IR 05000298/2017002: Difference between revisions

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If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Cooper Nuclear Station.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Cooper Nuclear Station.


If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station. 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.
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,
Sincerely,
/RA/
/RA/
Jason Kozal, Branch Chief Project Branch C Division of Reactor Projects Docket No. 50-298 License No. DPR-46
Jason Kozal, Branch Chief Project Branch C Division of Reactor Projects Docket No. 50-298 License No. DPR-46  


===Enclosure:===
===Enclosure:===
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REGION IV==
REGION IV==
Docket: 05000298 License: DPR-46 Report: 05000298/2017002 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 Jason Kozal By: Chief, Project Branch C Division of Reactor Projects Enclosure
Docket:
05000298 License:
DPR-46 Report:
05000298/2017002 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  


=SUMMARY=
=SUMMARY=
IR 05000298/2017002; 04/01/2017 - 06/30/2017; Cooper Nuclear Station; Maint. Risk
IR 05000298/2017002; 04/01/2017 - 06/30/2017; Cooper Nuclear Station; Maint. Risk  


Assessments and Emergent Work Control, Follow-up of Events & Notices of Enforcement Discretion.
Assessments and Emergent Work Control, Follow-up of Events & Notices of Enforcement Discretion.
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===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
*
: '''Green.'''
: '''Green.'''
The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 high 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 actions, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that Technical Specification 3.3.3.2,
The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 high 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 actions, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that 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.
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 licensees 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 Findings 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)
The licensees 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 Findings 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===
===Cornerstone: Barrier Integrity===
*
: '''Green.'''
: '''Green.'''
The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 fans preventive maintenance strategy.
The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 fans preventive maintenance strategy.
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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.
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)
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.'''
: '''Green.'''
The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-08744.
The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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 licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-08744.


The licensees 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)
The licensees 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===
===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 licensees corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
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 licensees corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.


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==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R01}}
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R01}}
==1R01 Adverse Weather Protection==
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01}}
{{IP sample|IP=IP 71111.01}}
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====a. Inspection Scope====
====a. Inspection Scope====
On June 2, 2017, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose one plant area that was susceptible to flooding:
On June 2, 2017, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose one plant area that was 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.
* 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.
These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R04}}
No findings were identified. {{a|1R04}}
==1R04 Equipment Alignment==
==1R04 Equipment Alignment==
{{IP sample|IP=IP 71111.04}}
{{IP sample|IP=IP 71111.04}}
===.1 Partial Walk-Down===
===.1 Partial Walk-Down===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors performed partial system walk-downs of the following risk-significant systems:
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 2, 2017, primary containment isolation system Group 6 isolation circuit
* June 16, 2017, reactor core isolation cooling, turbine cooling system
* June 16, 2017, reactor core isolation cooling, turbine cooling system
* June 23, 2017, standby gas treatment system train A The inspectors reviewed the licensees 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.
* June 23, 2017, standby gas treatment system train A  
 
The inspectors reviewed the licensees 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.
These activities constituted three partial system walk-down samples, as defined in Inspection Procedure 71111.04.
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===.2 Complete Walk-Down===
===.2 Complete Walk-Down===
====a. Inspection Scope====
====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 licensees 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, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
On May 26, 2017, the inspectors performed a complete system walk-down inspection of the control room emergency filtration system. The inspectors reviewed the licensees 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, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R05}}
No findings were identified. {{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05}}
{{IP sample|IP=IP 71111.05}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R06}}
No findings were identified. {{a|1R06}}
==1R06 Flood Protection Measures==
==1R06 Flood Protection Measures==
{{IP sample|IP=IP 71111.06}}
{{IP sample|IP=IP 71111.06}}
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====a. Inspection Scope====
====a. Inspection Scope====
On June 1, 2017, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:
On June 1, 2017, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees 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.
* 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.
These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R11}}
No findings were identified. {{a|1R11}}
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance==
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance==
{{IP sample|IP=IP 71111.11}}
{{IP sample|IP=IP 71111.11}}
===.1 Review of Licensed Operator Requalification===
===.1 Review of Licensed Operator Requalification===
====a. Inspection Scope====
====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.
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.
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===.2 Review of Licensed Operator Performance===
===.2 Review of Licensed Operator Performance===
====a. Inspection Scope====
====a. Inspection Scope====
On May 20, 2017, the inspectors observed the performance of on-shift licensed operators in the plants 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.
On May 20, 2017, the inspectors observed the performance of on-shift licensed operators in the plants 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.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R12}}
No findings were identified. {{a|1R12}}
==1R12 Maintenance Effectiveness==
==1R12 Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12}}
{{IP sample|IP=IP 71111.12}}
===.1 Routine Maintenance Effectiveness===
===.1 Routine Maintenance Effectiveness===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed one instance of degraded performance or condition of safety-significant structures, systems, and components (SSCs):
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 licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees 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.
* 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 licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees 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.
These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.
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===.2 Quality Control===
===.2 Quality Control===
====a. Inspection Scope====
====a. Inspection Scope====
On June 27, 2017, the inspectors reviewed the licensees quality control activities through:
On June 27, 2017, the inspectors reviewed the licensees quality control activities through:
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R13}}
No findings were identified. {{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control==
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13}}
{{IP sample|IP=IP 71111.13}}
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* April 21, 2017, high pressure coolant injection maintenance window
* April 21, 2017, high pressure coolant injection maintenance window
* May 20, 2017, main generator outage
* 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 licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the results of the assessments.
* 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 licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the results 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:
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:
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====b. Findings====
====b. Findings====
=====Introduction.=====
=====Introduction.=====
The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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.
The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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.
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=====Analysis.=====
=====Analysis.=====
The licensees 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 Findings 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 HPCI turbine inlet pressure instrument during surveillance testing [H.5].
The licensees 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 Findings 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 HPCI turbine inlet pressure instrument during surveillance testing [H.5].  


=====Enforcement.=====
=====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, Revision 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 73872, 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 licensees 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)
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, Revision 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 73872, 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 licensees 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)
{{a|1R15}}
{{a|1R15}}
==1R15 Operability Determinations and Functionality Assessments==
==1R15 Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15}}
{{IP sample|IP=IP 71111.15}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R18}}
No findings were identified. {{a|1R18}}
==1R18 Plant Modifications==
==1R18 Plant Modifications==
{{IP sample|IP=IP 71111.18}}
{{IP sample|IP=IP 71111.18}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R19}}
No findings were identified. {{a|1R19}}
==1R19 Post-Maintenance Testing==
==1R19 Post-Maintenance Testing==
{{IP sample|IP=IP 71111.19}}
{{IP sample|IP=IP 71111.19}}
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* May 4, 2017, emergency diesel generator 2 overcurrent relay replacement 51B and 51C
* May 4, 2017, emergency diesel generator 2 overcurrent relay replacement 51B and 51C
* May 9, 2017, reactor protection system test panel modification
* 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.
* 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.
These activities constituted completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1R22}}
No findings were identified. {{a|1R22}}
==1R22 Surveillance Testing==
==1R22 Surveillance Testing==
{{IP sample|IP=IP 71111.22}}
{{IP sample|IP=IP 71111.22}}


====a. Inspection Scope====
====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:
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:
In-service tests:
* June 21, 2017, service water pump C pretest Reactor coolant system leak detection 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:
* June 16, 2017, sump pump F discharge check valve back leakage testing Other surveillance tests:
* April 17, 2017, emergency diesel generator 1
* April 17, 2017, emergency diesel generator 1
* 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.
* 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.
These activities constituted completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.  


===Cornerstone: Emergency Preparedness===
===Cornerstone: Emergency Preparedness===
{{a|1EP2}}
{{a|1EP2}}
==1EP2 Alert and Notification System Testing==
==1EP2 Alert and Notification System Testing==
{{IP sample|IP=IP 71114.02}}
{{IP sample|IP=IP 71114.02}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1EP3}}
No findings were identified. {{a|1EP3}}
==1EP3 Emergency Response Organization Staffing and Augmentation System==
==1EP3 Emergency Response Organization Staffing and Augmentation System==
{{IP sample|IP=IP 71114.03}}
{{IP sample|IP=IP 71114.03}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1EP4}}
No findings were identified. {{a|1EP4}}
==1EP4 Emergency Action Level and Emergency Plan Changes==
==1EP4 Emergency Action Level and Emergency Plan Changes==
{{IP sample|IP=IP 71114.04}}
{{IP sample|IP=IP 71114.04}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|1EP5}}
No findings were identified. {{a|1EP5}}
==1EP5 Maintenance of Emergency Preparedness==
==1EP5 Maintenance of Emergency Preparedness==
{{IP sample|IP=IP 71114.05}}
{{IP sample|IP=IP 71114.05}}
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==RADIATION SAFETY==
==RADIATION SAFETY==
Cornerstones: Public Radiation Safety and Occupational Radiation Safety {{a|2RS1}}
Cornerstones: Public Radiation Safety and Occupational Radiation Safety {{a|2RS1}}
==2RS1 Radiological Hazard Assessment and Exposure Controls==
==2RS1 Radiological Hazard Assessment and Exposure Controls==
{{IP sample|IP=IP 71124.01}}
{{IP sample|IP=IP 71124.01}}
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====b. Findings====
====b. Findings====
No findings were identified. {{a|2RS3}}
No findings were identified. {{a|2RS3}}
==2RS3 In-Plant Airborne Radioactivity Control and Mitigation==
==2RS3 In-Plant Airborne Radioactivity Control and Mitigation==
{{IP sample|IP=IP 71124.03}}
{{IP sample|IP=IP 71124.03}}
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Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
{{a|4OA1}}
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 71151}}
{{IP sample|IP=IP 71151}}
===.1 Safety System Functional Failures (MS05)===
===.1 Safety System Functional Failures (MS05)===
====a. Inspection Scope====
====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.
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.
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===.2 Reactor Coolant System Specific Activity (BI01)===
===.2 Reactor Coolant System Specific Activity (BI01)===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensees 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 Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
The inspectors reviewed the licensees 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 Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
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===.3 Reactor Coolant System Identified Leakage (BI02)===
===.3 Reactor Coolant System Identified Leakage (BI02)===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensees records of reactor coolant system identified leakage for the period of April 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.
The inspectors reviewed the licensees records of reactor coolant system identified leakage for the period of April 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.
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===.4 Drill/Exercise Performance (EP01)===
===.4 Drill/Exercise Performance (EP01)===
====a. Inspection Scope====
====a. Inspection Scope====
The inspector reviewed the licensees 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 licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspector reviewed a sample of the licensees 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.
The inspector reviewed the licensees 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 licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspector reviewed a sample of the licensees 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.
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===.5 Emergency Response Organization Drill Participation (EP02)===
===.5 Emergency Response Organization Drill Participation (EP02)===
====a. Inspection Scope====
====a. Inspection Scope====
The inspector reviewed the licensees records for participation in drill and training evolutions between April 2016 and March 2017 to verify the accuracy of the licensees data for drill participation opportunities. The inspector verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.
The inspector reviewed the licensees records for participation in drill and training evolutions between April 2016 and March 2017 to verify the accuracy of the licensees data for drill participation opportunities. The inspector verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.
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===.6 Alert and Notification System Reliability (EP03)===
===.6 Alert and Notification System Reliability (EP03)===
====a. Inspection Scope====
====a. Inspection Scope====
The inspector reviewed the licensees records of alert and notification system tests conducted between April 2016 and March 2017 to verify the accuracy of the licensees 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.
The inspector reviewed the licensees records of alert and notification system tests conducted between April 2016 and March 2017 to verify the accuracy of the licensees 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.
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===.7 Occupational Exposure Control Effectiveness (OR01)===
===.7 Occupational Exposure Control Effectiveness (OR01)===
====a. Inspection Scope====
====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.
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.
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===.8 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual===
===.8 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual===
 
(ODCM) Radiological Effluent Occurrences (PR01)
      (ODCM) Radiological Effluent Occurrences (PR01)


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
No findings were identified. {{a|4OA2}}
No findings were identified. {{a|4OA2}}
==4OA2 Problem Identification and Resolution==
==4OA2 Problem Identification and Resolution==
{{IP sample|IP=IP 71152}}
{{IP sample|IP=IP 71152}}
===.1 Routine Review===
===.1 Routine Review===
====a. Inspection Scope====
====a. Inspection Scope====
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees 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 licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees 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 licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
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===.2 Semiannual Trend Review===
===.2 Semiannual Trend Review===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensees 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 reviewed the licensees 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.
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The inspectors identified the following trend that might indicate the existence of a more significant safety issue, and reviewed the licensees response to it. The inspectors identified multiple examples associated with a declining trend of licensed and nonlicensed operators operational fundamentals. These examples included:
The inspectors identified the following trend that might indicate the existence of a more significant safety issue, and reviewed the licensees 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: NCV 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 licensees 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-2017-00553: NCV 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 licensees 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 -
* 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 hours 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.
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 hours 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 Measures 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 licensees 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 high-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 NCV 05000298/2016003-02, Failure to Maintain Low Pressure Injection/Spray Operable from Internal Flooding Hazards.
* Licensee Event Report (LER) 05000298/2016010-00, Inadequate Compensatory Measures 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 licensees 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 high-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 NCV 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 licensees 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-2017-00054: NCV 05000298/2017001-03, Failure to Identify a Condition Adverse to Quality. This finding was in response to the licensees 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.
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* 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-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 05000298/2016002-01, 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 licensees 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 the traversing in-core probe B ball valve operable or isolate its flow path within 4 hours of indications 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-2016-03665: NCV 05000298/2016002-01, 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 licensees 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 the traversing in-core probe B ball valve operable or isolate its flow path within 4 hours of indications 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:
* 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 two 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 degrees Fahrenheit increments.
===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.


3. CR-CNS-2017-02645: A NLO failed to identify that water collected at the bottom of station startup service transformer relays during rounds.
===2. CR-CNS-2017-01768: The incorrect TS reading was taken for two===
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 degrees Fahrenheit increments.


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.
===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.
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.
===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.
===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.
There was no log entry or documentation for controlling the configuration of TEC-V-123 outside of a reactor building NLO watch turnover.
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These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
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:
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:
* The inspectors reviewed the above examples and concluded that four categories of operator fundamentals were impacted. These categories included:
: (1) configuration management;
: (1) configuration management;
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: (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
: (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.
: (4) implementation of TS operability calls.
* The licensee implemented the following corrective actions:
* The licensee implemented the following corrective actions:  
1. Use of an industry expert to provide mentoring and coaching of the operations department management team.
 
===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.
===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 recent issues at other nuclear facilities associated with operator fundamentals.
===3. Conducting high intensity training (HIT) for licensed and nonlicensed===
operators. This training was implemented by the Entergy Fleet for recent issues at other nuclear facilities associated with operator fundamentals.


4. Implementation of an excellence model during licensed 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. These grading criteria have been applied to the on-going HIT training cycle, and have resulted in two crew failures.
===4. Implementation of an excellence model during licensed 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. These grading criteria have been applied to the on-going HIT training cycle, and have resulted in two crew failures.


The inspectors determined that the operations departments declining performance in operator fundamentals represents a continued adverse trend worthy of additional monitoring for long term corrective actions and sustained improvement.
The inspectors determined that the operations departments declining performance in operator fundamentals represents a continued adverse trend worthy of additional monitoring for long term corrective actions and sustained improvement.
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===.3 Annual Follow-up of Selected Issues===
===.3 Annual Follow-up of Selected Issues===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors selected three issues for an in-depth follow-up:
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 licensees 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.
* April 26, 2017, emergency diesel generator 1 voltage regulator cabinet  
 
The inspectors assessed the licensees 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 inspectors reviewed the NRC-identified and licensee-identified issues documented in Inspection Report 05000298/2015403 for an in depth follow-up. The inspectors reviewed procedures, digital asset listings, and corrective action documents. The inspectors interviewed personnel involved in implementing the corrective actions.
* May 8 - June 2, 2017, during an in-office inspection, the inspectors reviewed the NRC-identified and licensee-identified issues documented in Inspection Report 05000298/2015403 for an in depth follow-up. The inspectors reviewed procedures, digital asset listings, and corrective action documents. The inspectors interviewed personnel involved in implementing the corrective actions.


The inspectors assessed the licensees 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.
The inspectors assessed the licensees 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 licensees 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.
* June 2, 2017, mission times for the DC batteries, high pressure coolant injection, and reactor core isolation cooling systems  
 
The inspectors assessed the licensees 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 samples, as defined in Inspection Procedure 71152.
These activities constituted completion of three annual follow-up samples, as defined in Inspection Procedure 71152.
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====b. Findings====
====b. Findings====
No findings were identified. {{a|4OA3}}
No findings were identified. {{a|4OA3}}
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==
{{IP sample|IP=IP 71153}}
{{IP sample|IP=IP 71153}}
===.1 (Closed) Licensee Event Report (LER) 05000298/2016006-00, High Vibration on===
===.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 Function
Control Room Emergency Filter System Fan Results in Inoperability and Loss of Safety       Function


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
=====Introduction.=====
=====Introduction.=====
The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of CREFS.
The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of CREFS.
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=====Analysis.=====
=====Analysis.=====
The licensees 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].
The licensees 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.=====
=====Enforcement.=====
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===.2 (Closed) Licensee Event Report (LER) 05000298/2016009-00, Control Room===
===.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
Emergency Filter System Fan Removed from Service Due to Human Error Results in       Loss of Safety Function


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
=====Introduction.=====
=====Introduction.=====
The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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.
The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees 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.
Line 658: Line 710:


=====Analysis.=====
=====Analysis.=====
The licensees 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].
The licensees 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.=====
=====Enforcement.=====
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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 licensees corrective action program as Condition Report CR-CNS-2016-08744, this violation is being treated as a non-cited violation (NCV) in accordance with Section 2.3.2.a of the NRC Enforcement Policy.
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 licensees corrective action program as Condition Report CR-CNS-2016-08744, 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 05000298/2017002-03, Loss of Control Room Ventilation Due to Improper Switch Manipulation)
(NCV 05000298/2017002-03, Loss of Control Room Ventilation Due to Improper Switch Manipulation)


===.3 (Closed) Licensee Event Report (LER) 05000298/2016010-00, Inadequate===
===.3 (Closed) Licensee Event Report (LER) 05000298/2016010-00, Inadequate===
Compensatory Measures Results in a Condition Prohibited by Technical Specifications
Compensatory Measures Results in a Condition Prohibited by Technical Specifications


Line 681: Line 732:


===.4 (Closed) Licensee Event Report (LER) 05000298/2017002-00, Valve Test Failures===
===.4 (Closed) Licensee Event Report (LER) 05000298/2017002-00, Valve Test Failures===
 
Result in Condition Prohibited by Technical Specifications and a Loss of Safety Function
Result in Condition Prohibited by Technical Specifications and a Loss of Safety       Function


====a. Inspection Scope====
====a. Inspection Scope====
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{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
===Exit Meeting Summary===
===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.
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.


Line 714: Line 763:


{{a|4OA7}}
{{a|4OA7}}
==4OA7 Licensee-Identified Violations==
==4OA7 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 non-cited violation:
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 non-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 southeast quadrant. Dose rates of 120 mrem/hr at 30 centimeters from the CRD filter were identified.
* 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 southeast quadrant. Dose rates of 120 mrem/hr at 30 centimeters from the CRD filter were identified.
Line 726: Line 775:


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee Personnel===
===Licensee Personnel===
: [[contact::M. Bacon]], Manager, Training
: [[contact::M. Bacon]], Manager, Training  
: [[contact::T. Barker]], Manager, Engineering Program and Components
: [[contact::T. Barker]], Manager, Engineering Program and Components  
: [[contact::J. Bebb]], Manager, Security
: [[contact::J. Bebb]], Manager, Security  
: [[contact::J. Bebb]], Staff Health Physicist, Radiation Protection
: [[contact::J. Bebb]], Staff Health Physicist, Radiation Protection  
: [[contact::S. Bebb]], Superintendent, Administrative Services
: [[contact::S. Bebb]], Superintendent, Administrative Services  
: [[contact::J. Bednar]], Supervisor, Radiation Protection
: [[contact::J. Bednar]], Supervisor, Radiation Protection  
: [[contact::K. Billiesbach]], Manager, Materials, Purchasing and Contracts
: [[contact::K. Billiesbach]], Manager, Materials, Purchasing and Contracts  
: [[contact::L. Bray]], Licensing Consultant
: [[contact::L. Bray]], Licensing Consultant  
: [[contact::D. Buman]], Director, Nuclear Safety Assurance
: [[contact::D. Buman]], Director, Nuclear Safety Assurance  
: [[contact::B. Chapin]], Manager, Maintenance
: [[contact::B. Chapin]], Manager, Maintenance  
: [[contact::T. Chard]], Manager, Quality Assurance
: [[contact::T. Chard]], Manager, Quality Assurance  
: [[contact::J. Dent]], Vice President, Chief Nuclear Officer
: [[contact::J. Dent]], Vice President, Chief Nuclear Officer  
: [[contact::L. Dewhirst]], Manager, Corrective Action and Assessment
: [[contact::L. Dewhirst]], Manager, Corrective Action and Assessment  
: [[contact::K. Dia]], Director, Engineering
: [[contact::K. Dia]], Director, Engineering  
: [[contact::R. Estrada]], Program Manager, Nuclear Oversight
: [[contact::R. Estrada]], Program Manager, Nuclear Oversight  
: [[contact::T. Forland]], Engineer, Licensing
: [[contact::T. Forland]], Engineer, Licensing  
: [[contact::G. Gardner]], Engineering Design Manager
: [[contact::G. Gardner]], Engineering Design Manager  
: [[contact::D. Goodman]], Manager, Operations
: [[contact::D. Goodman]], Manager, Operations  
: [[contact::K. Higginbotham]], former Vice President, Chief Nuclear Officer
: [[contact::K. Higginbotham]], former Vice President, Chief Nuclear Officer  
: [[contact::J. Hirner]], Radiation Operations Supervisor, Radiation Protection
: [[contact::J. Hirner]], Radiation Operations Supervisor, Radiation Protection  
: [[contact::H. Jeffrey]], Technician, Radiation Protection
: [[contact::H. Jeffrey]], Technician, Radiation Protection  
: [[contact::J. Kalamaja]], General Manager, Plant Operations
: [[contact::J. Kalamaja]], General Manager, Plant Operations  
: [[contact::L. Karpinski]], Technician, Radiation Protection
: [[contact::L. Karpinski]], Technician, Radiation Protection  
: [[contact::D. Kimball]], Director, Nuclear Oversight
: [[contact::D. Kimball]], Director, Nuclear Oversight  
: [[contact::J. Long]], Assistant Operations Manager
: [[contact::J. Long]], Assistant Operations Manager  
: [[contact::J. Olberding]], Licensing Specialist, Regulatory Affairs
: [[contact::J. Olberding]], Licensing Specialist, Regulatory Affairs  
: [[contact::C. Pelchat]], Manager, Nuclear Projects
: [[contact::C. Pelchat]], Manager, Nuclear Projects  
: [[contact::J. Reimers]], Manager, System Engineering
: [[contact::J. Reimers]], Manager, System Engineering  
: [[contact::J. Shaw]], Manager, Licensing
: [[contact::J. Shaw]], Manager, Licensing  
: [[contact::J. Stough]], Manager, Emergency Preparedness
: [[contact::J. Stough]], Manager, Emergency Preparedness  
: [[contact::C. Sunderman]], Manager, Radiation Protection
: [[contact::C. Sunderman]], Manager, Radiation Protection  
: [[contact::D. Van Der Kamp]], Licensing Technical Specialist
: [[contact::D. Van Der Kamp]], Licensing Technical Specialist  
: [[contact::D. Vice]], Cyber Project Manager
: [[contact::D. Vice]], Cyber Project Manager  


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
===Opened and Closed===
===Opened and Closed===
 
: 05000298/2017002-01 NCV Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing (Section 1R13)  
Failure to Assess Operability of Technical Specification System
: 05000298/2017002-02 NCV Loss of Control Room Ventilation Due to Ineffective Preventive Maintenance Strategy (Section 4OA3)
: 05000298/2017002-01 NCV Functions during Surveillance Testing (Section 1R13)
: 05000298/2017002-03 NCV Loss of Control Room Ventilation Due to Improper Switch Manipulation (Section 4OA3)  
Loss of Control Room Ventilation Due to Ineffective Preventive
: 05000298/2017002-02 NCV Maintenance Strategy (Section 4OA3)
Loss of Control Room Ventilation Due to Improper Switch
: 05000298/2017002-03 NCV Manipulation (Section 4OA3)


===Closed===
===Closed===
 
: 05000298/2016006-00 LER High Vibration on Control Room Emergency Filter System Fan Results in Inoperability and Loss of Safety Function (Section 4OA3)  
High Vibration on Control Room Emergency Filter System Fan
: 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)  
: 05000298/2016006-00 LER        Results in Inoperability and Loss of Safety Function (Section 4OA3)
: 05000298/2016010-00 LER Inadequate Compensatory Measures Results in a Condition Prohibited by Technical Specifications (Section 4OA3)  
Control Room Emergency Filter System Fan Removed from
: 05000298/2017002-00 LER Valve Test Failures Result in Condition Prohibited by Technical Specifications and a Loss of Safety Function (Section 4OA3)  
: 05000298/2016009-00 LER        Service Due to Human Error Results in Loss of Safety Function (Section 4OA3)
Inadequate Compensatory Measures Results in a Condition
: 05000298/2016010-00 LER Prohibited by Technical Specifications (Section 4OA3)
Valve Test Failures Result in Condition Prohibited by Technical
: 05000298/2017002-00 LER Specifications and a Loss of Safety Function (Section 4OA3)


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==


}}
}}

Latest revision as of 14:57, 8 January 2025

NRC Integrated Inspection Report 05000298/2017002
ML17219A670
Person / Time
Site: Cooper Entergy icon.png
Issue date: 08/03/2017
From: Jason Kozal
NRC/RGN-IV/DRP/RPB-C
To: Dent J
Nebraska Public Power District (NPPD)
JASON KOZAL
References
IR 2017002
Download: ML17219A670 (68)
v • d • e


Text

August 3, 2017

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 violations 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 the NRC resident inspector at the Cooper Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station.

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 05000298/2017002 w/ Attachments:

1. Supplemental Information 2. O

REGION IV==

Docket:

05000298 License:

DPR-46 Report:

05000298/2017002 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

SUMMARY

IR 05000298/2017002; 04/01/2017 - 06/30/2017; 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 NRCs Region IV office. Three findings 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 NRCs 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 licensees 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 high 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 actions, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that 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 licensees 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 Findings 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 licensees 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 fans preventive maintenance strategy.

The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-07426.

The licensees 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 licensees 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 licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-08744.

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

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 on 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

1R01 Adverse Weather Protection

Main article: IP 71111.01

Readiness to Cope with External Flooding

a. Inspection Scope

On June 2, 2017, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose one plant area that was 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.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

The inspectors reviewed the licensees 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 licensees 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, in-process design changes, temporary modifications, and other open items tracked by the licensees 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.

1R05 Fire Protection

Main article: IP 71111.05

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees 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, 2017, 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 licensees 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.

1R06 Flood Protection Measures

Main article: IP 71111.06

a. Inspection Scope

On June 1, 2017, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees 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.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 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 plants 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.

1R12 Maintenance Effectiveness

Main article: IP 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):

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees 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 licensees 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 licensees control of quality parts during maintenance;
(3) a review of whether quality control verifications were properly specified in accordance with the licensees 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.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 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:

  • May 20, 2017, main generator outage

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 licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the results 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:

  • 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 licensees 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 licensees actions to maintain the HPCI 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. The 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 actions, 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 licensees 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 Findings 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 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, Revision 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 73872, 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 licensees 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)

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

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

  • 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 licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees 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 samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 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.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

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

  • April 26, 2017, RWCU-MOV-18, 16A-K64 failed relay coil replacement
  • 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.

1R22 Surveillance Testing

Main article: IP 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:

Reactor coolant system leak detection tests:

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

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

1EP2 Alert and Notification System Testing

Main article: IP 71114.02

a. Inspection Scope

The inspector verified the adequacy of the licensees methods for testing the primary and backup alert and notification system (ANS). The inspector also reviewed the licensees 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 licensees 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 Plants; and the licensees 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.

1EP3 Emergency Response Organization Staffing and Augmentation System

Main article: IP 71114.03

a. Inspection Scope

The inspector verified the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees 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 licensees methods for staffing emergency response facilities, including the licensees 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 constituted completion of one emergency response organization staffing and augmentation testing sample, as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

Main article: IP 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
  • 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 These revisions were compared to their previous revisions, 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 constituted 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

Main article: IP 71114.05

a. Inspection Scope

The inspector reviewed the following for the period December 2015 through June 2017:

  • After-action reports for emergency classifications and events
  • After-action evaluation reports for licensee drills and exercises
  • Drill and exercise performance issues entered into the licensees corrective action 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 licensees 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 licensees 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 licensees 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 licensees emergency plan.

These activities constituted completion of one sample of the maintenance of the licensees 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

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

a. Inspection Scope

The inspectors evaluated the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees 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 plants radiological source terms and associated radiological hazards. The inspectors also reviewed the licensees 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 licensees controls for items stored in the spent fuel pool and evaluated airborne radioactivity controls and monitoring.
  • 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 constituted 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.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 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 licensees airborne monitoring protocols, including verification that alarms and set points were appropriate.

  • Use of respiratory protection devices, including an evaluation of the licensees 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 licensees 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 constituted 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

4OA1 Performance Indicator Verification

Main article: IP 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 licensees 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 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 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 licensees records of reactor coolant system identified leakage for the period of April 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 licensees 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 licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspector reviewed a sample of the licensees 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 licensees records for participation in drill and training evolutions between April 2016 and March 2017 to verify the accuracy of the licensees data for drill participation opportunities. The inspector verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensees 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 licensees records of alert and notification system tests conducted between April 2016 and March 2017 to verify the accuracy of the licensees 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 constituted 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 constituted 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.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees 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 licensees 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 licensees 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 licensees 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: NCV 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 licensees 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.
  • CR-CNS-2017-00054: NCV 05000298/2017001-03, Failure to Identify a Condition Adverse to Quality. This finding was in response to the licensees 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 05000298/2017002-03, 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 05000298/2017002-01, Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing. This finding was in response to the licensed 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 05000298/2016002-01, 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 licensees 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 the 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 indications 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 two

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 degrees 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 recent issues at other nuclear facilities associated with operator fundamentals.

4. Implementation of an excellence model during licensed 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. These grading criteria have been applied to the on-going HIT training cycle, and have resulted in two crew failures.

The inspectors determined that the operations departments 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:

The inspectors assessed the licensees 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 inspectors reviewed the NRC-identified and licensee-identified issues documented in Inspection Report 05000298/2015403 for an in depth follow-up. The inspectors reviewed procedures, digital asset listings, and corrective action documents. The inspectors interviewed personnel involved in implementing the corrective actions.

The inspectors assessed the licensees 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.

The inspectors assessed the licensees 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 samples, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Main article: IP 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 Function

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 licensees 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 licensees 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 licensees 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 for 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 licensees 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 licensees 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 licensee 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 licensees 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 fans PM strategy. Because this violation was of very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report CR-CNS-2016-07426, 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 05000298/2017002-02, 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 licensees 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 licensees 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 the 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 licensees 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 licensees 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 licensees 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 Appendix 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 licensees corrective action program as Condition Report CR-CNS-2016-08744, 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 05000298/2017002-03, Loss of Control Room Ventilation Due to Improper Switch Manipulation)

.3 (Closed) Licensee Event Report (LER) 05000298/2016010-00, Inadequate

Compensatory Measures 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 licensees 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 high-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) 05000298/2017002-00, 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.

4OA6 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, 2017, 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 licensees 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.

4OA7 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 non-cited violation:

This issue was identified as a result of a RPTs 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 licensees 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)
05000298/2017002-02 NCV Loss of Control Room Ventilation Due to Ineffective Preventive Maintenance Strategy (Section 4OA3)
05000298/2017002-03 NCV Loss of Control Room Ventilation Due to Improper Switch Manipulation (Section 4OA3)

Closed

05000298/2016006-00 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)
05000298/2016010-00 LER Inadequate Compensatory Measures 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)

LIST OF DOCUMENTS REVIEWED

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