IR 05000298/2019001

NRC Integrated Inspection Report 05000298/2019001

ML19130A227
Person / Time
Site:	Cooper
Issue date:	05/10/2019
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2019001
Download: ML19130A227 (26)

Text

SUBJECT:

COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000298/2019001

Dear Mr. Dent:

On March 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station and 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 one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements.

If you contest the violation or significance of the violation 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.

J. Dent, Jr. 2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jason W. Kozal, Chief Reactor Projects Branch C Docket No. 50-298 License No. DPR-46 Enclosure:

Inspection Report 05000298/2019001 w/attachment: Detailed Risk Evaluation

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000298 License Numbers: DPR-46 Report Numbers: 05000298/2019001 Enterprise Identifier: I-2019-001-0003 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, NE 68321 Inspection Dates: January 01, 2019, to March 31, 2019 Inspectors: M. Stafford, Resident Inspector (BWR)

P. Vossmar, Senior Resident Inspector (BWR/TL)

Approved By: Jason W. Kozal Chief, Reactor Projects Branch C Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a quarterly 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. Violations being considered in the NRCs assessment and additional items are summarized in the tables below.

List of Findings and Violations Failure to Maintain Configuration Control of a Fire Zone Boundary Barrier Resulting in a Fire Cornerstone Significance Cross-cutting Report Aspect Section Initiating Events Green [H.11] - 71152 NCV 05000298/2019001-01 Challenge the Open/Closed Unknown The inspectors reviewed a self-revealed, non-cited violation of License Condition 2.C(4), Fire Protection, for the failure to implement in effect all provisions of the approved fire protection program. Specifically, on September 19, 2018, the licensee failed to implement configuration control requirements for an FP2 fire zone boundary barrier during work activities associated with Maintenance Procedure 7.2.78.2, Pipe Penetration Seal Installation Using Gasket Placement, Revision 1. Contrary to procedure requirements, during work on a pipe penetration between the radwaste and augmented radwaste buildings, maintenance personnel injected a combustible foam sealant (Avanti-248) on piping that exceeded 150 degrees Fahrenheit. On December 29, 2018, the sealant caught fire, resulting in emission of toxic smoke and declaration of a Notification of Unusual Event.

Additional Tracking Items Type Issue Number Title Inspection Status Procedure LER 05000298/2018-001-00 Inadequate Packing on Motor 71153 - Closed Operated Valve Results in Follow-up of Unplanned High Pressure Events and Coolant Injection Notices of Inoperability and a Loss of Enforcement Safety Function Discretion LER 05000298/2018-003-00 Safety Valve Failure Results 71153 - Closed in Loss of Safety Function Follow-up of Events and Notices of Enforcement Discretion

PLANT STATUS

Cooper Nuclear Station began the inspection period at rated thermal power. On February 22, 2019, the licensee reduced power to 70 percent for a control rod sequence exchange. The plant was returned to rated thermal power on February 23, 2019 and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection External Flooding Sample (IP Section 03.04)

On March 11, 2019, the inspectors evaluated readiness to cope with external flooding for the following areas:

• Intake structure;

• Reactor building basement areas;

• Turbine building basement areas;

• External plant levees.

Impending Severe Weather Sample (IP Section 03.03) (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for a winter weather advisory on January 18, 2019.

71111.04 - Equipment Alignment Partial Walkdown (IP Section 02.01)

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

(1) Standby liquid control B with standby liquid control A out of service for maintenance on January 14, 2019;

(2) Emergency diesel generator 2 starting air during emergency diesel generator 1 maintenance on February 5, 2019;

(3) Reactor equipment cooling subsystem B with reactor equipment cooling A out of service for maintenance on March 11, 2019.

71111.04S - Equipment Alignment Complete Walkdown (IP Section 02.02)

The inspectors evaluated system configurations during a complete walkdown of the high pressure coolant injection system on March 8, 2019.

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

The inspectors evaluated fire brigade performance on January 18, 2019.

71111.05Q - Fire Protection (Quarterly) Quarterly Inspection (IP Section 03.01)

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

(1) Waste collector drain tank room on January 10, 2019;

(2) Torus basement area on February 11, 2019;

(3) Fire pump building on February 12, 2019;

(4) Intake structure and service water pump room on March 4, 2019;

(5) Southwest quad 859 feet elevation, Division 2 residual heat removal and high pressure coolant injection room on March 5, 2019.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

The inspectors observed and evaluated licensed operator performance in the control room during the first quarter downpower on February 23, 2019.

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

The inspectors observed and evaluated a simulator scenario on March 26, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

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

(1) MS-AO-738 and MS-AO-739 reactor vessel head vent valves on March 29, 2019;

(2) Primary containment pressure monitoring and relief on March 29, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

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

(1) Residual heat removal D and service water booster pump D maintenance windows on January 16, 2019;

(2) Residual heat removal loop B maintenance window on January 25, 2019;

(3) Reactor feed pump A discharge valve, RF-MOV-29MV, packing torque adjustment on January 30, 2019;

(4) Emergency diesel generator 1 maintenance window on February 7, 2019;

(5) Reactor equipment cooling heat exchanger cleaning and reactor core isolation cooling maintenance windows on March 6, 2019;

(6) Emergent flooding preparations on March 14, 2019.

71111.15 - Operability Determinations and Functionality Assessments Sample Selection (IP Section 02.01)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Elevated release point sump discharge check valve functionality on February 1, 2019;

(2) Emergency diesel generator 1 turbo bearing wear on February 19, 2019;

(3) High pressure coolant injection minimum flow valve closure signal failed to actuate on March 25, 2019;

(4) Emergency diesel generator 2 jacket water heat exchanger flange leak on March 25, 2019.

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) High pressure coolant injection steam isolation valve, HPCI-MO-16, backseating due to packing leakage on February 6, 2019;

(2) Reactor feed pump A discharge valve, RF-MOV-29MV, sealant injection modification on February 23, 2019.

71111.19 - Post Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Standby liquid control post work test on January 11, 2019;

(2) Residual heat removal B subsystem testing following system maintenance on January 25, 2019;

(3) Reactor feed pump A discharge valve, RF-MOV-29MV, backseat and packing adjustment post work testing on January 28, 2019;

(4) Reactor equipment cooling pump A testing following pump replacement on January 31, 2019;

(5) Diesel fire pump D testing following hose, belt, and oil change on March 27, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IST) (IP Section 03.01)

(1) High pressure coolant injection pump and valve quarterly inservice test on January 18, 2019;

(2) Emergency diesel generator fuel oil transfer pump inservice test on March 6, 2019.

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Standby liquid control chemistry sample on January 9, 2019;

(2) Northwest quad fan coil unit flow test on February 11, 2019;

(3) 4160 V critical switchgear undervoltage relay testing on March 1, 2019.

71114.06 - Drill Evaluation Emergency Preparedness (EP) Drill (IP Section 02.01)

Emergency preparedness drill on February 26,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

January 1, 2018 - December 31, 2018 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(1 Sample)

January 1, 2018 - December 31, 2018

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

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

(1) Operator challenge assessment on February 7, 2019;

(2) Declaration of a Notification of Unusual Event due to fire resulting in toxic gas on March 28, 2019;

(3) Unplanned shutdown due to high pressure coolant injection packing leakage on March 29, 2019.

Semiannual Trend Review (IP Section 02.02) (1 Sample)

The inspectors reviewed the licensees corrective action program for potential adverse trends in emergency preparedness and training performance that might be indicative of a more significant safety issue.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated when elevated release point sumps were nonfunctional which challenged standby gas treatment operability, and the licensees response, on January 30, 2019;

(2) The inspectors evaluated the March 2019 Missouri river flooding and the licensees response on March 25, 2019.

Event Report (IP Section 03.02) (2 Samples)

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

(1)

• LER 05000298/2018-001-00, Inadequate Packing on Motor Operated Valve Results in Unplanned High Pressure Coolant Injection Inoperability and a Loss of Safety Function, (ADAMS Accession: ML18136A539):

The inspectors concluded that no violation of NRC requirements occurred.

(2)

• LER 05000298/2018-003-00, Safety Valve Failure Results in Loss of Safety Function, (ADAMS Accession: ML18353A279):

Based on information at the time of inspection, the inspectors did not identify a violation of NRC requirements. The inspectors are awaiting Revision 1 to the LER, which will include the licensee's causal determination.

INSPECTION RESULTS

Failure to Maintain Configuration Control of a Fire Zone Boundary Barrier Resulting in a Fire Cornerstone Significance Cross-cutting Report Aspect Section Initiating Events Green [H.11] - 71152 NCV 05000298/2019001-01 Challenge the Closed Unknown The inspectors reviewed a self-revealed, non-cited violation of License Condition 2.C(4), Fire Protection, for the failure to implement in effect all provisions of the approved fire protection program. Specifically, on September 19, 2018, the licensee failed to implement configuration control requirements for an FP2 fire zone boundary barrier during work activities associated with Maintenance Procedure 7.2.78.2, Pipe Penetration Seal Installation Using Gasket Placement, Revision 1. Contrary to procedure requirements, during work on a pipe penetration between the radwaste and augmented radwaste buildings, maintenance personnel injected a combustible foam sealant (Avanti-248) on piping that exceeded 150 degrees Fahrenheit. On December 29, 2018, the sealant caught fire, resulting in emission of toxic smoke and declaration of a Notification of Unusual Event.

Description:

On December 29, 2018, Cooper experienced a fire in the augmented offgas (AOG) system pipe penetration F between the radwaste (RW) and augmented radwaste (ARW) buildings. The fire created hazardous smoke, preventing normal access to the RW and ARW buildings. As a result, the licensee declared a Notification of Unusual Event. The fire was caused by the licensees inappropriate injection of Avanti AV-248, a combustible foam sealant, into the penetration to address groundwater in-leakage.

Specifically, on September 19, 2018, maintenance personnel removed some of the insulation on piping running through penetration F and injected AV-248 sealant in response to groundwater in-leakage. The penetration contained AOG piping that normally operates at 500 degrees Fahrenheit (F). The licensee had a history of in-leakage at this location and had previously injected various types of Avanti sealant in 2004, 2011, and July 2018. During the July 2018 injection, noncombustible AV-315 was used because AV-248 was not allowed to be used in this location. On September 19, 2018, after AV-315 failed to adequately prevent the in-leakage, maintenance personnel injected AV-248 into the penetration. At the time the work activity occurred, the maintenance personnel questioned the use of AV-248 due to procedure limitations. Specifically, Maintenance Procedure 7.2.78.2, Pipe Penetration Seal Installation Using Gasket Placement, Revision 1, which was controlling the work, stated in Step 2.1, Avanti AV-248 Flexseal can be installed on piping systems with a maximum operating temperature up to 150 degrees F and, due to head pressure limitations, is not to be used on a penetration with the lowest point less than 886 feet elevation. Penetration F contained piping with 500 degrees F normal operating temperatures and was located in a basement elevation below 886 feet. Despite procedure compliance concerns, work continued due to an assumption that AV-248 was only combustible in its liquid form, and curing would occur prior to placing the 500 degrees F piping back in service.

On December 27, 2018, the licensee noticed a smoky haze around Penetration F. After engaging the vendor and discovering that the sealant material in the penetration was combustible, operations personnel acted to secure steam to AOG so that the combustible sealant could be removed. The licensee waited approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> before opening access covers on either side of the penetration tunnel. Sealant removal was performed with two teams, one on either side of the penetration. When the first team opened the access cover on the RW side and began removing sealant, they discovered unexpected smoke and notified supervision. Plant supervision determined that the first team should wait for the smoke to dissipate before resuming work. However, rather than stop the activity due to the uncertain conditions that were discovered, the licensee allowed the second team to continue work on the ARW side of the penetration. When the second team removed enough sealant from the second access point, they introduced fresh air into the space, which caused the AV-248 sealant that was already smoldering to ignite and release toxic fumes (carbon dioxide, carbon monoxide, nitrogen oxides).

Following the event, the inspectors reviewed the licensees apparent cause evaluation and applicable fire protection program requirements. The penetration in question was part of an FP2 fire zone boundary barrier. While not a fire-rated barrier credited in NFPA-805 nuclear safety capability analysis or controlled by the technical requirements manual, the barrier was credited in the licensees fire probabilistic risk analysis. As a result, according to Fire Protection Program Procedure 0.23, CNS Fire Protection Plan, Revision 79, FP2 barriers are qualified fire boundaries that must meet the requirements of the fire protection program.

Because the fire protection program requires control of installed combustible materials via configuration control through approved plant procedures, the inspectors determined that this issue represented a violation of the licensees fire protection program.

Corrective Action(s): Corrective actions included extinguishing the fire, removing all combustible sealant from the penetration, and long term actions to seal the penetration with a mechanical seal.

Corrective Action Reference(s): CR-CNS-2018-08638

Performance Assessment:

Performance Deficiency: The licensees failure to implement fire protection program configuration control requirements for an FP2 barrier was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the protection against external factors (including fire) attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency resulted in a fire that prevented normal access to the radwaste and augmented radwaste building basements, prevented operation of the augmented offgas system, and resulted in a plant emergency declaration.

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. The inspectors determined that the finding required a detailed risk evaluation (DRE) because it impacted the frequency of a fire or internal flooding initiating event. The DRE combined initiating event probabilities with the total conditional core damage and conditional large early release probabilities and estimated that the fire resulted in an increase in core damage frequency of 7.0E-7/year, and an increase in large early release frequency of 3.1E-8/year. As a result, the performance deficiency had very low safety significance (Green). The DRE is included as Attachment 1 to this report.

Cross-cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, workers were uncertain about the use of AV-248 prior to sealant injection, and again when smoke was unexpectedly found during subsequent sealant removal from the penetration; however, in each case the work activity was not stopped, and risks were not evaluated or addressed prior to proceeding.

Enforcement:

Violation: License Condition 2.C(4) requires, in part, that, NPPD shall implement and maintain in effect all provisions of the approved fire protection program. Fire Protection Program Procedure 0.23, CNS Fire Protection Plan, Revision 79, defines FP2 barriers as qualified fire boundaries that meet the requirements of the Fire Protection Program, and further states, in Section 5, Fire Prevention, that nontransient combustible materials are controlled by the configuration control process. Procedure 0.31, Equipment Status Control, Revision 89, states, all deviations from normal configuration shall be controlled by approved documents. Maintenance on the FP2 barrier penetration between the radwaste and augmented radwaste building basements was controlled by Maintenance Procedure 7.2.78.2, Pipe Penetration Seal Installation Using Gasket Placement, Revision 1. Step 2.1 states, in part, Avanti AV-248 Flexseal can be installed on piping systems with a maximum operating temperature up to 150 degrees F.

Contrary to the above, on September 19, 2018, the licensee failed to ensure that Avanti AV-248 Flexseal was installed on piping systems with a maximum operating temperature of up to 150 degrees F. Specifically, maintenance personnel injected AV-248, a combustible foam sealant, into an FP2 barrier penetration between the radwaste and augmented radwaste building basements on piping with an operating temperature of 500 degrees F. As a result, on December 29, 2018, the sealant caught fire, resulting in emission of toxic smoke and declaration of a Notification of Unusual Event.

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, 2019, the inspectors presented the quarterly integrated resident inspection results to Mr. K. Dia, Acting Site Vice President and Chief Nuclear Officer, and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed the most recently issued Institute of Nuclear Power Operations report during the inspection period.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Condition Reports (CR-CNS-)

2019-00304

Procedures

Number Title Revision

5.1FLOOD Flood 25, 26, 27

5.1WEATHER Operation During Weather Watches and Warnings 19

7.0.11 Flood Control Barriers 31

Drawings

Number Title Revision

4003 Overall Site & Vicinity Plan 45

4005, Sheet 5 Paving, Grading & Drainage 3

L-21755 Cooper Nuclear Station - 345/161 kV Substation 6

71111.04 - Equipment Alignment

Condition Reports (CR-CNS-)

2016-03874 2016-06346 2017-06179 2018-01346 2019-01343

2019-01346 2019-01368

Work Orders

238426 5240696 5242443

Procedures

Number Title Revision

2.2.33A High Pressure Coolant Injection System Component 32

Checklist

2.2.33B High Pressure Coolant Injection System Instrument 8

Valve Checklist

2.2.74A Standby Liquid Control System Component Checklist 11

2.2.74B Standby Liquid Control System Instrument Valve 1

Checklist

2.2A.DG.DIV2 Standby AC Power System (Diesel Generator) 7

Component Checklist

2.2A.REC.DIV2 Reactor Equipment Cooling Water System Component 1

Checklist

2.2B.REC.DIV2 Reactor Equipment Cooling Water System Instrument 0

Valve Checklist

Drawings

Number Title Revision

2031, Sheet 2 Flow Diagram - Reactor Building - Closed Cooling N65

Water System

2031, Sheet 3 Flow Diagram - Reactor Building - Closed Cooling AB/34

Water System

2044 High Pressure Coolant Injection and Reactor Feed 84

System

2045 Flow Diagram - Standby Liquid Control System N21

Miscellaneous

Documents

Number Title Revision/Date

High Pressure Coolant Injection System Health Report 12/2018

EC 18-055 Backseating Evaluation of HPCI-MOV-MO16 0

VM-0248 Crane Valve Composite Manual 16

VM-1282 Ohio Brass Valves 0

VM-1692 CT224 12 Channel Temperature Monitor, SLC-C-100 3

Controller

71111.05 - Fire Protection

Procedures

Number Title Revision

0.23 CNS Fire Protection Plan 79

0-BARRIER- Barrier Maps 9

MAPS

5.1INCIDENT Site Emergency Incident 39

5.4POST-FIRE- Turbine Building/Outside Areas Post-Fire Operational 5

Turbine Information

6.FP.305 Halon 1301 Service Water Pump Room Fire 17

Suppression Surveillance Checks

6.FP.606 Fire Barrier/Penetration Seal Visual Examination 25

Miscellaneous

Documents

Number Title Revision/Date

Fire Brigade Scenario #38 01/15/2019

CED 6029281 Bypass SW Halon Tanks Pressure Switches 0

CNS-FP-392 Reactor Building Suppression Pool, Elevation 859-9 AA/00

CNS-FP-214 Reactor Building Southwest Quadrant, Elevation 859-9 4

and 881-9

CNS-FP-39 Reactor Building Suppression Pool, Elevation 881-9 AA/00

CNS-FP-251 Turbine Building - Turbine Operating Floor AC/11

Miscellaneous

Documents

Number Title Revision/Date

CNS-FP-252 Turbine Building - Non-Critical Switchgear Room AB/04

CNS-FP-256 Intake Structure, Elevation 903 -6 5

CNS-FP-257 Radwaste Building Basement Floor, Elevation 877-6 8

CNS-FP-262 Augmented Radwaste Building Basement Floor, 4

Elevation 877-6

CNS-FP-265 Fire Protection Pump Rooms, Elevation 903-6 3

71111.11 - Licensed Operator Requalification Program

Condition Reports (CR-CNS-)

2019-01048 2019-01049 2019-01890

Procedures

Number Title Revision

0-EN-TQ-210 Conduct of Simulator Training 9C3

2.1.10 Station Power Changes 116

2.2.28.1 Feedwater System Operation 97

2.3_A-2 Panel A - Annunciator A-2 41

15.RF.101 RFPT Stop Valve Test 6

15.RF.102 RFPT Backup Oil Pumps and Filter/Cooler Differential 7

Pressure Alarm Tests

15.RF.103 RFPT Thrust Bearing Wear and Failure Alarm Test 3

Miscellaneous Documents

Title

Licensed Operator Requalification Scenario for 3/26/19

71111.12 - Maintenance Effectiveness

Condition Reports (CR-CNS-)

2016-07742 2018-07736 2018-07780 2018-08411 2019-00668

Work Orders

274155 5274250

Miscellaneous

Documents

Number Title Revision

Maintenance Rule Function PC-COMP1 3

Maintenance Rule Function PC-F03 4

Maintenance Rule Function PC-PF02 8

Miscellaneous

Documents

Number Title Revision

Maintenance Rule Function MS-F04 Performance Criteria 4

Basis

274251 TCC

DEC-5274251 MS-AOV-739AV Indicating Lights 1

Notifications

11579749 11584473 11586252 11589374

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Condition Reports (CR-CNS-)

2018-00440 2018-00674 2019-00241 2019-00305 2019-00333

2019-00425

Work Orders

284609 5284612

Procedures

Number Title Revision

0-BARRIER Barrier Control Process 27

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

0-PROTECT-EQP Protected Equipment Program 44

Miscellaneous

Documents

Number Title Revision/Date

Missouri River Flood Protection Plan

Protected Equipment Program Tracking Form - DG 1 02/04/2019

LCO Maintenance Week 1906

Protected Equipment Program Tracking Form - 01/13/2019

EE-CHG-125VDC 1B Maintenance Window

Protected Equipment Program Tracking Form - RCIC 03/04/2019

Window Week 1910

Protected Equipment Program Tracking Form - RHR 01/23/2019

Div 2 Window

Protected Equipment Program Tracking Form - RHR 01/15/2019

Pump D Maintenance

Protected Equipment Program Tracking Form - 01/15/2019

SWBP D Maintenance Window

Protected Equipment Program Tracking Form - Week 03/03/2019

1909 REC HX A Maintenance

OI 11 Operations Instruction - Aggregate Risk Assessment 12

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports (CR-CNS-)

2005-03329 2019-00439 2019-00443 2019-00534 2019-00549

2019-00553 2019-00569 2019-00702 2019-00757 2019-01659

2019-01680 2019-01945

Work Orders

5174247 5183073

Procedures

Number Title Revision

2.3_DG1 Panel DG-1 - Annunciator DG-1 21

6.HPCI.312 HPCI Pump Low Discharge Flow Channel Calibration 10

6.HPCI.712 HPCI Pump Low Discharge Flow Channel Functional 4

Test

Drawings

Number Title Revision

2044 Flow Diagram High Pressure Coolant Injection and 76

Reactor Feedwater Systems

2005, Sheet 2 Flow Diagram - Misc. Drains, Vents and Seal Systems N49

2192 Composite Yard Piping Arrangement Plan AB06

2193 Composite Yard Piping Arrangement Sections N05

450212268 Detector Wear N03

454223426 Composite Control Air Schematic AB/09

Miscellaneous

Documents

Number Title Revision

Floating Head Heat Exchanger Training Documents

NEDC 97-023 HPCI Minimum Flow Line Evaluation 1, 2, 3

Notifications

11583394 11586078 11594524

71111.18 - Plant Modifications

Condition Reports (CR-CNS-)

2018-08548 2018-08579 2019-00149 2019-00305 19-00339

2019-00498

Work Orders

5175367 5279727 5284046 5284609

Procedures

Number Title Revision

2.2.28A Feedwater System Component Checklist 31

6.HPCI.201 HPCI Valve Operability Test (IST) 28

Drawings

Number Title Revision

2015081 18 Anchor Gate Valve N01

Miscellaneous Documents

Title Revision/Date

CEM Slides for WO 5284609 to Address Temporary Leak Repair of Reactor

Feed A Discharge Valve

Risk Management Plan for Downpower and Reactor Feed Pump A 02/22/2019

Discharge Valve Maintenance

Valve Pack AX MSDS

Valve Packing Datasheet: CNS-0-RF-MOV-29MV 1

Engineering

Reports

Number Title Revision

EC 18-055 Backseating Evaluation of HPCI-MOV-MO16 0

EC 5284612 RF-MOV-29MV Packing Injection 0-2

71111.19 - Post Maintenance Testing

Condition Reports (CR-CNS-)

2019-00092 2019-00117 2019-00157 2019-00305 2019-00398

2019-00579 2019-00582 2019-01955 2019-01956

Work Orders

5117595 5171525 5175369 5188891 5207682 5209529 5209530

209531 5209532 5209539 5209540 5209542 5209544 5209570

209576 5209577 5209584 5210430 5210828 5211204 5211566

232527 5266729 5268847 5284609 5284612 52114961

Procedures

Number Title Revision

0.31MOV Motor Operated Valves 4

2.2.28 Feedwater System Startup and Shutdown 107

6.FP.101 Fire Pump Operability Test 43

6.SLC.101 SLC Pump Operability Test 26

6.1REC.101 REC Surveillance Operation (IST)(DIV 1) 20

6.2RHR.101 RHR Test Mode Surveillance Operation 38

Procedures

Number Title Revision

6.2RHR.201 RHR Power Operated Valve Operability Test 34

7.0.5 CNS Post-Maintenance Testing 59

7.5.8 Limitorque Mechanical/Electrical Examination 18

Miscellaneous

Documents

Number Title Revision

NUREG-1482 Guidelines for Inservice Testing at Nuclear Power Plants 2

71111.22 - Surveillance Testing

Condition Reports (CR-CNS-)

2016-03034 2019-00277 2019-00298 2019-00747 2019-00756

2019-00758 2019-00759 2019-00761 2019-00844 2019-01241

Work Orders

5112642 5207784

Procedures

Number Title Revision

6.HPCI.103 HPCI IST and 92 Day Test Mode 58

6.SLC.601 SLC Tank Sampling 12

6.1DG.401 Diesel Generator Fuel Oil Transfer Pump IST Flow Test 37

6.1EE.306 4160 Bus 1F Undervoltage Relay Channel Functional 4

Test

6.1HV.603 Air Flow Test of Fan Coil Unit FC-R-1J (DIV 1) 3

7.3.28.1 Lead Removal/Installation and Lug Installation 32

8.7.1.4 Boron Potentiometric Analysis (High Range) 12

Miscellaneous

Documents

Number Title Revision

EN-MA-118 Foreign Material Exclusion 9C0

GE SIL-336 Surveillance Testing Recommendations for HPCI and 0, 1

RCIC Systems

GE SIL-352 HPCI Turbine Stop Valve Steam Balance Chamber 0

Pressure Adjustment Implemented

71114.06 - Drill Evaluation

Condition Reports (CR-CNS-)

2019-01118 2019-01467

Procedures

Number Title Revision

0-EN-EP-306 Drills and Exercises 9C0

5.7.1 Emergency Classification 62

5.7.2 Emergency Director EPIP 36

Miscellaneous Documents

Title

Drill Scenario Package for 2/26/19 EP Drill

71151 - Performance Indicator Verification

Miscellaneous Documents

Title Date

2018 PI Validation Package 01/14/2019

CNS Operations Narrative Logs - May 2018 and November 2018

71152 - Problem Identification and Resolution

Condition Reports (CR-CNS-)

2017-02937 2018-01346 2018-04112 2018-04585 2018-04586

2018-08579 2018-08584 2018-08609 2018-08614 2018-08615

2018-08621 2018-08638 2018-08657 2019-00026 2019-00161

2019-00184 2019-00214 2019-00248 2019-01383 2019-01977

2019-02073 2019-02093

Work Orders

4368108 4783927 4789594 5254033 5260786 5260787 5266327

Procedures

Number Title Revision

0.23 CNS Fire Protection Plan 79

0.31 Equipment Status Control 89

0.31.1 Configuration Control During Maintenance Activities 9

0.7.1 Control of Combustibles 40

0-BARRIER Barrier Control Process 27

2.0.12 Operator Challenges 12

6.FP.606 Fire Barrier/Penetration Seal Visual Examination 25

7.2.78.2 Pipe Penetration Seal Installation Using Gasket 1

Placement

Drawings

Number Title Revision

28 Structural Augmented Radwaste Building Modifications 4

to Existing Radwaste Building - SH 1

Miscellaneous

Documents

Number Title Revision

Curtis Wright Packing Guide 5

EE 18-028 Various MOV Packing Load Adjustment Calculation 0

Revisions

EE 18-030 HPCI-MOV-MO16 Packing Adequacy 0

EPRI Technical Valve Packing Maintenance and Program Practices 1

Report

NEDC 10-004 Fire PRA Plant Boundary Definition and Partitioning 2

NEDC 10-080 NFPA 805 Chapter 3 Fundamental Fire Protection 4

Program and Design Elements Review

NEDC 14-043 Fire Safety Analysis for Entire Power Block 1

Operations Operations Routine Duties 73

Instruction #25

Notifications

10656343 11152470 11343404 11361838 11375256 11383555 11425458

11458460 11465713 11470178 11480499 11494730 11513724 11515171

11542935 11547258 11559692 11563581 11564210 11564621 11566741

11567991 11568779 11569204 11570043 11571041 11575092 11575173

11575663 11577547 11577550

71153 - Follow-up of Events and Notices of Enforcement Discretion

Condition Reports (CR-CNS-)

2018-01323 2018-01327 2018-01341 2018-01344 2018-01346

2018-01369 2018-06301 2018-06791 2019-00005 2019-00534

2019-00549 2019-00553 2019-00569 2019-01754 2019-01757

2019-01765

Work Orders

238426

Procedures

Number Title Revision

2.2.27 Equipment, Floor, and Chemical Drain System 59

2.3_S-1 Panel S - Annunciator S-1 30

5.1FLOOD Flood 25, 26

6.MS.401 Main Steam Safety Valve (SV) Testing (IST) 13

Drawings

Number Title Revision

2037 Flow Diagram - H&V Standby Gas Treatment & Off Gas 71

Drawings

Number Title Revision

Filters

Miscellaneous

Documents

Number Title Revision/Date

LBDCR 2007-018 TRM 3.7.1 and Bases River Level Change 06/12/2007

M266 Elevated Release Point Sump Drain Valve Installation 10

TR-113560 EPRI Topical Report for Dresser 3700 Series Relief 09/2000

Valves

Detailed Risk Evaluation

Cooper Nuclear Station

Penetration Sealant Fire

The analyst assumed that the sealant ignited and due to its location, the sealant could have

burned further and could have potentially caused fires in both the augmented radwaste building

basement and the radwaste building basement. As a result, two fire scenarios, one in each

basement room, were considered.

The analyst developed the initiating event probabilities for the two fire scenarios using the

following equation set forth in Volume 2, External Events, of the Risk Assessment of

Operational Events (RASP) Handbook:

IEfreq = Fif * SF * Pns, where

Ffi = Fire ignition frequency

SF = Severity Factor

Pns = Non-suppression probability

Using the guidance in Chapter 8, Initiating Events Analysis, Volume 1, Internal Events, of the

RASP Handbook, the analyst set Ffi, the fire ignition frequency, equal to 1.0 since an actual fire

event had occurred and all other fire initiating events were set to 0.0.

For development of the severity factor of the fires, the analyst used Appendix D, Severity

Factor vs. Vertical Distance to Target Above Ignition Source, and Appendix E, Severity Factor

vs. Radial Distance from Ignition Source to Target, from Attachment 8, Tables and Plots

Supporting the Phase 2 Risk Quantification, of Appendix F, of Manual Chapter 0609,

Appendix F, Fire Protection Significance Determination Process. After reviewing publicly

published information on the sealant material, the analyst considered the fire was best treated

as a transient fire. Discussions with the resident inspectors who toured the area of the fire

shortly after the fire event revealed that there were no targets or intervening combustibles within

feet of the fire event or sealant. Using Figure D.01, Severity Factor vs. Vertical Target

Distance for Motor, Pump, and Transient Fires, and Figure E.01, Severity Factor vs. Radial

Target Distance for Motor, Pump, and Transient Fires, the analyst estimated a severity factor

of 0.02. This analyst considered this to be a conservative assumption since there were no risk

significant targets in the areas and the combustibles were farther away than the lowest severity

factor of 0.02 in the referenced figures.

The analyst assigned a nonsuppression probability of 1.0 and assumed there were no automatic

suppression systems in the rooms and that the fire brigade would not be effective at

suppressing the fire. The analyst also viewed this as a conservative assumption.

In combining the assumed values, the initiating event probabilities of the fires in the two rooms

was estimated to be 2.0E-2, as calculated by:

IEfreq = Fif * SF * Pns

IEfreq = 1.0 * 0.02 * 1.0

IEfreq = 0.02 or 2.0E-2

The analyst used the licensees fire probabilistic risk assessment results to obtain a conditional

core damage probability to apply. Licensee Calculation NEDC 09-085, Task 7.14, Fire Risk

Quantification, Revision 3, Table D-6, All Fire Scenarios Sorted by Core Damage Frequency -

Post NFPA 805, detailed the following:

Scenario Conditional Core Scenario Conditional Large

Damage Probability Early Release Probability

Radwaste Building Basement 2.44E-5 8.69E-7

Augmented Radwaste 1.04E-5 6.65E-7

Building Basement

Combined Total 3.48E-5 1.53E-6

The analyst noted that the conditional core damage probability resulted largely from random

probabilistic failures and not from actual mitigating equipment becoming damaged in postulated

fire scenarios which led to considering the total conditional core damage and large early release

probabilities to be conservative.

When the analyst combined the initiating event probabilities with the total conditional core

damage and conditional large early release probabilities and multiplied the results by an inverse

year, estimates of an increase in core damage frequency of 7.0E-7/year and an increase in

large early release frequency of 3.1E-8/year for the fire event resulted. Use of qualitative

considerations for the conservatism of the assumptions led to analyst concluding that this issue

was of very low safety significance (Green).

ML19130A227

SUNSI Review Complete ADAMS Publicly Available Non-Sensitive Keyword:

By: DLP Yes No Non-Publicly Available Sensitive NRC-002

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

NAME PVossmar MStafford VGaddy GPick GWerner GWarnick

SIGNATURE PJV MHS vgg GAP GEW JFK for

DATE 04/29/2019 04/29/2019 4/23/19 4/27/19 04/25/2019 4/25/2019

OFFICE TL:DRS/IPAT ABC:DRS/RCB SPE:DRP/C BC:DRP/C

NAME RKellar NMakris DProulx JKozal

SIGNATURE RLK NFM DLP JWK

DATE 04/29/2019 04/27/2019 4/30/19 5/10//19