IR 05000298/2017002

NRC Integrated Inspection Report 05000298/2017002

ML17219A670
Person / Time
Site:	Cooper
Issue date:	08/03/2017
From:	Kozal J W NRC/RGN-IV/DRP/RPB-C
To:	Dent J Nebraska Public Power District (NPPD)
JASON KOZAL
References
IR 2017002
Download: ML17219A670 (68)

Text

August 3, 2017

Mr. John Dent Vice President

-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000298/2017002

Dear Mr. Dent:

On June 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. On July 6, 2017, the NRC inspectors discussed the results of this inspection with Mr. J. Kalamaja, General Manager Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented three findings of very low safety significance (Green) in this report. All of these findings involved violations of NRC requirements.

The NRC is treating these violation s as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. Further, inspectors documented a licensee

-identified violation, which was determined to be of very low safety significance

, in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555

-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and th e NRC resident inspector at the Cooper Nuclear Station.

If you disagree with a cross

-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555

-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station. UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD ARLINGTON, TX 76011

-4511 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 Kozal , Branch Chief Project Branch C Division of Reactor Projects Docket No. 50

-298 License No. DPR-46 Enclosure: Inspection Report 05000 298/2017002 w/ Attachment s: 1.Supplemental Information 2.Occupational Radiation Safety Inspecti on Request for Information

SUNSI Review:ADAMS: Non-Publicly Available Non-SensitiveKeyword: By: JKozal/dll Yes NoPublicly Available Sensitive NRC-002 OFFICE SRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB BC:DRS/PSB2 NAME PVoss CHenderson TFarnholtz GWerner VGaddy HGepford SIGNATURE /RA/ /RA/ /RA/JM for /RA/ /RA/ DATE 7/20/2017 07/20/2017 7/24/2017 7/20/17 07/20/2017 OFFICE TL:DRS/IPAT SPE:DRP/C BC:DRP/C NAME THipschman CYoung JKozal SIGNATURE /RA/ /RA/ /RA/ DATE 7/21/2017 7/26/2017 8/3/2017 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000 298 License: DPR-46 Report: 05000 298/20 17 0 02 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave Brownville, NE Dates: April 1 through June 30, 2017 Inspectors:

P. Voss, Senior Resident Inspector C. Henderson, Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector G. Pick, Senior Reactor Inspector M. Phalen, Senior Health Physicist N. Greene, Ph.D., Health Physicist Approved By: Jason Kozal Chief, Project Branch C Division of Reactor Projects

2

SUMMARY

IR 05000 298/20 17 0 02; 04/01/20 17 - 06/30/20 17; Cooper Nuclear Station

Maint. Risk Assessments and Emergent Work Control

, Follow-up of Events

& Notices of Enforcement Discretion

. The inspection activities described in this report were performed between April 1 and June 30 , 2017, by the resident inspectors at Cooper Nuclear Station and inspectors from the NRC's Region IV office. Three finding s of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. Additionally, NRC inspectors documented in this report one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (i.e., Green, greater than Green, White, Yellow, or Red), determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas," dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," dated July 2016.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to follow Station Procedure 0.26, "Surveillance Program," Revision 70, and to assess the operability of alternate shutdown reactor pressure instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of the hig h pressure coolant injection turbine steam inlet pressure instrument that provides indications of reactor pressure for the alternate shutdown panel when the instrument was isolated during surveillance testing. As a result, operations personnel failed to recognize that the instrument was inoperable and failed to enter the appropriate technical specification action statements. As immediate corrective action s, the licensee validated that the alternate shutdown reactor pressure function was inoperable and tha t Technical Specification 3.3.3.2, "Alternate Shutdown System," Condition A , should have been entered, and generated a procedure change request to ensure Technical Specification 3.3.3.2 would be entered during future surveillances. The licensee entered this deficiency into the corrective action program as Condition Report CR

-CNS-2017-02280.

The licensee's failure to assess the operability of alternate shutdown reactor pressure instrumentation when the high pressure coolant injection turbine inlet steam pressure instrument was isolated for surveillance testing, in violation of Station Procedure 0.26, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance 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. Specifically, the alternate shutdown reactor pressure instrument was inoperable when the high pressure coolant injection turbine inlet pressure instrument was isolated for surveillance testing, and the appropriate technical specification action statement was not entered. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Finding s At-Power," dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it:

was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. The finding had a cross-cutting aspect in the area of human performance associated with work management. Specifically, the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the identification and management of risk commensurate with the isolation of the high pressure coolant injection turbine inlet pressure instrument during surveillance testing [H.5]. (Section 1R13)

Cornerstone: Barrier Integrity

Green.

The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of the control room emergency filtration system. Specifically, prior to October 23, 2016, work order instructions for periodic preventive maintenance on the SF-C-1A supply fan failed to include industry recommended checks to ensure that the bearings were adequately engaged with the fan shaft, and failed to include proper work sequencing to ensure vibration data trending was meaningful.

The ineffective preventive maintenance strategy resulted in the failure of the control room supply fan inboard bearing during operation and a loss of the control room emergency filtration system function.

Corrective actions to restore compliance included repair of the supply fan and changes to improve the effectiveness of the fan's preventive maintenance strategy.

The license e entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-07426. The licensee's failure to maintain work order instructions for control room supply fan maintenance, in violation of Technical Specification 5.4.1.a, was a performance deficiency.

The performance deficiency was more than minor, and therefore a finding, because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (control room envelope) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, "Shutdown Operations Significance Process Phase 1 Initial Screening and Characterization of Findings," dated May 9, 2014, the inspectors determined that the finding had very low safety significance (Green) because the inspectors answered "no" to all of the Barrier Integrity screening questions. The finding had a cross-cutting aspect in the area of human performance associated with resources, because the licensee failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety [H.1]. (Section 4OA3)

Green.

The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to implement System Operating Procedure 2.2.38, "HVAC Control Building," Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan, RF

-C-1A, operations personnel instead inadvertently turned off the operating control room emergency filtration system supply fan, 1

-SF-C-1A, resulting in the loss of the control room emergency filtration system function.

Corrective actions to restore compliance included restoration of the control room emergency filtration supply fan and procedure changes to require peer checks for this surveillance test and similar activities. The license e entered this deficiency into the corrective action program as Condition Report CR

-CNS-2016-08744. The licensee's failure to implement System Operating Procedure 2.2.38, in violation of Technical Specification 5.4.1.a, was a performance deficiency.

The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (control room envelope) protect the public from radionuclide releases caused by accidents or events. 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 had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross-cutting aspect in the area of human performance associated with challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and did not ensure that risks were evaluated and managed before proceeding. Specifically, despite noting several abnormalities with the switch being manipulated, operations personnel did not stop to evaluate the uncertain conditions nor did they evaluate the risks associated with proceeding

[H.11]. (Section 4OA3)

Licensee-Identified Violations

A violation of very low safety significance (Green) that was identified by the licensee has been reviewed by the inspectors.

Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program.

This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

5

PLANT STATUS

The Cooper Nuclear Station began the inspection period at 100 percent power.

On May 19, 2017, the licensee commenced a planned down-power to approximately 15 percent, and removed the main generator from service to support repair of a 345 kV generator output breaker switch that was misaligned.

On May 21, 2017, the main generator was synched to the grid, and o n May 23, 2017 , the unit was returned to 100 percent power, where it remained for the rest of the reporting period, except for minor reductions in power to support scheduled surveillances and rod pattern adjustments.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1 R 01 Adverse Weather Protection (71111.01)

Readiness to Cope with External Flooding

a. Inspection Scope

On June 2, 2017, the inspectors completed an inspection of the station's readiness to cope with external flooding. After reviewing the licensee's flooding analysis, the inspectors chose one plant area that w as susceptible to flooding:

Control building

, elevation 903 feet and basement The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected area to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1 R 04 Equipment Alignment (71111.04)

.1 Partial Walk

-Down

a. Inspection Scope

The inspectors performed partial system walk

-downs of the following risk

-significant systems: June 2 , 2017, primary containment isolation system Group 6 isolation circuit June 16, 2017, reactor core isolation cooling

, turbine cooling system June 23, 2017, standby gas treatment system train A The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems or trains were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples , as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk

-Down

a. Inspection Scope

On May 26, 2017, the inspectors performed a complete system walk

-down inspection of the control room emergency filtration system. The inspectors reviewed the licensee's procedures and system design information to determine the correct control room emergency filtration system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, i n-process design changes, temporary modifications, and other open items tracked by the licensee's operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1 R 05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

May 23, 2017 , control room

, Fire Area CB-D, Zone 10B June 1, 2 017 , reactor building, elevation 903 feet , residual heat removal A heat exchanger room, Fire Area CB-CF, Zone 2B June 23, 2017 , reactor building, Fire Area RB-DI, Zone 1D June 23, 2017 , reactor building, Fire Area RB-DI, Zone 1E For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1 R 06 Flood Protection Measures (71111.06)

a. Inspection Scope

On June 1, 2017, the inspectors completed an inspection of the station's ability to mitigate flooding due to internal causes. After reviewing the licensee's flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:

Reactor building southeast quad

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1 R 11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On June 20, 2017, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities. These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On May 20, 2017, the inspectors observed the performance of on

-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to low power operations; raising power and restoring the main turbine and generator to service

. In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1 R 12 Maintenance Effectiveness (71111.12)

.1 Routine Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed one instance of degraded performance or condition of safety

-significant structures, systems, and components (SSCs):

April 24, 2017 , reactor core isolation cooling, turbine cooling system The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions.

The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

.2 Quality Control

a. Inspection Scope

On June 27, 2017, the inspectors reviewed the licensee's quality control activities through:

(1) a review of parts installed in control room emergency filtration system (CREFS) that were purchased as commercial

-grade parts but were dedicated prior to installation in a quality

-grade application;

(2) a review of the licensee's control of quality parts during maintenance;

(3) a review of whether quality control verifications were proper l y specified in accordance with the licensee's Quality Assurance Program, and were implemented as specified, during work associated with work activities.

These activities constituted completion of one quality control sample, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

April 21, 2017, high pressure coolant injection maintenance window May 20, 2017, main generator outage May 24, 2017, control room emergency filtration system maintenance window

The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result s of the assessments.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:

April 26, 2017 , reactor water cleanup inboard isolation valve, RWCU-MOV-18 , 16 A-K65 relay coil failure May 1, 2017 , emergency diesel generator 2 inoperability and unavailability due to overcurrent relay failure May 8, 2017, Division I service water pump C seizure The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constituted completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

Introduction.

The inspectors identified a Green

, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to follow Station Procedure 0.26, "Surveillance Program," Revision 70, and to assess the operability of alternate shutdown (ASD) reactor pressure instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of the high pressure coolant injection (HPCI) turbine steam inlet pressure instrument that provides indications of reactor pressure for ASD panel when the instrument was isolated during surveillance testing.

Description.

The inspectors reviewed the licensee's actions to maintain the HPC I system available during the performance of Surveillance Procedure 6.HPCI.306, "HPCI Turbine Steam Inlet Pressure Indication Channel Calibration," Revision 5, on April 17, 2017. During this procedure, the HPCI system was made inoperable when the HPCI controls were isolated from the control room and transferred to the ASD panel. From this review, the inspectors identified that the licensee had isolated the HPCI turbine steam inlet pressure instrument. This instrument provides indication of reactor pressure at the ASD panel in accordance with Technical Specification (TS) Basis Document 3.3.3.2, "Alternate Shutdown System," Table B 3.3.3.2-1. The inspectors noted that the licensee had not entered the associated ASD TS action statement.

Th e inspectors determined that the licensee should have declared the ASD reactor pressure function inoperable and entered the applicable action statement associated with Condition A of TS 3.3.3.2, "Alternate Shutdown System." As immediate corrective action s, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that TS 3.3.3.2, "Alternate Shutdown System," Condition A, should have been entered, and generated a procedure change request to ensure TS 3.3.3.2 would be entered during future surveillances.

The licensee entered this deficiency into the corrective action program as Condition Report CR

-CNS-2017-02280.

The inspectors noted that Station Procedure 0.26, "Surveillance Program," Revision 70, Section 5 , requires the licensee to assess operability of TS system functions during surveillance testing.

Section 5 of this procedure states, the "Shift Manager shall:

be aware of any other systems affected by the test and how they are affected." Additionally, the inspectors identified that the previous performance of Surveillance Procedure 6.HPCI.306 was conducted during a HPCI maintenance window which required both HPCI and ASD

-HPCI to be declared inoperable. To minimize unavailability of the HPCI system , the licensee had decided to perform Surveillance Procedure 6.HPCI.306 on April 17, 2017 , prior to conducting a HPCI maintenance window scheduled to commence on April 18, 2017. The inspectors concluded that the licensee had failed to implement their work management process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the identification and management of risk commensurate with the isolation of the HPCI turbine inlet pressure instrument during surveillance testing

.

Analysis.

The licensee's failure to assess the operability of ASD reactor pressure instrumentation when the HPCI turbine inlet steam pressure instrument was isolated for surveillance testing, in violation of Station Procedure 0.26, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance 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. Specifically, the ASD reactor pressure instrument was inoperable when the HPCI turbine inlet pressure instrument was isolated for surveillance testing, and the appropriate TS action statement was not entered. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Finding s At-Power," dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it:

was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety

-significant nontechnical specification train. The finding had a cross

-cutting aspect in the area of human performance associated with work management. Specifically, the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the identification and management of risk commensurate with the isolation o f the HPCI turbine inlet pressure instrument during surveillance testing

[H.5]. Enforcement

. Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, "Quality Assurance Program Requirements," Revisi on 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.f, requires specific procedures for scheduling surveillance tests and calibration. The licensee established Station Procedure 0.26, "Surveillance Program," Revision 70, to schedule and control surveillance testing.

Section 5 of Station Procedure 0.26 states, the "Shift Manager shall:

be aware of any other systems affected by the test and how they are affected." Contrary to the above, on April 17, 2017, the licensee failed to ensure that the shift manager was aware of any other systems affected by the test and how they were affected during HPCI surveillance testing. Specifically, the licensee failed to assess the operability of ASD reactor pressure instrumentation when the HPCI turbine inlet steam pressure instrument was isolated for surveillance testing. As an immediate corrective action, the licensee generated a procedure change request, IDOCS 7 3872 , to ensure that TS 3.3.3.2 would be entered during future surveillances. This violation is being treated as a non

-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was of very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report CR-CNS-2017-02280. (NCV 05000298/2017002

-01, "Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing")

1 R 15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed six operability determinations that the licensee performed for degraded or nonconforming SSCs:

May 1, 2017, operability determination of emergency diesel generator 2 overcurrent relay failure common cause May 5, 2017 , operability determination of Division II, 125 Vdc charger B ground May 18, 2017, operability determination of Division I and II service water system strainer control panel nonconforming condition June 2, 2017 , operability determination of the standby liquid control heat trace and portable heaters June 29, 2017, operability determination of the high pressure coolant injection system with out reactor equipment cooling flow during some alternate shutdown scenarios June 21, 2017, operability determination of the drywell to torus vacuum breaker, PC-NRV-21, failure to close during surveillance testing The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

These activities constituted completion of six operability review sample s , as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1 R 18 Plant Modifications (71111.18)

a. Inspection Scope

On May 1, 2017, the inspectors reviewed a temporary plant modification involving a manual action for maintaining the Z2 sump pump functional during Z1 sump pump high

-high level switch troubleshooting.

The inspectors verified that the licensee had implemented this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constituted completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1 R 19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk

-significant SSCs:

April 24, 2017, high pressure coolant injection maintenance window April 26 , 2017, RWCU-MOV-18 , 16 A-K64 failed relay coil replacement May 4, 2017, emergency diesel generator 2 overcurrent relay replacement 51B and 51C May 9 , 2017, reactor protection system test panel modification May 26, 2017, control room emergency filtration system maintenance window The inspectors reviewed licensing

- and design

-basis documents for the SSCs and the maintenance and post

-maintenance test procedures. The inspectors observed the performance of the post

-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1 R 22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

June 21, 2017 , service water pump C pretest Reactor coolant system leak detection tests:

June 16, 2017 , sump pump F discharge check valve back leakage testing Other surveillance tests:

April 17, 2017 , emergency diesel generator May 26, 2017, control room emergency filtration system The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1 EP 2 Alert and Notification System Testing (71114.02)

a. Inspection Scope

The inspector verified the adequacy of the licensee's methods for testing the primary and backup alert and notification system (ANS). The inspector also reviewed the licensee's program for identifying emergency planning zone locations requiring tone alert radios and for distributing the radios, and reviewed audits of distribution records. The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for ANS problems. The inspector compared the licensee's alert and notification system testing program with criteria in NUREG

-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1; FEMA Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plant s;" and the licensee's current FEMA

-approved alert and notification system design report, "Prompt Alert and Notification System Design Report for the Cooper Nuclear Station

," Revision 14, dated May 2016.

These activities constituted completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02.

b. Findings

No findings were identified.

1 EP 3 Emergency Response Organization Staffing and Augmentation System (71114.03)

a. Inspection Scope

The inspector verified the licensee's emergency response organization on

-shift and augmentation staffing levels were in accordance with the licensee's emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on

-shift emergency response staff to verify the adequacy of the licensee's methods for staffing emergency response facilities, including the licensee's ability to staff pre

-planned alternate facilities. The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments.

These activities constitute d completion of one emergency response organization staffing and augmentation testing sample

, as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

1 EP 4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspector performed an in

-office review of Cooper Nuclear Station Emergency Plan, Revision 69, implemented February 28, 2017, and submitted to the NRC on March 14, 2017, and on

-site reviews of Emergency Plan Implementing Procedure 5.7.1, "Emergency Classification," Revisions 57 and 58. These revisions:

Revised the description of alert and notification system sirens to conform with the current FEMA

-approved alert and notification system design report Updated the letter of agreement with the Nebraska State Patrol Added the inability to restore steam flow to greater than 800,000 lbm/hr as a condition of the fission product barrier loss criteria for fuel clad Added information about use of the minimum core steam flow to the emergency action level basis for the fission product barrier loss criteria for fuel clad and potential loss criteria for primary containment Removed the requirement to keep safety relief valves open following emergency depressurization in the fission product barrier loss criteria for the reactor coolant system Added notes to emergency action levels HU1.4, HA1.2, HA1.3, HA1.4, HA1.6, HA2.1, and HA3.1 to define the safety systems to be evaluated for impact from the event Made minor editorial and title corrections, and corrected typographical errors Th e s e revisions were compared to their previous revision s, to the criteria of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, to Nuclear Energy Institute (NEI)

Document 99-01, "Emergency Action Level Methodology," Revision 5, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revisions did not reduce the effectiveness of the emergency plan. These reviews were not documented in a safety evaluation report and did not constitute approval of licensee

-generated changes; therefore, the revisions are subject to future inspection.

These activities constitute d completion of three emergency action level and emergency plan change samples

, as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspector reviewed the following for the period December 201 5 through June 201 7: After-action reports for emergency classifications and events After-action evaluation reports fo r licensee drills and exercises Independent audits and surveillances of the licensee's emergency preparedness program Assessments of the emergency preparedness program conducted by the licensee Licensee evaluations of changes made to the emergency plan and emergency plan implementing procedures Drill and exercise performance issues entered into the licensee's corrective action program Emergency preparedness program issues entered into the licensee's corrective action program Maintenance records for equipment supporting the emergency preparedness program Emergency response organization and emergency planner training records The inspector reviewed summaries of 283 corrective action program reports associated with emergency preparedness and selected 25 to review against program requirements to determine the licensee's ability to identify and correct problems in accordance with the requirements of 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E , IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.

The inspector reviewed summaries of 412 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected 23 to review against program requirements to determine the licensee's ability to identify reductions in the effectiveness of the emergency plan in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented.

The inspector reviewed records pertaining to the maintenance of equipment and facilities used to implement the emergency plan to determine the licensee's ability to maintain equipment in accordance with the requirements of 10 CFR 50.47(b)(8) and 10 CFR Part 50, Appendix E, IV.E. The inspector also verified that equipment and facilities were maintained in accordance with the commitments of the licensee's emergency plan

. These activities constitute d completion of one sample of the maintenance of the licensee's emergency preparedness program

, as defined in Inspection Procedure 71114.05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones:

Public Radiation Safety and Occupational Radiation Safety 2 RS 1 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

The inspectors evaluated the licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensee's implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. During the inspection, the inspectors interviewed licensee personnel, walked down various areas in the plant, performed independent radiation dose rate measurements, and observed postings and physical controls. The inspectors reviewed licensee performance in the following areas:

Radiological hazard assessment, including a review of the plant's radiological source terms and associated radiological hazards. The inspectors also reviewed the licensee's radiological survey program to determine whether radiological hazards were properly identified for routine and nonroutine activities and assessed for changes in plant operations.

Instructions to workers including radiation work permit requirements and restrictions, actions for electronic dosimeter alarms, changing radiological condition, and radioactive material container labeling.

Contamination and radioactive material control, including release of potentially contaminated material from the radiologically controlled area, radiological survey performance, radiation instrument sensitivities, material control and release criteria, and control and accountability of sealed radioactive sources.

Radiological hazards control and work coverage. During walk downs of the facility and job performance observations, the inspectors evaluated ambient radiological conditions, radiological postings, adequacy of radiological controls, radiation protection job coverage, and contamination controls. The inspectors also evaluated dosimetry selection and placement as well as the use of dosimetry in areas with significant dose rate gradients. The inspectors examined the licensee's controls for items stored in the spent fuel pool and evaluated airborne radioactivity controls and monitoring.

High radiation area and very high radiation area controls. During plant walk downs, the inspectors verified the adequacy of posting and physical controls, including areas of the plant with the potential to become risk

-significant high radiation areas.

Radiation worker performance and radiation protection technician proficiency with respect to radiation protection work requirements. The inspectors determined if workers were aware of significant radiological conditions in their workplace, radiation work permit controls/limits in place, and electronic dosimeter dose and dose rate set points. The inspectors observed radiation protection technician job performance, including the performance of radiation surveys.

Problem identification and resolution for radiological hazard assessment and exposure controls. The inspectors reviewed audits, self

-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute d completion of the seven required samples of radiological hazard assessment and exposure control program, as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2 RS 3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

a. Inspection Scope

The inspectors evaluated whether the licensee controlled in

-plant airborne radioactivity concentrations consistent with as low as reasonably achievable (ALARA) principles

, and that , the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel, walked down various areas in the plant, and reviewed licensee performance in the following areas:

Engineering controls, including the use of permanent and temporary ventilation systems to control airborne radioactivity. The inspectors evaluated installed ventilation systems, including review of procedural guidance, verification the systems were used during high

-risk activities, and verification of airflow capacity, flow path, and filter/charcoal unit efficiencies. The inspectors also reviewed the use of temporary ventilation systems used to support work in contaminated areas such as high efficiency particulate air (HEPA)/charcoal negative pressure units. Additionally, the inspectors evaluated the licensee's airborne monitoring protocols, including verification that alarms and set points were appropriate.

Use of respiratory protection devices, including an evaluation of the licensee's respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health (NIOSH) certified equipment, air quality and quantity for supplied

-air devices and self-contained breathing apparatus (SCBA) bottles, qualification and training of personnel, and user performance.

Self-contained breathing apparatus for emergency use, including the licensee's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, hydrostatic testing of SCBA bottles, status of SCBA staged and ready for use in the plant including vision correction, mask sizes, etc., SCBA surveillance and maintenance records, and personnel qualification, training, and readiness.

Problem identification and resolution for airborne radioactivity control and mitigation. The inspectors reviewed audits, self

-assessments, and corrective action documents to verify problems were being identified and properly addressed for resolution.

These activities constitute d completion of the four required samples of in

-plant airborne radioactivity control and mitigation program, as defined in Inspection Procedure 71124.03.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA 1 Performance Indicator Verification (71151)

.1 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of April 1, 2016, through March 31, 2017, the inspectors reviewed licensee event reports (LERs), maintenance rule evaluations, and other records that could indicate whether safety system functional failures had occurred. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, and NUREG-1022, "Event Reporting Guidelines:

10 CFR 50.72 and 50.73," Revision 3, to determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensee's reactor coolant system chemistry sample analyses for the period of April 1, 2016, through March 31, 2017, to verify the accuracy and completeness of the reported data. The inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample on April 17, 2017. The inspectors used definitions and guidance contained in Nuclear Energy Institute Docum ent 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Reactor Coolant System Identified Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensee's records of reactor coolant system identified leakage for the period of Apr il 1, 2016, through March 31, 2017, to verify the accuracy and completeness of the reported data. The inspectors reviewed the performance of reactor coolant system leakage testing on April 18, 2017. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspector reviewed the licensee's evaluated exercises, emergency plan implementations, and selected drill and training evolutions that occurred between April 2016 and March 2017 to verify the accuracy of the licensee's data for classification, notification, and protective action recommendation (PAR) opportunities. The inspector reviewed a sample of the licensee's completed classifications, notifications, and PARs to verify their timeliness and accuracy. The inspector used Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7 , to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the drill/exercise performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Emergency Response Organization Drill Participation

(EP02)

a. Inspection Scope

The inspector reviewed the licensee's records for participation in drill and training evolutions between April 2016 and March 2017 to verify the accuracy of the licensee's data for drill participation opportunities. The inspector verified that all members of the licensee's emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensee's basis for reporting the percentage of ERO members who participated in a drill. The inspector reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the emergency response organization drill participation performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspector reviewed the licensee's records of alert and notification system tests conducted between April 2016 and March 2017 to verify the accuracy of the licensee's data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspector used Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7 , to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report

. These activities constituted verification of the alert and notification system reliability performance indicator

, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.7 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2016, to March 31, 2017. The inspectors reviewed a sample of radiologically controlled area exit transactions, focused on those showing exposures greater than 100 millirem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constitute d verification of the occupational exposure control effectiveness performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.8 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid and gaseous effluent releases, leaks, and spills that occurred between October 1 , 2016, and March 31, 2017, in order to verify the performance indicator data submitted to the NRC. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 7, to determine the accuracy of the reported data.

These activities constitute d verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA 2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensee's corrective action (CA) program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking CAs to address identified adverse trends. The inspectors did not review any cross

-cutting themes because none exist at the site.

The inspectors identified the following trend that might indicate the existence of a more significant safety issue, and reviewed the licensee's response to it. The inspectors identified multiple examples associated with a declining trend of licensed and nonlicensed operators' operational fundamentals. These examples included:

CR-CNS-2017-00553: N CV 05000298/2017009

-01, "Exceeding the Technical Specification Allowed Out of Service Time of the Division 1 Residual Heat Removal (RHR) System." This finding was in response to the licensee's failure to restore the Division 1 RHR system during clearance restoration, which resulted in exceeding the applicable technical specification (TS) action completion time. Between October 7, 2016, to February 5, 2017, operations personnel did not ensure that the Division 1 RHR subsystem had a minimum flow path. Specifically, nonlicensed operators failed to restore Division I RHR minimum flow isolation valves for RHR pump A and C to the open position prior to reinstalling the valve sealing devices following maintenance performed during Refueling Outage (RE) 29.

CR-CNS-2016-08685: On December 6, 2016, during operator rounds, the licensee identified that 250 Vdc, bus 1A, did not meet TS 3.8.4, "DC Sources

- Operating," Surveillance Requirement (SR) 3.8.4.1. Specifically, SR 3.8.4.1 requires 250 Vdc, battery 1A, terminal voltage on a float charge to be maintained greater than or equal to 260.4 Vdc. This condition was identified approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after operations personnel transferred 250 Vdc, bus 1A, from the 250 Vdc, charger 1A, to the 250 Vdc, charger 1C, in support of 250 Vdc, charger 1A, maintenance. The licensee immediately restored 250 Vdc, battery 1A, terminal voltage to meet the requirements of SR 3.8.4.1. The inspectors observed that the licensee inappropriately closed CR-CNS-2016-08685 based on actions taken.

Licensee Event Report (LER)05000298/2016010-00, "Inadequate Compensatory Measure s Results in a Condition Prohibited by Technical Specifications.

" From July 11, 2016, to July 15, 2016, the licensee placed the torus area and reactor building floor drain valve switches in the open position for an impaired fire detector, defeating the automatic flood protection function credited in the licensee's internal flooding analysis, and failed to implement adequate compensatory measures. These barriers were credited to protect the Division 1 core spray and Division 1 residual heat removal systems from flooding caused by a hig h-energy line break from the 18

-inch feedwater line contained in the steam tunnel. This resulted in inoperability of both systems for a period greater than allowed by Technical Specification 3.5.1, "Emergency Core Cooling Systems and Reactor Core Isolation Cooling System." This issue was documented as an NRC

-identified N CV 05000298/2016003

-02, "Failure to Maintain Low Pressure Injection/Spray Operable from Internal Flooding Hazards." CR-CNS-2017-00054: NCV 05000298/2017001

-03, "Failure to Identify a Condition Adverse to Quality." This finding was in response to the licensee's failure to identify a condition adverse to quality for Division 1 RHR service water booster pump A (SWBP-A) from January 3, 2017 , to January 5, 2017, during nonlicensed operator (NLO) rounds. Specifically, on January 5, 2017, during a plant status walk

-down, the inspectors identified a lower than expected oil level in the Division 1, RHR SWBP

-A inboard sight glass, oil on the pump skid, and an oil droplet formed on the sight glass. The inspectors informed the licensee of this condition. The licensee assessed operability for the pump and determined the oil leakage was three drops per hour. The licensee determined that this leakage rate would have prevented SWBP

-A from operating its required 30 days during a design basis accident, and it was declared inoperable.

CR-CNS-2016-08744: NCV 05000298/2017002

-0 3 , "Loss of Control Room Ventilation Due to Improper Switch Manipulation." This finding was in response to a licensed operator failure to implement System Operating Procedure 2.2.38, "HVAC Control Building," Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan, RF

-C-1A, the licensed operator instead inadvertently turned off the CREFS supply fan, 1

-SF-C-1A, resulting in the loss of CREFS function.

CR-CNS-2017-02280: NCV 05000298/2017002

-0 1 , "Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing." This finding was in response to the license d operators' failure to follow Station Procedure 0.26, "Surveillance Program," Revision 70, and assess the operability of alternate shutdown (ASD) reactor pressure instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of the high pressure coolant injection (HPCI) turbine steam inlet pressure instrument that provides indications of reactor pressure for ASD panel when the instrument was isolated during surveillance testing.

CR-CNS-2017-02834: The licensed operators' failed to follow Surveillance Procedure 6.SW.202, "Service Water Power Operated Valve Operability Test," Revision 21 , for the restoration of the sparging system to service.

This resulted in receiving a Division 1 and 2 service water low pressure isolation during service water valve surveillance testing.

This condition resulted in the automatic closure of service water isolation valves SW

-MOV-36 and SW-MOV-37 and isolating the service water from turbine equipment cooling (TEC) system heat exchangers. The licensed operators took immediate actions per station alarm cards to restore service water flow to the TEC heat exchangers. There were no impacts to plant operations given the short period of time service water flow was isolated to the TEC heat exchangers.

CR-CNS-2017-00620: The licensee identified an adverse trend for inadequate configuration management, applicable to the operations department, based on multiple condition reports (CRs) written for configuration management

.

CR-CNS-2016-03665: NCV 05000298/2016002

-0 1, "Failure to Meet Technical Specification Requirements for Traversing In

-Core Probe B Ball Valve."

The inspectors identified a non-cited violation of TS 3.6.1.3, "Primary Containment Isolation Valves," for the licensee's failure to maintain traversing in

-core probe (TIP) B ball valve, a primary containment isolation valve, operable for its containment isolation function

. Specifically, on May 5, 2016 , from 5:20 a.m. until 1:08 p.m., the licensee failed to maintain t he traversing in-core probe B ball valve operable or isolate its flow path within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of indication s that the mechanical in-shield limit switch had failed. This failure prevented the ball valve from performing its containment isolation function. Operations personnel had failed to declare the valve inoperable and take the required actions because they had failed to recognize the need to enter the formal operability process until the TS clock had been exceeded.

CR-CNS-2017-03538 and CR

-CNS-2017-00630: Identified a quality assurance (QA) performance assessment finding (PAF) issued on February 2, 2017 , associated with multiple events in the conduct of operations since the conclusion of RE 29. This QA finding identified

, "that if the cause is not addressed, there may be further impactful plant issues or events. These events may indicate that corrective actions taken to address previous issues with operations performance have not been effective or sustained (CR-CNS-2017-00630)." The following have been identified since the PAF was issued: 1. CR-CNS-2017-01234: During a review of clearance order for reactor core isolation cooling (RCIC) steam admission valve, RCIC

-MOV-131, it was determined that the reactor building northeast fan coil unit would be tagged out of service. The limited condition of operation (LCO) tracker for this maintenance activity did not include the impact of Division 1 core spray operability.

2. CR-CNS-2017-01768: The incorrect TS reading was taken for tw o instruments during the implementation of Station Procedure 6.LOG.601, "Daily Surveillance Log

- Modes 1, 2, and 3," Revision 124. Specifically, the increments of 5 degrees Fahrenheit were used instead of the actual 10 degree s Fahrenheit increments.

3. CR-CNS-2017-02645: A NLO failed to identify that water collected at the bottom of station startup service transformer relays during rounds.

4. CR-CNS-2017-02667: During the performance of Station Procedure 2.2.71, "Service Water System," Revision 120 , for TEC heat exchanger backwash, the station received a TEC header low pressure alarm and high exciter cold air temperature alarm while removing TEC heat exchanger A from the backwash line

-up. This was due to the licensed operator directing the NLO to throttle closed the in

-service heat exchanger too far while not allowing sufficient time for system response. This caused the system temperature to rise resulting in TEC temperature control valves to open which lowered system pressure. The third TEC pump was started during this evaluation, as covered during the pre

-job brief. No impact to plant operations occurred.

5. CR-CNS-2017-03091: During verification

, a reactor water cleanup (RWCU) clearance order was ready to support scheduled maintenance

, it was identified the required second check was not completed. An NLO was dispatched to verify tags were hanging, and it was observed that the incorrect fuse was removed and tagged.

6. CR-CNS-2017-03050: TEC throttle valve TEC

-V-123 was found throttled about 11/2 turns open instead of the normal configuration of full open. There was no log entry or documentation for controlling the configuration of TEC-V-123 outside of a reactor building NLO watch turnover.

These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152. b. Observations and Assessments The inspectors reviewed the trend identified above and produced the following observations and assessments:

The inspectors reviewed the above examples and concluded that four categories of operator fundamentals were impacted. These categories included:

(1) configuration management; (2)procedure use and adherence; (3)watch standing principals (i.e., taking of logs, system monitoring for abnormal conditions, system response following equipment operation, and knowledge of expected system responses during equipment operation); and

(4) implementation of TS operability calls

.

The licensee implemented the following corrective actions:

1. Use of an industry expert to provide mentoring and coaching of the operations department management team.

2. Increased oversight of equipment operation in the control room and in the plant. 3. Conducting high intensity training (HIT) for licensed and nonlicensed operators. This training was implemented by the Entergy Fleet for re cent issues at other nuclear facilities associated with operator fundamentals.

4. Implementation of an excellence model during license d operator requalification. Specifically, grading licensed operators on operator fundamentals (i.e, maintaining reactor water level in band during an event),

instead of solely on the minimum required critical steps. Th e s e grading criteria have been applie d to the on-going HIT training cycle, and ha ve resulted in two crew failures.

The inspectors determined that the operations department's declining performance in operator fundamentals represents a continued adverse trend worthy of additional monitoring for long term corrective actions and sustained improvement.

c. Findings

No findings were identified.

.3 Annual Follow

-up of Selected Issues

a. Inspection Scope

The inspectors selected three issues for an in

-depth follow

-up: April 26, 2017 , emergency diesel generator 1 voltage regulator cabinet The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews

, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition

.

May 8 - June 2, 2017, during an in

-office inspection, the inspector s reviewed the NRC-identified and licensee

-identified issues documented in Inspection Report 05000298/2015403 for an in depth follow

-up. The inspector s reviewed procedures, digital asset listings, and corrective action documents. The inspector s interviewed personnel involved in implementing the corrective actions.

The inspector s assessed the licensee's cause analyses, extent of condition reviews, and compensatory actions. The inspector verified that the licensee appropriately prioritized the planned corrective actions and that these actions were appropriate.

June 2, 2017 , mission times for the DC batteries, high pressure coolant injection, and reactor core isolation cooling systems The inspectors assessed the licensee's problem identification threshold and cause analyses. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition

.

These activities constituted completion of three annual follow

-up sample s , as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA 3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report (LER)

05000298/2016006-00, "High Vibration on Control Room Emergency Filter System Fan Results in Inoperability and Loss of Safety Functio n"

a. Inspection Scope

On October 23, 2016, while conducting refueling activities and operations with a potential for draining the reactor vessel activities, control room emergency filtration system (CREFS) supply fan A, SF-C-1A, experienced high vibration.

The licensee performed a vibration analysis

, and the results indicated that vibration readings were elevated across all points for the motor and fan.

As a result, the licensee declared CREFS inoperable and entered the associated technical specification (TS) action statements. Operations personnel started the redundant CREFS supply fan, SF

-C-1B , transferred CREFS to the alternate supply, and secured fan SF-C-1A. At the time of the event, the Division 2 emergency diesel generator that backed fan SF-C-1B was unavailable for planned maintenance.

The licensee's root cause evaluation determined that the preventive maintenance (PM) strategy for the fan was ineffective to ensure shaft to bearing engagement was maintained. The licensee took corrective actions to prevent recurrence, which included revising the associated maintenance plan to include verification that the bearings were adequately engaged to the fan shaft

. This issue resulted in a loss of safety function for the CREF system. The licensee reported this failure under 10 CFR 50.72(b)(3)(v)and 10 CFR 50.73(a)(2)(v

)(D) as a condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. The inspectors reviewed the event, including station logs and TS requirements; walked down the affected components; and discussed the events with the licensee. The inspectors also reviewed the root cause evaluation, extent of condition and cause reviews, and the corrective actions associated with the event to ensure they were appropriate.

This licensee event report is closed.

b. Findings

Introduction.

The inspectors reviewed a self

-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of CREFS. Specifically, prior to October 23, 2016, work order instructions for periodic PM on the SF-C-1A supply fan failed to include industry recommended checks to ensure that the bearings were adequately engaged with the fan shaft, and failed to include proper work sequencing to ensure vibration data trending was meaningful.

This deficiency resulted in the failure of the control room supply fan inboard bearing during operation and a loss of the CREFS function.

Description.

On October 23, 2016, while conducting refueling and operations with a potential for draining the reactor vessel activities, CREFS supply fan A, SF-C-1A, experienced high vibration.

Licensee personnel observed that the control room supply fans were shaking while fan SF-C-1A was running

. In addition, they noted that a belt guard bracket had broken off of the A supply fan

. In response to identification of the shaking fan, the licensee performed a vibration analysis on the running A supply fan. The results indicated that vibration readings were elevated across all points for the motor and fan. As a result, the licensee declared CREFS inoperable and entered the associated TS action statements. Operations personnel started the redundant CREFS supply fan B, SF-C-1B, and secured fan SF-C-1A. At the time of the event, the Division 2 emergency diesel generator that backed fan SF-C-1B was unavailable for planned maintenance. As a result, CREFS did not have an essential power supply for fan SF-C-1B at the time of the event.

During subsequent investigation of the A supply fan high vibration, the licensee found that the drive end bearing locking collar was loose from the bearing and the shaft.

This allowed the shaft to turn within the bearing inner race, causing damage to the shaft and resulting in high vibration levels.

The fan was repaired on October 25, 2016, and a vibration analysis was performed on October 26, 2016, with satisfactory results.

Operations personnel declared CREFS operable at 1: 41 p.m. on October 27, 2016. The licensee initiated a root cause evaluation to review the cause of the event. The licensee's root cause evaluation determined that the PM strategy for the fan was ineffective to ensure shaft to bearing engagement was maintained

. Specifically, PM activities on the CREF system specified that the supply fans needed to be lubricated every 26 weeks. However, the PM did not include verification that the bearing setscrews or locking collars were tight or that the bearings were adequately engaged with the fan shaft. The root cause evaluation noted that the Entergy PM templates recommended verification of setscrew or locking collar tightness for important fans. Although this was an essential and critical fan, this task was not included in the PM fo r fan SF-C-1A. In addition, the root cause evaluation noted that vibration trending was performed for these fans on a 26

-week frequency. However, this activity was always performed as a post

-maintenance activity, after lubrication of the supply fan bearings had occurred. As a result, this sequencing of work had potentially masked the degrading condition associated with the fan bearings.

The inspectors reviewed the licensee's root cause evaluation, observed licensee response at the time of the event, reviewed the completed work orders, and evaluated the adequacy of licensee procedures. As a result of their review, the inspectors questioned the licensee's criticality classification of the supply fans. Specifically, loss of a supply fan results in a loss of safety function of a single train system, which would drive the licensee to classify these components as having a classification of criticality 1. However, the license e maintained the supply fans as having a criticality 2 classification. The licensee was in the process of evaluating the criticality of the component in response to inspector questions at the end of this inspection period.

Analysis.

The licensee's failure to maintain work order instructions for control room ventilation supply fan maintenance, in violation of Technical Specification 5.4.1.a, was a performance deficiency.

The performance deficiency was more than minor, and therefore a finding, because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (control room envelope) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, "Shutdown Operations Significance Process Phase 1 Initial Screening and Characterization of Findings," dated May 9, 2014, the inspectors determined that the finding had very low safety significance (Green) because the inspectors answered "no" to all of the Barrier Integrity screening questions. The finding had a cross

-cutting aspect in the area of human performance associated with resources, because the licensee failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety

[H.1]. Enforcement

. Technical Specification 5.4.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for performing maintenance that can affect the performance of safety

-related equipment.

The licensee established PM Work Order 5060572 to meet the Regulatory Guide 1.33 requirement. Contrary to the above, prior to October 23, 2016, the licensee failed to maintain procedures for performing maintenance that can affect the performance of safety

-related equipment. Specifically, instructions contained in PM Work Order 5060572 for periodic PM on the SF-C-1A control room supply fan failed to include industry recommended checks to ensure that the bearings were adequately engaged with the fan shaft, and failed to include proper work sequencing to ensure vibration data trending was meaningful.

The ineffective PM strategy resulted in the failure of the control room supply fan inboard bearing during operation and a loss of the control room emergency filtration system function.

Corrective actions to restore compliance included repair of the supply fan and PM changes to improve the effectiveness of the fan's PM strategy. Because this violation was of very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report CR-CNS-2016-07 426, this violation is being treated as a non

-cited violation (NCV) in accordance with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000298/201 7 00 2-0 2 , "Loss of Control Room Ventilation Due to Ineffective Preventive Maintenance Strategy

")

.2 (Closed) Licensee Event Report (LER)

05000298/2016009-00, "Control Room Emergency Filter System Fan Removed from Service Due to Human Error Results in Loss of Safety Function

"

a. Inspection Scope

On December 7, 2016, during control building ventilation surveillance testing, an operator incorrectly manipulated a switch associated with CREFS. When directed by the procedure to turn off control building ventilation recirculation fan RF-C-1A, the operator instead inadvertently turned off the operating control room emergency filtration system supply fan A , 1-SF-C-1A. The error was revealed when another operator entered the control room several minutes later and noticed the increased temperature in the room. The operator was directed to review the control room ventilation system line

-up and discovered the mispositioned switch. As a result of this event, the control room emergency filtration system was declared inoperable upon discovery, and the event was determined to be a safety system functional failure. Approximately 30 minutes after the error was made, CREFS was restored to operable status when the supply fan was restarted.

The licensee's root cause evaluation determined that operations personnel did not apply fundamental human performance tools to the surveillance procedure task; therefore, the risk associated with an error was not properly evaluated or mitigated. The licensee took corrective actions to prevent recurrence, which included revising their control building ventilation surveillance and system operating procedures to require peer checks during component manipulations

. This issue resulted in a loss of safety function for the CREF system. The licensee reported this failure under 10 CFR 50.72(b)(3)(v)and 10 CFR 50.73(a)(2)(v

)(D) as a condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. The inspectors reviewed the event, including station logs and technical specification (TS) requirements; walked down the affected components; and discussed the events with the licensee. The inspectors also reviewed the root cause evaluation, extent of condition and cause reviews, and the corrective actions associated with the event to ensure they were appropriate.

This licensee event report is closed.

b. Findings

Introduction.

The inspectors reviewed a self

-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to implement System Operating Procedure 2.2.38, "HVAC Control Building," Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan RF

-C-1A, operations personnel instead inadvertently turned off the CREFS supply fan, 1

-SF-C-1A, resulting in the loss of the CREFS function.

Description.

On December 7, 2016, at approximately 10:

20 p.m., the licensee was performing surveillance testing of the control building heating ventilation and cooling (HVAC) in accordance with Surveillance Procedure 6.1HV.302, "Essential Control Building Ventilation Functional Test (Div 1)," and System Operating Procedure 2.2.38, "HVAC Control Building." One operator was performing the surveillance test, which was controlled on the back control room panels, without a peer check. While using System Operating Procedure 2.2.38, the operator was attempting to remove nonessential control building HVAC from service when he incorrectly manipulated a switch associated with CREFS. Step 15.2.3 of System Operating Procedure 2.2.38 stated, in part, "At VBD

-R, place the following fans to OFF:

RF-C-1A, Recirc Fan." When directed by the procedure to turn off this control building ventilation recirculation fan, RF-C-1A, the operator instead inadvertently turned off the operating CREFS supply fan, 1

-SF-C-1A. Before the error was made, the operator had noted that the CREFS damper position tag was located immediately next to the switch he was operating, which he noted was abnormal, but the operator failed to stop when faced with uncertainty to address this abnormality. In addition, in several instances during performance of the procedure, the operator was directed by the procedure to place control building ventilation fans to off or run configurations, but due to the operator being positioned at the wrong set of switches, the switches were already in the specified position. The inspectors determined that this should have prompted the operator to stop and re

-evaluate the indications, since the switches should not have already been in the specified position, but th e operator again failed to stop when faced with uncertainty. The inspectors also noted that operations supervision had discussed during the pre-job brief that there were several similarly labeled switches in close proximity of each other on the back control room panels.

However, operations supervision failed to recognize the risk of losing CREFS and failed to assign a peer check for the manipulations. The inspectors determined that this lack of risk recognition contributed to the switch mispositioning event.

The inspectors also observed that at the time of the event, peer checks were only required for front panel component manipulations.

This practice was under review at the end of this inspection period.

After the error was made, it was ultimately discovered when another operator entered the control room several minutes later and noticed the increased temperature in the room. As a result of these self

-revealed indications, the control room supervisor directed this operator to review the control room ventilation system line

-up at the back control room panels. During this review, the operator discovered the mispositioned switch. As a result of this event, CREFS was declared inoperable upon discovery, and the event was determined to be a safety system functional failure. Approximately 30 minutes after the error was made, CREFS was restored to operable status when the supply fan was restarted.

The licensee initiated a root cause evaluation in order to review the factors that led to the event. The inspectors reviewed the licensee's root cause evaluation, observed licensee response at the time of the event, reviewed the completed work orders, and evaluated the adequacy of licensee procedures. The licensee's root cause evaluation determined that operations personnel did not apply fundamental human performance tools to the surveillance procedure task; therefore, the risk associated with an error was not properly evaluated or mitigated.

However, the inspectors noted that the root cause evaluation was narrowly focused, in that it appeared to link the cause of the event almost entirely to the performance of a single individual, and considered it an "isolated" incident. The corrective actions that were developed to prevent recurrence also reflected this assessment. The inspectors observed that the causal evaluation should have focused on the emerging trend in operations department performance challenges and looked more broadly at the barriers that were either in place and broke down or the barriers that should have been put in place by the organization. The inspectors noted that focus on the performance of the organization and the associated barriers would allow for a more insightful evaluation and development of more effective corrective actions. At the end of this inspection period, the licensee was in the process of revising the root cause evaluation to shift its focus toward the organizational barriers.

Analysis.

The licensee's failure to implement System Operating Procedure 2.2.38, in violation of Technical Specification 5.4.1.a, was a performance deficiency.

The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (control room envelope) protect the public from radionuclide releases caused by accidents or events.

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 had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross-cutting aspect in the area of human performance associated with challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and did not ensure that risks were evaluated and managed before proceeding. Specifically, despite noting several abnormalities with the switch being manipulated, operations personnel did not stop to evaluate the uncertain conditions nor did they evaluate the risks associated with proceeding

[H.11]. Enforcement

. Technical Specification 5.4.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Append ix A of Regulatory Guide 1.33, Revision 2. Section 4.s of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for startup, operation, and shutdown of the control room heating and ventilation system. The licensee established System Operating Procedure 2.2.38, "HVAC Control Building," Revision 43, to meet the Regulatory Guide 1.33 requirement. Step 15.2.3 of System Operating Procedure 2.2.38 states, "At VBD

-R, place the following fans to OFF:

RF-C-1A, Recirc Fan." Contrary to the above, on December 7, 2016, during control building ventilation surveillance testing at the VBD

-R control room panel, operations personnel failed to place the RF

-C-1A recirc fan to OFF. Specifically, when directed to turn off control building ventilation recirculation fan RF

-C-1A, operations personnel instead inadvertently turned off the operating CREFS supply fan, 1

-SF-C-1A, resulting in the loss of the control room emergency filtration system function. Corrective actions to restore compliance included restoration of the control room emergency filtration supply fan and procedure changes to require peer checks for this surveillance test and similar activities. Because this violation was of very low safety significance (Green) and was entered into the licensee's corrective action program as Condition Report CR-CNS-2016-0 8744, this violation is being treated as a non

-cited violation (NCV) in accordance with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000298/201 7 00 2-0 3 , "Loss of Control Room Ventilation Due to Improper Switch Manipulation

")

.3 (Closed) Licensee Event Report (LER)

05000298/2016 010-00, "Inadequate Compensatory Measure s Results in a Condition Prohibited by Technical Specifications"

a. Inspection Scope

From July 11, 2016, to July 15, 2016, the licensee placed the torus area and reactor building floor drain valve switches in the open position for an impaired fire detector, defeating the automatic flood protection function credited in the licensee's internal flooding analysis, and failed to implement adequate compensatory measures. These barriers were credited to protect the Division 1 core spray and Division 1 residual heat removal systems from flooding caused by a hig h-energy line break from the 18

-inch feedwater line contained in the steam tunnel. This resulted in inoperability of both systems for a period greater than allowed by Technical Specification 3.5.1, "Emergency Core Cooling Systems and Reactor Core Isolation Cooling System.

" The licensee initiated an apparent cause evaluation (ACE) to determine the cause of the event. The licensee determined the cause of the event was Station Procedure 2.3_FP-1, "Fire Protection

- Annunciator 1," Revision 12, contained inappropriate directions to defeat the flood barriers because it did not recognize the flood protection function of the valves. The licensee reported this failure under 10 CFR 50.73(a)(2)(i)(B)and 10 CFR 50.73(a)(2)(v)(D) as a condition prohibited by TS and a condition that could have prevented the fulfillment of the safety function of structures, systems, or components as defined by 10 CFR 50.73(a)(2)(v). The inspectors reviewed the event, including TS requirements

, and discussed the events with the licensee. The inspectors also reviewed the ACE, extent of condition evaluation , and the corrective actions associated with the event to ensure they were appropriate.

This licensee event report is closed.

b. Findings

One non-cited violation (NCV) of NRC requirements was identified and documented as NCV 05000298/2016003

-02, "Failure to Maintain Low Pressure Injection/Spray Operable from Internal Flooding Hazards." (ADAMS Accession No.

ML16315A141

).

.4 (Closed) Licensee Event Report (LER)

05000298/2017 002-00, "Valve Test Failures Result in Condition Prohibited by Technical Specifications and a Loss of Safety Function"

a. Inspection Scope

In February and March 2017, two of the eight 2-stage Target Rock safety relief valve (SRV) pilot valve assemblies removed during Refueling Outage (RE) 29 failed to meet required lift setpoints of Surveillance Requirement (SR) 3.4.3.1 of Technical Specification (TS) 3.4.3, "Safety/Relief Valves and Safety Valves." TS 3.4.3 requires the safety function of seven SRVs and three safety valves to be operable. The nominal set pressure and tolerances for these valves are established in SR 3.4.3.1. The licensee demonstrated through an engineering analysis that reactor vessel integrity would not be challenged during an overpressure event. Additionally, the reactor safety limits would not have been challenged during an event of an anticipated operational occurrence.

The licensee initiated an apparent cause evaluation (ACE) to determine the cause of the event. The licensee determined the cause of the event was that one of the SRV pilot assemblies failed due to corrosion bonding, and that the other SRV pilot assembly failed due to a lack of a barrier to prevent inadvertent disassembly of the SRV pilot prior to testing. The licensee reported this failure under 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(D) as a condition prohibited by TS and a condition that could have prevented the fulfillment of the safety function of structures, systems, or components as defined by 10 CFR 50.73(a)(2)(v). The inspectors reviewed the event , including TS requirements, and discussed the events with the licensee. The inspectors also reviewed the ACE, extent of condition evaluations, and the corrective actions associated with the event to ensure they were appropriate.

This licensee event report is closed.

b. Findings

No findings were identified.

These activities constituted completion of four event follow-up samples, as defined in Inspection Procedure 71153. 4OA 6 Meetings, Including Exit

Exit Meeting Summary

On May 26 , 2017, the inspectors presented the radiation safety inspection results to Mr. J. Kalamaja, General Manager

, Plant Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On June 2, 201 7, the inspector presented the problem identification and resolution cyber security inspection results to Mr.

D. Buman, Director , Nuclear Safety Assurance, and other members of the licensee staff. The inspector did not review any proprietary information

. On June 30, 2017, the inspector presented the results of the onsite inspection of the licensee's emergency preparedness program to Mr.

J. Kalamaja, General Manager, Plant Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 6, 2017, the inspectors presented the inspection results to Mr. J. Kalamaja, General Manager , Plant Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA 7 Licensee-Identified Violations The following licensee

-identified violation of NRC requirements was determined to be of very low safety significance (Green) and met the NRC Enforcement Policy criteria for being dispositioned as a n on-cited violation:

Technical Specification 5.7.1 states, in part, that high radiation areas with dose rates greater than 0.1 rem/hr at 30 centimeters shall be barricaded and conspicuously posted as a high radiation area.

Contrary to the above, on November 2, 2016, a high radiation area with does rates greater than 0.1 rem/hr at 30 centimeters was not barricaded and conspicuously posted as a high radiation area.

Specifically, a radiation protection technician (RPT) identified an unposted high radiation area at the control rod drive (CRD) "A" pump filter area on reactor building 881 feet southe a st quadrant.

Dose rates of 120 mrem/hr at 30 centimeters from the CRD filter were identified.

This issue was identified as a result of a RPT's deliberate and focused observations during the course of performing their normal duties of performing radiological surveys. The licensee documented this issue in the corrective action program as Condition Report CR-CNS-2016-00788. The finding was determined to be of very low safety significance (Green) because it was not an ALARA planning issue, there was no overexposure or potential for overexposure, and the licensee's ability to assess dose was not compromised.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Bacon, Manager, Training

T. Barker, Manager, Engineering Program and Components

J. Bebb, Manager, Security

J. Bebb, Staff Health Physicist, Radiation Protection

S. Bebb, Superintendent, Administrative Services

J. Bednar, Supervisor, Radiation Protection

K. Billiesbach, Manager, Materials, Purchasing and Contracts

L. Bray, Licensing Consultant

D. Buman, Director, Nuclear Safety Assurance

B. Chapin, Manager, Maintenance

T. Chard, Manager, Quality Assurance

J. Dent, Vice President, Chief Nuclear Officer

L. Dewhirst, Manager, Corrective Action and Assessment

K. Dia, Director, Engineering

R. Estrada, Program Manager, Nuclear Oversight

T. Forland, Engineer, Licensing

G. Gardner, Engineering Design Manager

D. Goodman, Manager, Operations

K. Higginbotham, former Vice President, Chief Nuclear Officer

J. Hirner, Radiation Operations Supervisor, Radiation Protection

H. Jeffrey, Technician, Radiation Protection

J. Kalamaja, General Manager

, Plant Operations

L. Karpinski, Technician, Radiation Protection

D. Kimball, Director, Nuclear Oversight

J. Long, Assistant Operations Manager

J. Olberding, Licensing Specialist, Regulatory

Affairs

C. Pelchat, Manager, Nuclear Projects

J. Reimers, Manager, System Engineering

J. Shaw, Manager, Licensing

J. Stough, Manager, Emergency Preparedness

C. Sunderman, Manager, Radiation Protection

D. Van Der Kamp, Licensing Technical Specialist

D. Vice, Cyber Project Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000298/2017002

-01 NCV Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing

(Section 1R13)

05000298/2017002

-0 2 NCV Loss of Control Room Ventilation Due to Ineffective Preventive Maintenance Strategy

(Section 4OA3)

05000298/2017002

-0 3 NCV Loss of Control Room Ventilation Due to Improper Switch Manipulation (Section

4OA3)

Closed

05000298/LER-2016-006-00 LER High Vibration on Control Room Emergency Filter System Fan Results in Inoperability and Loss of Safety Function

(Section 4OA3)

05000298/2016009

-00 LER Control Room Emergency Filter System Fan Removed from Service Due to Human Error Results in Loss of Safety Function

(Section 4OA3)

05000298/2016 010-00 LER Inadequate Compensatory Measure

s Results in a Condition Prohibited by Technical Specifications

(Section 4OA3)

05000298/2017002

-00 LER Valve Test Failures Result in Condition Prohibited by Technical Specifications and a Loss of Safety Function

(Section 4OA3)

Section 1R01: Adverse Weather Protection

Miscellaneous Documents

Number Title Revision

6034482 Change Evaluation Document, Removal of Conduit Seals in Electrical Manholes

Procedures

Number Title Revision 2.3_S-1 Panel S - Annunciator S

-1 24 5.1Flood Flood 20 7.0.11 Flood Control Barriers

Condition Reports

(CRs)

CR-CNS-2017-02454

CR-CNS-2017-02458

Work Orders

22155

Section 1R04: Equipment Alignment

Miscellaneous Documents

Number Title Revision 01-030 NEDC, HPCI Room Heatup During Appendix

R Shutdown from Alternate Shutdown Panel

88-201E/DC-201C NEDC, HPCI Room Cooling Modification

B 89-1886 NEDC, CNS Station Blackout (SBO) Condensate

90-284 NEDC, Analysis of RCIC Baro Cond Cooling Water System

2019 Flow Diagram Main Control Rm, Cable Rm, and Computer Rm Heating, Ventilation, & Air Cond, Sh eet 1 50 2019 Flow Diagram Chilled Water System Electrical Shop, Non

-Critical Switchgear, Control, and Office Building, Sheet 2 11 2037 Burns and Roe, Cooper Nuclear Station Flow Diagram H&V Standby Gas Treatment and Off Gas Filters

3065 Burns and Roe, Control Elementary Diagram Cooper Nuclear Station, Sheet

17A 12

PSA-ES072 Evaluation of HPCI Room Equipment Reliability During Loss of Room Cooling

Procedures

Number Title Revision 2.2.73 Standby Gas Treatment System

2.2.84 HVAC Main Control Room and Cable Spreading Room

2.2.84A HVAC Main Control Room and Cable Spreading Room System Component Checklist

2.2A.SGT.DIV1

Standby Gas Treatment System Component Checklist (DIV 1) 5 5.1ASD Alternate Shutdown

17, 18

Condition Reports

(CRs)

CR-CNS-2016-05361

CR-CNS-201 7-03070

CR-CNS-2017-03076

CR-CNS-2017-03096

CR-CNS-2017-03102

Work Orders

4988096

5067023

5078661

5121452

5121467

5121468

5121965

5122028

5122029

5122030

5122031

5127355

5127356

5134232

5155854 5160525

Section 1R05: Fire Protection

Miscellaneous Documents

Number Title Revision

FP17-BLDG-Door-R114-5121837, R114 Fire Impairment

FP17-BLDG-Door-R114-5121970, R114 Fire Impairment

FP17-BLDG-Door-R114-5145369, R114 Fire Impairment

11-088 NEDC, Fire Safety Analysis for Fire Area CB

-D 3 11-093 NEDC, Fire Safety Analysis for Fire Area RB

-DI, EPM Report R1906

-008-RBB 2 11-094 NEDC, Fire Safety Analysis for Fire Area RB

-CF EPM Report R1906

-008-RBCF 3

CNS-FP-230 Pre-Fire Plan

- Control Room and Computer Room

Procedures

Number Title Revision 0.23 CNS Fire Protection Plan

0.7.1 Control of Combustibles

0.7.1.1 Control of Flammable Material Lockers

0-Barrier Barrier Control Process

0-Barrier-Reactor Reactor Building

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

Condition Reports

(CRs)

CR-CNS-2017-03295

Section 1R06: Flood Protection Measures

Miscellaneous Documents

Number Title Revision 02-059 Engineering Evaluation

09-102 NEDC, Internal Flooding

- HELB, MELB, and Feedwater Line Break

1, 2

Procedures

Number Title Revision 0-Barrier Barrier control Process

Condition Reports

(CRs)

CR-CNS-2012-04808 CR-CNS-2017-03066

Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

Number Title Revision 2.1.9 Low Power Operation for Maintenance Activities (Hot Standby Condition)

2.2.14 22 KV Electrical System Operating Procedure

2.2.77 Turbine Generator System Operating Procedure

115 2.4PC Primary Containment Control

2.4RR Reactor Recirculation Abnormal

2.4SRV Stuck Open Relief Valve

5.2SW Service Water Casualties

Condition Reports

(CRs)

CR-CNS-2017-03014 CR-CNS-2017-03019

Section 1R12: Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision

11016695 Engineering Change, Commercial Grade Dedication of MM

2069003

0

Miscellaneous Documents

Number Title Revision

CGI 92-012 Commercial Grade Dedication of Mobilux EP

-2 Grease 9

CGI 94-019 Commercial Grade Dedication of HV

-FAN/MOT-SF-C-1A/B Bushing 1

CGI 94-022 Commercial Grade Dedication of HV

-FAN/MOT-SF-C-1A/B Sheave 2 Q-93-73 Evaluation of Safety Classification for Versilube for

HV-AO/AOV's 1

RCIC-PF01 Maintenance Rule Function RCIC

-PF01 Performance Criteria Basis

RCIC-PF02 Maintenance Rule Function RCIC

-PF02 Performance Criteria Basis

Procedures

Number Title Revision 3-EN-DC-203 Maintenance Rule Program

3C0 3-EN-DC-204 Maintenance Rule Scope and Basis

3C0 3-EN-DC-205 Maintenance Rule Monitoring

5C0 7.2.67.5 Allis-Chambers Butterfly Valves 8" and 10" Maintenance

7.2.68 NOPAK Air Operator Maintenance

Condition Reports

(CRs)

CR-CNS-2016-08122

CR-CNS-2017-03067

CR-CNS-2017-03888

Work Orders

5134232

Section 1R13: Maintenance Risk Assessments and

Emergent Work Control

Miscellaneous Documents

Number Title Revision

Failure Modes Analysis

SW Pump C Tripped During Normal Start on Overcurrent

2017-010 Standing Order

- B Reactor Recirc Motor Generator

2041 Burns and Roe, Cooper Nuclear Station Flow Diagram Reactor Building Main Steam System

N87

Miscellaneous Documents

Number Title Revision 73872 Intranet Document Control System (IDOCS)

045107-01 Recirculation MG Set Interconnect Wiring Drawing

115D6011 Rack 25-50 Drawing, Sheet

11

Procedures

Number Title Revision 0.36.3 Confined Space Procedure

0-CNS-WM-104 On-Line Scheduled Risk Assessment

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

0-Protected-EQP Protected Equipment Program

2.1.9 Low Power Operation for Maintenance Activities (Hot Standby Condition)

2.2.68.1 Reactor Recirculation System Operations

2.2.84 HVAC Main Control Room and Cable Spreading Room

2.4RR Reactor Recirculation System Abnormal

5.3EMPWR Emergency Power During Modes

1, 2, or 3 30 6.HPCI.306

HPCI Turbine Steam Inlet Pressure Indication Channel Calibration

6.2RWCU.302

RWCU Space High Temperature Channel Functional Test (DIV 2) 8 7.3.16 Low Voltage Relay Removal and Installation

Condition Reports

(CRs)

CR-CNS-2017-02280

CR-CNS-2017-02419

CR-CNS-2017-02424

CR-CNS-2017-02533

CR-CNS-2017-02661

CR-CNS-2017-02662

CR-CNS-2017-02665

CR-CNS-2017-02751

CR-CNS-2017-02752

CR-CNS-2017-02754

CR-CNS-2017-02982

CR-CNS-2017-02979

CR-CNS-2017-02989

CR-CNS-2017-03070

CR-CNS-2017-03076

CR-CNS-2017-03096

CR-CNS-2017-03102

Work Orders

25644

4988096

5060425

5066959

5067023

5074241

5078661

5121452

5121467

5121468

Work Orders

21785

5121965

5122028

5122029

5122030

5122031

5122112

5127355

5127356

5134232

5155854

5160525

5176802

5178598

5180353

5186551

5187057

5187080 5188697

Section 1R15: Operability Determinations and Functionality Assessments

Miscellaneous Documents

Number Title Revision/Date

Annunciator History Report, Torus

-DW Vacuum Relief Entries May 23, 2017

Annunciator History Report, Torus

-DW Vacuum Relief Entries June 19, 2017 3058 Burns and Roe, Cooper Nuclear Station DC One Line Diagram 68 3059 Burns and Roe, Cooper Nuclear Station D.C. Panel Schedules, Sheet

N41

11360607 Notification

DC 91-001 Torus to Drywell Vacuum Breaker Disc Position Indication Replacement January 7, 1993 EQDP.1.144

Environmental Qualification Data Package

EQDP.2.179DOR

Environmental Qualification Data Package

LF-240-117 Vacuum Breaker Assembly

NRV-21 Failure Modes and Effects Analysis

S5108 Control Panel Schematic Diagram

Procedures

Number Title Revision 0.5.OPS Operations Review of Condition Reports/Operability Determination

2.0.1 Plant Operations Policy

2.2.25.2 125 Vdc Electrical System (DIV

2) 27 2.2.74 Standby Liquid Control System 54 5.3DC125 Loss of 125

Vdc

40 6.PC.207 Torus To Drywell Vacuum Breaker Operation

Procedures

Number Title Revision 7.3.27.2 125/250 VDC System Ground Fault Locator

Condition Reports

(CRs)

CR-CNS-2017-01403

CR-CNS-2017-01779

CR-CNS-2017-02533

CR-CNS-2017-02538

CR-CNS-2017-02540

CR-CNS-2017-02600

CR-CNS-2017-02606

CR-CNS-2017-02638

CR-CNS-2017-03721

Work Orders

5057355 5059781

Section 1R18: Plant Modifications

Miscellaneous Documents

Number Title Revision 95-001 NEDC, Z Sump Fill Rate Due to Condensation in the SGTS Discharge Lines and ERP

Procedures

Number Title Revision 0.5.OPS Operations Review of Condition Reports/Operability Determination

5.3EMPWR Emergency Power During Modes

1, 2, or 3 30, 65 6.SUMP.101

Z Sump and Air Ejector Holdup Line Drain Test (IST)

Condition Reports

(CRs)

CR-CNS-2017-00394

Section 1R19:

Post

-Maintenance Testing

Miscellaneous Documents

Number Title Revision 79E256 Elementary Diagram Reactor Protection System, Sheet

22 79E256 Reactor Protection System, Sheet

12

Procedures

Number Title Revision 6.HPCI.103

HPCI IST and 92 Day Test Mode

6.HPCI.201

HPCI Valve Operability Test (IST)

6.HV.104 Control Room Emergency Filter System Flow Test, Charcoal and HEPA Filter Leak Test, Filter DP Test, and Charcoal Sample Analysis

6.HV.105 Control Room Envelope Pressurization and CREFS Flow Test 17 6.HV.303 Control Room HV Isolation AOV Accumulator Functional Test 9 6.MISC.401

Position Indicator Inservice Testing (IST)

6.2RWCU.302

RWCU Space High Temperature Channel Functional Test (DIV 2) 8 7.0.5 CNS Post-Maintenance Testing

7.3.1.19 GE

IJCV-51A/IFCV-51AD Overcurrent Relay Testing and Maintenance

Condition Reports

(CRs)

CR-CNS-2017-02277

CR-CNS-2017-02279

CR-CNS-2017-02280

CR-CNS-2017-02287

CR-CNS-2017-02296

CR-CNS-2017-02298

CR-CNS-2017-02329

CR-CNS-2017-02333

CR-CNS-2017-02334

CR-CNS-2017-02336

CR-CNS-2017-02337

CR-CNS-2017-02533

CR-CNS-2017-02538

CR-CNS-2017-02800

CR-CNS-2017-02910

CR-CNS-2017-03070

CR-CNS-2017-03076

CR-CNS-2017-03096

CR-CNS-2017-03102

Work Orders

4310659

5060425

5100450

5121452

5121467

5122034

5130407

5134232

5155854

5160525

5186551 5187057

Section 1R22: Surveillance Testing

Miscellaneous Documents

Number Title Revision 97-012 NEDC, Emergency Diesel Generator Fuel On

-Site Storage Technical Specification Requirements

Miscellaneous Documents

Number Title Revision 2017-018 Engineering Report, Service Water Pump In

-Service Testing Requirement for Fifth 10

-year Interval (RP

-08) 0

Procedures

Number Title Revision 2.2.84 HVAC Main Control Room and Cable Spreading Room

2.2.84A HVAC Main Control Room and Cable Spreading Room System Component Checklist

3.9 ASME OM Code Testing Pumps and Valves

6.HV.104 Control Room Emergency Filter System Flow Test, Charcoal and HEPA Filter Leak Test, Filter DP Test, and Charcoal Sample Analysis

6.1DG.101 Diesel Generator Day Operability Test (IST)

6.1SW.101 Service Water Surveillance Operation (DIV 1) (IST)

Condition Reports

(CRs)

CR-CNS-2016-08549

CR-CNS-2017-01144

CR-CNS-2017-01168

CR-CNS-2017-02136

CR-CNS-2017-02154

CR-CNS-2017-02661

CR-CNS-2017-02662

CR-CNS-2017-02665

Work Orders

5075976 5187911

Section 1EP2: Alert and Notification System Testing

(71114.02)

Miscellaneous Documents

Number Title Revision/Date

WPS2900 Series Siren Checklist, Annual Fixed Siren Maintenance Records for 2016

EPDG-2 Attachment C

-1 Semi-Monthly Alert and Notification System Siren Testing

EPDG-2 Attachment C

-5 Annual Full Cycle Sounding of Alert and Notification System Sirens 13

EPDG-2 Attachment C

-6 Annual Fixed Siren Maintenance

EPDG-2 Attachment C

-7 Issuance of NOAA/EAS Radio Receivers

Miscellaneous Documents

Number Title Revision/Date

EPDG-2 Attachment C

-8 Quarterly Review/Update of NOAA/EAS Radio Receiver Recipient Data Base

EPIP 5.7.27

Alert and Notification System, Revision 18

February 28, 2017 EPIP 5.7.27.2

False Activation of the Alert and Notification System, Revision 8

September 14, 2014

Condition Reports

(CRs)

CR-CNS-2016-02329

CR-CNS-2016-03887

CR-CNS-2016-04139

CR-CNS-2016-04142

CR-CNS-2016-05853

CR-CNS-2016-06437

CR-CNS-2017-03255 CR-CNS-2017-03256

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

(71114.03)

Miscellaneous Documents

Number Title Revision/Date

EPDG2, Attachment E5, Monthly Verification of ANS Module Phone Numbers Bimonthly ERO Call

-In Test Conducted August 31, 2015

September 3, 2015

Bimonthly ERO Call

-In Test Conducted October 29, 2015

December 2, 2015

Bimonthly ERO Call

-In Test Conducted December 29, 2015 January 27, 2016

Bimonthly ERO Call

-In Test Conducted February 27, 2016

February 8, 2017

Bimonthly ERO Call

-In Test Conducted April 21, 2016

May 19, 2016

Bimonthly ERO Call

-In Test Conducted June 29, 2016

July 1, 2016

Bimonthly ERO Call

-In Test Conducted August 9, 2016

September 12, 2016

Bimonthly ERO Call

-In Test Conducted December 20, 2016

December 29, 2016

Bimonthly ERO Call

-In Test Conducted February 20, 2017

April 25, 2017

Bimonthly ERO Call

-In Test Conducted May 12, 2017

June 19, 2017

Miscellaneous Documents

Number Title Revision/Date Bimonthly ERO Call

-In Test Conducted June 15, 2017

June 19, 2017

Procedures

Number Title Revision 0-EP-02 Configuration Control of the Automated Notification System

Section 1EP5: Maintenance of Emergency Preparedness

(71114.05)

Miscellaneous Documents

Number Title Revision/Date Control Room Getronics System Test June 29, 2017

Cooper Nuclear Station Emergency Plan

68, 69

EPDG2, Attachment B1, Monthly State Notification Telephone System Testing January 5, 2016

EPDG2, Attachment B1, Monthly State Notification Telephone System Testing April 5, 2016

EPDG2, Attachment B1, Monthly State Notification Telephone System Testing August 2, 2016

EPDG2, Attachment B1, Monthly State Notification Telephone System Testing December 6, 2016

EPDG2, Attachment B1, Monthly State Notification Telephone System Testing December 27, 2016

EPDG2, Attachment B5, Monthly Testing 2

-Way Radio October 23, 2015

EPDG2, Attachment B5, Monthly Testing 2

-Way Radio December 16, 2015

EPDG2, Attachment B5, Monthly Testing 2

-Way Radio March 31, 2016

EPDG2, Attachment B5, Monthly Testing 2

-Way Radio September 26, 2016

EPDG2, Attachment B5, Monthly Testing 2

-Way Radio January 31, 2017

EPDG2, Attachment C2, Quarterly EAS Newspaper and Radio Advisories June 14, 2016

Miscellaneous Documents

Number Title Revision/Date

EPDG2, Attachment C3, Semi

-Annual Dissemination of Emergency Public Information/Transient Population Information December 31, 2015

EPDG2, Attachment C3, Semi

-Annual Dissemination of Emergency Public Information/Transient Population Information December 20, 2016

EPDG2, Attachment C7, Issuance of NOAA/EAS Radio Receivers, First Quarter 2017

EPDG2, Attachment D2, Annual Emergency Plan Training for Local Law Enforcement Agencies October 16, 2015

EPDG2, Attachment D4, Annual Volunteer Fire Department Training December 12, 2016

EPDG2, Attachment E2, Monthly and Post Drill Emergency Response Facility Walkdowns and Testing of Facility Equipment December 18, 2015

EPDG2, Attachment E2, Monthly and Post Drill Emergency Response Facility Walkdowns and Testing of Facility Equipment May 12, 2016

EPDG2, Attachment E2, Monthly and Post Drill Emergency Response Facility Walkdowns and Testing of Facility Equipment October 19, 2016

EPDG2, Attachment E2, Monthly and Post Drill Emergency Response Facility Walkdowns and Testing of Facility Equipment February 28, 2017

Evaluation Report for the Exercise Conducted July 21, 2015

August 14, 2015

Evaluation Report for the Exercise Conducted September 15, 2015 October 6, 2015

Evaluation Report for the Exercise Conducted December 10, 2015 December 31, 2015

Evaluation Report for the Exercise Conducted February 9, 2016 February 17, 2016

Evaluation Report for the Exercise Conducted March 29, 2016 April 20, 2016

Evaluation Report for the Exercise Conducted June 14, 2016 June 30, 2016

Evaluation Report for the Mini

-Drills Conducted August and September 2016

September 15, 2016

Miscellaneous Documents

Number Title Revision/Date Evaluation Report for the Exercise Conducted December 20, 2016 January 17, 2017

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

Evaluation Report for the Exercise Conducted April 12, 2017 April 17, 2017

Evaluation Report for the Exercise Conducted May 16, 2017

May 24, 2017

LO-2015-0199-007 June 6, 2016

LO-2015-0199-009 June 6, 2016

Lower Tier Apparent Cause Evaluation, Met Tower Off

-Line, Condition Report CR

-CNS-2015-0 4229 August 17, 2015

Lower Tier Apparent Cause Evaluation, Repeat

CFR 50.54(q) QA Audit Findings, Condition Report

CR-CNS-2015-0 6041 November 15, 2015

Lower Tier Apparent Cause Evaluation, Adverse Trend in Partial Siren Failures Occurring Over a Five Week Period, Condition Report CR

-CNS-2015-0 6713 November 24, 2015

Lower Tier Apparent Cause Evaluation, Untimely Actions during Emergency Drill, Condition Report

CR-CNS-2015-0 7195 January 18, 2016

Lower Tier Apparent Cause Evaluation, EP Scenario Knowledge Control, Condition Report CR

-CNS-2016-0 3413 July 12, 2016

Lower Tier Apparent Cause Evaluation, Green

, Non-Cited Violation of 10CFR50.54(q)(3), Condition Report

CR-CNS-2017-00465 May 3, 2017

September 3, 2016, Notification of Unusual Event Critique September 8, 2016

Snapshot Self

-Assessment of a Sampling of Plant Activities from January 2014 to Present Ensuring 10

CFR 50.54(q) Process is Being Implemented Appropriately by Specifically Looking for Areas Where 10

CFR 50.54(q) Screens and Evaluations Could Have Been Warranted but Were Missed,

CR-CNS-2016-04401-CA-1 October 27, 2016

QA-2015-CNS-011~Initial Follow

-Up of

CR-CNS-2015-05728

QS-2015-CNS-009~20151207~QA Surveillance Report December 8, 2015

Miscellaneous Documents

Number Title Revision/Date

QS-2015-CNS-013~20151215~Initial Follow

-Up of

CR-CNS-2015-0 5548 December 16, 2015

QS-2015-CNS-016~20151218~Initial Follow

-Up of

CR-CNS-2015-0 6041 December 18, 2015

QS-2016-CNS-013~20160801~Repeat QA Findings During EP Audit

QS-2016-CNS-021~20160916~Ineffective Corrective Action taken to address a QA Finding

QS-2016-CNS-032~20161221~Second Follow

-Up on

CR-CNS-2016-0 4401 December 21, 2016

QS-2017-CNS-007~20170201~Third Follow

-Up of

CR-CNS-2016-04401 EP Elevation

WT-2014-0092-123 August 17, 2015

WT2015-0126-036 June 6, 2016

WT2015-0126-037 June 7, 2016

2015-121 Emergency Preparedness Impact Screen, EPIP 5.7.20, Revision 27

August 14, 2015 2015-122 Emergency Preparedness Impact Screen, EPIP 5.7.20, Revision 27

August 14, 2015 2015-128 Emergency Preparedness Impact Screen, PIMS EOF4

, Revision 17, EOF16

, Revision 16, EOF17

, Revision 12, and OSC02 , Revision 20

September 9, 2015 2015-143 Emergency Preparedness Regulatory Review: Change/Removal of EP Staff Position October 23, 2015 2015-145 Emergency Preparedness Impact Screen, Automated Notification System Upgrade November 23, 2015 2015-146 Emergency Preparedness Impact Screen, CNS Dose Software Code October 8, 2015 2015-148 Emergency Preparedness Impact Screen, Change to Radio System and ONS Management Connectivity November 2, 2015 2015-163 Emergency Preparedness Impact Screen, EP Lessons EPD0050101

and EPD0050101

December 18, 2015 2016-009 Emergency Preparedness Impact Screen, Engineering Change

5098686, Meteorology Tower January 20, 2016 2016-011 Emergency Preparedness Impact Screen, EPIP 5.7.1, Restore and Maintain RPV Level, Revision 54

January 27, 2016

Miscellaneous Documents

Number Title Revision/Date

2016-011 Emergency Preparedness Impact Screen, Revision 1, EPIP 5.7.1, Restore and Maintain RPV Level, Revision 54

October 19, 2016 2016-023 Emergency Preparedness Impact Screen, EP Fundamentals:

Emergency Response, Revision 16

January 29, 201 6 2016-048 Emergency Preparedness Impact Screen, EPIP 5.7.16, Revision 25

March 8, 2016 2016-051 Emergency Preparedness Impact Screen,

TPP 101, Revision 26

March 14, 2016 2016-067 Emergency Preparedness Impact Screen, Removal of EP Training Scenario from TQD's March 11, 2016 2016-075 Emergency Preparedness Impact Screen, Revision 1, EPIP 5.7.1, Revision 54

June 8, 2016

2016-093 Emergency Preparedness Impact Screen, EPE

5.7.8, Revision 9 April 19, 2016

2016-122 Emergency Preparedness Impact Screen, EPDG2 Attachment G1, Revision June 13, 2016 2016-137 Emergency Preparedness Impact Screen, SAMG Diesel Relocation August 15, 2016 2016-143 Emergency Preparedness Impact Screen, Access Controls at the EOF

August 22, 2016 2016-147 Emergency Preparedness Impact Screen, EPIP 5.7.15, Revision 21 August 29, 2016 2016-168 Emergency Preparedness Impact Screen, Revision 1, EPIP 5.7.1 Alignment to EPG/SAG Revision 3, Revision 56

April 18, 2016

2016-172 Emergency Preparedness Impact Screen, EPIP 5.7.1 Editorial, Revision 56

October 19, 2016 2016-179 Emergency Preparedness Impact Screen, Removal of Dose Assessment EP Module and EPIPS 5.7.16, 5.7.17, and 5.7.17.1 from CR Chem/RP Tech Qualification Documents MCR005-01-01, MCR005

-02-01, and MCR005

-01-02 November 18, 2016 2016-182 Emergency Preparedness Impact Screen, 5.7COMMUN, Revision 29

January 13, 2017 2016-195 Emergency Preparedness Impact Screen, ERO Drill TQD MCR0060202P, Dose Assessor, Revision 2

December 28, 2016 2017-005 Emergency Preparedness Impact Screen, EPIP 5.7.27 Revision 18

January 12, 2017

Miscellaneous Documents

Number Title Revision/Date

2017-023 Emergency Preparedness Impact Screen, EPIP 5.7.1

, Revision 57, EAL Hard Card, EPIP 5.7.17

, Revision 15, EPIP 5.7.17.1

, Revision 48, and CNSDOSE

, Revision 3

March 24, 2017 2017-027 Emergency Preparedness Impact Screen, EPIP 5.7.6, Revision 69

April 13, 2017

EPDG-2 Attachment C

-2 Quarterly EAS New spaper and Radio Advisories

EPDG-2 Attachment C

-3 Semi-Annual Dissemination of Emergency Public Information/Transient Population Information

EPDG-2 Attachment C

-4 Semi-Annual Alert and Notification Sign and Evacuation Map Verification

EPIP 5.7.31

Maintaining Emergency Preparedness, Emergency Exercises, Drills, Tests and Evaluations, Revision 54

September 14, 2016 LO2014-0182 2015 Emergency Preparedness Pre

-NRC Focused Self

-Assessment April 24, 2015

LO2015-0185 Focused Self

-Assessment, CNS Emergency Response October 29, 2015 LO2015-0199 2016 Emergency Preparedness Pre

-NRC Focused Self

-Assessment Report April 14, 2016

LO2016-0183 2017 Emergency Preparedness Pre

-NRC Focused Self

-Assessment Report February 10, 2017 QAD20160036

QA Audit 2016

-06, Emergency Preparedness October 17, 2016

WT-2016-0017-045

QS-2016-CNS-027~20161114~Review of Graded Exercise on 6-14-16

Procedures

Number Title Revision 0-CNS-LI-102 Corrective Action Process

0-EN-EP-306 Drills and Exercises

7C0 0-EN-EP-308 Emergency Planning Critiques

2C2 0-EN-QV-108 QA Surveillance Process

10C4 0-QA-02 Conduct of Internal Audits

Condition Reports

(CRs)

CR-CNS-2015-04400

CR-CNS-2015-04781

CR-CNS-2015-05608

CR-CNS-2015-05640

Condition Reports

(CRs)

CR-CNS-2015-05757

CR-CNS-2015-05882

CR-CNS-2015-07205

CR-CNS-2016-00246

CR-CNS-2016-00550

CR-CNS-2016-01896

CR-CNS-2016-03887

CR-CNS-2016-04139

CR-CNS-2016-04142

CR-CNS-2016-04196

CR-CNS-2016-04401

CR-CNS-2016-04501

CR-CNS-2016-04791

CR-CNS-2016-04991

CR-CNS-2016-05077

CR-CNS-2016-05321

CR-CNS-2016-05697

CR-CNS-2016-08333

CR-CNS-2017-00465

CR-CNS-2017-00622

CR-CNS-2017-01508

CR-CNS-2017-01631

CR-CNS-2017-01857

CR-CNS-2017-02990

CR-CNS-2017-03914

CR-CNS-2017-03993 CR-CNS-2017-03994

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Audits and Self

-Assessments Number Title Revision/Date

2016 Internal Dose Assessment Prospectus

LO-2016-0186-002 Radiological Hazard Assessment and Exposure Controls and In-Plant Airborne Radioactivity Control and Mitigation February 16, 2017

Miscellaneous Documents

Number Title Date

CNS Fuel Pool Inventory April 04, 2017

Hot Spot Master Index May 25, 2017

LHRA Entry Door / Gate Check May 25, 2017

Off Site Radioactive Material Storage Inventory May 25, 2017

Onsite Radioactive Materials Storage Areas May 25, 2017

CNS

RP-504 Radioactive Source Inventory and Leak Test Record June 20, 2016 CNS

RP-504 Radioactive Source Inventory and Leak Test Record December 16, 2016 NRC Form 748

National Source Tracking System Annual Inventory Reconciliation Report

- #S256 January 5, 2017

Procedures

Number Title Revision 0-CNS-WM-101 Work Week Process

0-EN-HU-105 Human Performance

- Managed Defenses

2C2

Procedures

Number Title Revision 0-EN-HU-106 Procedure and Work Instruction Use and Adherence

3C0 9.ALARA.1 Personnel Dosimetry and Occupational Radiation Exposure Program

47 9.ALARA.4 Radiation Work Permits

9.EN-RP-100 Radiation Worker Expectations

9.EN-RP-101 Access Control for Radiologically Controlled Areas

9.EN-RP-104 Personnel Contaminations

9.EN-RP-106-01 Radiation and Contamination Surveys

9.EN-RP-108 Radiation Protection Posting

9.EN-RP-109 Hot Spot Program

9.EN-RP-110-04 Radiation protection Risk Assessment Process

9.EN-RP-110-05 ALARA Planning and Controls

9.EN-RP-121 Radioactive Material Control

9.EN-RP-141 Job Coverage

9.EN-RP-141-01 Job Coverage Using Remote Monitoring Technology

9.EN-RP-151 Radiological Diving

9.EN-RP-203 Dose Assessment

9.EN-RP-205 Prenatal Monitoring

9.EN-RP-311 Self-Reading Dosimeters

9.EN-RP-102 Radiological Control

9.RADOP.1 Radiation Protection At CNS

9.RADOP.2 Radiation Safety Standards and Limits

9.RADOP.5 Airborne Radioactivity Sampling

9.RADOP.8 Receipt of Radioactive Materials

9.RADOP.14

Off-Site Radioactive Material Storage

9.RADOP.21

Radiological Control of Systems with Potential for Changing Radiological Conditions

9.RW.7 Waste Stream Sampling

Condition Reports

(CRs)

CR-CNS-2016-02913

CR-CNS-2016-05843

CR-CNS-2016-07254

CR-CNS-2016-07552

Condition Reports

(CRs)

CR-CNS-2016-07615

CR-CNS-2016-07701

CR-CNS-2016-07888

CR-CNS-2017-02023

CR-CNS-2017-00478 CR-CNS-2017-00597

Section 2RS3:

In

-plant Airborne Radioactivity Control and Mitigation Audits and Self

-Assessments Title Date 2014 Respiratory Program Evaluation Written Appraisal

2014 2015 Respiratory Program Evaluation Written Appraisal 2015 2016 Respiratory Program Evaluation Written Appraisal

2016

In-Place Filter Testing Records Number Title Date

4907090 Control Room Emergency Fan Charcoal and HEPA Filter Leak Test

- TS Surveillance May 23, 2013

4908363 TSC Emergency Ventilation Charcoal and HEPA Filter Leak Test - Non-TS Surveillance November 15, 2013

4942498 Alternate OSC Emergency Ventilation Charcoal and HEPA Filter Leak Test

- Non-TS Surveillance June 2, 2014

22671 TSC Emergency Ventilation Charcoal and HEPA Filter Leak Test - Non-TS Surveillance June 3, 2015

28440 Alternate OSC Emergency Ventilation Charcoal and HEPA Filter Leak Test

- Non-TS Surveillance June 8, 2016

Miscellaneous Documents

Number Title Revision/Date

DAW Alpha Characterization: 2016 DAW System Beta

-Gamma/Alpha Ratio February 27, 2017

Emergency Plan

5.7.2.1 Emergency Equipment Maintained

CNS

RP-402 Cooper Nuclear Station SCBA Functionals March 23, 2017

TQD 0415 Respirator Detail Report May 23, 2017

Procedures

Number Title Revision 2.2.60 Primary Containment Ventilation and Nitrogen Inerting System 95 9.EN-RP-122 Alpha Monitoring

9.RADOP.5 Airborne Radioactivity Sampling

9.RADOP.17

Operation and Maintenance of HEPA Vacuum Cleaners and HEPA Ventilation Units

9.RADOP.20

HEPA Vacuums and Portable HEPA Filter Unit Filter Leak Testing 1 9.RESP.1 Respiratory Protection Program

9.RESP.2 Self-Contained Breathing Apparatus

9.RESP.5 Air Quality Monitoring

9.RESP.6 HEPA Portable Ventilation Unit Maintenance and Use 3

TEDE/ALARA Reviews Number Title Date 2016-01 ALARA TEDE Worksheet: CRDMs in RE29

May 2, 2016

2016-03 ALARA TEDE Worksheet: "F" & "G" Sumps in RE29

November 12, 2015 2016-05 ALARA TEDE Worksheet: Refuel Floor and IVVI

October 17, 2016

Condition Reports

(CRs)

CR-CNS-2014-06800

CR-CNS-2014-07439

CR-CNS-2014-08156

CR-CNS-2015-00422

CR-CNS-2015-00666

CR-CNS-2015-01545

CR-CNS-2016-03400

CR-CNS-2016-04892

CR-CNS-2016-04912

CR-CNS-2016-04973

CR-CNS-2016-04975

CR-CNS-2016-05779

CR-CNS-2016-05843

CR-CNS-2017-01397 CR-CNS-2017-02151

Section 4OA1: Performance Indicator Verification

Miscellaneous Documents

Number Title Revision

EPDG-2 Attachment G1

Emergency Preparedness Performance Indicator Guide

24, 25 EPIP 5.7.1

Emergency Classification

56, 57

Miscellaneous Documents

Number Title Revision EPIP 5.7.6

Notification

69, 70 EPIP 5.7.20

Protective Action Recommendations

27, 28, 29

NEI 99-02 Regulatory Assessment Performance Indicator Guideline

Procedures

Number Title Revision 0-EN-LI-114 Performance Indicator Process 5C2

Condition Reports

(CRs)

CR-CNS-2015-04622

CR-CNS-2015-05467

CR-CNS-2015-05575

CR-CNS-2015-05879

CR-CNS-2015-06220

CR-CNS-2015-06350

CR-CNS-2015-06481

CR-CNS-2015-06713

CR-CNS-2015-07113

CR-CNS-2016-01423

CR-CNS-2016-02097

CR-CNS-2016-02590

CR-CNS-2016-02705

CR-CNS-2016-03967

CR-CNS-2016-04142

CR-CNS-2016-04144

CR-CNS-2016-04501

CR-CNS-2016-04695

CR-CNS-2016-04972

CR-CNS-2016-05290

CR-CNS-2016-05566

CR-CNS-2016-05704

CR-CNS-2016-06781

CR-CNS-2016-08130

CR-CNS-2016-08695

CR-CNS-2017-00122

CR-CNS-2017-00260

CR-CNS-2017-00742

CR-CNS-2017-01203

CR-CNS-2017-01805

CR-CNS-2017-01857

CR-CNS-2017-02185

CR-CNS-2017-02896

CR-CNS-2017-02937 CR-CNS-2017-02973

Section 4OA2: Problem Identification and Resolution

Miscellaneous Documents

Number Title Revision

Network Connectivity Diagram, Sheets 1 and

CDA-FP-001-LP Fire Local Control Panel Controls Group Assessment

CDA-HPCI-001-IVTR Inverter Controls Group Assessment

Procedures

Number Title Revision 11.Cyber-Security Cyber Security

11.Cyber.03

Cyber Security Scope

Procedures

Number Title Revision 11.Cyber.10

Cyber Security Assessment

11.CS-Dedicated Media Dedicated Use of Media

Condition Reports

(CRs)

CR-CNS-2014-03043

CR-CNS-2015-00212

CR-CNS-2015-00236

CR-CNS-2015-00257

CR-CNS-2015-00439

CR-CNS-2015-00476

CR-CNS-2015-00509

CR-CNS-2015-00646

CR-CNS-2017-00122

CR-CNS-2017-00312

CR-CNS-2017-00779

CR-CNS-2017-00847

CR-CNS-2017-01168

CR-CNS-2017-01330

CR-CNS-2017-01577

CR-CNS-2017-01741

CR-CNS-2017-02555

Digital Equipment Evaluations (DEVAL) 2015-0031 2015-0032 2015-0042 2015-0111

Work Orders

5180525

Section 4OA3:

Follow

-up of Events and Notices of Enforcement Discretion

Procedures

Number Title Revision 2.2.38 HVAC Control Building

43, 53 6.1HV.302 Essential Control Building Ventilation Functional Test (DIV 1) 13 6.MS.401 Main Steam Valve (SV) Testing (IST)

6.MS.402 Main Steam Safety Relief Valve (SRV) Testing (IST)

Condition Reports

(CRs)

CR-CNS-2016-07426

CR-CNS-2016-07494

CR-CNS-2016-07991

CR-CNS-2016-08338

CR-CNS-2016-08363

CR-CNS-2016-08369

CR-CNS-2016-08373

CR-CNS-2016-08744

CR-CNS-2017-01175

CR-CNS-2017-02091

CR-CNS-2017-03102

CR-CNS-2017-03130

Work Orders

5060572

The following items are requested for the Occupational Radiation Safety Inspection Cooper Inspection Dates May 22 to 26, 2017

Integrated Report 2017002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before April 24, 2017.

Please submit this information using the same lettering system as below.

For example, all contacts and phone numbers for Inspection Procedure 71124.0

should be in a file/folder titled

"1- A," applicable organization charts in file/folder "

1- B," etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.

Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact Martin Phalen at (817) 200

-1158 or Martin.Phalen@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).

Existing information collection requirements were approved by the Office of Management and Budget, control number 3150

-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151)

Date of Last Inspection:

October 3 through 7, 2016

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff and Technicians

B. Applicable organization charts

C. ALL radiation protection related licensee (Cooper) assessments and audits, all independent or third party radiation protection related assessments and audits, all radiation protection related self

-assessments, and all radiation safety related LERs, including but not limited to radiation monitoring instrumentation and radioactive effluents, releases and / or spills, written since September 1, 2016.

D. Procedure indexes for the radiation protection procedures

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and sub

-tiered systems) since September 1, 2016.

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches.

If not covered above, a summary of corrective action documents since September 1, 2016 involving unmonitored releases, unplanned releases, or releases in which any dose limit or administrative dose limit was exceeded (for Public Radiation Safety Performance Indicator verification in accordance with IP 71151)

Additionally, a copy of ALL radiation protection AND chemistry department root cause evaluations, apparent cause evaluation, and condition evaluations performed since September 1, 2016.

G. List of radiologically significant work activities scheduled to be conducted during the inspection period (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose estimate for the work activity.)

H. List of active radiation work permits

I. Radioactive source inventory list

a. All radioactive sources that are required to be leak tested

b. All radioactive sources that meet the 10 CFR Part 20, Appendix E, Category 2 and above threshold.

Please indicate the radioisotope, initial and current activity (w/assay date), and storage location for each applicable source.

J.

The last two leak test results for the radioactive sources inventoried and required to be leak tested.

If applicable, specifically provide a list of all radioactive source(s) that have failed its leak test within the last two years

K. A current listing of any non

-fuel items stored within your pools, and if available, their appropriate dose rates (Contact / @ 30cm)

L. Computer printout of radiological controlled area entries greater than 100 millirem since the previous inspection to the current inspection entrance date.

The printout should include the date of entry, some form of worker identification, the radiation work permit used by the worker, dose accrued by the worker, and the electronic dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).

3.

In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection:

October 06 through 10, 2014

A. List of contacts and telephone numbers for the following areas:

1. Respiratory Protection Program

2. Self-contained breathing apparatus

B. Applicable organization charts

C. Copies of audits, self

-assessments, vendor or NUPIC audits for contractor support (SCBA), and LERs, written since date of last inspection related to:

1. Installed air filtration systems

2. Self-contained breathing apparatuses

D. Procedure index for:

1. Use and operation of continuous air monitors

2. Use and operation of temporary air filtration units

3. Respiratory protection

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes.

1. Respiratory protection program

2. Use of self

-contained breathing apparatuses

3. Air quality testing for SCBAs

4. Use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation

F. A summary list of corrective action documents (including corporate and sub

-tiered systems) written since date of last inspection, related to the Airborne Monitoring program including:

1. Continuous air monitors

2. Self-contained breathing apparatuses

3. Respiratory protection program

NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches.

G. List of SCBA qualified personnel

- reactor operators and emergency response personnel

H. Inspection records for self

-contained breathing apparatuses (SCBAs) staged in the plant for use since date of last inspection.

I. SCBA training and qualification records for control room operators, shift supervisors, STAs, and OSC personnel for the last year.

A selection of personnel may be asked to demonstrate proficiency in donning, doffing, and performance of functionality check for respiratory devices

J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer, and model.