expansion room on March 11, 2024

(3) intake structure, 903-foot 6-inch elevation, on March 13, 2024

(4) division 1 emergency diesel generator room, 917-foot 6-inch and 903-foot 6-inch elevations, on March 13, 2024

(5) control building basement on March 22, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on March 25, 2024.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the reactor building southwest quadrant and high-pressure coolant injection room on March 21, 2024.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) division 1 emergency diesel generator lube oil and jacket water heat exchangers on February 23, 2024

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a quarterly down power for core management on February 28, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a simulator emergency preparedness scenario on February 12, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) reactor building heating, ventilation, and air conditioning maintenance hatch (a)(1)evaluation on March 14, 2024

(2) reactor protector system function RPS-F01A (a)(1) evaluation due to limit switch failure causing an unplanned power reduction on March 29, 2024

(3) emergency diesel generator heating, ventilation, and air conditioning maintenance hatch (a)(1) evaluation on March 29, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) risk assessment and management during emergency diesel generator 1 maintenance window on February 5, 2024

(2) emergent work due to unplanned inoperability of residual heat removal service water booster pump B on February 7, 2024

(3) planned Yellow online risk during residual heat removal division 2 outlet valve and emergency diesel generator division 2 maintenance window on February 22, 2024

(4) emergent work due to unplanned inoperability of 250 Vdc batteries on February 28, 2023

(5) emergent work due to potential through-wall leakage of high-pressure coolant injection piping on March 1, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) residual heat removal service water booster pump B high vibrations on February 9, 2024

(2) low temperatures inside 125 Vdc battery rooms on February 15, 2024

(3) emergency diesel fuel oil transfer pump auto-start on March 20, 2024

(4) main turbine generator stop valve limit switch loose linkages on March 29, 2024

(5) division 2 service water heat exchanger outlet valve stem galling on March 29, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) emergency diesel generator heating and ventilation hatch door modification on March 28, 2024

(2) division 1 250 Vdc battery temporary jumper installation due to second faulty cell on March 28, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)

(1) division 2 residual heat removal maintenance window post-work testing on February 9, 2024

(2) residual heat removal service water booster pump B emergency maintenance and restoration testing on February 9, 2024

(3) division 1 250 Vdc battery with jumper installed on March 25, 2024

(4) residual heat exchanger B outlet valve post-maintenance testing on March 27, 2024

(5) reactor equipment cooling motor-operated valve REC-MO-695 post-work testing on March 27, 2024

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) emergency diesel generator B operability test with isolation switches in isolate on February 16, 2024

(2) main turbine stop valve closure limit switch functional test on March 6, 2024

(3) division 2 residual heat removal service water booster pump flow test and valve operability test on March 27, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) main steam isolation valve operability in-service test on March 27, 2024

71114.06 - Drill Evaluation

Required Emergency Preparedness Drill (1 Sample)

(1) emergency preparedness drill on February 29,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) January 1, 2023, through December 31, 2023

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) January 1, 2023, through December 31, 2023

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) January 1, 2023, through December 31, 2023

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) January 1, 2023, through December 31, 2023

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) January 1, 2023, through December 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) work package development and work control deficiencies on February 7, 2024

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program to identify potential trends in secondary containment tracking and control room response that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000298/2023-002-00, Secondary Containment Differential Pressure Perturbation Exceeds Technical Specifications (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23355A120). The inspection conclusions associated with this LER are documented in Inspection Report 05000298/2023004 (ML24038A256) under Inspection Results section 71111.15. This LER is Closed.

(2) LER 05000298/2024-001-00, Inoperable Turbine Stop Valve Limit Switch Causes Condition Prohibited by Technical Specifications (ML24064A252). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71111.15. This LER is Closed.

(3) LER 05000298/2024-002-00, Technical Specifications Prohibited Condition for Inoperable Service Water Booster Pump (ML24064A255). The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71111.15. This LER is Closed.

INSPECTION RESULTS

Failure to Incorporate Vendor Instructions Resulting in Residual Heat Removal Service Water Booster Pump Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.15 Systems NCV 05000298/2024001-01 Conservative Open/Closed Bias The inspectors are documenting a self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specifications 5.4.1.a, "Instructions, Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the work instructions for the rebuilding of residual heat removal service water booster pumps failed to incorporate vendor instructions directing the installation of the outboard thrust bearing.

Description:

In January 2018, the licensee removed A residual heat removal (RHR) service water booster pump (SWBP) for replacement. The pump was subsequently rebuilt from November 2020 to June 2022, including replacement of the pump's shaft and bearings. The pump was reinstalled into the SWBP-D location and passed all post-maintenance testing. On August 27, 2022, the outboard bearing high temperature warning alarm was received while the pump was supporting service water chemical injection, and the licensee declared the pump inoperable. This licensee entered this condition into their corrective action program as condition report CR-CNS-2022-03653. Following repairs to the inboard and outboard bearings, the licensee returned SWBP-D to service after completing post-maintenance testing following a pump run of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

In December 2023, the licensee performed a reportability audit of previous evaluations of adverse conditions to determine if new evidence related to these evaluations could result in a reportable condition. In January 2024, a review of condition report CR-CNS-2022-03653 identified a question related to the past operability of SWBP-D. The licensee captured this question on the past operability condition of SWBP-D as condition report CR-CNS-2023-05194 with corrective action to perform a thorough engineering evaluation related to the outboard bearing high temperature. The evaluation determined SWBP-D would not have been capable of performing for its 30-day mission time and the licensee exceeded the limiting condition for operation (LCO) action statement completion time for technical specifications (TS) 3.7.1, which requires two RHR SWBP subsystems, including two SWBP per subsystem to be operable in Modes 1 through 3. The condition of one inoperable SWBP (Condition A) requires restoration of the pump to operable within 30 days. Initially, the licensee declared the pump inoperable from when the high temperature alarm was received on August 27, 2022. The pump was declared operable following repairs on September 1, 2022.

The evaluation determined the high temperature warning alarm was a result of maintenance technicians overtightening the outboard bearing. Based on this information the licensee determined the pump was inoperable since July 27, 2022, when TS 3.7.1 LCO action statement A was entered for the pump replacement. This amount of time resulted in SWBP-D being inoperable for 36 days, exceeding the 30-day action statement to restore the pump to operable. Additionally, not satisfying this action would have resulted in entering condition C, which requires the plant to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The SWBP-B was rebuilt using station Procedure 7.2.14, "RHR SWBP Overhaul and Replacement," revision 46. The station procedure did not contain the manufacturer's instructions for installation of the service water booster pump thrust bearing. The vendor manual contains detailed instruction for tightening the thrust bearing locknut to prevent overheating between the pump shaft, the bearings, and the thrust bearing locknut. The work package developed from station procedure 7.2.14 instead relied on skill of craft to complete the SWBP-D rebuild vice incorporating all required vendor instructions.

Corrective Actions: The station entered the condition into its corrective action program as condition report CR-CNS-2023-03653 and CR-CNS-2024-00463. The licensee submitted a licensee event report to the NRC to document the condition prohibited by technical specifications. Additionally, the licensee has since instituted a policy that all work packages developed for work on safety-related equipment must incorporate all relevant vendor instructions, refer to all relevant engineering calculations, and incorporate all relevant industry operating experience.

Corrective Action References: condition reports CR-CNS-2022-03653, CR-CNS-2023-05194, and CR-CNS-2024-00463

Performance Assessment:

Performance Deficiency: NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The inspectors determined that the licensees work instructions for the rebuild of RHR SWBP-D failed to incorporate instructions from the vendor that would have prevented a failure of the pump and was therefore a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure for rebuilding RHR SWBP-D failed to incorporate vendor instructions resulting in the pump being declared inoperable.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that this finding is of very low safety significance (Green) because the finding did not represent a deficiency affecting design or qualification of a mitigating structure, system, or component; did not involve the loss of a single-train technical specification (TS)system longer than its TS allowed outage time; did not represent the loss of probabilistic risk assessment (PRA) function one train of a multi-train system for greater than its TS allowed outage time; did not represent the loss of PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; did not represent the loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and did not represent the loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Additionally, the finding did not involve external events mitigating systems, the reactor protection system, fire brigade, or flexible coping strategies.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee relied upon skill of the craft and non-specific instructions to perform work on safety-related equipment. The licensee's failure to incorporate vendor instructions for maintenance on safety-related equipment demonstrated a lack of awareness for the risk involved and a lack of forethought for the potential to impact the operability of mitigating systems.

Enforcement:

Violation: Technical specification section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978.

NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Maintenance Procedure 7.2.14, "RHR SWBP Overhaul and Replacement," dated April 20, 2022, was a quality document that the licensee used to perform replacement of the outboard thrust bearing on SWBP-D.

Technical specification 3.7.1.a LCO requires two RHR SWBP subsystems, including two RHR SWBPs per subsystem, to be operable in Modes 1 through 3.

Contrary to the above, in July 2022, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, appendix A, section 9. Specifically, maintenance procedure 7.2.14 did not incorporate vendor guidance specifying torque requirements for the outboard thrust bearing. As a result, the outboard thrust bearing was over-tightened, and subsequently, while being placed in service on August 27, 2022, the RHR SWBP-D outboard bearing high temperature was high out of tolerance, rendering the pump inoperable. Because of this the RHR service water LCO was not met between July 29, 2022, and September 1, 2022.

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

Failure to Incorporate Vendor Instructions Resulting in Turbine Stop Valve Limit Switch Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000298/2024001-02 Management Open/Closed The inspectors are documenting a self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specification 5.4.1.a, "Instructions, Procedures, and Drawings," for the licensee's failure to implement maintenance that can affect the performance of safety-related equipment. Specifically, the work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor manual that would have prevented a failure of the limit switches.

Description:

On August 19, 2023, November 18, 2023, and January 3, 2024, safety-related limit switch A1 (NAMCO series EA740) for main turbine stop valve SV1 failed to actuate during performance of surveillance Procedure 6.RPS.302, Main Turbine Stop Valve Closure and Steam Valve Functional Test, revision 65. This surveillance ensures the reactor protection system limit switches associated with the turbine stop valve actuate upon a turbine stop valve closure. The limit switches are relied upon to initiate an automatic reactor scram upon closure of both turbine stop valves.

In both the August 2023 and November 2023 surveillance failures, the failures were initially attributed to operator action failures and the steps associated with limit switch A1 were reperformed. Limit switch A1 successfully actuated during the reperformance both times.

Following the November 2023 surveillance, Cooper Nuclear Station engineers determined that grease hardening could be a potential cause of the initial failure of limit switch A1 to actuate during the August 2023 and November 2023 surveillances. The licensee initiated corrective actions to increase the frequency of performing surveillance 6.RPS.302 from 13 weeks to 6 weeks. Additionally, prior to the performance of the surveillance on January 3, 2024, the licensee implemented a contingency whereby if a limit switch failed to actuate, the site would lower reactor power to 60 percent and replace the limit switch.

On January 3, 2024, after limit switch A1 again failed to actuate, the site lowered reactor power to 60 percent and replaced limit switches A1 and A2. Limit switch A2 was replaced despite passing the surveillance because limit switch A2 was in the same procurement batch as A1. The removed limit switches were sent to a lab for analysis to determine the cause of the failures.

The vendor manual for NAMCO series EA740 limit switches, Maintenance & Surveillance Instructions for EA740 Limit Switches, revision C (dated May 15, 1991), contains detailed instructions for ensuring the linkage is tightened correctly to the input shaft cam and ensuring proper alignment of components to prevent failure of the limit switch.

During the installation and post-work testing of the limit switches in November 2022, the work instructions for the installation failed to incorporate vendor installation details nor the did the work instructions contain guidance to verify proper alignment. The work package instructions for the installation of the limit switches utilized CNS Procedure 7.3.28.1, "Lead Removal/Installation and Lug Installation," revision 33. This procedure is a generic, high-level procedure that does not incorporate component-specific or vendor-specific guidance. As part of the licensees reportability process it was determined that the A1 limit switch was inoperable from August 19, 2023, to January 4, 2024.

Cooper Nuclear Station technical specification 3.3.1.1, table 3.3.1.1-1 states that when reactor power is greater than or equal 29.5 percent, two channels per trip system are required for the turbine stop valve closure reactor protection system. Condition A of technical specification 3.3.1.1 requires placing a channel in trip if a channel is inoperable. Since limit switch A1 was inoperable, this LCO was applicable. If the required action for condition A is not met, condition D requires entering condition E immediately per table 3.3.1.1-1.

Condition E requires reducing thermal power to less than 29.5 percent power. However, the station did not perform the actions of technical specifications 3.3.1.1, conditions A, D, or E within the required time frames. This represented a condition prohibited by technical specifications. As a result, the station submitted a licensee event report to the NRC to document the condition.

Based upon the above information the inspectors determined the following:

Contrary to technical specification 5.4.1.a and Regulatory Guide 1.33, the site did not properly utilize vendor manual guidance for developing work instructions for the installation of turbine stop valve limit switches, a safety-related component, which led to the failure of limit switch A1 for a period of time prohibited by technical specification 3.3.1.1.

Corrective Actions: The station entered the condition into its corrective action program as condition report CR-CNS-2024-00019. Additionally, the site reinstalled limit switches A1 and A2 using the vendor detailed instructions and reperformed the surveillance as post-work testing to ensure operability of the reactor protection system components. The vendor detailed instructions were also permanently incorporated into the work instructions for further installation practices. The B1 and B2 limit switches associated with turbine stop valve 2 are scheduled to be replaced during the fall 2024 refueling outage.

Corrective Action References: condition report CR-CNS-2024-00019

Performance Assessment:

Performance Deficiency: NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that "maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The inspectors determined that the licensees work instructions for the installation of turbine stop valve limit switches failed to incorporate instructions from the vendor that would have prevented a failure of the limit switches and was therefore a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure for installing the turbine stop valve limit switches failed to incorporate vendor instructions resulting in repeated failure of the A1 limit switch.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green) because the finding did affect a single RPS trip signal to initiate a reactor scram and did not affect the function of other redundant trips or diverse methods of reactor shutdown.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the site's utilization of a generic procedure without incorporating vendor-specific guidance was representative of the site's failure to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority.

Enforcement:

Violation: Technical specification section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978.

NRC Regulatory Guide 1.33, revision 2, appendix A, section 9, provides recommendations for "Procedures for Performing Maintenance." Part a of section 9, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Technical specification 3.3.1.1.a and 3.3.1.1.b LCO requires two reactor protection system instrumentation channels in each turbine stop valve closure scram to be operable while rated thermal power is greater than or equal to 29.5 percent.

Contrary to the above, on November 10, 2022, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, appendix A, section 9. Specially, the licensee failed to implement vendor-developed installation guidance for the turbine stop valve limit switches that specified steps for tightening the linkage to the cam shaft and aligning the actuator leading to the limit switch failing to actuate. Because of this the reactor protection system instrumentation LCO for the turbine stop valve closure scram was not met between August 19, 2023, and January 4, 2024.

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

Failure to Report Deviation of a Basic Component Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000298/2024001-03 Applicable Open/Closed EA-24-029 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(d)(1) for the licensee's failure to properly evaluate the reportability of a deviation in a basic component. As a result, the licensee failed to report a deviation identified on September 14, 2022, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected.

Description:

On August 27, 2022, a three-drop per minute oil leak was observed from the inboard bearing of RHR SWBP-D during a planned service water chemical injection. During the same run, SWBP-D was declared inoperable due to high outboard bearing temperature.

On September 20, 2022, while repairing SWBP-D, the licensee identified a difference in the inboard bearing cover plates labyrinth seal when compared to a spare. This defect affected the oil drain path and resulted in the three-drop per minute leakage. The licensee contacted Flowserve, the original equipment manufacturer, who determined a drawing error was introduced in 2012. The pump cover was fabricated in accordance with the drawing error resulting in oil leakage past the labyrinth seal along the pump shaft. The vendor provided information to restore the covers to the correct configuration.

On October 19, 2022, the licensee approved a 10 CFR Part 21(Part 21) discovery and reportability evaluation in accordance with station Procedure 0-CNS-LI-108-01, "10 CFR 21 Evaluations and Reporting," revision 2, which is derived from guidance in NEI-14-09, "Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance,"

revision 1. The evaluation incorrectly concluded this defect was not reportable as the defect would not create a substantial safety hazard if it were to remain uncorrected. The licensee's basis for not reporting the condition stated the pump could have operated consecutively for 10 days without operator action and that procedural guidance to take operator action by checking oil every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would maintain the operational status of the pump for the 30-day mission time and prevent a substantial safety hazard.

The vendor completed their own internal Part 21 evaluation, NPO-NNF-07, "Formal Evaluation of Deviation for Impact to Safety," revision 00, and submitted the results to the licensee on January 18, 2023. The vendor's evaluation stated the defect would result in a depletion of the 1-gallon oil reservoir within 10.5 days causing the inboard bearing to overheat. This would likely result in the pump rotor seizing, thus challenging the 30-day mission time of the pump. Additionally, the vendor asserted the defect is considered a potential safety hazard and confirmed they had only supplied the defective component to Cooper Nuclear Station. The licensee maintained their original position that the defect did not create a substantial safety hazard due to compensatory measures and the defect was not reportable.

On February 15, 2024, the inspectors reviewed the Part 21 evaluation and questioned the licensee's basis for determining this deviation would not create a substantial safety hazard and questioned the reportability of the defect. The licensee credited a compensatory measure to add oil, directed by station Procedure 2.2.70, "RHR Service Water Booster Pump System,"

revision 96, which would prevent the manifestation of a substantial safety hazard.

The inspectors determined the compensatory action was a correction to the defect and was not a disqualifier to submit notification to the NRC pursuant to 10 CFR 21.21(a)(1),notification of failure to comply or existence of a defect and its evaluation, which states in part, "evaluate deviations and failures to comply to identify defects and failures to comply associated with substantial safety hazards as soon as practicable, in order to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected."

The inspectors concluded the licensee should have submitted the Part 21 notification within two days following receipt of information regarding the defect from Flowserve as specified in 10 CFR 21.21(d)(3)(i).

Corrective Actions: The station entered the condition and the concerns raised by the resident inspectors into its corrective action program. The affected bearing housing covers were replaced or scheduled to be replaced, and the vendor will rework the affected bearing house covers and ensure the covers are machined correctly. Additionally, the licensee submitted the Part 21 notification (Event Number 57001) on March 1, 2024.

Corrective Action References: condition reports CR-CNS-2024-00463 and CR-CNS-2024-00693

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the failure to make a timely Part 21 report was contrary to licensee procedure 0-CNS-LI-108-01 and was a performance deficiency. This performance deficiency was minor because the inspectors answered No to all three screening questions in appendix B of IMC 0612.

Enforcement:

The ROPs 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.

Severity: This performance deficiency was evaluated in accordance with the Enforcement Manual and determined to be a Severity Level IV NCV because

(a) there was little to no impact to the inspection process/regulatory process,

(b) the seals were only supplied to Cooper Nuclear Station and no other licensees,

(c) the licensee entered the issue into the corrective action program and issued a Part 21 report to the NRC,

(d) the licensee only requires one SWBP to meet mission requirements, and

(e) the failure to report a defect did not have any impact on the function of any systems, structures, or components at Cooper Nuclear Station, so it would constitute a minor violation on the Reactor Oversight Process path of IMC 0612, appendix B.

Violation: Title 10 CFR 21.21(d)(1) requires, in part, that a responsible officer subject to the regulations of 10 CFR Part 21 must notify the Commission when he or she obtains information reasonably indicating a failure to comply or a defect affecting a basic component.

Contrary to the above, from October 27, 2022, to March 1, 2024, the licensee, subject to the regulations of 10 CFR Part 21, failed to notify the Commission after obtaining information reasonably indicating a failure to comply or a defect affecting a basic component. Specifically, on August 27, 2022, the licensee identified a three-drop per minute oil leak on RHR SWBP-D caused by a machining defect that resulted in the pump being inoperable and then failed to notify the Commission within 60 days after discovery of a defect associated with a substantial safety hazard evaluation described in 10 CFR 21.21(a)(1).

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

EXIT MEETINGS AND DEBRIEFS

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

• On April 18, 2024, the inspectors presented the integrated inspection results to Khalil Dia, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action CR-CNS-2024-00063, 2024-00067, 2024-00075, 2024-00077, 2024-

Documents 00080, 2024-00081, 2024-00082, 2024-00098, 2024-00120,

24-00125, 2024-00126, 2024-00127, 2024-00129, 2024-

00161, 2024-00275

71111.01 Procedures 5.1WEATHER Operation During Weather Watches and Warnings 22

71111.01 Procedures 5.2SW Service Water Casualties 34

71111.04 Corrective Action CR-CNS-2023-03071, 2023-03196, 2023-03696, 2023-05100, 2024-

Documents 00337, 2024-00454, 2024-00752, 2024-00758, 2024-00759,

24-00968, 2024-00969, 2024-00989

71111.04 Drawings DWG 2031, Flow Diagram Reactor Building Closed Cooling Water 24

Sheet 1 System

71111.04 Drawings DWG 2045, Flow Diagram Standby Liquid Control System 21

Sheet 2

71111.04 Procedures 2.2.70 RHR Service Water Booster Pump System 96

71111.04 Procedures 2.2.74A Standby Liquid Control System Component Checklist 12

71111.04 Procedures 2.2A.REC.DIV0 Reactor Equipment Cooling Water System Non-Divisional 18

Component Checklist

71111.04 Procedures 2.2A.REC.DIV2 Reactor Equipment Cooling Water System Component 3

Checklist (DIV 2)

71111.04 Procedures 2.2A.REC.DIV3 Reactor Equipment Cooling Water System Common 3

Divisional Component Checklist

71111.04 Procedures 5.2REC Loss of REC 21

71111.04 Procedures 6.SLC.101 SLC Pump Operability Test 29

71111.05 Corrective Action CR-CNS-2024-00041, 2024-00675, 2024-00958

Documents

71111.05 Fire Plans CNS-FP-228 Cooper Nuclear Station Fire Protection Pre-Fire Plan Control 8

Building Battery/SWGR RMS 1B Elevation 903 6

71111.05 Fire Plans CNS-FP-234 Fire Protection Pre-Fire Plan Office Building Cable 4

Expansion Room Elevation 918-6

71111.05 Fire Plans CNS-FP-236 Fire Protection Pre-Fire Plan Diesel Generator Building 7

DG#1 Elevations 917-6 and 903-6

71111.05 Fire Plans CNS-FP-256 Fire Protection Pre-Fire Plan Intake Structure Elevation 903-7

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Procedures 0-BARRIER-Reactor Building 16

REACTOR

71111.05 Procedures 0.23 Fire Protection Plan 93

71111.05 Procedures 2.2.30 Fire Protection System 84

71111.05 Procedures 3.6.1 Fire Barrier Control 22

71111.05 Procedures 5.1INCIDENT Site Emergency Incident 49

71111.05 Procedures 5.4Fire-S/D Fire Induced Shutdown from Outside Control Room 83

71111.05 Procedures 6.FP.204 Fire Door Examination 22

71111.06 Corrective Action CR-CNS-2013-04701

Documents

71111.06 Miscellaneous NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line Break3

71111.07A Drawings DWG KSV47-Jacket Water Schematic 1

9NP

71111.07A Miscellaneous CR-CNS-2024-00015, 2024-00445, 2024-00470, 2024-00472, 2024-

00477, 2024-00488

71111.07A Miscellaneous VM-1778 ITT/American Heat Exchangers Composite Manual 4

71111.07A Procedures 3.34 Heat Exchanger Program Implementation 20

71111.11Q Corrective Action CR-CNS-2023-04939

Documents

71111.11Q Procedures 10.13 Control Rod Sequence and Movement Control 78

71111.11Q Procedures 2.0.3 Conduct of Operations 107

71111.11Q Procedures 2.1.10 Station Power Changes 124

71111.11Q Procedures 2.1.5 Reactor Scram 79

71111.11Q Procedures 2.2.17 Emergency Station Transformer 80

71111.11Q Procedures 2.4PC Primary Containment Control 23

71111.11Q Procedures 4.2 Rod Worth Minimizer 31

71111.11Q Procedures 5.1QUAKE Earthquake 17

71111.11Q Procedures 5.7.1 Emergency Classification 73

71111.11Q Procedures 5.8.3 Alternate Rod Insertion Methods 18

71111.11Q Procedures EOP-1A RPV Control (1-3) 24

71111.11Q Procedures EOP-6A RPV Pressure/Reactor Power (Failure to Scram) 21

71111.11Q Procedures EOP-7A RPV Level (Failure to Scram) 23

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Corrective Action CR-CNS-2022-02184, 2023-04582, 2023-04902, 2023-05221, 2024-

Documents 00019, 2024-00071

71111.12 Miscellaneous CR-CNS-2023-Maintenance Rule (a)(1) Evaluation and Action Plan 1

04902

71111.12 Miscellaneous DGHV-PF04 Maintenance Rule Function DGHV-PF04 Performance 4

Criteria Basis

71111.12 Miscellaneous HV-F03 Maintenance Rule Function HV-F03 Performance Criteria 4

Basis

71111.12 Miscellaneous RPS-F01A Maintenance Rule Function RPS-F01A Performance Criteria 2

Basis

71111.12 Procedures 3-CNS-DC-203 Maintenance Rule Program 0

71111.12 Procedures 3-CNS-DC-204 Maintenance Rule Scope and Basis 0

71111.12 Procedures 3-CNS-DC-205 Maintenance Rule Monitoring 0

71111.12 Procedures 3-CNS-DC-206 Maintenance Rule (a)(1) Process 0

71111.12 Procedures 3-CNS-DC-324 Preventative Maintenance Program 8

71111.13 Miscellaneous DGA-1-DG1, Protected Equipment Tagout

Week 2405

71111.13 Miscellaneous EDC1-1-EE-BAT-Protected Equipment Tagout

250(1A) INOP

71111.13 Miscellaneous HPCI-1-HPCI Protected Equipment Tagout

ISOLATION

71111.13 Miscellaneous HPCI-1-HPCI-TP-Clearance Orders

S57-STEAM

LEAK

71111.13 Miscellaneous RHWB-1-Clearance Orders

5480050 SWBP

D

71111.13 Miscellaneous RHWB-1-Clearance Orders

5480579 SW-P-

BPB REBUILD

71111.13 Miscellaneous RHWB-1-SW-Protected Equipment Tagout

MO89B, WK 2407

71111.13 Procedures 0-BARRIER-16

REACTOR

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Procedures 0-CNS-WM-104 On-Line Schedule Risk Assessment 18

71111.13 Procedures 0-PROTECT-Protected Equipment Program 63

EQP

71111.13 Procedures 2.0.2 Operation Logs and Reports 124

71111.13 Procedures 2.0.3 Conduct of Operations 107

71111.13 Procedures 6.2SWBP.101 RHR Service Water Booster Pump Flow Test and Valve 37

Operability Test (DIV 2)

71111.13 Procedures 6.EE.601 125V/250V Station and Diesel Fire Pump Battery 7 Day 25

Check

71111.13 Work Orders WO 5432848, 5480050, 5480579

71111.15 Corrective Action CR-CNS-2006-08170, 2020-00340, 2023-02794, 2023-03794, 2023-

Documents 04939, 2023-05071, 2024-00019, 2024-00029, 2024-00033,

24-00037, 2024-00183, 2024-00260, 2024-00441, 2024-

00463, 2024-00617, 2024-00665, 2024-00643, 2024-00643-

CA-001, 2024-00686, 2024-00696, 2024-00700

71111.15 Drawings 3040, Sheet 9 Cooper Nuclear Station Control Elementary Diagrams 44

71111.15 Drawings 3045, Sheet 14 Control Elementary Diagrams 53

71111.15 Miscellaneous VM-1034 NAMCO Composite Limit Switch & Connector Manual 13

71111.15 Miscellaneous VM-1459 Drag Velocity Control Element Model 103190 AND 709791 4

71111.15 Procedures 6.RPS.302 Main Turbine Stop Valve Closure and Steam Valve 65

Functional Test

71111.15 Procedures 6.RPS.303 Turbine Stop Valve Closure Channel Calibration 19

71111.15 Procedures 7.2.70 Valve Packing Maintenance 16

71111.15 Procedures 7.3.28.1 Lead Removal/Installation and Lug Installation 34

71111.15 Work Orders WO 5282573, 5381769, 5382651, 5408016, 5417964, 5433573,

5443952, 5462978, 5524979

71111.18 Calculations NEDC 87-131A 250VDC Division 1 Load and Voltage Study 14C6

71111.18 Calculations NEDC 91-044 Cable Resistance Calculation for 125VDC and 250 VDC 5C5

Buses and Loads

71111.18 Corrective Action CR-CNS-2023-04770, 2023-04773, 2023-05221, 2024-00909

Documents

71111.18 Drawings SWG E150, Relay Settings for Battery Chargers & RPS MG Set Relays N13

Sheet 14

71111.18 Miscellaneous DEC-5521738 Diesel Generator Intake HVAC Hatch Securing Screws 0

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Miscellaneous Maintenance Plan

71111.18 Miscellaneous TCC-5501351 Temporary Configuration Change 0 (Field

Change

Revision 2)

71111.18 Miscellaneous VM-1188 125 & 250 Volt Batteries & Chargers 15

71111.18 Procedures 2.1.12 Control Room Data 149

71111.18 Procedures 3-CNS-DC-141 Design Inputs 0

71111.18 Procedures 3-EN-DC-115 Engineering Change Process 3C6

71111.18 Procedures 6.1EE.602 DIV 1 125V/250V Station Battery 92 Day Check 13

71111.18 Procedures 6.EE.601 125V/250V Station and Diesel Fire Pump Battery 7 Day 25

Check

71111.18 Procedures 6.EE.609 125V/250V Station Battery Intercell Connection Testing 23

71111.24 Corrective Action CR-CNS-2024-00260, 2024-00261

Documents

71111.24 Miscellaneous VM-0144 RHR Service Water Booster Pumps and Motors 36

71111.24 Procedures 6.1EE.602 DIV 1 125V/250V Station Battery 92 Day Check 13

71111.24 Procedures 6.2DG.104 Diesel Operability Test with Isolation Switches in Isolate 39

(DIV 2)

71111.24 Procedures 6.2SWBP.101 RHR Service Water Booster Pump Flow Test and Valve 36

Operability Test (DIV 2)

71111.24 Procedures 6.EE.609 125V/250V Station Battery Intercell Connection Testing 23

71111.24 Procedures 6.MISC.401 Position Indicator Inservice Testing (IST) 22

71111.24 Procedures 6.MS.201 Main Steam Isolation Valve Operability Test (IST) 29

71111.24 Procedures 6.RPS.302, Main Turbine Stop Valve Closure and Steam Valve 65

Section 5 Functional Test, Turbine Stop Valve Limit Switch Manual

Actuation

71111.24 Procedures 6.SWBP.201 SW-MO-89A/B Full Stroke Operability (IST) 7

71111.24 Procedures 7.3.28.1 Lead Removal/Installation and Lug Installation 34

71111.24 Procedures 7.5.12 SMB-0 Through SMB-4 MOV Refurbishment 18

71111.24 Procedures 7.5.8 Limitorque Mechanical/Electrical Examination 19

71111.24 Work Orders WO 5339776, 5381769, 5433573, 5434209, 5436535, 5437844,

5437845, 5479861, 5479879, 5479881, 5480054, 5480103,

5480244, 5489851, 5536537, 5537525,

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.06 Miscellaneous Cooper Nuclear Emergency Preparedness Drill

Station

Qualification Drill

71151 Corrective Action CR-CNS-2024-01006, 2023-04337

Documents

71151 Miscellaneous MSPI Derivation Reports 1Q23 thru 4Q23

71151 Miscellaneous Operator Logs 1Q23 thru 4Q23

71151 Procedures 0-CNS-LI-114 Regulatory Performed Indicator Process

71152A Corrective Action CR-CNS-2022-06623, 2022-06878, 2023-00982, 2023-02574, 2023-

Documents 03277, 2023-04455, 2024-00019, 2024-00260, 2024-00658,

24-00769, 2024-01035, 2024-01098

71152A Procedures EN-MS-S-013-System Engineering Work Planning and Prioritization 6C0

MULTI

71152S Corrective Action CR-CNS-2021-00194, 2023-04582, 2024-01036,

Documents

71152S Procedures 2.2.47 HVAC Reactor Building System 67, 68

71152S Procedures 3-CNS-DC-112 Engineering Change Request and Project Initiation Process3

71153 Corrective Action CR-CNS-2022-02184, 2022-03653, 2023-04582, 2023-04584, 2023-

Documents 04770, 2023-04775, 2023-04902, 2023-04939, 2023-05071,

23-05221, 2024-00019, 2024-00319, 2024-00325, 2024-

00463, 2024-00498, 2024-00655, 2024-00693, 2024-05194

71153 Miscellaneous VM-1034 NAMCO Composite Limit Switch & Connector Manual 13

71153 Procedures 6.2SWBP.101 RHR Service Water Booster Pump Flow Test and Valve 36

Operability Test (DIV 2)

71153 Procedures 6.RPS.302 Main Turbine Stop Valve Closure and Steam Valve 65

Functional Test

71153 Procedures 6.RPS.303 Turbine Stop Valve Closure Channel Calibration 19

71153 Work Orders WO 5327796, 5433802, 5460250, 5520987

23